Petition to Danone/Horizon to stand with NE organic dairies

Danone (owner of Horizon Organic Milk), the global leader in over 20 brands of fresh dairy products and a $10.3B company, just abruptly ended contracts with 89 Northeast organic dairy farm families.  That includes ALL their dairy farmers in Maine, New Hampshire, Vermont, and almost 50 from New York state.  These farmers have no other market options.  As a certified “B Corp” Danone is required to use its business as a force for good, but this action from Danone is disgraceful and will hurt Northeast farm families and their communities.

Danone/Horizon claims they cannot afford to continue supporting the family-owned organic dairy farms that have helped build the Horizon Organic brand for decades due to logistics and trucking issues. But there are other issues in the organic marketplace that are a part of this story – especially USDA’s failure to update and enforce key organic standards for dairy farms such as the enforcement of the pasture standards and long overdue updates to the Origin of Livestock rule to stop the continuous cycling of animals in and out of organic on large operations.

Sign your name to this petition to demand that Danone/Horizon do the right thing and reinstate these farmers who are producing organic milk the right way. Treat family farmers with RESPECT!


Thank you for your support of organic farmers.  We are stronger together!  Please help spread the word.

More Background Information

Partner articles on the issue

Organic Grain Buyer Files for Bankruptcy – Resources for Organic Farmers

On July 8th, Pipeline Foods filed for Chapter 11 bankruptcy. According to the company’s website, it contracted with 1,461 growers in 2019 (most recent number available).

If you are an organic grain producer who sold grain to Pipeline Foods and have not been paid, there are a couple of things you can do right now:

  1. Contact the state department of agriculture for the state where your grain was delivered. Many states have grain dealer licensing programs that administer funds or insurance programs to cover obligations from grain dealer defaults. Each state has its own program, so the details vary on how to apply and how much of the loss will be covered. The websites for programs in many of the states where Pipeline bought grain are listed below.
  1. If you delivered grain in a different state than where your farm is located, you may also want to contact your state department of agriculture to see if there are programs that cover this loss. Most states license the grain dealer, so they cover transactions at grain facilities in the state (where the grain is delivered, not where it is grown.) But it is also worth checking with your home state in case they have a program that could help. Some state programs may eventually hold information sessions about what options farmers have in this situation, so keep an eye on the websites for your state grain program.
  1. Consider seeking legal help if you made deliveries shortly before the bankruptcy filing, or before making any new deliveries to Pipeline (several states have suspended the company’s grain dealer license.) There may be steps you can take to impact your standing as a creditor in the bankruptcy process, depending on the terms of your agreement.

OFA will continue to look for other options for organic farmers who are impacted by this bankruptcy and will share more information as we find it. But contacting a state grain program and getting your own legal advice are short-term steps you should take as soon as possible.

State Programs

Illinois Grain Insurance Fund

Indiana Grain Indemnity Program

Iowa Grain Depositors and Sellers Indemnity Fund

If you have a contract with Pipeline Foods for delivery in Iowa on a date after July 8, 2021 (the date the company filed for bankruptcy), you can now be relieved of any liability or claim by Pipeline to fulfill this contract.

Here is what you need to do:

–  Go to the Pipeline Foods Bankruptcy webpage and fill out the Undelivered Grain Sellers – Non-Delivery Notice Submission Form

–  After you make this notification, you can sell the contracted grain or beans elsewhere. Keep records of where you sold the grain and for how much.

This procedure covers:

  1. Iowa farmers who would truck their grain under a Pipeline contract to a facility in Iowa;
  2. Farmers in states other than Iowa who would truck grain under a Pipeline contract to a facility in Iowa; and
  3. Farmers in Iowa for whom Pipeline (rather than the farmer) would arrange the trucking to pick up grain/beans at an Iowa farm but that would be delivered to a facility in a state other than Iowa.

It does not cover contracts under which the grain/beans would be delivered to a facility in a state other than Iowa.

Michigan Farm Produce Insurance Fund,4610,7-125-1569_16993_16996---,00.html

If you have a contract with Pipeline Foods for delivery in Michigan on a date after July 8, 2021 (the date the company filed for bankruptcy), you can now be relieved of any liability or claim by Pipeline to fulfill this contract.

Here is what you need to do:

–  Go to the Pipeline Foods Bankruptcy webpage and fill out the Undelivered Grain Sellers – Non-Delivery Notice Submission Form

–  After you make this notification, you can sell the contracted grain or beans elsewhere. Keep records of where you sold the grain and for how much.

This procedure covers:

  1. Michigan farmers who would truck their grain under a Pipeline contract to a facility in Michigan
  2. Farmers in states other thanMichigan who would truck grain under a Pipeline contract to a facility in Michigan; and
  3. Farmers in Michigan for whom Pipeline (rather than the farmer) would arrange the trucking to pick up grain/beans at a Michigan farm but that would be delivered to a facility in a state other than Michigan.

It does not cover contracts under which the grain/beans would be delivered to a facility in a state other than Michigan.

Minnesota Department of Agriculture’s Grain Licensing Program
****Minnesota Grain Program held a (virtual) public information session about this bankruptcy on Weds. July 21 at 1-3 pm central. Click here to watch a recording of the session.

If you have a contract with Pipeline Foods for delivery on a date after July 8, 2021 (the date the company filed for bankruptcy), you can now be relieved of any liability or claim by Pipeline to fulfill this contract.

Here is what you need to do:

-  Go to the Pipeline Foods Bankruptcy webpage and fill out the Undelivered Grain Sellers – Non-Delivery Notice Submission Form at

-  After you make this notification, you can sell the contracted grain or beans elsewhere.

This procedure covers:

  1. Minnesota farmers who would truck their grain under a Pipeline contract to a facility in Minnesota;
  2. Farmers in states other than Minnesota who would truck grain under a Pipeline contract to a facility in Minnesota; and
  3. Farmers in Minnesota for whom Pipeline (rather than the farmer) would arrange the trucking to pick up grain/beans at a Minnesota farm but that would be delivered to a facility in a state other than Minnesota.

It does not cover contracts under which the grain/beans would be delivered to a facility in a state other than Minnesota.

Missouri Grain Regulatory Services Program
Please contact the Missouri Department of Agriculture if you or your business have any unsettled obligations with Pipeline Foods, LLC. You may call Grain Regulatory Services Program Manager Eric Berwanger at (573) 751-4112.

North Dakota Grain and Livestock Licensing Division
ND Grain Complaint Form:

Ohio Grain, Feed & Seed Program     (choose Grain Indemnity Fund button)
Claim forms:

South Dakota Public Utilities Commission Grain Warehouse Program
Producers who are not being paid in a timely manner are encouraged to report problems to the PUC by calling 1-800-332-1782 or sending an email to

Wisconsin Agricultural Producer Security Default Claims





OFA Origin of Livestock USDA Comments



July 12, 2021

Jennifer Tucker
Deputy Administrator
National Organic Program
1400 Independence Ave. SW
Room 2642-So., Ag Stop 0268
Washington, DC 20250-0268

Re: Docket Number AMS-NOP-11-0009; NOP-21-04PR

Dear Dr. Tucker,

The Organic Farmers Association (OFA) is a membership organization that represents U.S. certified organic farmers. Our organization was founded by and is controlled by certified organic farmers, and only domestic certified organic farmers vote on OFA’s policies and leadership. OFA appreciates the opportunity to provide comments on the “National Organic Program; Origin of Livestock; Reopening of Comment Period.”

Our farmer members have ranked increasing NOP enforcement, especially origin of livestock and pasture rule enforcement, as a top priority every year that we have administered a national organic farmer survey.

The economic viability of organic dairy farmers is dependent upon clarification of regulations to stop the varied interpretations or loopholes regarding dairy livestock transitioning practices.

Finalizing a strong, enforceable rule on the origin of livestock is important for the future of organic dairy farmers, their families, and the integrity of the entire organic label. The organic label is one of the most highly trusted labels for consumers. This is due to the strong Federal standards and enforcement behind the label. Solidifying standards to ensure all organic farmers operate under the same rules is essential for the entire organic community.

Unfortunately, the organic dairy producers who have utilized a loophole in the regulations, allowed by some certifiers, to continuously transition conventional animals into organic production have gained an economic advantage and contributed to the oversupply of organic milk. This has contributed to a significant drop in recent years in the milk prices paid to organic dairy farmers, the majority of whom were held by their certifiers to a higher standard and stricter enforcement.

The long delay in clarifying the regulations on Origin of Livestock is inhibiting the National Organic Program (NOP)’s ability to provide consistent and fair enforcement, leaving our nation’s organic animal standards unfair and inconsistent. Our members, who are independent small rural businesses, have experienced the inequities created by the lack of clarity within the current rules outlining bovine dairy transition to organic dairy production.

