"Access to pasture" for dairy cows

October 28, 2005

Secretary Mike Johanns
United States Department of Agriculture
Whitten Building - Suite 200A
1400 Independence Ave SW
Washington, DC 20250

Dear Secretary Johanns,

For over five years, thousands of farmers and consumers, through public testimony, formal written comments, letters, e-mails, and petitions, have communicated with the 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 (3000-5000 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.

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 and putting family-scale farmers at a serious competitive disadvantage.

NOP staff have come under criticism for rejecting a draft rule change that was promulgated by the NOSB and unanimously adopted by that expert body. Crafted only after careful consideration and significant public input, the rule change would have tightened regulatory language requiring cows to actually "graze"-rather than strictly just have access to pasture-and to very specifically require lactating cows to be pastured, not just young stock and dry cows, as has been the alleged practice on some industrial-scale farms.

Instead of collaborating with NOSB members to promulgate language that would allay the staff's concerns, while continuing to respect the spirit of the original language, the NOP has scheduled one more in a series of public comment sessions to garner additional input. After five years of earnest participation in the rule making process, organic dairy producers and consumers are unwilling to go to the expense of making one more trek to Washington. All stakeholders have had ample opportunity to participate to date.

If additional public comments focusing on specific staff questions are justified, the Department could certainly accept written input prior to the meeting and still allow for the NOSB to act at their forthcoming meeting. Chairman Jim Riddle has publicly stated, "If scheduled, we will be prepared to take final action on the rule change."

We appeal to you, Mr. Secretary, to personally intervene and assure that pasture is back on the November NOSB meeting agenda so that final regulatory language can be adopted. We need you to partner with the organic community to protect the integrity of organic farming and food.

Respectfully yours,

(groups listed below)

PS: The organic community is about to lose five of the most knowledgeable and well-spoken leaders on the NOSB who have been addressing this and other critical issues. In the past, the organic community worked in concert with the USDA in order to recruit and retain the highest possible caliber members for NOSB-this is a nonpartisan body of exemplary quality. The Department previously released the names of candidates for the NOSB. This resulted in highly qualified candidates being appointed.

Engaged members of the organic community want to be involved and want to help you, Mr. Secretary, make the best possible choices. I respectfully ask that you please intervene and have the names of all current candidates released publicly so that organic farmers, processors, marketers, and consumers can participate in the appointment process.

Organizations/Businesses
Agricultural Missions, Inc.
Animal Welfare Institute
Bronx Greens - NY
Carolina Farm Stewardship Association
Cayuga Pure Organics
Center for Rural Affairs
Church Women United
Concerned Citizens of Central Ohio
Cooperative Development Services
The Cornucopia Institute
Court St Joseph #139, Catholic Daughters of the Americas - BY
D'BugLady Pest Management Co.
Demeter USA
Diocese of Jefferson City
DownRiver Alliance
Ecological Farming Association - CA
Eden Foods
Endangered Habitats League
Food Animal Concerns Trust (FACT)
Farm Sanctuary
Friends Fields, Inc.
Georgia Chapter of Sierra Club
Greenstar Cooperative Market - NY
Heavenly Organics, LLC
Highlands Bar & Grill - AL
Hmong American Comm.
Horseheads Grange #1118 - NY
The Humane Society of the United States
Iowa Citizens for Community Improvement
Iowa Farmers Union
La Crosse Coalition for Peace and Justice
Ladies of Charity - NY
Lake Erie West Foodshed Network - OH
Michigan Farmers Union
Milk Outrage Organization (MOO)
National Cooperative Grocers Association
Nebraska Wildlife Federation
New England Small Farm Institute
New Entry Sustainable Farming Project
Ohio Family Farm Coalition
Organic Consumers Assocation
Organic Food Network
Public Citizen
Northeast Organic Farming Association of Connecticut
Northern Plains Sustainable Agriculture Society
Politics of Food
Rachel's Network
Revitalization Institute
River Alliance - Wisconsin
The Sierra Club National Agriculture Committee
Sierra Club Atlantic Chapter
Small Farm Today
Sisters of St. Francis of Tiffin - OH
Slow Food Pittsburgh
Small Planet Institute
South Tex Organics, LLC
The Southern Cheesemakers' Guild
Southern Sustainable Agriculture Working Group
Stellar Certification Services
Traders Point Creamery
Twin Pines Cooperative Foundation
Union of Concerned Scientists
UWL Progressives
Valley Stewardship Network
Virginia Association for Biological Farming
Weston A. Price Foundation
Weston A Price Foundation, Toledo Chapter
Wisconsin Farmers Union
Wisconsin Resources Protection Council

