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National Organic Coalition Position Statements

NODPA is a member of the National Organic Coalition: www.NationalOrganicCoalition.org

July 12, 2010
NOC Comments to FDA Docket No.Docket No. FDA 2010 N 0085:
Preventive Controls for Fresh Produce.
Read NOC Response
NOC Attachments to Comments [Referenced Food Safety Studies] to FDA Docket No.Docket No. FDA 2010 N 0085: Preventive Controls for Fresh Produce.

May 2010
Opposition to Mandating Research Funding for GMOs
NOC joins over 140 organizations signing on to a letter submitted by Pesticide Action Network North America (PANNA) to make sure that The Global Food Security Act (H.R.3077) remains technologically neutral and does not include a clause mandating research funding for one particular agricultural technology (genetically modified crops).
Read Letter

April 20, 2010
NOC signed on to Consumers Union letter to FDA/USDA
about the US position [Codex] on GE/GM labeling.
See the Letter

April 19, 2010
NOC Comments on NOP "Access to Pasture Rule"
Including NOC proposal for an "Organic Grassfed Label."
Read Comments

March 19, 2010
NOC Enthusiastic about USDA/OIG Report on National Organic Program
Read Press Release

March 19, 2010
NOC Testimony to House on FY 2011 Appropriations
Read Testimony

March 17, 2010
NOC's letter to Blanche Lincoln, Chairman, Committee on Agriculture, Nutrition, and Forestry
urging to include language in the Child Nutrition Reauthorization bill to remove the barriers of access to organic foods within the WIC program.
View Letter

February 2010
USDA Press Release on Access to Pasture regulations
See press release

February 2010
National Organic Coalition Gives Thumbs Up to USDA ‘Access to Pasture’ Rule
See press release

January 27, 2010
Post-Hearing brief on proposed Leafy Green Marketing Agreement (NOC and FWW)

January 4, 2010
NOC's Comments on Guides to Minimize Microbial Food Safety Hazards

January 4, 2010
Food and Water Watch comments to FDA Guidance on Melons

January 4, 2010
Food and Water Watch comments to FDA Guidance on Leafy Greens

January 4, 2010
Food and Water Watch comments to FDA Guidance on Tomatoes

November 2, 2009
Comments of NOC to the National Organic Standards Board

November 1, 2009
Letter to Senate Finance Committee on the nomination of Mr. Siddiqui to the USTR.

October 28, 2009
OFRF Comments: CSP Interim Final Rule

October 27, 2009
NOC letter to Senator Stabenow
regarding the Senator's draft legislation regarding allowable agriculture and forestry offset credits for climate change legislation.
View Letter

September 14, 2009
Sign-on letter of comments regarding the implementation of the Cooperative State Research, Education, and Extension Service (CSREES) Agriculture and Food Research Initiative (AFRI),
as authorized by the 2008 Farm Bill.
View Comments

August 11, 2009
NOC Comments to NRCS regarding Conservation Practice Standard

View Comments

August 11, 2009
OFRF Substantive Comments to NRCS
regarding Conservation Practice Standard to which NOC is a signatory
View Comments

August 6, 2009
USDA Seeks Independent Oversight of National Organic Program
NOC press release

July 13, 2009
Letter to Senate Agriculture Committee on Climate Change
View letter

July 13, 2009
Letter to Senate environment and Public Works Committee on Climate Change
View letter

June 29, 2009
NOC and CFS Sign-on letter (nearly 200 signators) to USDA/APHIS
regarding The Proposed Rule and Programmatic Environmental Impact Satement for the Introduction of Genetically Engineered Organisms, APHIS Docket 2008-0023.
View Comments

May 4, 2009
NOC Comments to the National Organic Standards Board
on several topics related to the NOSB Agenda.
View Comments

April 22, 2009
NOC testimony submitted to the House Subcommittee on Agriculture, Rural Development, Food and Drug Administration
, and Related Agencies regarding Fiscal Year 2010 Appropriations Requests.
View Testimony

April 20, 2009
NOC Comments to the National Organic Standards Board on the "Peer Review Panel"
and NOP compliance with Accreditation standards, ISO 17011 (formerly 61).
View Comments

April 16, 2009
NOC Comments on the Organic Conversion Assistance program within the NRCS Environmental Quality Incentives Program
, recently passed in the 2008 Farm Bill
View Comments

April 2009
June may be Dairy Month but not for organic family farmers that sell to Horizon Organic who will see a pay cut of $1/cwt for their milk. NODPA urges consumers to buy more branded organic milk
See press release