For 15 years, organic dairy farmers have advocated for an enforceable regulation applied equally to all certified producers. In 2015, USDA published a proposed rule to close the loopholes in the current regulations, by clarifying that “After completion of a one-time, 12-month transition period of an existing conventional dairy herd (or livestock to form new organic dairy operations), all new dairy animals milked on the organic dairy farm would need to be managed organically from the last third of gestation.”

The organic community has provided comments two times on the proposed rule and it garnered strong, united support from the organic community and consumers, especially the provision to stop conventional livestock from continuously entering the organic herd. Unfortunately, the 2015 rule has never been finalized.

This delay has had real consequences for organic dairy farmers. Organic has been an important market that has provided for the viability of family-scale farms across the nation for both dairy farms and associated feed and grain producers. But there are conditions in the organic milk market in some regions of the country, especially the Northeast, that are different than those in conventional milk markets. Because USDA dedicates resources to ensuring the orderly marketing of conventional milk through the federal milk market order system, changes in the conventional milk market are predictable and widely publicized. But changes in the organic milk market in recent years came suddenly and without warning for organic dairy farmers. For example, in January 2017, organic milk marketers in New York were looking for more organic milk, in February 2017, they said there was an oversupply, and by March 2017, they were imposing quotas on organic dairy farms in the state.

One factor behind this volatility is the arrival of large supplies of cheaper organic milk from large dairies in the West and Midwest that expanded rapidly when the organic milk price was high in 2016. These large operations were able to expand rapidly to capitalize on the high organic milk price by working with organic certifiers that allowed them to continuously transition conventional cows to organic. The great majority of organic dairy operations are held to higher standards by their certifiers that reflect the intent of the origin of livestock regulations and consumer expectations. But the exploitation of regulatory loopholes has upset the balance of supply and demand previously found in the organic milk market. This has impacted the economic viability of organic dairy operations. According to the NOP’s Organic Integrity Database, the number of organic dairy farms in the United States has remained essentially stagnant over the last five years, which is shocking given the dramatic annual growth rates seen in organic product sales. The number of organic dairies declined year each year since 2016, with the exception of a large increase in 2019. In all other years since 2016, the organic dairy sector lost an average of 128 farms per year. One factor that has made it challenging for dairy operations to remain organic has been the inconsistent enforcement of standards like the origin of livestock.

It is not just organic dairy farmers who believe the lack of consistent enforcement of origin of livestock rules must be addressed. As referenced in this request for comment and in previous public comment periods, the USDA’s Office of Inspector General released an audit in 2013 identifying the lack of clarity in the regulations and different interpretation by different certifiers as problems that could undermine consumer confidence in the organic milk certification process.[1] Furthermore, organic farmers across commodities support a strong origin of livestock rule because inconsistent standards weaken consumer trust in the label, which hurts the entire organic industry.

It is long past time for the NOP to finalize a rule to close the loopholes on origin of livestock. A final rule on origin of livestock must:

  • Prohibit the continuous transition of conventional dairy livestock and stop the one-time exemption from being used to combine multiple transitioned herds to form one operation.
  • Prohibit first calf heifers and young cows being transitioned from conventional production and then being sold to an existing organic dairy, which is not in line with the rule and undermines certified organic dairies by providing a cheaper, quicker alternative to raising organic replacements under organic management.
  • Ensure that the whole transition happens over a twelve-month period and under the supervision of a certifier as part of the producer’s organic system plan. If organic management of the dairy animal, starting at the last third of gestation or at any other time it has been organic, is interrupted, the animal cannot be returned to organic certification.
  • Prohibit the practice of adding conventional animals during a transition process and extending the transition period.
  • Prohibit the sale of transitioned animals (not raised in organic production from the last third of gestation) being sold as organic dairy animals that can be used to produce organic milk.
  • Prohibit transitioned animals from retaining their organic status if they are moved to a different location under the same ownership.
  • Prohibit the practice of having an organic and conventional dairy operation at the same location. While a split operation may be practical with other commodities, it is very difficult to audit and ensure that organic dairy product (raw milk) is not mixed with non-organic product. This will prevent any abuse or the
    perception of abuse.

Therefore, we urge the department to swiftly finalize an Origin of Livestock regulation that:

  • Goes into effect immediately.
  • Allows an operation or responsibly connected person(s) to transition bovine dairy animals into organic production only once.
  • This transition must occur over a continuous 12-month period prior to production of milk or milk products that are to be sold, labeled, or represented as organic.
  • An operation or responsibly connected person(s) must not transition any new bovine dairy animals into organic production after the end of the 12-month transition period. Once a distinct herd is transitioned to organic, all animals must be raised organically from last third of gestation.
  • The certifying entity will file an organic system plan prior to the start of transition and the transition process is overseen by the certifier as part of their accountability.
  • Prohibits the transfer or sale of transitioned animals to any other operation as certified organic, for any purpose.
  • Prohibits split bovine conventional and organic milking herds at the same location.

In addition to these overarching comments and priorities, we offer the following specific thoughts in response to questions posed in the request for comments.

Movement of Transitioned Animals

NOP should not allow transitioned animals to remain certified organic if they are sold, transferred, gifted, or moved to another operation. This includes preventing transitioned animals from retaining their organic status if they are moved to a different location under the same ownership. A transitioned animal should only be certified organic on the operation that used its one-time exemption. If a transitioned animal moves to new operation through sale, gift or other transfer, it must be considered a conventional animal.

OFA believes that the final rule should prohibit organic dairy operations from acquiring transitioned animals to expand or replace animals to produce organic milk for several reasons:

  • This is necessary to close the loopholes that have been plaguing the organic dairy sector for years.
  • Ending this practice does not affect the value of the transitioned animal because its initial value was as a conventional animal. The cost of transitioning the animal was reflected by the higher pay price received for the milk produced after the animal was certified as organic.
  • Family members or other responsibly connected persons who were part of the ownership of the transitioned entity who later want to start a new operation will need to purchase organically certified animals that were under organic production from the last third of gestation. They would not be eligible to transition conventional animals because they have already used their one-time exemption to transition conventional animals for the original operation. While this may complicate succession planning, strict clarity within this rule is required to end the abuse that has been undermining the integrity of organic certification across the dairy sector.
  • This is consistent with existing requirements that transitioned animals cannot be certified organic for slaughter.

Certifiers will play a critical role in ensuring a level playing field when it comes to the supply of organic livestock. We urge the NOP to provide clear instructions to certifiers about recordkeeping and inspection practices necessary to enforce this standard. Certifiers should already have systems to ensure that transitioned livestock are not sold as organic for slaughter. NOP should work with certifiers to build on those procedures and ensure that an adequate level of detail, beyond just ear tag numbers, is used to track transitioned animals and ensure that their status is accurately reflected on organic certificates and other paperwork that would be used in a sale or transfer. NOP should also instruct certifiers on adequate auditing and verification activities to incorporate into their inspections so that new regulations are actually enforced. Finally, the NOP should work with certifiers to ensure that the plan for transitioning animals using the one-time exemption is part of the approved organic systems plan that operations use to plan their start-up phase and future growth.

Description of Regulated Entity

OFA supports using the term “operation” to describe the regulated entity, with the addition of a “responsibly connected person(s),” as already defined in the organic regulations.

Using the term “operation” for this regulation is consistent with the proposed rule being developed on Strengthening Organic Enforcement. We believe that the addition of the “responsibly connected person(s)” will address another problem facing the organic dairy sector, in which new business structures are created at the same operation in order to create new opportunities to use the one-time exemption. In addition to limiting an operation to using the exemption on transitioning animals to one time, NOP also needs to limit the key people involved in the operation as well.

In accordance with the “responsibly connected person(s)” approach, any person who is a partner, officer, director, holder, manager, or owner of 10 percent or more of the voting stock of an applicant or a recipient of certification would be allowed to execute the one-time herd transition exemption only once on any operation where they have a significant financial or managerial stake. After an operation they are connected to uses the one-time exemption, all responsibly connected persons for that operation will have used up their transition exemption allowance, even for different operations in the future. Any person with a significant financial or managerial stake in a dairy operation would utilize their one-time eligibility once a transition occurs at that operation and not be allowed to participate in another operation that is using the one-time exemption.

Implementation Timeframe

OFA supports an immediate effective date for the final rule. Those conventional dairy operations with existing herds that have not yet entered the certification process should be able to plan for their transition with their certifier using the one-time transition allowance as part of their approved organic systems plan. For operations that are in the process of getting certified on the final rule’s effective date, they should complete the one-time transition approved by their certifier within 12 months of the effective date.

Regulatory Impact Analysis

While ongoing gaps in economic and other data about organic operations presented a challenge for the agency in performing this analysis, we believe that the conclusions presented provide ample justification and support for prohibiting the transfer or sale of transitioned animals to another operation without losing their organic status.

