Pasturing standards for organic livestock

December 10, 2008

Honorable Ed Schafer
Secretary of Agriculture
U.S. Department of Agriculture
1400 Independence Ave., S.W.
Washington, DC 20250

Dear Secretary Schafer:

As the largest community-owned natural foods retailer in the country, I am writing on behalf of our 45,000 member households to urge you to extend the comment period for the Proposed Pasture Rule [Docket No. AMS–TM–06–0198; TM–05–14].

Although we are pleased that the new proposed rule complies with the requests of the organic community to close specific loopholes exploited by factory farms, we feel that more time is needed to evaluate the rule adequately.

The proposed rule is complex and reflects extensive revisions of the federal organic livestock regulations as well as several new concepts. It will require careful reading to understand and interpret its full impact, so more time is needed to thoroughly understand and prepare comments.

We are requesting a 60 day extension to the public comment period for the proposed rule to allow enough time for organic livestock producers to analyze its impact on their operations. They are the people who are most able to advise on what is or is not feasible. They also have the most at stake, but the demands of farm life make it very difficult to meet short, arbitrary deadlines for comment.

Besides livestock farmers, many stakeholders in the organic community — including retailers and consumers — need more time to comprehend and comment on the rule.

Please consider our request to extend the comment period by 60 days so that it will end February 23, 2009 instead of December 23, 2008.

Sincerely,

Tracy Wolpert
Chief Executive Officer
PCC Natural Markets

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