Pasture access for organic livestock

April 18, 2006

Kevin R. O'Rell, Chairman
National Organic Standards Board
United States Department of Agriculture
1400 Independence Avenue, SW
Washington, DC 20250-0020

Dear Chairman O'Rell,

For over five years, thousands of farmers and consumers, through public testimony, formal written comments, letters, e-mails, and petitions, have communicated with the USDA's National Organic Standards Board (NOSB) and the National Organic Program (NOP), articulating grave concern over the growing trend of organic milk production from massive factory farms (2000-5000 milk cows plus young stock).

At issue are a handful of large farms in the arid West that are producing milk on concentrated animal feeding operations (CAFOs), allowing their animals only token access to pasture and offsetting an unsustainable slaughter rate with the purchase of conventional (nonorganic) replacement cattle. In an attempt to cut costs, and sell more of their increasingly valuable organic milk to consumers, some of these farms have chosen not to feed organic milk to their new calves. Instead, some of these farms are selling off all their calves at birth and later replacing them with conventionally raised year-old heifers (then "transitioning" the conventional animals to organic status).

In terms of pasture, even though the organic regulations (§ 205.239) require producers to "maintain livestock living conditions which accommodate the health and natural behavior of animals," including "access to pasture for ruminants," these corporate farm operators are gaming the system by providing token pasture at best, which puts family-scale farmers-the vast majority of whom strictly follow the regulations-at a serious competitive disadvantage. And consumers, who assume their organic milk comes from farms that pasture their animals and raise them organically, from birth, are being deceived.

We cannot afford to sacrifice the stellar reputation of organic food and farming to those who abuse the organic standards. That is why we are calling on you and your fellow committee members to support strong additional language that is consistent with current law and regulations requiring livestock to be managed promoting their natural instinctive behavior-and in the case of ruminants requiring pasture as a meaningful part of their feed. The following should be incorporated to close loopholes now being exploited:

  1. After a dairy operation has transitioned to organic production, and has been certified, all animals brought onto the operation must be certified as organically raised from the last third of gestation, just as all young stock on the farm need to be under continuous organic management. Whole herd conversion must be a one-time only opportunity, encouraging transition, but should not be used to continuously bring nonorganic animals into an organic herd.
  2. Organic dairy livestock over 6 months of age must graze on pasture during the months of the year when pasture can provide edible forage. The grazed feed must provide significant intake, at minimum 30% of the dry matter intake during the growing season but for no less than 120 days per year. This provision must apply to all cows, whether dry or lactating. In order to protect soil and water quality, the stocking rate must not exceed 3 cows per acre and in most cases the stocking rate must be far below 3 cows per acre in order to reach and exceed the minimum intake and to protect the ecological and feed value of the pasture as required by other sections of the regulations.

We appeal to members of the NOSB to make clear to USDA staff and the Department's political leadership that years of inaction, in terms of enforcing the organic livestock regulations, needs to come to a swift end.

And furthermore, any new rule making must include adequate protections so that loopholes currently being exploited are closed, and that new loopholes will not intentionally or unintentionally be created.

Respectfully yours,

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