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Newsletter of Penn Dutch Cow Care April 2005

Hi Folks,

The newsletter this month is actually about news regarding what went on at the National Organic Standards Board (NOSB) meeting held in early March in Washington, DC. The NOSB exists as part of the Organic Foods Production Act of 1990 and it is the official advisory Board to the National Organic Program (NOP). The NOP implements the regulations and makes sure that certifiers and farmers are in compliance with the law. After having returned from the 31/2 day meeting, many farmers asked me how things went regarding the dairy issues. The over riding issue was that of organic cattle and pasture. As it stands now, it is possible to potentially have lactating organic cows which have minimal or no pasture. Many farmers were aware that this issue was going to be front and center at the meeting.

There was quite a campaign by NODPA, the Cornucopia Institute and the Organic Consumers Association to send in letters and signed petitions. All in all, there were about 8,000 comments officially submitted to the NOSB which then forwarded them on to the NOP. There were about 28 farmers who came to Washington from all parts of the nation to give official public testimony regarding their views on organic cows and pasture. Every citizen is allowed 5 minutes of public testimony on any issue that they wish to address in front of the NOSB, whether it livestock, crops, processing, handling or retail issues. There were never so many farmers at one NOSB meeting as this one. This was pointed out by the USDA NOP staff. They were duly impressed. There were many passionate statements regarding the absolute need for organic cows to be grazing pasture. There were also a few statements questioning the body condition and energy requirements of dairy cows in production when on pasture. But all in all, the entire Board got to see how important this issue is to both farmers and consumers of organic dairy products.

As a new NOSB member, I also had to listen to many other topics that were on the agenda regarding the organic industry. I want to note, however, that this Moo News expresses my views as a private practitioner and not as official USDA or NOSB directives. Official directives only come from the USDA. At any rate, one rather troubling development is the lawsuit that a blueberry grower in Maine brought against the USDA. Among other things, he successfully had the "80/20" provision struck down for dairy farmers during their 2nd to 3rd year of transition. For the last 10 years, the "80/20" has been to allow farmers to feed 80% organic feed and 20% conventional feed for the first 9 months of their last year of transition and then a full 100% for the last three months just prior to shipping organic milk. In the original OFPA of 1990, it mentions only 100% feed for the 12 months preceding organic milk production. The court agreed that the original law cannot be weakened and this then means that cows in their final year of transition must be consuming 100% organic feed for the entire 12 months. It remains to be seen when this will take effect - there may be possibly a 2 year phase in period. In any event, farmers that are right on the edge of the 2nd-3rd year transition (i.e. the last year) should not delay in letting a certifier know that they are interested in getting an inspection to get the ball rolling. It seems to reason that the further along a farmer is in the final year of transition when the court makes its final decree, the better the chance that the farmer would have to possibly still be allowed to use the "80/20" rule. This is all up in the air right now and I'll keep you posted.

But back to the pasture issue...NODPA representatives came and gave testimony to support the Pasture Guidance Document that was posted on the NOSB website prior to the meeting. That Guidance Document basically will give direction to certifiers to know if a farmer is actually pasturing cows or not. It does not have legal teeth as does the regulation which implements the actual law. What we on the NOSB did was to put forward an actual change in the regulation to make sure lactating cows will be grazing pasture and that lactating cows will not be confined. We submitted to the NOP the following language changes in the regulation:
Previously: "Access to pasture for ruminants"
Proposed: "Ruminant animals grazing pasture during the growing season" . This includes all stages of life except: a)birthing; b) dairy animals up to 6 months of age and c) beef animals during the final finishing stage, not to exceed 120 days. Note: Lactation of dairy animals is not a stage of life under which animals may be denied pasture for grazing"

Notice the term "stage of life" used above. This term is used in the regulation in a previous section and the NOSB also proposed the following change:
Previously: Access to outdoors, shade, shelter, exercise areas, fresh air, and direct sunlight suitable to the species, its stage of production, the climate and the environment"
Proposed: Access to outdoors, shade, shelter, exercise areas, fresh air, and direct sunlight suitable to the species, its stage of life, the climate and the environment"

These two proposed changes to the regulation tighten up loop holes that could be used to keep lactating cows off pasture and be kept inside. The NOSB went above and beyond what the 8,000 letters and petitions asked for and also more than what the farmers who came to DC were asking in their statements. Both of these proposed regulation changes are open for public comment. All comments need to be sent to the NOP.

The proposed Pasture Guidance Document that was open for public comment prior to the meeting was changed to reflect the public comments received. It now has a sentence which reads: "The Organic System Plan (OSP) shall have the 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" This was specifically inserted due to NODPA testimony. In addition, it was pointed out to some NOSB members (myself included) prior to the meeting of possibly using the USDA NRCS Prescribed Grazing (Code 528) to determine "Appropriate Pasture Conditions" for the number of animals in the OSP. While the need to keep organic cows on pasture is paramount (in my opinion), we need to keep in mind areas of the US where dairy farming has existed for generations and the amount of animals per acre or the number of days on pasture will vary due to local growing conditions. This is why the NRCS Prescribed Grazing, with its specifications applied to local growing areas, was inserted during the meeting. Please note that farmers would not have to sign up with NRCS - it would just be a tool for certifiers to make sure that there are appropriate pasture conditions on a given organic farm. The nicest thing about the NRCS Prescribed Grazing Code 528 is that it takes into account the agro-ecology of the farm while the 30%dry matter for 120 days does not. While the intentions and energy of NODPA and Cornucopia are quite admirable, casting a fishnet to catch a few farms which aren't grazing cows will also catch some "dolphins" as well. If a set number of cows per acre were inserted, it would mean the grazed acres, not the entire farm acreage. Should it perhaps just be that cows shall be out on appropriate pasture conditions simply for a minimum of 120 days (no dry matter attached)? We need to always remember what the organic consumer would think. Do they know what dry matter intake is? Would they not like to actually see as many cows out on pasture as possible (the more, the merrier)? They are the folks that drive the organic industry and its premiums. Think about what you would like to see put in the pasture guidance and send your comments to the NOSB, as this will once again be voted on at the next meeting.

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