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Thoughtful Steps to the Final Pasture Rule
By Ed Maltby
Final Pasture Rule by Spring 2009 – Implementation in Spring 2010
As we predicted in the last NODPA news the Proposed Pasture Rule was published October 23, 2008 with a 60-day comment period. NODPA was happy to provide a venue for the first listening session on the last day of the NODPA Field Days.
What happens next?
The comment period on the proposed rule will end on December 23, 2008. After reviewing the comments, the USDA NOP will write up a final rule, take it through the federal process and hopefully publish a final rule in spring 2009. There will likely be a phase in period of a complete grazing season to give certifiers time to adapt their forms, educate inspectors and give producers time to make any changes they may need to their existing farm. IF we can keep the process moving, final implementation would likely be in spring 2010.
NODPA has devoted a large chunk of this edition of NODPA News to give perspective and analysis of the proposed rule. NODPA and FOOD Farmers will be working with many organizations including the National Organic Coalition, National Campaign for Sustainable Agriculture, Sustainable Agriculture Coalition, Organic Trade Association, Organic Farming and Research Foundation, Accredited Certifiers Association, processors, and certifiers, coordinating comments, data and suggested language to submit to the NOP.
NODPA will work to find as much consensus as possible in providing comment and ask producers to send questions, opinions and comments they have on the proposed rule to NODPA either by mail, fax or email.
NODPA will circulate producer thoughts on Odairy and email newsletters, and will hold producer meetings at convenient locations as time and circumstances permit. The NODPA Board and State Reps, MODPA and WODPA will hold conference calls to discuss comments and coordinate positions wherever possible.
There will be at least two more listening sessions by the USDA in December 2008—one in La Crosse, Wisconsin in the first week of December and one in California in early December. These are a great opportunity for producers and others to ask questions directly to Richard Mathews and other NOP employees.
What can you as a producer do?
Send NODPA information and data on how you already meet these standards or where you see difficulties in incorporating these practices into your operation.
Write a personal letter (form letters are bundled together and don’t carry the weight of individual letters) to the NOP explaining that you support the rule and the importance of a pasture standard that has specific language and is very clear about it’s intent. You should also explain how this rule will affect your operation and include any areas of concern you may have.
We will need as many personal letters from producers as possible to send into the NOP.
This can either be done by sending the by mail or email to NODPA and we can forward them to the NOP or send them directly to the USDA addressed to:
Richard H. Mathews
Chief, Standards Development and Review Branch,
National Organic Program, Transportation and Marketing Programs, USDA–AMS–TMP–NOP
1400 Independence Ave., SW., Room 4008– So., Ag Stop 0268, Washington, DC 20250.
By Internet: http://www.regulations.gov. Written comments on this proposed rule should be identified with the docket number AMS–TM–06–0198;TM–05–14.
NODPA Contact Information:
Ed Maltby, NODPA Executive Director
30 Keets Rd, Deerfield, MA 01342
Posted: to Policy on Fri, Nov 7, 2008
Updated: Fri, Nov 7, 2008