These conclusions include:

  • The benefits of clarifying the regulations will ensure a level playing field for all organic dairy producers, support consumer trust in the USDA organic seal by assuring consumers that organic dairy products meet a consistent standard, and support producer confidence in the organic label.
  • Despite years of delay in finishing this proposed rule, there remains a need for this rulemaking.
  • The uneven application of the current rule suggests that a smaller share of producers is benefitting from the cost advantage of transitioned heifers, at a higher level than is suggested by the average number of head purchased. Therefore, the majority of organic dairy farms that exclusively raise their own replacement animals are not expected to have higher production costs under the final rule. Producer cost increases would occur in limited scenarios and would amount to less than 2.5% of producer costs.
  • Consumer milk price increases are estimated to be less than 0.08% (which translates to an extra 2 or 3 cents for a half gallon of organic milk). This very low price increase is not likely to limit industry growth nor noticeably affect consumer demand for organic milk.
  • Sufficient numbers of organic heifers (organically managed from last third of gestation) would be available after the implementation of the rule to maintain and/or grow existing organic dairy operations.
  • The long-term economic impact on producers of not implementing the proposal is greater than the economic impact of the rule due to the need for greater consistency in applying the origin of livestock standard across the organic dairy sector. We believe that this point is not fully developed in the analysis. Because of limitations in the availability of data on organic agriculture, waves of economic damage to organic dairy farms are not fully captured by examining the USDA’s Census of Agriculture results or even the NOP’s Organic Integrity Database. But even using the simplified metric of number of certified operations in the OID that specify that they produce milk or dairy, there have been recent years where significant numbers of certified dairy operations exited the organic market. One year with significant increases in the numbers of certified operations, 2019, offsets some of those significant losses. Therefore, simply looking at the growth between the 2015 proposed rule and today gives an incomplete picture of the economic health of the organic dairy sector. The failure to adequately enforce the origin of livestock rules has caused ongoing disruption and economic damage to the organic dairy sector that is not adequately captured in this analysis.

Additionally, the analysis fails to fully develop some of the benefits that should come from a final rule being enforced. One benefit that should be more fully appreciated is the opportunity for growing the organic dairy sector, as well as the affiliated organic grain sector that provides feed for organic dairy operations, if loopholes are closed. According to OFA members, organically certified livestock (managed organically from the last third of gestation) currently have no premium as most are sold on the conventional market. Addressing the problem of continuous transition that undermines the price of organic replacement animals will help create value for organic operations to sell organically-raised replacement animals and create a market that could help them diversify their operations and have a better tool to avoid overstocking and better manage their herd size relative to their land base.

Fay Benson, Cornell Cooperative Extension educator and project manager for the Cornell Organic Dairy Program, investigated the cost differences between organic and conventional practices during the first year of a dairy heifer’s life and found that dairies that raised heifers conventionally to one year of age were able to save on average $884 per animal compared to animals raised using organic methods on three farms in New York. The major components of these savings were due to increased labor and more expensive feed (organic milk) on organic operations.  As an article about this research states, “Allowing the conventional raising of “pre” organic heifers allows these dairies to avoid the higher costs of feeding organic milk and also shortens the expensive period prior to weaning… This puts dairies that follow the NOP rule at a significant disadvantage, specifically in the Northeast.”[2]  The benefit of closing a loophole that provides an $884 per head advantage to those operations that continuously transition animals into organic is significant.

Another benefit of a final rule to prohibit continuous transition and sale or transfer of transitioned animals as organic would be to reduce some of the volatility experienced in recent years in regional organic milk markets, as described earlier. The use of continuous transition allowed some herds to grow at a rapid pace and created market surpluses. Requiring operations to source organic animals would provide for a more gradual rate of growth of existing herds that does not undermine existing organic operations. This could also help assure conventional dairy operations that are considering a transition to organic that it is worth the effort and time to transition because, once certified, they will be able to count on steady growth and a level playing field based on uniform enforcement.

In the discussion of benefits of the proposed rule, the agency mentions that it expects the proposed rule to help support consumer confidence and that increased confidence could “disincentivize the (costly) establishment of credentials that are alternative to USDA organic certification.” The concept that USDA organic does not represent the most credible marketplace standard for milk production is presented as an abstract possibility. But the proliferation of animal welfare and other label claims that certified organic producers feel increasing pressure to pursue in addition to USDA organic is not an abstract possibility. This pressure to pursue additional certifications is happening now and creating more work and expense for organic operations. If the USDA needs data on this, we urge you to work with groups like OFA or through USDA census processes to ask organic farmers about the pressure to pursue additional certifications because of perceived weaknesses in the organic standards and what these additional certifications are costing operations in both time and fees.

Exceptions to the One-Time Allowance

OFA does not support any exceptions to the one-time allowance.


In addition to the issues raised for comment, we urge the agency to consider two more important topics.

Recordkeeping and Certification Procedures: The final rule should include details about how operations will communicate with their certifier about using the one-time exemption for transition and how those transitioned animals will be tracked. Certifiers should already be tracking transitioned animals to ensure they are not being sold for slaughter as certified organic. We also believe that the transition status of animals should be indicated on organic certificates and on records used when animals are taken to auction or sold off the farm. Animal lists with information such as vaccine numbers should be part of the records certifiers examine during their inspections of dairy operations, similar to how examination of pasture recordkeeping is now part of inspection procedures.

Organic Data: The regulatory impact analysis for this rulemaking has been challenging because of the inadequate state of data and understanding of the economics of organic dairy production. Even calculating the number of certified organic dairy operations over time proved challenging because of limitations in the NOP’s Organic Integrity Database and the inadequate coverage of organic operations by the Census of Agriculture. This is in stark contrast to the wealth of data that is collected about the conventional milk sector, as a result of AMS’ charge to administer pricing programs and ensure orderly marketing conditions. We urge the NOP to coordinate with the dairy program in AMS to establish better reporting on the movement of organic milk between regions and market conditions including organic pay price. It is difficult to persuade dairy farmers to make the significant commitment of transitioning to organic production if they cannot gain a clear view of the state of the organic milk market in their region. And as the volatility of the last several years shows us, organic producers can no longer assume that growth in the organic milk sector will be gradual or regionally-based.

The changes being considered by the agency are needed to uphold consumers’ expectations about organic dairy. Finalizing this rulemaking is critical to bring consistent enforcement which would create a level playing field among all organic dairy producers and uphold strong organic integrity for all organic farmers across the country. Our members believe they can compete with the most efficient organic dairy operation of any size if they are treated equitably. Loopholes in the current rule put our members at a competitive disadvantage and allow inequitable interpretation and enforcement of the rule by some certifiers. Because organic certification is typically conducted by a regional certifier, inequitable interpretation between certifiers can pit different geographic regions or states against others.  The current system places the majority of organic dairy farmers, and particularly family-owned and operated rural dairy operations, at a significant competitive disadvantage.

We appreciate that the USDA has committed itself to responding to the pandemic by addressing long-standing issues of limited resilience in the food and agriculture system. The USDA’s new vision of a food system that is “fair, competitive, distributed, and resilient” is a worthy goal and we hope that regionally-dispersed family-scale organic operations are part of USDA’s vision. One item on USDA’s agenda for strengthening resilience in the agriculture supply chain is encouraging more farms to transition to certified organic and providing assistance for them to do so.[3] It is vital that those new entrants into the organic marketplace are able to compete on a level playing field, otherwise USDA’s investment and encouragement will be wasted. A key step to making sure that new organic operations can thrive is to close the loopholes that allow a small number of large operations to create an unfair economic advantage by continuously transitioning conventional animals into organic. A strong, enforceable rule will help ensure economic equity for all organic dairy operations and ensure continued consumer confidence in the organic label.

Thank you for your consideration of these comments on the critical issue of the origin of organic livestock. Please contact Patty Lovera, (202) 526-2726 or, if you have questions or need additional information.


Kate Mendenhall

Executive Director


[1] USDA Office of Inspector General. “AMS-NOP – Organic Milk Operations.” July 2013. Audit Report 01601-0002-32.

[2] Fay Benson. Cornell Collee of Agriculture and Life Sciences. “USDA Puts Northeast Organic Dairies at a Disadvantage.” Small Farms Quarterly. January 13, 2020.


Dairy Farmer Comments Needed – Origin of Livestock Rule

Since 2013, the organic community has been working to fix a loophole in the Origin of Livestock rule for organic cow dairies. The USDA National Organic Program’s failure to strengthen the standards for organic livestock has allowed large-scale organic dairies to continuously transition animals into organic, undermining those organic farms that comply with the intent of the organic label.

In 2015, the NOP published a proposed rule to clarify that, after completion of a one-time transition from a conventional dairy farm, all new dairy animals milked on an organic dairy farm would need to be managed organically from the last third of gestation. The 2015 proposed rule garnered strong public support from the entire organic community but has never been finalized.

