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Commentary from around the
country on the pasture rule

Below you'll find commentary and thank yous from farmers around the country about the pasture rule and the revision process.

What Legacy Do You Want To Leave?

As I look back over the past two months of working on the proposed pasture rule, I see how a very diverse group of people and farmers can truly make progress working together for a common cause for the betterment of all of us. When we put our minds to it ,we can be at the top of our game in whatever we want to accomplish.

I feel that we need to continue to this action as a group to push forward in other areas that will affect our future, not just tomorrow but for years to come. We as farmers have a voice that needs to be heard and I for one am going to use mine. 
Looking to the future, I see several things that we as farmers need to address. Among them is the need for a fair and sustainable price. If we do not step up to the plate now, I doubt that we will have a long-term future for ourselves let alone the future generations of farmers.

This is a frightening thought to me that we may be setting ourselves up as the last generation of truly family farmers to work the land. I believe that the only chance we have for the future generations of farmers is going to be through organic agriculture. The organic community is the one community that is receptive to seeing a farmer make a living at working the land.

As I look around the area that I live in, I do not see any young people that are interested in making a living from farming. None of my children are interested, and who can blame them when all they see is working seven days a week for little to no pay. I know I am not alone in having all of the children leave the farm, from talking to other farmers that I know and deal with. Presently there is no incentive for a young person to want to get involved in farming for a career and I think it is going to take more than throwing some money at them to get them back.

We all know there is more to life than money, although it is a good place to start. 
Do we want to be known as the last generation of farmers or do we want to be known as the generation that finally stood up and said that it is time for the farmer to get the respect and credit he or she deserves. I for one think it is time for all of us to stand up and demand what we as farmers are entitled to: 1) A fair and decent price for our milk and 2) the ability to help tomorrows farmers have the opportunity to succeed in this world, not just as farmers but also people to be respected and appreciated for what they do - after all we do help to feed a growing world.

Public opinion in this day and age wants to belittle farming, but we need to be proud of what we do. 
One of the surest ways I know of to make this happen is through your local ODPA and through the FOOD Farmers group. Please take the time to support these organizations if at all possible. At the very least make sure that you use the voice that you have to let others know that you are going to take responsibility for seeing to it that tomorrow is a better day for the future farmers. I for one am going to use mine. We owe it to the next generation.

Which brings me back to my question : What Will Our Legacy Be?


Bruce Drinkman
Organic Dairy Producer
MODPA Board Member
Glenwood City, WI

Hello Ed,

PLEASE extend my congratulations to the entire FOOD farmers group for submitting a document that, it appears to me, represents the consensus of organic and beef farmers from all corners of the USA. While I haven’t read every addendum document word for word, I can see that you have submitted documentation that backs up the greatly improved wording the rule, with clear data.

I am very impressed with and proud of FOOD Farmers for the way they brought all stakeholders to the table and worked very
hard to find a workable consensus on the proposed reg. I am incredibly impressed at tenacity of the group to put clear and verifiable wording into the proposed rule.

My comments to the NOP mostly referenced your comments as the best solution for a variety of issues, thanks for making my comment writing easier! Say thanks to Kathie Arnold and everyone else; you all deserve a relaxing and joyous holiday.

Harriet Behar, Outreach Specialist
Midwest Organic and Sustainable Education Service (MOSES)

To Richard H. Mathews, USDA-AMS-TMP-NOP

I am writing to you to comment on the recently proposed NOP pasture ruling. We are the oldest and longest standing organic dairy in the United States. We have always been very serious about pasturing our 100 Jersey cows. I journeyed to Washington DC several years ago to comment on the importance of pasture in an organic dairy program. Our grazing season is a bit shorter here along the Canadian border here in northern Vermont, but our cows receive at least 75% of their dry matter intake from pasture between the middle of May to the middle of October. I applaud you for including the 30% dry matter/120day provision in your rewritten pasture proposal.

I would like to suggest a few changes to the ruling, which will make it more workable for farmers who live in regions where winter is long, cold, harsh, and windy. It is five degrees out right now, and the wind is blowing with great intensity. When a human being walks between the house and the barn, your face begins to freeze in less than a minute. Our cows run free in a bedded pack hoop barn. They can go out into a yard anytime they want. However, on a day like today, we close the big door at the south end of our solar barn in order to keep our cows from freezing. Severe cold and exposure can undermine the wellbeing of a dairy cow in very short order.

I am asking you to take a more common sensed approach to the keeping of cattle in parts of the country where winter is a reality. All this business about having the cows outside all the time on some sort of a “sacrifice pasture” is an unsound agronomic practice. It is far better to house dairy cows in a bedded structure so that manure and urine can be absorbed into the bedding. In this manner, nutrients can be captured and preserved in carbonaceous material (straw, hay or wood products) to be applied to the earth when the warmer weather returns. If cows were simply outside most of the time, most of their waste would be deposited on frozen ground and washed into the nearest water course at the time of spring melt and runoff.