March 6, 2009
NOC comments to the USDA Audit Review and Compliance Branch (ARC)
regarding recent changes to its auditing procedures.
View Comments

December 22, 2008
NOC comments to USDA NOP on the Proposed Access to Pasture Rule
with suggested changes to the Proposed Rule, and support for the line-by-line changes suggested by Federation of Organic Dairy Farmers (FOOD Farmers).
View Comments

November 8, 2008
NOC Comments to the NOSB
National Organic Coalition provides comments to the NOSB on Grower Groups, Biodiversity Standards, Aquaculture Standards, removal of Soy Lecithin and use of Technical Advisory Panels (TAP’s). MORE (opens PDF)>

November 3, 2008
Food and Water Watch comments to the National Organic Standards Board Livestock Committee's proposed organic aquaculture standards
, specifically the recommendations on "Fish Feed and Related Management Issues" and "Net Pens and Related Management Issues"
View Comments

September 24, 2008
NOC comments to CSREES on the Agriculture and Food Research Initiative (AFRI)
newly authorized in the 2008 Farm Bill regarding the provisions of the Act which specify conventional plant and animal breeding as a priority area of research within AFRI.
View Comments

September 23, 2008
NOC letter expressing concern about a "Sustainable Agriculture Label"
to the members of the Leonardo Academy's "Sustainable Agriculture Draft Standard for Trial Use Standards Committee"
View Letter

September 19, 2008
National Certification Cost Share letter to USDA Agriculture Marketing Service (AMS)
from various organizations.
View Letter

May 20, 2008
NOC Comments to the National Organic Standards Board May 2008 meeting
regarding materials being reviewed by the board.
View Comments

May 20, 2008
NOC Comments to the National Organic Standards Board May 2008 meeting
regarding the certification of Grower Groups.
View Comments

March 7, 2008
NOC testimony to the Senate Subcommittee on Agriculture, Rural Development, Food and Drug Administration
, and Related Agencies regarding Fiscal Year 2009 Appropriations Requests
View Testimony

March 12, 2008
NOC testimony to the House Subcommittee on Agriculture, Rural Development, Food and Drug Administration
, and Related Agencies regarding Fiscal Year 2009 Appropriations Requests
View Testimony

February 2008
Organic Dairy Farmers going bankrupt
– FOOD Farmers demand an increase in pay price for their organic milk
See press release

February 26, 2008
HP Hood supports FOOD Farmers Access to Pasture recommendations
See press release

February 14, 2008
NOC letter to House and Senate Farm Bill conferees urging inclusion of the organic conversion program
with mandatory access to funding in the 2008 Farm Bill.
View Letter

February 6, 2008
NOC letter to House and Senate Farm Bill conferees opposing the specialty crop marketing provision
in the House version of the Farm Bill
View Letter

November 20, 2007
Organic Dairy Farmers Join together to demand a fair price for their milk
See press release

November 12, 2007
NOC comments to the National Organic Standards Board
regarding organic certification of "grower-groups" and multi-site operations
View Comments

September 2007
Organic Dairy Farmers Are Outraged at the Alleged “Willful” Violation of Organic Rules by Aurora Organic Dairy
See press release

July 17, 2007
Letter to Representative Kagen supporting his amendment to the 2007 Farm Bill
to increase funding for organic research
View Letter

July 13, 2007
CFS and allied consumer organizations letter supporting mandatory implementation of country of origin labeling (COOL).

View Letter

June 18, 2007
Letter to Chairman of the House Agriculture Committee opposing section 123 of the House Farm Bill
View Letter

April 25, 2007
National Organic Coalition letter to USDA Secretary Johanns regarding grower group certification under USDA organic standards

View Letter

April 24, 2007
NOC Testimony of Kathy Arnold, Twin Oaks Dairy, before the Senate Committee on Agriculture, Nutrition and Forestry
addressing the economic challenges and opportunities faced by American agricultural producers
View Testimony

April 18, 2007
NOC Testimony of Bea James, National Cooperative Grocers Association, before the House Committee on Agriculture, Subcommittee on Specialty Crops and Organic Programs
, hearing on Organic Agriculture and Rural Development
View Testimony

March 4, 2007
Testimony of NOC's Legislative Coordinator Steve Etka before the House Subcommittee on Agriculture, Rural Development, Food and Drug Administration
and related agencies, regarding the fiscal year 2008 appropriations request
View NOC FY08 Appropriations Request Chart

December 22, 2006
NOC letter to the USDA Agricultural Marketing Service
supporting clear, objective, and enforceable pasture standards for organic livestock
View Letter

March 30, 2006
National Organic Coalition comments to Congress on FY 2007 organic agriculture appropriations.
View Testimony

May 20, 2005
NOC letter to the National Organic Standards Board regarding pasture requirements
for organic livestock production
View Letter

MORE LINKS

November 7, 2008
NODPA Press Release: Access to Pasture Rule for Organic Livestock supported by organic dairy farmers. Click here to open the PDF.