Now, after years of advocacy by the organic community, the NOP has released a revised proposed rule for public comment. They need to hear from organic dairy farmers! Here are some points you can include in your comment.


1. Whether the final rule should prohibit organic dairy operations from acquiring transitioned animals to expand or replace animals to produce organic milk.

OFA supports the final rule prohibiting organic dairy operations from acquiring transitioned animals. A transitioned animal should only be considered organic on the farm it was transitioned on.

2. Whether the final rule should use the term “operation” to describe the regulated entity [instead of "producer".]

OFA supports using the term “operation” to describe the regulated entity, with the addition of linking the transition of animals to a "responsibly connected person(s)."  In accordance with the “responsibly connected person” approach, any person who is a partner, officer, director, holder, manager, or owner of 10 percent or more of the voting stock of an applicant or a recipient of certification would be allowed a one-time herd transition exemption. Any person with a significant financial or managerial stake in a dairy operation would utilize their one-time eligibility once a transition occurs at that operation.

THE NOP IS ALSO ASKING FOR COMMENTS ON SEVERAL ADDITIONAL ISSUES.  You can add these to your comment if you have thoughts to share:

1. IMPLEMENTATION TIMEFRAME: The NOP had proposed that all requirements be implemented upon the effective date of a final rule, with an exception for any transition that was already approved by a certifying agent. They request comments about whether an implementation timeframe is necessary for organic dairies to comply and what that timeframe should be.

OFA supports an immediate effective date for the final rule. For those operations who have not yet entered the certification process, they should be able to plan for their transition with their certifier using the one-time transition allowance. For those operations that are in the process of getting certified on the final rule’s effective date, they should complete the one-time transition approved by their certifier within that first year.

2. ECONOMIC IMPACT: The NOP requests feedback related to the costs and benefits of this proposed rule.

This is where you can provide examples to USDA to make the case that failure to close this loophole is harming organic farms. Any examples you can provide could be helpful. Does your operation already meet the requirements laid out in this proposed rule? Have years of delay in closing this loophole caused economic harm for your operation? Have you had trouble selling organic animals, or not been able to get an adequate price, because of competition from transitioned animals offered for sale to organic operations?


To read the revisions to the proposed rule and SUBMIT A COMMENT, GO HERE.

  • You can type your comment directly in the text box on the site or attach a word or pdf file.
  • Mention "Docket No. AMS-NOP-11-0009-2321" in your letter.
  • You can cover as many of the questions USDA posed for public comment as you want, but you don’t have to comment on all of them.
  • Mention that you are an organic dairy farmer and give any relevant examples about how failure to close this loophole has impacted your operation.
  • Questions? Contact Patty Lovera at

118 Organizations & 249 Farms Send Letter to USDA RE: Organic Dairy Rule

January 28, 2021

U.S. Department of Agriculture
1400 Independence Ave., S.W.
Washington, DC 20250

RE: USDA National Organic Program – Origin of Livestock Rulemaking

Dear Acting Secretary Shea:

As members of the organic community, we look forward to working closely with you to advance a food and agriculture system that benefits the health of people and the planet.

In that regard, we are writing today about an issue that is important for the future of organic dairy farmers, their families, and the integrity of the organic label.  This issue is the need to clarify the regulation regarding Origin of Livestock (7 CFR 205.236), pertaining to the process of transitioning conventional dairy livestock to organic production.

The organic label is one of the most highly trusted labels for consumers. This is due to the strong Federal standards and enforcement behind the label. There are, however, some areas where the USDA’s National Organic Program standards need to be strengthened to retain that consumer trust.  Solidifying standards to ensure all organic farmers operate under the same rules is essential for the entire organic community. The economic viability of organic dairy farmers is dependent upon clarification of regulations to stop varied interpretations or loopholes regarding dairy livestock transitioning practices.

The problem has been that those organic dairy producers who have utilized the loophole to continuously transition conventional animals into organic production have gained an economic advantage and contributed to the oversupply of organic milk. This has contributed to a significant drop in the milk prices paid to organic dairy farmers, the majority of whom were held to a higher standard and stricter enforcement.

In 2015, during the Obama-Biden Administration, USDA published a proposed rule to close the loopholes related to ‘Origin of Livestock’ (80 FR 23455). Specifically, the proposed Rule would clarify that:  “After completion of a one-time, 12-month transition period of an existing conventional dairy herd (or livestock to form new organic dairy operations), all new dairy animals milked on the organic dairy farm would need to be managed organically from the last third of gestation.”

The 2015 proposed rule garnered strong, united support from the organic community and consumers, especially the provision that stopped conventional livestock from continuously entering the organic herd. Implementing the 2015 Proposed Rule would clarify the regulation so that all certifiers will consistently enforce the same standards, with confidence that their decision would be upheld in any legal challenge. Unfortunately, the 2015 rule has never been finalized.

Organic dairy farmers understand the economic importance of maintaining the integrity of the organic label by finalizing the ‘Origin of Livestock’ (80 FR 23455). For 15 years, organic dairy farmers have advocated for an enforceable regulation applied equally to all certified producers. The organic community has provided comments two times on Proposed Rules from the National Organic Program (NOP) to stop the continuous transition and two-track system interpretation created by loopholes in the current regulation. USDA’s unconscionable delay in issuing a Final Rule has resulted in economic damage, financial hardships, and closure of businesses for organic dairy farmers following the true intent of the organic standards.

Congress included a provision in the Fiscal Year 2020 Agriculture Appropriations bill requiring USDA to finalize the long-delayed rule by June 17, 2020. USDA missed that deadline. On October 21, 2020, the NOP announced plans to publish another Proposed Rule to address enforcement issues raised by USDA’s Office of General, instead of moving directly to a final rule as required by Congress. NOP has failed to provide a timeframe for issuing the new regulations. Organic dairy farmers and the organic community more broadly are frustrated by the NOP’s continued delay in finalizing this regulation.

The undersigned organizations urge you to take the immediate actions necessary to finalize this important rulemaking, to establish a consistent and fully enforceable standard regarding the origin of dairy livestock used for organic production.


National Organic Organizations (21):

Alliance for Natural Health USA, USA, National
Beyond Pesticides, USA, National
Bioagricert (a FoodChain ID company), USA, National
Family Farm Defenders, USA, National
Food & Water Watch, USA, National
Food Animal Concerns Trust (FACT), USA, National
Friends of the Earth, USA, National
Green America, USA, National
National Center for Appropriate Technology, USA, National
National Family Farm Coalition, USA, National
National Farmers Organization, USA, National
National Organic Coalition, USA, National
Natural Resources Defense Council, USA, National, USA, USA, National
Organic Consumers Association, USA, National
Organic Farmers Association, USA, National
Organic Farming Research Foundation, USA, National
Organic Seed Alliance, USA, National
Organic Eye, USA, National
The Cornucopia Institute, USA, National
Wild Farm Alliance, USA, National

State & Local Organic Organizations (90):
350 Sonoma, Regenerative Agriculture group, CA
Albert Lea Seed, MN
Arizona Natural Health Center, AZ
Baystate Organic Certifiers, MA
Bethlehem Farmers' Market, PA
Bionutrient Food Association, MA
Bucks Environmental Action, PA
California Certified Organic Farmers, CA
Carolina Farm Stewardship Association, NC
Central Indiana Organics, IN
Centralas Wine LLC, CA
Community Involved in Sustaining Agriculture (CISA), MA
Compost Carpool, TX
Cuatro Puertas, NM
Ecological Farming Association, OR
FairShare CSA Coalition, WI
Farm2Table Co-op & Cafe', WI
Good Earth Natural Foods, CA
Govinda Goshala Cow Haven Inc, NY
Green City Growers, MA
Green Creations Landscape Services LLC, PA
Green State Solutions, IA
Hanover Co-op Food Stores of NH & VT, NH
Honeybee Kitchen and Market, DE
Hoosier Organic Marketing Education, IN
iEat Green, LLC, NY
Iowa Organic Association, IA
Iroquois Valley Farmland REIT, IL
Kanalani Ohana Farm, HI
KOL Foods, MD
Maine Dairy Industry Association, ME
Maine Organic Farmers and Gardeners Association, ME
Maine Organic Milk Producers, ME
Maple Hill Creamery, NY
Michigan Organic Food and Farm Alliance, MI
Midwest Organic & Sustainable Education Service (MOSES), WI
Miskell's Conservation Land Consulting LLC, VT
MOFGA Certification Services, ME
Montana Organic Association (MOA), MT
MOSA Certified Organic, WI
Natural Grocers, CO
Nature's Way Resources, TX
North End Organic Nursery, ID
Northeast Organic Dairy Producers Alliance (NODPA), MA
Northeast Organic Farming Association of New Hampshire (NOFA-NH), NH
Northeast Organic Farming Association of New York (NOFA-NY), NY
Northeast Organic Farming Association of Vermont (NOFA-VT), VT
Northeast Organic Farming Association-Interstate Council(NOFA-IC), MA
Northern Plains Sustainable Agriculture Society (NPSAS), ND
OCIA Research & Education, Inc., NE
OFARM (Organic Farmers Agency for Relationship Marketing), MN
Ohio Ecological Food and Farm Association, OH
One Cert, Inc., NE
Oregon Organic Coalition (OOC), OR
Oregon Tilth, OR
Organic Advocacy, CA
Organic Association of Kentucky, KS
Organic Seed Growers and Trade Association (OSGATA), ME
Out There Coffee Co, OK
Pacha, CA
PCC Community Markets, WA
Pennsylvania Certified Organic (PCO), PA
Pikes Peak Farm to School, CO
Pioneer Valley Performing Arts Charter Public School Sustainability Club, MA
Primus Auditing Ops, CA
Provender Alliance, OR
Real Organic Project, VT
Revolution Rickshaws. L.L.C., NY
Rodale Institute, PA
Rural Vermont, VT
Save Our Soil, WV
Sebastian's Restaurant Racine, WI
Sebastopol Farmers Market, CA
Slow Food North Shore, NY
Slow Food Western Slope, CO
Socially Responsible Agriculture Project, CO
Sonoma County Farm Bureau, CA
Spring Sunrise Natural Foods, IA
Straus Family Creamery, CA
Syntax Land Design, LLC, MO
Texas Organic Farm & Garden Association, TX
The Brice Institute, PA
The Garden of Giving, PA
The Hemp Shield Company, OR
The Land Connection, IL
Upstate Niagara Cooperative, Inc., NY
Valley Organic Growers Association, CO
Virginia Association for Biological Farming, VA
Western Organic Dairy Producers Alliance (WODPA), WA

