Ms. Phyllis Fong

USDA – Office of Inspector General

Room 117-W Jamie Whitten Bldg

1400 Independence Avenue SW

Washington, DC 20250

Dear Ms. Fong –

The Organic Consumers Association (OCA), representing more than 850,000 members, subscribers and volunteers, strongly supports Cornucopia Institute’s recent formal legal complaint with the USDA regarding Dean Foods.

As indicated in the complaint, Dean Foods, under its Horizon label, continues to inundate the market with USDA certified “organic” dairy products inappropriately sourced from two large-scale dairy operations (up to 8,000 head of cattle each). The majority of the cattle are confined to feedlots and are not given fresh grass and access to pasture in the manner outlined by the federal organic regulations. The USDA responded to previous complaints about similar factory farms, launched investigations, and implemented sanctions where appropriate, but the agency has failed to investigate one of the biggest profiteers of organic dairy, Dean Foods.

The OCA regularly surveys its members to determine which issues are of deepest concern, so we can better serve as a representative for this important sect of the market. Our constituents range everywhere from organic farmers, to upper income suburban families, to low income students. Due to the diversity of our membership, our survey results are often mixed.  With that said, we have never had a survey as conclusive as our 2006 survey regarding Horizon.  A full 99% of those surveyed indicated they felt Horizon should be boycotted until Dean Foods discontinues its “organic” factory farm operations.

A gallon of conventional milk can cost as little as $2.99; meanwhile, the privilege of consuming organic milk can run consumers up to $7 dollars a gallon. Surveys clearly show consumers are willing to pay extra for organic milk, because they believe they are paying for the milk to be produced by grass-fed cattle raised humanely on modest-sized family farms. In contrast, the current organic dairy market is ruled by large industry-scale operations overseen by Dean Foods and Aurora who are taking advantage of this price variation for the sake of massive profit margins.

The USDA was originally created to serve the same farmers and consumers who have expressed near unanimous concern about this issue. Therefore, the Cornucopia Institute’s formal legal complaints should not continue to be overlooked. We call on you, in large numbers, to issue unannounced investigations of the two previously mentioned Dean foods dairy operations.

Ronnie Cummins

National Director

Organic Consumers Association