Dear Acting Secretary Young:
Thank you for listening to the concerns of many industry stakeholders and state regulatory agencies by delaying the effective date for the final rule, “National Organic Program: Organic Livestock and Poultry Standards” by 60 days to May 19, 2017. On behalf of the undersigned organizations, we are writing to urge the U.S. Department of Agriculture (USDA) to initiate another 60 day extension of the effective date, to July 18, 2017, of the final rule to allow the incoming USDA leadership time to review the final rule before it takes effect.
The Organic Livestock and Poultry rule has raised significant concerns from several industry stakeholders, state departments of agriculture, and several Members of Congress, as documented by the letters authored by Rep. John Moolenaar, the leadership of both the House Agriculture Committee and the Senate Agriculture, Nutrition, and Forestry Committee, and the Members of the Senate Agriculture, Nutrition, and Forestry Committee. This flawed rule is a prime example of a controversial regulation being pushed through the regulatory process with no scientific backing, stakeholder involvement, or consideration of the concerns or recommendations put forward by the impacted producers or state regulatory agencies.
The unfortunate recently diagnosed cases of Highly Pathogenic Avian Influenza (HPAI) serve to illustrate the critical importance of ensuring biosecurity throughout poultry and egg production systems, and in this regard, the new Administration deserves a fair opportunity to examine whether the final rule adequately emphasizes disease prevention – a review that would be facilitated by the further delay we have recommended. In addition, more than 9 million organic layers currently use porch systems, complying with previous definitions within the organic standard. Many farmers simply do not have the land available to adhere to the new standard, being on small plots or with buildings that were originally built close to roads and other permanent boundaries.
We would welcome the opportunity to discuss these concerns further and explain why the additional 60 day extension is necessary to afford the incoming USDA leadership the opportunity to review and address these significant animal health, biosecurity, and compliance challenges. Thank you for your attention to this matter, and please let us know if you have any questions or would like any additional information at this time.
American Farm Bureau Federation
National Assembly of State Animal Health Officials
National Association of State Departments of Agriculture
National Cattlemen’s Beef Association
National Milk Producers Federation
National Pork Producers Council
United Egg Producers
Rep. Moolenaar letter – May 26, 2016
Joint House and Senate Agriculture letter – May 26, 2016
Senate Agriculture letter – July 26, 2016
Rep. Moolenaar letter – December 19, 2016