Since we are one of America’s first organic dairies, we are very interested in preserving the integrity of the system. For the health of our cows and our land, please adopt a very simple pasture rule. A grazing season of 120 days with a 30% minimum of dry matter intake works in all parts of the country. Please ensure that all farms, large and small, employ pasture in their management systems. I also hope that the ruling will insist that already transitioned organic dairies must only import organic replacements.

Thank you very much for the work you have done trying to craft a very complex ruling that needs to work for many different types of farms in very different geographic regions. In the wintry Northeast, we need to be able to house our cattle indoors out of severe weather. Daily access to the outdoors is necessary, but our cows don’t need to live outside.

Sincerely yours,
Jack and Anne Lazor
Butterworks Farm, Westfield, Vermont

Docket Number AMS-TM-06-0198
To Richard H. Mathews, NOP

My name is Ward Burroughs, from Full Circle Dairy and California Cloverleaf Farms, Denair, Ca. in the northern San Joaquin Valley. We seasonally milk 500 cows at each dairy. We thank the NOP for publishing this proposed pasture rule regarding access to pasture and for giving all of us the opportunity to comment on the rule.

I thank the NOP for ensuring that grazing is a major enforceable criterion of the NOP’s new pasture rule.

I urge the NOP to adopt the revisions put forth and recommended by the FOOD Farmers with others in order that this pasture rule will be doable for organic dairymen and livestock farmers and enforceable by certifiers and the NOP. This FOOD Farmers revised rule will become a rule that to which all of us will adjust and that with these revisions will level the playing field across the country for the organic dairy industry. This revised rule will ensure the integrity of the organic seal for both producers and consumers of organic livestock products and thus, will ensure long term sustainability for my family’s organic dairy farms.

I am sure that my families’s two dairies are meeting these new standards of a minimum of 120 days grazing and 30% DM intake from that grazing during our grazing season. On our dairies, in a grazing season that averages around 200 days, milking cows graze for 100% of their forage needs for 180 days and for 50% of their forage needs for another 90 days. Both of these scenarios far exceed the 120 day/ 30% requirement. In our minds, it is important that grazing season, not growing season, become one of the foundations for this proposed rule because it is during a grazing season, when animals can actually graze and receive dry matter intake from that grazing, that dry matter intakes can be measured and documented for our Organic Systems Plan.

It is important for the NOP, a government agency, to understand that California organic dairy producers already have nutrient management plans and water quality plans mandated by the State Regional Water Quality Control Board, a governmental agency, as well as Air Quality Plans mandated by the Air Quality Board, another governmental agency. For our dairies, most sacrificial pasture and required access to outdoors during inclement weather would certainly violate the state water control board’s mandates. It is also important that the NOP does not put California or any other organic dairymen in a position that they would have two or more “masters” regarding these kinds of environmental matters.

Finally the October 24, 2008 proposed pasture rule as is written will destroy our organic dairy industry. The Food Farmers revisions correct the unworkable aspects of the proposed pasture rule. I urge the NOP to adopt the Food Farmers revisions to this new pasture rule and move forward quickly to an Access to Pasture final rule.

In conclusion, we look forward to the publication of a new, separate, simple proposed rule for the Origin of Livestock that eliminates the existing two track replacement system and establishes one criterion for organic replacement animals, in other words – to level the “replacement” playing field so that all organic dairy farmers operate under the same set of replacement rules. Thank You.

Ward N. Burroughs, Denair, CA

Hi Ed and Kathie,

Thanks for your excellent leadership in putting together a consensus of comments on the proposed pasture rule. I very much appreciate all the work you both put into it. Thanks again.

Francis Thicke
Organic Dairy Farmer,
OFRF Board Member

Ed, thank you for this!

I was amazed, watching you and others through this entire process [at the November NOSB Meeting]. I learned so much about livestock as well as about how diverse our regional agriculture is in this country. Despite major (or minor) differences between players, everyone really was passionate about organic and wanted to be helpful to each other, which is a value I treasure. I like the way we in the industry can disagree civilly and keep focused on what’s really important – organic integrity!

Claudia Reid
Policy Director
CCOF -- Organic Certification

Hi Ed,

At the conclusion of this process, and after reading the FOOD Farmers impressive and comprehensive submission, I want to congratulate you and everyone involved for all the incredible work, inclusiveness and comprehensiveness that characterized this effort over many weeks. The FOOD Farmers comments have set a very high mark indeed for quality and completeness. A great many individuals and organizations have benefited and learned from your work -- myself, VOF and NOFA-VT among them. Our thanks and appreciation..

Dave Rogers, Policy Advisor
NOFA Vermont

Hi Ed and Kathie:

Wow! What a comprehensive document! Thank you both for the hard work and long hours you have put into NODPA/FOOD Farmers’ comments on the pasture rule. I hope you now have time to enjoy the holidays and RELAX with your families!

Lisa Engelbert
Organic Dairy Farmer , Nichols, NY
NOFA NY Certified Organic, LLC
Dairy Program Administrator