International Organic Organizations (7):

IFOAM North America, USA, Canada, Mexico
International Organic Inspectors Association, Headquarters, USA
Nature's Path Foods Inc., BC, Canada
SULADS Canada Foundation, BC, Canada
Extension Unit of Banat University, Romania
Global Certification Society, Palampur, India

Farms (249):

Mountain Sun Farm, AL
Green Goat of Misty Mountain Farm, AR
Royal Berry Farm, AR
Sanctuary Farm & Rest House, AR
Alexandre Dairy, CA
Alexandre Acres, CA
Alexandre Family Farm, CA
DeBernardi Dairy Inc, CA
Full Belly Farm, CA
Galaxy Farm, CA
Handy Farms, CA
Malibu Sangha, CA
McGrath Family Farm, CA
Birdsong Orchards, CA
Cornerstone Farm, CA
Creekside Farms Silveira Farms, CA
For the People Seed Farm, CA
Indian Springs Organic Farm, CA
LaRocca Vineyards, CA
Orchard Flats Farm, CA
Puma Springs Vineyards, CA
Rancho Roben, CA
Somerset Gourmet Farm, CA
Bucher Farms, CA
Renati dairy, CA
Trinity land & livestock Inc., CA & OR
Irongate Ranch, CA.
Natural Ag LLC, CO
Nighthawk, CO
Protect Your Assets LLC, CO
Black Fox Farm, LLC, CO
Sweet Ring Farm, CT
Just Organic Inc, FL
Community Meat Co., GA
LS Adderson, Inc., GA
W.C. Bradley Farms, Inc., GA
Maui Bees Inc, HI
New Dream organic farm llc, HI
Andrew Riniker Jr. Farm, IA
Andy Helmuth Farm, IA
Blueberry Bottom Farm, IA
David W Bangert Farm, IA
Maple View Dairy, IA
Prairie Star Farms, IA
Radiance Dairy, IA
Wells, Inc, IA
Bridgewater Farm, IA
Fantasy Farms, IA
Heritage Organic Acres, IA
Madison Hill Farm, IA
O’Lynch Dairy, IA
Okoboji Organics, IA
Patchwork Green Farm, IA
Randy Riediger, IA
Magic Valley Organic Dairy, ID
Turner Dairy Inc., ID
Deelstra Dairy, ID
Double Eagle Dairy, ID
Eagle View Dairy, ID
Frisian Farm, ID
Ken Backstrom, ID
Mills Farm & Cattle Co., ID
Ackerman Certified Organic Farm & More, IL
Adsit Farms, IL
Amanda Busse Dairy Farm, IL
Mint Creek Farm, IL
Gary E. McDonald/McDonald Farms, IL
Lily Lake Organic Farm, IL
Snow Rocky Road Dairy inc, IL
Ramsey Organic Farms, IN
Center Valley Organic Farm, IN
Sterling Ag., IN
Conway's Produce, KS
ReQua Family Farm, KS
Organic Association of Kentucky, KS
Moon on the Meadow farm, KS
Mt. Folly Farm, LLC, KY
Rolling Fork Organic Farm Inc, KY
Keets Croft, MA
NaMac Farm, MA
Good Soil Farm LLC, MD
Rosebud Estates, MD
Silvercloud Farm LLC, MD
Abundant Grace Farms, MD
Milk and Honey Farm, MD
Chase Farm, ME
Forster Ricardo Farm, ME
Grace Pond Farm, ME
Midsummer Night's Meadow Farm, ME
Milkweed Farm, ME
Noon Family Sheep Farm, ME
Sheepscot Valley Farm, ME
The Milkhouse, ME
Hatchet Cove Farm, ME
Reed Farm, ME
Wolfe’s Neck Center, ME
Ford Farms, MI
Sherman Family Farm LLC, MI
Guza organic farm, MI
Nodding Thistle, MI
Plymouth Orchards, MI
Wingnut Farms, MI
Blue Skye Farms, MN
Ladwig Acres, MN
Mohs Dairy, MN
Robin & Karen Brekken Farm Partnership, MN
School House Place, MN
The Boreal Farm, MN
Valley Organic Farm, MN
Allen Berg Farm, MN
Askegaard Organic Farm, MN
Dean Walz Farm, Mn
Enchanted Meadows, MN
First Foods Farm &Seeds, MN
JPR Acres, LLC, MN
Pleasant Hill Farms, MO
Blue Heron Orchard, MO
Karbaumer Farm, MO
Wacha farms, MO
Quinn Farm & Ranch, MT
Craig & Lori Schmitt Farm, MT
Fox Hollow Farms, MT
Crow Holler Produce, NC
GODS Country, NC
Green Life, LLC, NC
Rose Mountain Farm, NC
Ecological Insights, ND
Michael Zegers, NE
Chad Christianson, NE
Mo-Day Farms, NE
Rhea Brothers GP, NE
Brookfield Farm, NH
Brookvale Pines Farm, NH
Hop N Hen Farm, NH
Pedlar's End, NH
Fertile Fields Farm, NH
Comeback Farm, NJ
Neshanic Pastures LLC, NJ
Stephens Farm, NJ
Still Hill Farm, NS/Canada
Casey dairy farm, NY
Cobblestone Valley Farm, NY
Dewey Produce, Inc., NY
Gianforte farm LLC, NY
Minde Farm, NY
Mr. & Mrs. John J. Saeli, NY
Murphys Grass Farm, NY
Myer Farm, NY
Naturally Organic Realty, NY
Road's End Farm, NY
Rocky Top Acres LLC, NY
Twin Ponds Farm, NY
Biophilia Organic Farm, NY
Breese Hollow Dairy, NY
Be a Blessing Farm, NY
Bundy Creek Farm LLC, NY
Clearview Farm, NY
Elderberry Pond Farm, NY
Hodgins Harvest, NY
Rosewalk Farms LLC, NY
Solstice Hill Farm, NY
The Hoppy Acre, NY
Twin Oaks Dairy LLC, NY
White Feather Farm, NY
Baker Fork Farm, OH
Bezold Farms, OH
Schmidt Family Farms, OH
Straits Brothers Farms Inc., OH
Turner Farm, OH
Circle K Stables, OH
Dahlinghaus Farms, OH
Hi Dew Meadow Farm, OH
Hidden Springs, OH
Jordan Gingerich Farm, OH
Pohl Dairy, OH
Straits Brothers Farm Inc., OH
Timberlane Organic Farms, OH
Tom Cail Farm, OH
Three Springs Farm, OK
Farmer Gene's Bees, OR
Hinsvark Farm, OR
Redwing Farm, OR
Wren Vineyard, OR
High 5 Acres inc., OR
Danish Dairy, LLC, OR
Deschutes Canyon Garlic, OR
Gentle Rain Farm, OR
LaNa's Conscious Farm Inc., OR
Medina dairy, OR
Pacific Botanicals, OR
Plum Thickets Farm, OR
Spring Up Farm, OR
Poland Organic Dairy, OR
Earl Groff Farm, PA
Brian Mizikar, PA
Butt Ugly Farm, PA
Hillside Farm, PA
Lehigh Valley Organic Growers, Inc., PA
Provident Farms, PA
Quarry Hill farm, PA
Lancaster Farm Fresh Cooperative, PA
Regenerative Farm LLC, PA
Snipes Farm and Education Center, PA
Lady Moon Farms, PA-FL-GA
Blue Sky Sunny Day, SC
Bill and Janine Fonder Family Organic Dairy, SD
K&N Organic Farm, SD
Floyd Farms, TX
Stonefield Farm, TX
Self Employed Millberg Farm, TX
King Hill Farm, VA
Oak Grove Meadows LLC, VA
Flack Family Farm, VT
Grateful Morning Dairy, LLC, VT
The Corse Farm Dairy LLC, VT
Riverstone Organic Farm, VT
Buck Mountain Maple, VT
Green Wind Farm LLC, VT
Long Wind Farm, VT
Vermont Compost Company, VT
Downriver Orchard, WA
Northstar Nurseries, Inc., WA
Pure Eire Dairy, WA
Uhlenkott Farm, WA
Whitestone Mountain Orchard, WA
Dykstra Farms, WA
Fayette Ranch, WA
Mallonee Family Farm, LLC, WA
Mensonides LLC, WA
Olivers Northwest Produce, WA
Osceola Jerseys LLC, WA
Breezy Hills Farm of Baldwin, WI
DeFere Family Farms LLC, WI
Franklin Farm, WI
Sweet Springs Farm, WI
Wonderfarm, WI
David Olson Farm, WI
Homer Ridge Organic Dairy, WI
Hughes Farms, WI
Klefstad Natural Dairy, WI
Mark and Kim Mueller Farm, WI
Towlealen Farm, WI
Weiterman Farm LLC, WI
Whitefeather Organics LLC, WI
Full Harvest Farm LLC, WI
Belle Vue Dairy, WV
Thistle Ridge Farm, WV
Windspring Farms, Inc., WV

