Here is information on how to comment on the rules concerning use of pasture for organic livestock. Use your own judgment when considering the proposed changes below.




David S. Conner, Ph.D.

C.S. Mott Group for Sustainable Food Systems

Department of CARRS

309 Natural Resources Bldg

Michigan State University

East Lansing MI 48823

Voice: 517-353-1914

Fax: 517 353-3834

Email: [log in to unmask]


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From: Liana Hoodes [mailto:[log in to unmask]] On Behalf Of Liana Hoodes
Sent: Monday, December 08, 2008 1:46 PM
To: David Conner
Subject: NOC Pasture Rule Action Alert!


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Dear David,


Support Strong Rules for Organic Pasture

Comment NOW to USDA -- Comment period closes December 23, 2008


The USDA National Organic Program (NOP) released the long anticipated proposed rules tightening the pasture requirements for organic livestock on Friday October 24, 2008. This is a strong proposal that guarantees that organic milk production meets consumer expectations. 


The proposal needs to be improved to remove overly prescriptive language that will cause problems for the health and safety of animals, might have negative impacts on the environment, and place extensive record keeping burdens on farmers. This can be done while preserving the requirement that organic ruminants be on pasture as much as possible during the grazing season. 


Please submit your comments ASAP - see below for detailed instructions


See the NOC website, or for more detailed information and a suggested re-write of rule language.  Suggested key points for comment:


§         Support the requirement for a minimum 30% dry matter intake (DMI) from pasture, averaged over the full growing season, with the growing season ranging from 121 -365 days, but substitute  "grazing season" for "growing season," to take into account the reality of the grazing seasons in different areas.


§         Require that ruminants are managed on pasture only during the grazing season, (not year round) to take into account different farming conditions, to protect pastures from damage, and to protect the health and safety of the livestock during adverse weather conditions.


§         NOP must provide needed exemptions for ruminants from pasture and outdoor access during periods of inclement weather and to protect soil and water quality.

§         Revise the definition of "inclement weather" so that any condition that causes physical harm to animals is a valid reason for limiting pasture and outdoor access.  


§         Dry lots and feed lots, where animals are confined and there is little or no vegetation, should be explicitly banned for ruminants. However, clean well-managed feeding pads (barn yards) are essential facilities needed for exercise and outdoor access during the non-grazing season, and as a supplement to pasture during the grazing season.


§         Modify the definition of "sacrificial pasture" to indicate this can be used during the non-grazing season to provide outside access, and make use of this practice optional, as the practice may be detrimental to the environment, including to soil and water quality, and to animal health when operations do not have well drained land that is accessible for livestock or during winter weather or excessive rain conditions.


§        Streamline the proposed record keeping requirements for livestock operations so that farmers can document their pasture feed rations in various ways that are acceptable to certifiers.

§         NOP must drop proposed language regarding replacement dairy animals. As proposed, it will allow certain farms to buy non-organic animals, and require others to buy or raise only organic young stock.  The NOP must move quickly to publish a Proposed Origin of Livestock Rule that has one criterion for dairy replacement animals for all operations: "Once an operation has been certified for organic production, all dairy animals born or brought onto the operation shall be under organic management from the last third of gestation." 


§         Permit grain finishing of beef slaughter stock, such that these animals may be exempt from the 30% pasture DMI requirement during the finishing period, not to exceed 120 days, but must not be denied access to pasture during that period.


§         Remove "bee" and "fish used for food" from the definition of "livestock" until proposed standards are issued for those production systems.


Please also demand that USDA NOP enforce the current regulation in regards to pasture while the proposed rule goes through the process of becoming a Final Rule


Once in effect and with implementation by 2010, we urge NOP to enforce the new regulation and work with producers and certifiers to educate them on the requirements of the new rules. With these changes, a final rule can be written that can safeguard the long-term integrity of organic farming.


How to  submit comments:

Give your name, farm name (if appropriate), location and the reason for sending comments (consumer, producer, advocate etc.). 

There are three ways to submit comments:


1) Mail. Written comments must be received (not postmarked) by Dec. 23, 2008. They must be identified with, "Docket Number AMS-TM-06-0198; TM-05-14" at the heading of the document. Mail written comments to:

Richard H. Mathews, Chief, Standards Development and Review Branch,
National Organic Program, Transportation and Marketing Programs
USDA-AMS-TMP-NOP, 1400 Independence Ave., SW.
Room 4008- So., Ag Stop 0268
Washington, DC 20250.


2) Online. Visit the Regulations web portal: Use the search terms "organic pasture." Comments must be submitted online by Dec. 23, 2008. Do not leave it to the last moment to submit comments to the site as it tends to get overloaded at the end of comment periods.


3) Send to NOC Mail, fax or email your comments to Ed Maltby by 12/19/08 and he will forward them to the NOP. By mail: Ed Maltby, NODPA Executive Director, 30 Keets Rd, Deerfield, MA 01342. Fax: 866-554-9483. Email: [log in to unmask]



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