Comments to the NOP

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

May 20, 2008
Comment on access to pasture and origin of livestock
A letter from NODPA to the NOP addresses publication of the access to pasture rule and the publication of an origin of livestock rule. MORE >

New, February 14, 2008:
NODPA Signs On To Two Letters to the House And Senate
Regarding Organic Provisions In The Farm Bill:
Research Dollars: A request that organic farming and ranching get a fair share of agricultural research and education spending. Click here to view the letter in PDF format.
Organic Conversion Dollars: An urgent appeal to include a strong Organic Conversion Program in the final farm bill package, with access to mandatory funding. Click here to view the letter in PDF format.

Previous Comments:

1. FOOD Farmers comment on Natural Raised label 1.24.08
   
   
2. FOOD Farmers letter to USDA commenting on the consent agreement with Aurora Dairy 9.25.07
   
   
3. Kathie Arnold’s testimony to Senate Agriculture Committee 4.24.07
   
   
4. NODPA’ s comment on no cloning within organic dairy 3.16.07
   
   
5. NODPA comments on addition of materials to the National list 9.15.06
   
   
6. Comment by Steve Morrison, NODPA President

Federation Of Organic Dairy  Farmers (FOOD Farmers) which is an umbrella group for the three regional organic dairy farmer organizations: Northeast Organic Dairy Producers Alliance (NODPA), Midwest Organic Dairy Producers Association (MODPA), and Western Organic Dairy Producers Alliance (WODPA) and represent over 800 organic dairy farmers across the country have repeatedly asked the USDA NOP to adopt the following recommendations as part of their proposed rulemaking.

Clarification of the access to Pasture standards

1. Organic dairy livestock over 6 months of age must graze on pasture during the months of the year when pasture can provide edible forage.
2. The grazed feed must provide significant intake for all milking-age organic dairy cows. At a minimum, an average of 30% of the dry matter intake each year must come from grazed pasture during the region’s growing season, which will be no less than 120 days per year. 
3. Temporary exemption from pasture may be allowed because of:
   1. Conditions under which the health, safety, or well-being of the animal could be jeopardized, including to restore the health of an individual animal or to prevent the spread of disease from an infected animal to other animals.
   2. Short term inclement weather.
   3. Temporary conditions which pose a risk to soil and water quality.
4. In no case will temporary confinement and exemption from this pasture standard be allowed as a continuous production system.
5. The measurement of the consumption of dry matter from grazed pasture will be calculated based on the daily dry matter intake from grazing averaged over the total time period grazed per year

1. FOOD Farmers pasture measurement committee report 8.14.07
   
   
2. FOOD Farmers letter to USDA NOP about the need for publication of pasture and origin of livestock standards 10.30.06
   
   
3. NODPA comments on Access to Pasture ANPR 6.12.06
   
   
4. NODPA pasture policy 2.1.05
   

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Pasture symposium:

Ann Wells Presentation Blake Alexandre Presentation Carl Polan Presentation George Kuepper Presentation Jim Cropper Presentation Juan Velez Presentation Kathie Arnold Presentation

Kathy Soder Presentation Linda Tikofsky Presentation Lisa McCrory Presentation Margaret Wittenberg Presentation Mary Ellen Molyneux Presentation Straus Pasture Percent Calculator

FOOD Farmers proposes  that the USDA NOP immediately proceed to publish a proposed rule to have one clear standard for organic dairy herd replacement:
Once an operation has been certified for organic dairy production, all dairy replacement animals, including all young stock whether subsequently born on or brought onto the operation, shall be under organic management from the last third of gestation prior to the animal’s birth.t third of gestation prior to the animal’s birth.

1. NOP 5003 Dairy Acquisition interpretation 10.3.06
   
   
2. NODPA comments to NOP on rearing of organic dairy replacements 8.24.06
   
   
3. Final Rule to correct livestock standard after lawsuit between USDA and Arthur Harvey 6.7.06
   
   
4. NODPA and Certifiers’ comments on Origin of Livestock proposed rule 5.12.06
   
   
5. FOOD Farmers comments on Origin of Livestock May 2006
   
   
6. Comment on regulatory change following the Harvey ruling 3.24.06