Deputy Under Secretary of Marketing and Regulatory Programs Mae Wu
National Organic Standard Board



To read more about the Origin of Livestock Rule, below are links to past blog posts on OFA action to call on USDA to finalize OOL
June 2020 Letter to USDA regarding missed rulemaking deadline last June.



OFA & NOC Submit Letter to USDA RE: Covid Relief

January 15, 2021

Dear Secretary-designate Vilsack,

We are writing to make recommendations about the USDA’s implementation of the “Covid-19 Relief and Fiscal 2021 Omnibus Act.” We are deeply concerned about the impact of Covid-19 on organic farmers, farmworkers, businesses, certifiers, inspectors, and consumers. We are mindful of the need to protect the health and safety of all who are involved in organic agriculture, certification, and compliance. Because of the annual organic certification process and the need to protect the integrity of the USDA organic seal during this time of ongoing market disruption, some of our concerns and recommendations may be unique from those raised by other sectors of agriculture.

Support for Organic Farmers

The recently enacted Covid-19 Relief and Fiscal 2021 Omnibus Act includes $11.2 billion to:

“prevent, prepare for, and respond to coronavirus by providing support for agricultural producers, growers, and processors impacted by coronavirus, including producers and growers of specialty crops, non-specialty crops, dairy, livestock, and poultry, producers that supply local food systems, including farmers markets, restaurants, and schools, and growers who produce livestock or poultry under a contract for another entity:”

as well as a provision that:

“in making direct support payments in this section, the Secretary of Agriculture may take into account price differentiation factors for each commodity based on specialized varieties, local markets, and farm practices, such as certified organic farms (as defined in section 2103 of the Organic Foods Production Act of 1990 (7 U.S.C. 6502)):”

As you make plans to implement this section of Act, we would like to point out that organic farmers represent a significant percentage of the farmers in each of the specialty crop, livestock and dairy, and local food supply categories prioritized by Congress. Therefore, it is critical that organic farmers be included in any payment programs created to implement this provision of the Act. The following financial assistance recommendations would be extremely helpful for the organic sector:

  • In making direct payments, it is critical that the criteria used to distribute those payments be more finely-tuned to support the diversity and richness of U.S. agriculture than was reflected in the previous coronavirus-related payment programs, and that more reasonable payment limitations govern those payments to ensure that more farmers get help with these funds.
  • Most organic and small farms have not traditionally accessed food purchasing programs run by the agency using Commodity Credit Corporation funding. As you develop new purchasing programs to both aid farms and procure food for emergency feeding or other nutrition programs, we urge you to make the procurement process flexible enough to work for organic and small farms, not just large conventional operations. This should include purchases of a diverse set of crops, not just commodity crops.
  • As farmers innovate to respond to the social distancing recommendations related to the pandemic, USDA should provide financial assistance for farms setting up virtual platforms to facilitate the sale of their products, as well as “on-farm” stands, curbside pickup, and other direct to consumer “no-touch” distribution channels that minimize interaction. In the same way that restaurants across the nation have shifted to take-out pick-up options, farmers too are shifting to this model. But farmers need some financial assistance to facilitate this shift.
  • The federal government has historically reimbursed up to 75 percent of organic certification fees paid by organic farms and businesses, with a maximum reimbursement of $750 per certification scope (crops, livestock or handling) per operation. Congress reinforced these reimbursement rates when it reauthorized the National Organic Certification Cost Share Program through the 2018 Farm Bill. Unfortunately, in August, the Farm Services Agency cut reimbursement rates for 2020 certification costs to 50 percent, up to a maximum of $500 per scope. This action leaves organic operations – who had been planning on being reimbursed for their certification costs at the same level as previous years – burdened with an unplanned expense, in the midst of a period of higher costs and disrupted markets caused by the pandemic. The cost share program is particularly important to small and mid-sized organic farms, and those who are just starting out with organic certification. We urge you to act quickly to restore the funding levels for this program mandated by Congress.

Relaxing USDA Nutrition Program Rules to Give Low-Income Consumers Greater Access to Nutritious Food During the Pandemic

Allow Supplemental Nutrition Assistance Program (SNAP) payments to be made online directly to farms and CSAs, and expand SNAP on-line options for customers of smaller retailers, such as local food cooperatives.

  • Provide waivers and direction to States to broaden their WIC-approved food lists to allow WIC participants to purchase organic foods.
  • Support the ability of food banks and other emergency feeding programs to purchase organic products directly from farmers at market prices.

Move Critical Rulemaking Forward to Protect Organic Integrity

There are several long-overdue rulemakings that are critical to the organic sector and the economic viability of organic farms. We urge you to move these rulemakings along without delay in order to protect the integrity of the organic label and to strengthen enforcement to shield operations from unfair competition.

The rulemaking to improve organic enforcement, both domestically and internationally, (the “Strengthening Organic Enforcement” rule) is critical for the economic viability of the U.S. organic sector. The 2018 Farm Bill required USDA to complete the rulemaking by December 19, 2020, but it has not. The public comment period on the proposed rule closed on October 5, 2020. This rulemaking must be finalized and move forward to implementation as quickly as possible.

  • The final rule on Origin of Livestock (OOL), to close loopholes in the organic standards related to the transitioning of conventional dairy cows into organic dairy operations, is another critical regulation for the organic sector. Through the Fiscal Year 2020 appropriations process, Congress mandated that the USDA complete the OOL final rule by June 17, 2020 but the USDA missed this deadline. We need the USDA to finalize an enforceable rule on Origin of Livestock as quickly as possible
  • The Organic Livestock and Poultry Practices (OLPP) rule is another long-overdue measure to strengthen the organic standards, which was delayed and ultimately withdrawn by the Trump Administration. The OLPP final rule would allow the NOP to consistently enforce stronger animal welfare standards on organic farms and close loopholes being taken advantage of by some large operations. We urge you to reinstate the final OLPP rule as quickly as possible.

We thank you in advance for your efforts to respond quickly to the needs of organic farmers and businesses in light of the COVID-19 pandemic.


Abby Youngblood                                                                  Kate Mendenhall
Executive Director                                                                  Executive Director
National Organic Coalition                                                     Organic Farmers Association

OFA Starts the New Year Strong!

January 1, 2021

Organic Farmers Association (OFA) and Rodale Institute are proud to announce an exciting new chapter for farmers: OFA has obtained its own IRS 501(c)(5) status to operate as an independent agricultural organization.

This is a significant milestone for both Rodale Institute and OFA, as OFA will become the first, and only, independent national policy organization led by certified organic farmers. OFA will continue to provide a strong voice for domestic certified organic producers in Washington, D.C. and around the country.

