Access to pasture and replacement animals in organics

May 11, 2006

Mark A. Bradley
Associate Deputy Administrator
Transportation and Marketing Programs
National Organic Program
1400 Independence Avenue, SW
Room 4008-So. Ag Stop 0268
Washington D.C. 20250

Re: docket number TM-05-14

Dear Mr. Bradley,

As a consumer-owned, certified organic food retailer, we wish to comment on how USDA should address the relationship between dairy animals and pasture or grazing land under the National Organic Program.

Our 38,000 member/owners have made it clear they want and expect dairy livestock to be raised in a pasture-based system as nature intended. Their expectations are rooted in the fact that cows have four stomachs and the dental structure for a fresh, grass-based diet and that therefore a pasture-based system is the only system consistent with the needs of the species. This means ruminants should be allowed "access to pasture" throughout the growing season so fresh, green pasture is the basis of their diet. In turn, such access to pasture ensures the land will be nourished by animal manure.

Regular confinement of lactating cows for other than temporary health issues or extreme weather is not suitable to the species' natural needs, or the needs of the land, and therefore not acceptable. Some parts of the country simply are too arid to provide conditions suitable to the species. Allowing "organic" feedlots with thousands of cows in these arid regions raises serious concerns about USDA's enforcement of existing regulations and value in the organic label.

We urge you to support the NOSB's recommendations that all replacement animals for certified organic herds must be managed organically from the last third of gestation. The practice of some dairies to sell off their baby heifers to avoid the cost of raising them on 100 percent organic milk, and then replacing them with mature, non-organic cows "transitioned" into the herd is not acceptable. The practice of transferring or selling calves to neighboring feedlots, then bringing them back to the farm later for integration into the herd also is deplorable and should result in heavy penalties and loss of certified organic status.

A recent industry survey (soon to be published on the USDA Web site) reports that 72 percent of the respondents expect milk to be from cows that graze on pasture. Another survey from the Center for Food Safety found that 61 percent of shoppers would stop buying organic if they learned the cows weren't pastured. Virtually all organic milk cartons depict happy cows at pasture. Our shoppers have a right to expect that what they see is what they get.

We urge the NOP/USDA to allow clarification of "access to pasture" for a rule reflecting pasture-based systems. We also urge that USDA include language to ensure all replacement animals for organic herds are managed organically from the last third of gestation.

Sincerely,

Tracy Wolpert
Chief Executive Officer

Randy Lee
Chief Financial Officer

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