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Comments to the NOP: May 20, 2008
A letter from NODPA to the NOP addresses publication of the access to pasture rule and the publication of an origin of livestock rule

To:  National Organic Standards Board
       Valerie Francis
       Room 4008–South Building
       1400 Independence Avenue­­–SW
       Washington, DC, 20250-0001

From:
  Northeast Organic Dairy Producers Alliance (NODPA)
Re: Publication of the access to pasture rule and the publication of an origin of livestock rule

Date:  May 20, 2008

Dear NOSB Members and NOP staff,

NODPA is the largest organic dairy farmer organization in the country and has a membership of over eight hundred organic dairy farmers. NODPA’s mission is to “enable organic dairy family farmers, situated across an extensive area, to have informed discussion about matters critical to the well being of the organic dairy industry as a whole.” NODPA is not aligned with any one processor or cooperative and is therefore able to represent the views of many different farmers both in the northeast and across the country by working with its sister organizations, MODPA and WODPA, under the umbrella organization of the Federation of Organic Dairy Farmers (FOOD Farmers).

We want to see the immediate publication (or as soon as possible under the present federal rules) of a rule that clearly states the following as a minimum for compliance:

Access to Pasture standards

  1. Organic dairy livestock over 6 months of age must graze on pasture during the months of the year when pasture can provide edible forage.
  2. The grazed feed must provide significant intake for all milking-age organic dairy cows. At a minimum, an average of 30% of the dry matter intake each year must come from grazed pasture during the region’s growing season, which will be no less than 120 days per year. 
  3. Temporary exemption from pasture may be allowed because of:
      1. Conditions under which the health, safety, or well-being of the animal could be jeopardized, including to restore the health of an individual animal or to prevent the spread of disease from an infected animal to other animals.
      2. Short term inclement weather.
      3. Temporary conditions which pose a risk to soil and water quality.
      4. In no case will temporary confinement and exemption from this pasture standard be allowed as a continuous production system.

The measurement of the consumption of dry matter from grazed pasture will be calculated based on the daily dry matter intake from grazing averaged over the total time period grazed per year.
NODPA, FOOD Farmers, NOC and WhiteWave Foods request that the USDA NOP do not issue an Advanced Notice of Proposed Rulemaking (ANPR) to clarify the rule for organic dairy replacement but move straight to a proposed rule making. In May of 2006 the NOP received and documented a large number of comments received in favor of last third of gestation for replacement dairy animals and it seems unlikely that eventual rulemaking would go against such a swell of public opinion. Organic dairy farmers across the country have arrived at the following position on organic dairy replacements “After a dairy operation has been certified, animals brought on to the operation must be organically raised from the last third of gestation, regardless of how or when the operation converted to organic dairy production. All replacement animals born on certified operations must be managed organically.    

When Kelly Shea (WhiteWave Foods), Steve Etka (National Organic Coalition) and I  met with Bruce Knight (Under Secretary for Marketing and Regulatory Programs),  J. Burton Eller, Jr. ,(Deputy Under Secretary for Marketing and Regulatory Programs); David Shipman (Associate Administrator for AMS) and Richard Mathews (NOP) for 45 minutes we discussed the clarification of the access to pasture rule and the proposed origin of livestock and cloning rule.

We were able to provide a unique presentation to the Under Secretary of all sides of the industry (processors, farmers and non-profits) with a unified position on the two priorities for the organic community, the immediate publication of the access to pasture rule and the publication of a rule (rather than an ANPR) for the origin of livestock. The Under Secretary confirmed that the publication of the access to pasture rule and the origin of livestock were priorities for him and the department. NOP assured us that the proposed access to pasture rule will clearly define the requirements that producers have to meet and will be a strong rule that protects the integrity of the Organic Seal.
Organic dairy farmers in the northeast strongly support the above position as it will preserve the integrity of the USDA Organic seal thereby guaranteeing the livelihood of family farms across the country and the continued confidence of the consumer.

The two rules need to be published quickly in order to create a level playing field by having a clear definition of the minimum requirements for grazing and one easily understood rule for organic dairy replacements, rather than the many confusing criteria we have now. Farmers are suffering very real financial hardship and are concerned about the future marketability of the organic seal unless it is strongly defended by the USDA NOP.

The future of organics rests with a transparent system at the regulatory level which the NOP is now implementing with their new website and continued meetings to work together on moving issues forward that are critical to the future integrity of organic dairy. With organic under attack from many levels (price, supply and imitators) it’s time for all of us to work together to promote organics as the only third party certified product that is produced under protocols that benefit the environment and provide a product that can be traced back to the farm and provides a premium to the farmer, not just the marketer. Now is not the time to cast doubt on the integrity of organic certification and we stress to the USDA that we need them to act now before it’s too late.

Respectfully submitted,
Ed Maltby, NODPA Executive Director

The NODPA Board and State Reps
Kathy Arnold, President, Charleston, ME
Dave Johnson, Vice President, Liberty, PA
Henry Perkins, Treasurer, Albion, ME
Liz Bawden, Secretary, Otselic, NY
John Stoltzfus, Whitesville, NY
Jim Gardiner, Otselic, NY
Rick Segalla, Canaan, CT
Arden Landis, Kirkwood, PA
Siobhan Griffin, Schnevus, NY
Craig Russell, Brookfield, VT
Beverly Rutter, Bridport, VT
Morvan Allen, Sheffield, MA
Steven Russell, Winslow, ME
Steve Morrison, Charleston, ME
Aaron Bell, Edmunds, ME