Since OFA was founded in 2016, Rodale Institute has acted as the organization’s fiscal sponsor—ensuring OFA has the organizational capacity to allow its organic farmer leadership to focus on impacting policy. Together, we aimed to ensure that farmer priorities were authentically represented among the other organic stakeholders in the Farm Bill, NOSB decisions, and other national arenas. Five years later, OFA is strong enough to stand on its own, having built a solid foundation as a leading voice for organic farmers in D.C. and beyond.

Moving forward, Rodale Institute will continue to support OFA’s efforts in a reduced capacity. While the nature of our partnership is changing, the close relationship between the two organizations will remain, with Rodale Institute maintaining a voting seat on OFA’s Governing Council and continuing to provide 501(c)(3) support when necessary.

Obtaining 501(c)(5) status allows OFA to become its own tax-exempt agricultural organization, enabling us to achieve our primary mission—giving organic farmers independent control of the organization. This status also allows us more freedom in policy advocacy, fundraising, and legitimacy in the agricultural policy space.

With this update, OFA is excited to begin an independent relationship with the Biden administration as well as the new leadership at the U.S. Department of Agriculture. Farm Bill discussions will begin this year, and OFA will be there to make sure organic farmer priorities are represented. OFA collaborates with the other national organic organizations and together we intend to see to fruition a final Origin of Livestock rule, re-introduction and implementation of the Organic Livestock & Poultry Practices Rule, and stronger NOP enforcement to ensure the integrity of organic and uniform application of organic standards.

OFA will host virtual lobby days this March, open to all OFA members. The advocacy days allow organic farmers an opportunity to share their priorities with their elected officials. OFA provides training and support for the lobby days and hopes for strong farmer attendance this year due to the virtual nature of the event.

As we close one chapter and start another, OFA and Rodale Institute are proud to move forward together as two organizations committed to supporting organic farmers, the organic movement, and protecting the health of people and the planet.

We thank Rodale Institute for all their support in our founding years and ensuring that the voices of organic farmers are always at the table.

Kate Mendenhall
Executive Director
Organic Farmers Association

2021 OFA Elected Leadership

The following certified organic farmers and organic farm organizations were elected to fill open seats in their region for the Governing Council or Policy Committee.  The ballot closed November 15.  Their terms begin in March 2021.  Only OFA farm members have the right to vote on OFA decisions.  OFA policy is ONE FARM, ONE VOTE.  Each farm has an equal place at the table.


Governing Council: Farmer
Judith Redmond, Full Belly Farm, Guinda, CA
Policy Committee: Farmer
Kenneth Kimes, Greensward / New Natives, LLC, Aptos, CA

MIDWEST   (Missouri, Illinois, Indiana, Michigan, Ohio, Pennsylvania)                  

Governing Council: Farmer
Dave Bishop, PrairiErth Far, Atlanta, IL
Policy Committee: Farmer
Michael Adsit, Plymouth Orchards, Plymouth, MI
Policy Committee: Organization
Illinois Stewardship Alliance (ISA), Molly Gleason, Communications Director, Springfield IL

NORTH CENTRAL   (Nebraska, North Dakota, South Dakota, Minnesota, Iowa, Wisconsin)                           

Governing Council: Farmer
Mike Kelly, High Meadow Farm, Johnson Creek, WI
Governing Council: Organization
Midwest Organic & Sustainable Education Service (MOSES): David Perkins, President, Spring Valley, WI
Policy Committee: Farmer
DeEtta Bilek, Tom & DeEtta Bilek Farm, Aldrich, MN

WEST   (Alaska, Hawaii, Washington, Oregon, Nevada, Arizona, Idaho, Utah, New Mexico, Montana, Wyoming, Colorado, Kansas)                           

Governing Council: Farmer
Linley Dixon, Adobe House Farm, Durango, CO
Governing Council: Organization
Montana Organic Association (MOA): Becky Weed, Board of Directors, MT
Policy Committee: Farmer
Nathaniel Powell-Palm, Cold Springs Organics, Bozeman, MT
Policy Committee: Organization
Tilth Alliance: Melissa Spear, Executive Director, WA

SOUTH (Texas, Oklahoma, Arkansas, Louisiana, Mississippi, Alabama, Georgia, Florida South Carolina, North Carolina, Tennessee, Kentucky, Virginia, West Virginia, Maryland, U.S. Virgin Islands, Guam, Puerto Rico, Northern Mariana Islands, American Samoa)                        

Governing Council: Farmer
Shawn Peebles, Shawn Peebles Organic Farm LLC, Augusta, AR
Policy Committee: Farmer
Laura Freeman, Mt. Folly Farm, Winchester, KY
Policy Committee: Organization
Carolina Farm Stewardship Association: Roland McReynolds, Executive Director, NC

NORTHEAST   (New York, Vermont, New Hampshire, Maine, Massachusetts, Rhode Island, Connecticut, New Jersey, Delaware)                          

Governing Council: Farmer
Eve Kaplan-Walbrecht, Garden of Eve Organic Farm & Market, Riverhead, NY
Governing Council: Organization
Northeast Organic Dairy Producers Alliance: Edward Maltby, Executive Director, Deerfield, MA
Policy Committee: Farmer
Luke Gianforte, Gianforte Farm LLC, Cazenovia NY




Judith Redmond, Full Belly Farm, Guinda, CA

Bio/Statement: I have been a co-owner and farmer at Full Belly Farm since 1989. I also serve as an adviser to the California Climate and Agriculture Network, the Community Alliance with Family Farmers, and as a Commissioner of the Capay Valley Volunteer Fire Department. With the diversity of livestock, produce and flowers that we raise here at Full Belly, we are constantly made aware of the importance of regulations and policy and how they strongly influence the viability and success of different kinds of

farms. People making policy and the public at-large do not understand on-the-ground challenges of farming. Through the work of OFA, organic farmers can build a stronger voice for themselves as part of reducing agriculture’s environmental footprint. Full Belly Farm is a certified organic, multi-generational farm founded in 1985. We enjoy cooking, eating, growing, harvesting and selling fruits, nuts and vegetables year-round. We also grow beautiful flowers and top off our activities caring for a herd of sheep and a flock of chickens. We make every effort to foster sustainability on many levels — from fertility in our soil and care for the environment, to creating a stable and respectful workplace for our employees. We attend farmers markets, have a CSA program and sell to many stores and wholesalers. We often invite our CSA members and customers to the farm and offer numerous events for people who want to learn more about organic agriculture and the farmers that grow their food. Through this work we hope to invigorate the agricultural economy and build the social well-being of the small communities in our Valley.


Kenneth Kimes, Greensward / New Natives, LLC, Aptos, CA

Bio/Statement:  I have been farming greenhouse microgreens year-round for over 35 years and have always farmed organically (certified since 1982) and have only ever used organic seed (90k lbs. per year). We lobby the public to promote organic continuously at the farmers markets. My wife and I run the farm with ten full-time employees and five part-time employees. I have served on the Board of Directors for the following organizations: Community Alliance with Family Farmers (CAFF) (10+ years), Santa Cruz County Farm Bureau Board (6 years), Agriculture Policy Advisory Commission (10 years), Monterrey Bay Certified Farmers Markets, Action Pajaro Valley (farmland preservation task force), Santa Cruz County GMO Commission (we banned GMO's), and was on the Board of Directors for CCOF for many years.



Dave Bishop, PrairiErth Far, Atlanta, IL

Bio/Statement:  PrairiErth is a 300-acre farm with diverse crops and livestock and has been certified organic since 2004. With my family we also run the 100- acre farm where I grew up. Over these combined 400 acres, we grow organic corn, soybeans, oats, wheat, livestock forages, vegetables, fruit, and flowers and produce organic beef, pork, eggs and honey. We sell at local farmers’ markets and to restaurants and stores and offer a vegetable CSA and winter CSA. PrairiErth Farm has been participating in research with the University of Illinois for many years. Current research is studying the impact of various cover crop mixtures on weed suppression, soil microbial activity, and field productivity. We are passionate about growing organically, a system I adopted after years of conventional farming. I view organic farming as a way to limit our ecological footprint by caring for the earth, not just for us, but for future generations. We've reduced our farm “footprint” even further by using solar-powered pasture fencing and livestock watering systems. In addition to farming, I have lobbied in DC with NSAC for organic and local food issues, both in writing the farm bill and in the appropriations process. He currently serves as President of the Illinois Food, Farms, and Jobs Council, a Governor appointed entity created to advise the Governor and the Legislature on agricultural issues.


Michael Adsit, Plymouth Orchards, Plymouth, MI

Bio/Statement: I also served as a member of the founding OFA Steering Committee. During this time, serving OFA, I have spent a significant amount of time establishing communications with other organic farmers, promoting OFA to farmer interest groups and meeting with members of the Congress and Senate on behalf of OFA. I am committing to doing everything I can to represent and further the interests of organic farmers. My farm, Plymouth Orchards, is a 120-acre organic orchard and farm. We are also a regional agri-tourism destination. The farm was originally started in 1977. We grow organic apples, raspberries, asparagus, vegetables, small grains and hay. Plymouth Orchards is also certified as a processor for organic dried apples. Vegetables are marketed through a CSA. Fruits are direct marketed and wholesale. At Plymouth Orchards, I am responsible for organic crop production and marketing.


