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National Survey Shows Overwhelming Opposition to Factory Farm/Intensive Confinement Organic Dairy Practices

NODPA News (summer 2005 edition)

Northeast Organic Dairy Producers Alliance Survey Shows Great Support for Pasture Proposal from Organic Dairy Farmers By Will Fantle

CORNUCOPIA, WI: A national survey conducted by The Cornucopia Institute reveals overwhelming support by organic dairy farmers for the National Organic Standards Board's (NOSB) proposed guidance document on pasture for dairy cows and livestock ruminants.

"We mailed surveys to nearly 600 certified organic dairy producers in the Midwest, Northeast, Pacific Northwest and California," says Mark Kastel, Senior Farm Policy Analyst for The Cornucopia Institute. "Approximately 93% of the dairy producers who answered the survey stated that they supported the draft guidance document as written and could meet the delineated benchmarks," Kastel notes.

The pasture issue reached a boiling point earlier this year after The Cornucopia Institute filed formal complaints with the USDA over the lack of pasture for milking herds at the Aurora dairy in Colorado, the Horizon dairy in Idaho, and the Vander Eck dairy in California. (Pictures from the Aurora and Horizon operations are posted on the group's Web page at < .)

These huge certified organic factory dairies, with their thousands of milking cows, allegedly provide only limited pasture and then almost exclusively for their young stock and dry cows. The lactating herd is mostly fed TMR rations in confined dirt drylots, pens or sheds.

Since Cornucopia's complaints were filed this spring, a groundswell of farmers and consumers have been urging the NOSB to close the stage of production loophole and adopt and enforce a minimum pasture standard requiring a pasture component for the ruminant¹s diet (as required by the current regulations).

And the NOSB has responded. In addition to a pending rule change, requiring cattle to actually "graze" rather than just having "access to pasture", the NOSB's Livestock Committee has set a livestock ruminant management plan goal of "providing grazed feed greater than 30% dry matter intake on a daily basis during the growing season but not less than 120 days." (The full text of the proposed guidance document can be viewed on the National Organic Program's Web page at:

But is this an acceptable, workable plan?

To find out, The Cornucopia Institute decided to survey the nation¹s organic dairy community. According to Kastel, 30% of those receiving the survey mailed back their opinions. And this extraordinarily high response rate even came during the height of spring planting as well as, for some farmers, their first cutting of hay.

Kastel says every effort was made to remove bias from the survey questions so as to gather the farmers' true opinions. Three paragraphs introduced the issue and provided background, and then presented balanced pro and con statements outlining how and why some farmers and organizations support or oppose the guidance proposal.

A few of the 93% of the farmers supporting the NOSB guidance language indicated that they would have to make some management changes on their farm to meet the pasture benchmarks. They also indicated they were willing to make the changes.

Says Kastel: "In other words, almost all farmers responding do not anticipate any significant problems in modifying their operations to meet the new guidance parameters."

Several farmers also added written comments expanding on their viewpoints:

* One Pennsylvania farmer, with 33 milkers, wrote: "I feel all cows and heifers should at least have access to pasture with edible forage for the entire grazing season as a bare minimum except for temporary confinement because of inclement weather - we have been doing this ever since being certified."

* A Vermont farmer, with 100 milking cows, noted that he provides at least one acre of pasture per cow for his milking herd. And he adds that "fresh pasture has been proven to produce higher levels of the following nutrients in the milk of cows: CLA, Omega3, Vitamin E, Beta Carotene."

* An Oregon farmer with 130 milking cows wrote that his only concern was that "sometime in the fall, the pastures aren't growing as fast, because of weather or irrigation, that I would supplement the milk cows instead of the heifers. The 30% dry matter for the cows for 120 days should be OK as long as common sense is used."

* An Iowa producer wrote that "those other farms need to seed down some of their cropland to pasture like I did. This not only gives them the pasture to meet requirements but also helps with water quality, erosion, provides nitrogen for a crop of corn."

According to Kastel, about 5% of the dairy producers responding to the pasture survey said they philosophically supported the NOSB proposal but would have a difficult time meeting the 120 day and 30% dry matter intake requirements.