National Organic Coalition Gives Pasture Rule a Thumbs Up
Click here for a PDF of the release.

September 27, 2008
National Organic Coalition opposes proposed Sustainability Standards from Leonardo Institute
Added September 27, 2008. The National Organic Coalition is deeply concerned about the adverse impact that a sustainable agriculture label will have on the urgent need to increase our nation’s organic acreage and production practices. View their letter to the Leonardo Institute, which NODPA has signed on to. (in PDF format)

August, 2008
NODPA has signed on and
supports the following two positions:

Opposition to the ANSI SCS-Leonardo
sustainable agriculture standard

NODPA and longstanding leaders in the field of sustainable agriculture have a number of serious concerns with the genesis, organizational development and potential for serious harm in the development of the ANSI SCS-Leonardo sustainable agriculture standard. First of all, we are unconvinced of the need for or merit of a new and broad sustainable agriculture standard beyond already existing ecolabels addressing sustainability in the farm and food sector. The United States already has a very reliable and effective organic standard. View the letter.

Supporting organic farmers' access
to USDA conservation programs

NODPA is working with other groups through the National Organic Coalition to ensure the rapid and fair implementation of the organic provisions within the Farm Bill. Organic and sustainable agriculture groups met with USDA Farm Bill implementation staff and delivered the following letter that highlights important requirements in USDA’s implementation of the Food, Conservation and Energy Act of 2008 Conservation Title as it relates to organic agriculture. In enacting FCEA, Congress recognized the conservation benefits of organic agriculture. The new law has substantial provisions to foster increased adoption of organic systems by improving organic farmers’ access to USDA conservation programs.
View the letter.

NODPA stands for a living wage for organic dairy farm families and a temporary moratorium on transitioning livestock farms to organic. 06/18/2008.

HP Hood LLC refuses to address increase in costs of production for their organic family farms and demands money back for a one month overpayment of 17 cents a gallon. 04/28/2008.

Organic Dairy Farmers Join together to demand a fair price for their milk and
work with their farm partners
The Federation Of Organic Dairy Farmers (FOOD Farmers) representing organic dairy farmers across the country have requested a 20% increase in the price they are paid for their organic milk.
11/20/07 (pdf)

Organic Dairy Farmers Support Consumers Right for Organic Dairy Products that meet all of the Organic Regulations, 10/22/07

Letter to USDA Acting Secretary Conner, 9/25/07

Northeast Organic Dairy Producers Alliance's 7th Annual Field Days August 17 & 18, 2007
at Freund's Farm Market, East Canaan, CT.

Organic Dairy Summit 6/26/07

Formation of FOOD Farmers 3/5/07


Family Farmers Say NO to Factory Farms in Organic Dairy Cattle must be managed organically from birth and have access to pasture 4/14/06, (pdf)

NODPA Letter To NOP: In Response to the ANPR posted on the Federal Register on April 10th 2006. 6/12/06 (pdf)

Press release on revision of OFPA 10/25/05

Letters Regarding Organic Dairy Pasture Policy

NODPA Letter Regarding Organic Dairy Pasture Policy
October 8, 2004

Recent questions about the pasture requirement in the National Organic Rule have prompted NODPA to issue a Pasture Policy. This policy reflects our need as producers for a quantitative, measurable and enforceable standard for all certified organic dairy operations. We feel that the ambiguous language currently used to define pasture requirements in the Organic Rule has led to disparity between operations in various regions certified by various certification agencies and has opened the door for operations without adequate or any pasture systems to pursue organic dairy production.

Pasture is basic to what organic dairying is all about -- using natural systems to produce healthy organic food for consumers. There is no more natural system for organic dairy cows than pasture. Pasture leads not only to healthy cows, but to a healthy environment and to milk with superior health qualities for our consumers. Look at most any reference generically describing organic milk and they have the same basic message -- organic milk comes from pastured cows. That's what consumers of organic dairy products expect and that is what we as organic dairy producers must ensure they get.

