Cows Need Grass, and USDA Agrees

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After one of the most contentious issues in the organic food world was put to rest a week and a half ago, I happened to be feeding a few goats in Massachusetts. I pulled some grass from a nearby field and walked over to the animals. They came right up to me and started eating the fresh forage from my hand. There was hay nearby but the green stuff clearly won the taste test.

Over at the USDA, it took more than a decade of complaints and advisory statements, reams of documents, a dairy symposium, five listening sessions, at least two comment periods, the overhaul of the USDA's National Organic Program, the new Obama administration, and vigorous lobbying by small dairy farmer groups to arrive at the same conclusion as these goats: ruminants such as cows prefer grass, and on organic farms they should be required to graze a minimum amount of pasture.

It also found ample organic land for grazing, especially in the West, where many objections to the pasture standard originated.

Why was this so contentious? Because cows don't need to be on pasture to produce milk. In many conventional dairies, cows are housed indoors. In fact, if they eat more grain rations and expend less energy walking to pasture they actually produce more milk, not less. That efficient factory-like reality led large-scale organic dairy operations to minimize pasture, maximize milk production and thus undercut all those other farmers who wanted to let cows express their natural behavior and eat grass. And these large-scale farms could do so because organic regulations, until now, only required vague "access to pasture," not a bright-line minimum standard for grazing that all farms must meet.

Now, with the new pasture rule released last week, the bright line is there. The regulation states that cows must be out on pasture throughout the grazing season, for at least 120 days. They must also get a minimum of 30 percent of their nutrition from fresh grass (as measured by dry weight, since grass contains far more water than grain). This standard was arrived at by consensus by organic dairy farmers around the nation nearly five years ago. It will take full effect a year from now.

The National Organic Standards Board (NOSB), an advisory panel that recommends all regulatory changes to the Secretary of Agriculture, had at first recommended that the 120 day/30 percent minimum be for "guidance" only. But in an especially detailed and well-reasoned document explaining the regulation (PDF), the USDA said, "public comments showed strong backing for a regulatory change"—not simply guidance.

The agency enacted the bright line standard to avoid confusion among certifiers who had interpreted the "access to pasture" prescription quite differently. (Some required grazing while others clearly did not.) Secondly, and perhaps more crucially, the USDA made the change "to satisfy consumer expectations that ruminant livestock animals graze on pastures during the grazing season."

Evidence of those consumer expectations appeared after the first proposed rule, released in April 2006, when more than 80,500 commented. Of those, just 28 were opposed to any changes in the pasture requirement and "there was a consistent theme of opposition to confining animals and feedlot feeding," the agency noted.

Consumers, farmers, retailers, and public advocates spoke. And, in this case, the USDA listened—it just took awhile.

That voice is especially important because the National Organic Program was designed by Congress as a "marketing program." (It is officially agnostic on whether organic foods or organic production practices are better or healthier.) If the market, defined by the 30 percent or so of Americans who occasionally buy organic products, think organic practices are failing to live up to their expectations, the agriculture secretary has reason to "satisfy consumer expectations" and change the program. That was clearly the case in the pasture dispute, where consumers felt large-scale feedlot organic farms were manipulating organic practices with a loophole.

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Samuel Fromartz is a Washington-based writer focusing on food, the environment, and business. He is the author of Organic, Inc.: Natural Foods and How They Grew and is currently working on a book about bakers and bread.

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