Kastel thinks that at least some of this small group of farmers may have misunderstood the draft guidance document. For example, one farmer mentioned that drought could cause problems for his operation. But the current USDA regulations make an exception for this type of weather event, allowing for "temporary" confinement of the herd and providing the cows with stored feed.

Others in this group said they would have to make significant capital investments to meet the proposal. While sympathetic to their individual situations, Kastel says that ³many producers have had to make great investments in capital and knowledge to properly make their organic transition. We should expect no less from all organic producers and look for mechanisms, and potential public funding, to help them successfully transition and meet the minimum organic benchmarks.² The Cornucopia Institute is interested in learning more about the specific circumstances on these farms that present difficulties in meeting the proposed pasture guidance. The organization will seek follow-up interviews with the farmers to learn more about their problems and see if any practical solutions can be suggested to the NOSB.

One percent of the survey¹s respondents expressed outright opposition to the pasture proposal. These farmers did not indicate whether or not their operations can meet the guidance requirements but one mentioned his general opposition to more government intervention.

The Cornucopia Institute will prepare a full report on their survey for presentation to the NOSB at its August 15-17 meeting in Washington, D.C.

Mr. Fantle is the Research Director for The Cornucopia Institute
A Look Behind the Public Comments on the NOSB Pasture Proposal

By Will Fantle

A total of 128 comments have been posted on the USDA's National Organic Program Web site concerning the NOSB's proposed pasture guidance document for ruminants. We thought it might be worthwhile, perhaps even a little revealing, to take a closer look at the comments and their authors.

In general, it can be said that a clear (super) majority of those submitting public comments supported the draft pasture guidance document. In all, 91 submissions endorsed (with minor tweaking, in some cases) the guidance document. A handful of submissions, including one petition containing 63 signatures, expressed general support of aggressive enforcement of the pasture regulations.

About one out of every three public comments came from organic dairy farmers. Impressively, by a ratio of approximately 10 to 1, comments from the farmers supported the thrust of the guidance document. And their remarks came in from across the country Maine-2, Vermont-5, New Hampshire-1, Connecticut-1, New York-10, Pennsylvania-8, Ohio-1, Wisconsin-11, Minnesota-2, California-2, and 1 from an unknown location.

Also supporting the pasture guidance were 10 organizations, including OFARM, National Organic Coalition, Farm Animal Concerned Trust (FACT), National Campaign for Sustainable Agriculture, Organic Consumers Association, NODPA, NOFA-VT/RI/NY/NJ, CROPP/Organic Valley, Oregon Tilth, and Maine Organic Farmers and Gardeners Association.

One organic crop farmer from South Dakota supported the pasture guidance, as did 32 consumers scattered across the county. And several other supportive comments came from individuals that could not be clearly identified as a consumer or farmer.

The Aurora Organic Dairy in Colorado opposed the guidance document, as did Case Vander Eck of California (both dairies have been named in complaints to the USDA, filed by The Cornucopia Institute, regarding their pasture practices). Vander Eck called the document "simply not fair." One Wisconsin dairyman also opposed the pasture guidance on philosophical grounds.

Thirteen comments opposing the pasture guidance came from organic crop producers. 11 of these were Idaho-based farmers and one was from Colorado (the home states of the country's two largest industrial-scale organic dairies, Dean/Horizon and Aurora. The Horizon Idaho dairy was also named in a USDA complaint for their questionable pasture practices). "I think you can conclude," says The Cornucopia Institute's Senior Farm Policy Analyst Mark Kastel, "that Aurora and / or others mobilized the feed suppliers to speak out against the pasture requirement. These contract producers know that they may lose a major commodity buyer should the guidance document be adopted." One of the arguments made by opponents of the guidance document is that the arid western climate makes it difficult to pasture dairy cows for 120 days the pasture feed component is organic grain, and there's no doubt that the arid state grain producers, like those opposing the pasture guidance, rely heavily upon irrigation to grow their crops. "There is sound ecological and economic reasoning behind the historic predominance of family-scale dairy farms in the upper Midwest, New York, Pennsylvania, New England, and even the Northwest production," states Kastel.

