Nov 4: Election day. Perhaps the one day every four years where most
(ok, many) American citizens actively engage in our political system.
Your participation matters: the President sets the agenda, picks the
advisors, and influences the funding, application and even creation of
laws and the rules that enforce them. So, please VOTE.
But you can engage beyond voting. I’m sure some of you have called or
written your Reps and Senators about a bill– check out the websites
for the House and the Senate if you haven’t. The most underused
system is commenting on proposed rules. So what’s a rule? And why do
A rule is the method by which agencies interpret laws for action–
whether it is creating a program, ending a program, enforcing a ban,
etc. Most laws are pretty stretchy (politically easier to pass), so
the rules are where political agendas can be acted out relativley
unseen. But wait, transparency does exist! You just have to know the
system: rules are required to have a public comment period (posted on
this handy website: regulations.gov) and agencies are required to
respond to each comment and take them into account as they write the
Right now, there is a rule about pasture and organic dairy open to
comment. Some of it is good, some of it is bad (awful, like, what were they
The good: some of the loopholes that industrial dairy
has been using to confine their cows and/or restrict access to actual
grazing as a food source during lactation are being trimmed down.
Herds must now obtain a minimum of their diet from pasture, and be on
pasture for 120+ days per year. Also, beginning animal welfare standards
are included (aka animal living conditions).
The foolish: Define bees as livestock in the organic standard. Now,
we all know bees fly around to collect their food. Even the USDA is
aware that bees fly. While you can drop your hives in the middle of
an organic orchard, you cannot build a wall to keep them from flying
over to the non-organic orchard next door, making organic bees
impossible to regulate.
Lack of creativity: USDA created a provision for devleoping
“sacrificial pastures”– low-risk pastures that are used in inclement
weather when other pastures would have high rates of erosion,
compaction, or other soil/water issues– that can be abused in the
rain. I find the concept disturbing, particularly in terms of MA
dairy farmers, who tend to have less overall land than diary farmers
in other states. Setting aside a section of pasture aside for a cycle
of abuse and recovery seems inefficient and downright foolish.
However, in terms of rulemaking, a clause for “You cannot always keep
your cows inside because it is raining!!” is needed. So what’s the
Pandering to industry: Allowing full grown dairy cows to be converted
to organic and brought onto previously converted farms. This is
little convoluted. Currently, it takes three years to convert an
entire operation to organic (needed, so farms can covert without
buying an entire new herd). Under the current rules, any organic cow
bought after converstion to organic must be raised organically from
the last third of gestation. However, the new rules allow non-organic
cows to be managed organically for one year and they magically become
organic animals. Not so great– it undermines the value of organic
heifers (currently high, good for organic farms selling ’em)– and it
allows a loophole that would be abused by the mega organic feedlot
operations to bring in cheap cows, convert, milk ’em out fast, and buy
I will comment on this rule, and post the link to it sometime in the
next couple weeks. Thoughts? Reactions?