See the note below from the Cornucopia Institute regarding the fate of the National Organic Dairy Pasture & Feed Standards. Write a note today! (see email addresses at the bottom of the letter)
Dear Organic Consumer,
We believe that you need to know about an important behind-the-scenes development occurring at USDA that may very well determine how the agency resolves the controversy on pasture and the origin of organic livestock.
A small group of the nation's largest conventional and organic dairy processors and their powerful lobbyist (who works for, among others, Dean Foods, Kraft and the OTA) collaborated with bureaucrats at the National Organic Program to develop a proposed regulation that USDA could offer and adopt on pasture. These large players, representing the vast majority of the organic milk in this country, have crafted and provided the USDA with a proposed regulation. We understand that the guts of this proposal will be what the agency releases by as soon as the end of this year.
The proposed regulation does not include a 30% DMI requirement (dry matter intake), only that animals be pastured for 120 days. The proposed rule that the vast majority of the organic dairy industry came to a consensus on, with support from the USDA's expert advisory panel, the National Organic Standards Board (NOSB), would require all dairies to graze animals for the entire growing season, but not less than 120 days. And it would have included the 30% requirement (it should be noted that farmers truly dedicated to grazing might be feeding as much as 50-80% DMI from pasture during the growing seasonso 30% is a quite reasonable compromise figure that the dairy farmers across the country could reach consensus on).
One of the guiding principles of organic food and agriculture has been transparency. It is terribly troubling that this proposal has not been the subject of public debate and/or input from the broader organic community. This is highly disrespectful and utterly undemocraticpolitics as usual in Washington in the worst sense.
Over the past six years, more than one hundred thousand consumers, farmers, businesses and non-profit groups have commented to and engaged with the USDA about specific rule-making, scores of farmers made the trek to Washington to testify on their own, and the National Organic Standards Board has passed their own guidance and rule-making recommendations. Yet now this small group of industry players and their powerful Washington lobbyists might very well have more influence in the entire process.
We ask you as partners in this industry: We're you consulted in this process? Would you have liked to have had a voice in shaping how this will affect your operation and relations with farmers and consumers?
We are told that USDA believes the organic community is fractured on a consensus proposal and that they cannot support a 30% guideline. But the farm communityand their three major regional producer associationshave all been visibly united behind the 120 day/30% proposal. When we circulated a sign-on letter to the USDA last year supporting the 120 day/30% proposal approximately 150 different consumer and farm organizations signed on (available upon request). Furthermore, the only independent survey work that we are aware of that has actually gone to rank-and-file organic dairy farmers and asked for their views (conducted by Cornucopia) found 97% support for the 30% proposal from the nearly 600 organic producers polled who offered their perspectives (also available upon request).
This past spring, the voices on the USDA's producer panel didn't all agree at the national organic dairy forum in Pennsylvania. But it is important to note that the panel, selected by the USDA and screened by at least one industry lobbyist, was deliberately constructed to present conflicting viewsnot to air the overwhelming majority viewheavy on Western dairies milking hundreds or thousands of cows in confinement-type conditions. It is disingenuous for USDA to now point to their hand-picked panel and throw up their hands saying we can't agree on a common course of action.
It may not be too late to change what USDA will shortly offer as their new regulation. But that will only be true if you and other important members of the organic community are aware of the process taking place. We urge you to use your influence to ensure that all voices have a say in the drafting of this very important dairy regulation.
We are presently fund-raising for a legal challenge that will assert that the present law is not being enforced by the USDA (additional language to close loopholes would be fine but the USDA has not even made an attempt to crack down on confinement dairies currently milking as many as 10,000 cows). This is a separate action we are working on to protect pasture-based organic dairies and marketers.
Please stay tuned, we hope to give you some tools to help you and the farmers who supply your milk respond aggressively. The bottom line is that this weakened rule, that the larger dairy processors and USDA appear to have reached consensus on, will soon be put forward and willallow the scores of new 1000-3000 cow industrial dairies (mostly in the West) to drive down the price of organic milk and force many of the family farmers and smaller marketers out of business.
Today we sent a letter to USDA Secretary Mike Johannes asking him to intervene and prevent the NOP from joining with major organic dairy marketers selling and selling out to the factory-farm interests. We suggested in our letter that if the department puts this draft rule forward it will be met with the most aggressive consumer and farm response since the initial draft rule of the organic standards (generating 300,000 angry responses) was published in the mid-1990s. We hope that he will save the organic community from going through this disruption and the USDA from widespread public displeasure and harassment in the media.
We understand the USDA has also been working with these same manufacturers to promulgate a weakened rule that would allow conventional cattle to continue to be transitioned and brought onto existing organic dairy farms. These large factory farms cannot continue to operate without a constant stream of replacement animals because of their high slaughter rates. Some of these provisions are also in conflict with the spirit of organics that so many in the industry are trying to uphold.
We think this is a watershed event in the making. We will keep you posted on further developments. If you have questions please feel free to contact me.
PS: A very short note from you today, as a business owner/manager, to the Secretary of agriculture, Mike Johannes: firstname.lastname@example.org, with a copy to his Chief of Staff, Dale Moore: email@example.com, could make a difference.
Mark A. Kastel
The Cornucopia Institute
Sneak Attack on Organic Dairy Pasture and Feed Requirements by Horizon, Dean, Kraft , USDA, & Industry Bureaucrats
By Mark Kastel
The Cornucopia Institute, Dec 21, 2006
Straight to the Source