Passed on from Center for Rural Affairs

ACTION ALERT 

USDA's organic program sides with factory dairy farms

Ask Secretary Johanns to intervene 

Note: this is not an issue that the Center for Rural Affairs works on directly. However, it is an important issue and one that we think you should be informed about. If this is not addressed it could set a very ugly precedent not only for the organic community, but for all niche markets. WE MUST HOLD THEM ACCOUNTABLE!!

Way back in the year 2000, concerned consumers and farmers asked the National Organic Standards Board (NOSB) to address a new and troubling trend-factory farms producing "organic" milk in confinement conditions.

The board responded in 2001 by adopting a guidance document that would have helped farmers and certifiers understand what is expected of them and closed loopholes being exploited by industrial-scale farms.  The USDA sat on this document, never posting it on their web site or enforcing its provisions. 

This spring The Cornucopia Institute filed legal complaints with the USDA alleging that a growing number of factory farms were ignoring the organic law that requires ruminants (dairy cows) to have "access to pasture." The Center for Rural Affairs signed on to their complaints to prevent large corporate type farms from capturing a market that most farmers and most consumers would like to be retained by family farms.  Finally, after years of delay, the USDA asked the NOSB to revisit their recommendations.  The 
board responded by passing a rule change and new guidance document.   

Again!  The USDA has thrown a monkey wrench into enforcing organic integrity.  They rejected the language adopted unanimously by the NOSB, a respected and diverse expert advisory panel (saying it was "ambiguous"), and now have refused to allow the board to vote on new language at their next meeting this November.  Years of delays continue as the factory farms expand. 

Farmers and Consumers Have Lost Their Patience  

No More USDA Foot Dragging! 

No more delays can be tolerated!  The USDA allotted two hours for more public comments at November's meeting but has forbidden the NOSB from taking a vote and adopting final rule change language.  The bureaucrats and the corporate farm operators know very well that this will be the last meeting for NOSB Chairman Jim Riddle and a number of other experienced board leaders, whose terms are ending.  These folks have been the champions of cracking down on factory-farm abuses in the dairy industry.  Public comments can be submitted prior to the meeting, reserving the two-hour time slot for board action on this issue. 

Please send a message to USDA Secretary Mike Johanns appealing for the Secretary to step in and demand that the will of the people, as evidenced by thousands of comments, letters, and petitions in support of pasture enforcement, not be subordinated to corporate interests. 

Letters and e-mails can be directed to: USDA Secretary Mike Johanns, 1400 Independence Ave SW, Whitten Building - Suite 200A, Washington, DC 20250, [log in to unmask]  

A sample letter has been included for your use. If you need additional assistance, please contact Traci Bruckner at the Center for Rural Affairs by emailing [log in to unmask] or by calling (402) 687-2103, Ext. 1016.


SAMPLE LETTER

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, 
  
  
SIGNATURE: 
  
NAME (please print):    
ADDRESS:  
  
E-MAIL ADDRESS:  
FARMER/CONSUMER/OTHER (please specify):   


_______________________________________

Jim Redmond
Professor of English
Briar Cliff University
712-279-5544
[log in to unmask]


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