Cooperative Grocers
Amazing Grains Natural Food Market - ND
Ashland Food Co-op - OR
Berkshire Co-op Market - MA
Bloomingfoods Market and Deli
The Blue Hill Co-op - ME
Common Ground Food Co-op - IL
Community Markets - NY
Community Mercantile - KA
Coos Head FoodStore - OR
East End Food Co-op - PA
Ever'man Natural Foods Co-op - FL
Flatbush Food Coop
Green Fields Market
Good Foods Market
Green Hills Harvest - MO
GreenTree Cooperative Grocery
Cooperative Grocers (continued)
Harvest Co-op Market - MA
Honest Weight Food Co-op - NY
La Montanita Coop - NM
Lexington Co-op - NY
Linden Hills Co-op - MN
Marquette Food Co-op - MI
Mississippi Market - MN
MOMS Food Co-op - MN
North Coast Bakery - CA
Ocean Beach People's Organic Food Co-op - CA
Open Harvest Cooperative - NE
Oryana Natural Foods Market Cooperative - MI
Outpost Natural Foods - WI
PCC Natural Markets - WA
Peoples Food Co-op of Ann Arbor - MI
People's Food Co-op - OR
People's Food Co-op of Kalamazoo - MI
Rainbow Natural Grocery - MS
Rising Tide Natural Foods Cooperative - ME
River Valley Market - MA
Selene Whole Foods co-op - PA
Sevananda Natural Foods Market - GA
Seward Cooperative Grocery and Deli - MN
Sacramento Natural Foods Cooperative - CA
Stueve Certified Organic - CA
Takoma Park Co-op - MD
The Food Co-op - WA
Weaver Street Market
Wedge Co-op - MN

Individual Signers — mostly organic farmers
Steven Adams - WI
Tony and Carol Azevedo - CA
Patricia Bigelow - CT
Cissy Bowman - IN
Brent Charnley - WA
Paul Conway
Jim Pierce - WI
John Dieterich
Early Morning Organic Farm - NY
David and Mary Eggen
The Franklin Farm
Hayes Acres - WI
Hart to Hart Farm - ME
Jersey Ridge Organic Dairy
Charlie Johnson - SD
Lehouillier Farm - VT
Susan Loesser - CA
Lourdes Fernandez - PA
Nicholas Francisco - CA
Rose Green - CO
Marcia Halligan - WI
Perry Hart
Deborah Hill
Leslie Hutchins
Ruth Hockley
Lauren Hunt - WI
Gregory J. Jackmauh - VT
Richard Katz
Judith King
Klauke Family Farm - MS
Sharon L. Knopp & Ingolf Vogeler
Gary and Carolyn Lamson - MN
Lehouillier Farm - VT
Richard Magyar - WI
R & G Miller & Sons, Inc. - WI
Robert & Pamela Moore - NY
Jim Munsch - WI
Sister M. Severina Caron, osf
Nature's Clover Dairy - CA
Richard Newsome - WI
Michelle Niedermeier - PA
Karen Odessa Piper - DC
Nojoqui Ranch Produce
Rick North - OR
HOney GRace Farm - MD
Annie Pedret - IL
Red Lion Farm - MD
R. H. Richardson - TX
Pat Richardson - TX
Samish Bay Cheese/Rootabaga Country Farm - WA
Sprout Creek Farm - NY
Leland Thomas
Tristana von Will - WI
Uriel Levi - VA
Paco John Verin
Wray-Todd Ranch, LLC
Paul Zarchin - AZ

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