An organic foods watchdog group is calling on USDA to extend the public comment period on new draft rules regulating grazing for organic milk production. The current deadline for comments is Dec. 23.

“This is such a comprehensive rewrite of the rules,” says Mark Kastel, senior analyst for the Cornucopia Institute, a Wisconsin-based farm policy research group. “Out of fairness to everyone involved, USDA should extend the comment period by a minimum of 30 days.”

The 60-day comment period began in late October when USDA published the draft rules in the Federal Register. At that time, Kastel says, farmers in many parts of the country were still involved with crop harvest. “The comment period also covers a time when we’ve had a national election and Thanksgiving and now we have the run-up to Christmas,” he says. “Now half of the comment period is already gone, and people are just starting to focus on what’s in the rules. We think it’s very reasonable to ask for extra time so livestock producers and other stakeholders can review the rules and respond.”

Small-farm advocacy groups, organic livestock producers and consumer groups have been pressing USDA for years to tighten enforcement of existing organic milk rules. They contend lax enforcement and loopholes in the current law have allowed a few large feedlot dairies, mostly in the western U.S., to sell milk as organic even though cows on those dairies rarely graze.

At stake, says Kastel, is consumer confidence in the organic food supply. In a public comment session two years ago, he notes, only 28 out of more than 80,000 responses were against tightening the rules for organic milk production. Numerous surveys have also shown consumers support grazing requirements for organic dairy operations. “Consumers are willing to pay a premium for organic food products,” he says. “If they lose confidence, all organic producers – big and small – will suffer.”

The draft rules now under consideration require cows on organic dairies to be on pasture for at least 120 days each year. They also require animals get at least 30% of their dry matter intake from grazing during the growing season.

Many organic advocates find those provisions acceptable. But other provisions are cause for concern, says George Siemon, a Wisconsin organic farmer and chief executive at Organic Valley, the country’s largest farmer-owner organic dairy co-op. One example: a proposed rule allowing organic dairies to bring conventionally raised heifers into an operation and then sell their milk as organic.

"We believe firmly, as all of the organic dairy community does, that there should be only one replacement standard once a producer enters organic dairy production,” says Siemon. “We are very disappointed that the proposed rule continues this inequity of having two standards once you are an organic dairy farmer.”

Kastel says other provisions of the draft rules, such as requiring drinking water equipment to be cleaned weekly, are so restrictive they could put many organic livestock producers out of business. “What was needed were some minor tweaks in the existing laws,” he says. “What we got instead was major surgery. Farmers need to voice their demand to crack down on these giant industrial dairies now, and to let the USDA know that the current set of proposed rules is unworkable.”

For more information on the draft rules and the Cornucopia Institute’s proposal, go to To see Organic Valley’s proposal, go to" To contact Kastel, phone 608-525-2042 or email