Two other opponents of the pasture guidance, contract heifer ranches raising organic replacement animals, both are Colorado operations. Says Kastel:

"These farms have an intimate relationship with at least one of the huge, pasture-deficient dairies operations have unsustainable cull rates, probably like the most of the very large confinement setups, because they are pushing the animals so hard and constantly need replacement animals. We believe that pastured animals on smaller operations have significantly less stress and lead longer, healthier lives."

One other noteworthy opponent of the pasture guidance was Dairy Farmers of America (DFA). We understand DFA markets conventional milk from some or all of the other Aurora farms located in Texas, Georgia, and Florida. It should also be noted that DFA has a controlling interest, as recently reported in the Milkweed, in Dairy Marketing Service (DMS), an organization doing procurement of organic milk on behalf of the largest corporate players, Dean/Horizon and Hood/Stonyfield.

And a half dozen comments came from opponents of the portion of the draft pasture guidance that sets a 30% dry matter intake for 120 days. Two Wisconsin dairymen, who employ pasture, indicated they opposed this section because they didn't like the number requirement. Interestingly, another opponent was the Wild Oats food chain. Wild Oats opposition may seem odd given their emphasis on organics coupled with their recent declaration that "demand for improving the welfare of farm animals has never been higher," but industry sources have told us that their private label organic milk is supplied by Aurora.

Two sets of comments were relatively neutral in tone, such as the position taken by the Organic Trade Association (OTA). OTA backed "the farm plan as the vehicle for constant improvement." OTA had also requested an extension of the comment period from the NOP so that they could file their remarks. That extension was granted but it was also utilized by a number of others. DFA, for example, didn¹t take action on the pasture document until their June 9 board meeting. Kastel notes that a number of the public comments opposing the pasture guidance were received after the initial May 20 deadline Idaho feed producers and the one from Wild Oats.

A big glitch in the NOP comment and review process was uncovered by The Cornucopia Institute right before the NOSB's Livestock Committee meeting in mid-June. A priority for the committee was the review of the pasture guidance proposal, and public comments were one component of that review. A significant batch of public comments (including comments from a number of farmers and Cornucopia¹s dairy farmer survey) had not been provided to the committee even though the comments were filed with the NOP by its May 20 deadline.

"How can we expect our public officials to make informed and wise decisions if critical information is withheld from them?" he asks. "It's an insult to the family farmers and consumers who trust that the process is being handled in a democratic fashion," says Kastel.

In this particular case, the serious concern that Cornucopia raised about the matter with Jim Riddle, the citizen chair of the NOSB, and Riddle¹s last-second intervention, caused NOP staff to supply the Livestock Committee with many of the missing public comments.

It is not too late for dairy producers who believe in the integrity of the organic production and who support the judicious enforcement of the pasture requirement by the USDA to make their voices heard. Farmers are encouraged to consider attending the upcoming NOSB meetings in Washington on August 15­17.

Farmer testimony is respected and carries much weight. However, if you can't be in Washington, please make the effort to return the petition letter that you should receive from The Cornucopia Institute. It will be hand carried to Washington, and if enough dairy farmers respond, officials in Washington will not be able to ignore your opinion.

"A lot is at stake right now for the organic dairy community," Kastel observed. "If farmers do not take a strong and aggressive stand now, assuring scale-neutral pasture enforcement, we could see a surplus of milk in coming years, created by these large confinement operations, driving down the price of organic milk, and forcing families off the land, the same way conventional milk prices were the ruin of so many farmsteads." Will Fantle is research director for the Wisconsin-based Cornucopia Institute

SIDEBAR: Urgent Request Dairy Farmer Response Needed

Look for a proxy-letter, to the NOSB, in your mailbox from The Cornucopia
Institute. Please sign your letter and mail it right back using the postage-paid envelope provided! Your letter will back up NODPA and many of its members who have worked tirelessly over the past six months advocating for the USDA draft rule change and pasture guidance document. Please show respect for your fellow dairy producers who are going to the expense, and taking the time, to be at the USDA/NOSB meetings in Washington in August by supporting them with your letter. Please mail it back to The Cornucopia Institute at once so it can be hand-carried into the NOSB meeting!
Questions: 608/625-2042, <