Consumer confidence in the USDA "Certified Organic" logo is the cornerstone of current and future growth in the industry. To compromise that confidence by overlooking the intent of the National Organic Rule and the NOSB recommendation on pasture is not in the best interest of the organic dairy sector. Processors, with the cooperation of producers and certifieds, can set and enforce minimum standards for pasture which can help protect the integrity of "organic" until the NOP adopts language capable of doing so.

We have invited organic dairy processors to endorse and adopt the (below) Pasture Policy. We believe it can keep America's organic dairy cows on pasture, ensuring the green in organic dairy as intended. If you are an organic dairy producer, encourage your milk buyer to adopt the Pasture Policy. If you are a consumer of organic dairy products, encourage the company behind your favorite brand to adopt this Pasture Policy. And we all need to push the National Organic Program to require that certifiers make sure all organic dairy farms have credible pasture systems that meet this minimum standard before they can become certified organic.

Please contact Bob Pooler, Bob.Pooler@usda.gov, 202-690-3655 or Arthur Neal, Arthur.Neal@usda.gov, 202-720-8405 at the National Organic Program and express your view.

If you have any questions, please feel free to contact us, NODPA Board Members, or Kathie Arnold, randkarnold1@juno.com, 607-842-6631.

Sincerely,

Steve Morrison, NODPA President, Charleston, ME, 207-285-7085, mmorrison@midmaine.com
Jim Gardiner, Otselic, NY, 315-653-7819, horseingaround@citlink.net
Dave Johnson, NODPA Vice President, Liberty, PA, 570-324-2285, provident@epix.net
Mia Morrison, Charleston, ME, 207-285-7085, mmorrison@midmaine.com
Henry Perkins, NODPA Treasurer, Albion, ME, 207-437-9279, bullridge@uminet.net
Rick Segalla, Canaan, CT, 860-824-0241, mocow@earthlink.net
John Stolzfus, Whitesville, NY 607-356-3272, jtstribe@yahoo.com


Organic Dairy Pasture Policy

The Northeast Organic Dairy Producers Alliance (NODPA) supports the Pasture Recommendation of the National Organic Standards Board (NOSB) Livestock Committee, dated June 7, 2001, which stated that "grazed feed must provide a significant portion of the total feed requirements" for organic ruminant animals. The National Organic Program (NOP) has failed to adopt this recommendation and has also failed to ensure that all certifiers require sufficient pasture systems as a basis for certification. NODPA concludes that a quantitative minimum pasture policy with measurable parameters needs to be adopted by certifiers, processors, and the NOP. Consistent with the NOSB recommendations and consumer expectations, NODPA recommends the following pasture standard for all organic milk producers:

Organic dairy animals, from 6 months of age and up, must consume no less than 30% of their daily dry matter intake from pasture for a minimum of 120 calendar days per year, with a maximum stocking rate for lactating ruminants of 3000 animal pounds per acre of pasture up to a maximum of 3 cows per acre.

  • Pasture is land growing suitable grasses and other forages from which the ruminant animals self-harvest the plant material, which is still connected to its roots, for food by grazing. Feeding green chop or any mechanically harvested or stored feed on a pasture setting does not qualify as pasture.
  • Pasture must be managed to prevent environmental degradation
  • The only stage of production exemption allowed is from birth to six months of age. Lactation is not an allowable stage of production exemption from providing pasture for milking animals for the entire grazing season.
  • Unless under irrigation, most farms will have to maintain a lower stocking rate than the maximum noted in order to meet the minimum 30% dry matter intake from pasture.
  • The maximum stocking rate of 3000 animal pounds per acre means that the ratio of animals to the total number of acres in the lactating ruminant pasture system for the full grazing season cannot exceed 3000 animal pounds per 1 acre of pasture. Thus, herds with larger breed cows will have to maintain a stocking rate lower than 3 cows per acre and smaller breeds can have no more than 3 cows per acre.
  • This standard sets a base minimum. Organic dairy producers are encouraged to provide much more pasture than this minimum, as many producers are so doing. Ideal intake of pasture for organic dairy animals is 50% of more of their dry matter needs, from weaning age onup through their full life cycle, and for the fullest extent of the grazing season.
  • Climates, areas, or farms that cannot provide a minimum of 120 days of grazing should not be considered for organic dairy production.
  • Herd size must be adjusted appropriately to the amount of pasture that can be provided by the farm's land base. Land that normally produces stored feed may need to be converted to pasture to ensure adequate pasture intake.
NODPA, 30 Keets Rd, Deerfield, MA 01342 FAX: 866- 554-9483 PHONE: 413 772 0444