Illinois Stewardship Alliance (ISA), Molly Gleason, Communications Director, Springfield IL

Bio/Statement:  I was raised on my family's 4th generation grain farm in Elkhart, Illinois and currently manage 63 acres of that farm. In the future, I hope to diversify our land into organic production. While my family farm does not currently use organic practices, my involvement with the farm provides a front-row seat to the issues involved with making the decision to transition to organic and all the challenges that entails, especially as it relates to generational transfer of farm management. In addition, my experience at Illinois Stewardship Alliance brings me into contact with direct-market fruit and vegetable growers on a regular basis, many of which use organic practices or who have gone through the certification process. I work with them to understand the barriers and opportunities facing local food producers, drive demand for local food, and shape and promote local food policy. I bring strong communications skills, community-organizing and coalition-building experience, and an in-depth knowledge of the food system. If elected, I would love to put these assets to work to raise the profile of organic farming, advance organic initiatives, and garner recognition for organic farming as more than a niche method of farming, but as a real and lasting solution to restore soils, feed communities, and build thriving local economies and ecosystems.  Illinois Stewardship Alliance (ISA) is a membership-based organization. We are an organization of local food producer, concerned citizen or food-systems related organization. Alliance members span the state and have one thing in common: they all care about the food that is produced and consumed in Illinois and want to support the increase of fresh, local foods.


North Central Region: GOVERNING COUNCIL 

Mike Kelly, High Meadow Farm, Johnson Creek, WI

Bio/Statement:  My family and I started a Community Supported Agriculture program in 2009, and today raise certified organic veggies, poultry and sheep on our gorgeous, well-maintained 40-acre certified organic farm with the help of farm friends, volunteers and employees. Our CSA has over 200 members, we also sell wholesale accounts, and have workplace CSA relationships with local businesses. I served on the FairShare CSA Board of Directors and currently serve as a county supervisor with Jefferson County and on the Farmers Union water committee. Prior to farming, I had a career as a utilities superintendent. I am very interested in promoting organic agriculture and do that from my work on the farm and through my position as county supervisor.


Midwest Organic & Sustainable Education Service (MOSES): David Perkins, President, Spring Valley, WI

Bio/Statement: Educating farmers about organic and sustainable production is the foundation of our work. The cornerstone of this foundation is the annual MOSES Organic Farming Conference, the country’s largest conference on organic and sustainable farming, which draws 3,000+ people each February to La Crosse, Wis. We also educate farmers about specific farming practices through MOSES Organic Field Days and the MOSES Organic Answer Line. We manage several projects to support and empower organic farmers: Farmer-to-Farmer Mentoring Program, New Organic Stewards program, and our Rural Women’s Project. We also advocate for national policies that encourage organic production.

David Perkins currently serves as President of MOSES. David returned to his rural roots in 1994 to create Vermont Valley Community Farm located in southern Wisconsin. After a wonderfully successful 24 years of connecting thousands of people to their food, the CSA was retired in 2018. The farm continues its organic seed potato business. Committed to nurturing more CSA farms, David has spoken across the country on CSA, organic vegetable production and financial management. Certified organic since 1999, David is passionate about organic. He is the current Board President of Midwest Organic and Sustainable Education Services (MOSES) and served on the FairShare CSA Coalition Board, the Organic Farmers Association Board, and the UW- Madison Center for Integrated Agriculture Systems council.

North Central Region: POLICY COMMITTEE 

DeEtta Bilek, Tom & DeEtta Bilek Farm, Aldrich, MN

Bio/Statement:  My husband and I have owned and operated our 220-acre farm since 1977. We have been certified organic since 1998. On the farm we have crop production, graze beef cattle, and maintain forest. My primary role on the farm is the paperwork and help with overall management. My past experience with farm policy includes several opportunities to testify at Minnesota Legislature hearings and meetings with individual policy makers to share organic and sustainable agriculture information from a farmer perspective. I have attended two NOSB meetings and presented on behalf of OCIA International. At that time, I was a Board member and served one year as President of the Board. From 1997 - 2003, I was Program Manager for the Sustainable Farm Association of MN. From 2004 - 2016, I was Chair for the MN OCIA Chapter's Education Committee. I have also served on the MISA Certification Board of Directors and have participated on the Land Stewardship's Federal Farm Policy Committee.



Linley Dixon, Adobe House Farm, Durango, CO

Bio/Statement: Starting on rented land, over the past 10 years, our family has worked hard to build our farm business and finally purchase a farm on which we can live and continue to grow. This experience has exposed me to the challenges new organic farmers face to get started and succeed. I have a Masters in Plant and Soil Science and a PhD in Plant Pathology. My hope is that OFA can help ensure that USDA organic standards and enforcement continues to represent the values of the organic community and the way the vast majority of us farm, that is with the responsibility to maintain healthy soil and pasture. For the past ten years, we have farmed 3 acres of vegetables intensively in Durango, CO, with a prime focus on soil health. We direct market to local restaurants, SWFF Local Distribution Cooperative, James Ranch, and the Durango Farmers Market. Our specialties are soil-grown greenhouse tomatoes, salad greens, peppers and strawberries. Daily operations are managed by my husband, Peter Dixon, and brother, Reid Smith. I am the associate director of the Real Organic Project by day and tomato pruner extraordinaire by night.


Montana Organic Association (MOA): Becky Weed, Board of Directors, MT

Bio/Statement: Montana Organic Association currently serves on the OFA Governing Council and will serve another term. Becky currently represents Montana Organic Association on the Governing Council and would like to serve another two-year term. Since 2002, The Montana Organic Association has been the voice of Montana's organic community. MOA believes that the organic movement is the one best hope for keeping small family farms viable while providing clean, nutritious, and safe food to the community; helping secure our food system by supporting farm diversity; and contributing to a healthier environment which helps protect our precious wildlife and natural resources. MOA's mission is to advocate and promote organic agriculture for the highest good of the people, the environment and the state's economy.

Becky Weed and her husband Dave Tyler have owned and operated Thirteen Mile Farm in Southwest Montana for thirty years (certified since 1999). They primarily run a certified organic grassfed sheep flock, although their operation has included a wool processing mill (2003-2017), as well as grassfed organic cattle and small-scale commercial vegetables intermittently. One of Becky’s employees is purchasing and continuing the wool mill, opening up time for Becky to return her focus more fully to her land, integrating crops and livestock, and to agriculture more broadly. Becky has served on the Montana Board of Livestock, and the boards of the Wild Farm Alliance, People and Carnivores, and has recently joined the board of the Montana Organic Association. She also served on the Conservation & Science Board of a very large ranch operation in Central Idaho, Lava Lake Land & Livestock, continuing her lifelong interest in the interface of agriculture and conservation. Before becoming involved in agriculture, Becky worked for more than ten years as a geologist with degrees in the Geological Sciences from Harvard (B.A.) and University of Maine (M.S.). That mixed background in research in some of the wildest places on earth, along with hazardous waste cleanup in some extremely urban locations continue to influence Becky’s perceptions and hopes for agriculture.


Nathaniel Powell-Palm, Cold Springs Organics, Bozeman, MT

Bio/Statement: I am a certified organic grain and beef cattle producer located in Bozeman, MT. As a first-generation farmer and rancher, I started my operation in 2004 and received organic certification in 2008. From my original leased 10 acres in 2004 my operation today consists of 875 acres on which I produce organic small grains and grass finished beef cattle. In addition to my farm, I work as an IOIA trained independent organic inspector. Currently contracted with 6 Accredited Certifying Agencies, I inspect approximately 225 operations per year. I have inspected organic operations to the NOP standard in 36 states for all three scopes (crops, livestock, and processing). I hold a BS in Environmental Science, with a focus on soil and water resources from Montana State University. My training as an agronomy researcher and my research history in soil chemistry has allowed me to hone a strong analytical skill set directly related to organic production agriculture. I believe my 9 years as a certified organic beef and grain producer has equipped me with significant technical expertise in organic production. My experience as an organic inspector has allowed me to examine operations and listen to the concerns of organic producers in every region of the country. If selected to serve on the Governing Council, I would bring both my expertise as a producer and broad experience as an organic inspector to my work with the OFA. Lastly, as a young farmer, I have experienced firsthand the challenges of starting a successful farming business and have spent most of my time farming certified organic. As the organic production community expands to include more and more young growers, I will bring a viewpoint and understanding to my work with the OFA that will align closely with a quick growing sector of the industry.


Tilth Alliance: Melissa Spear, Executive Director, WA

Bio/Statement: Tilth Alliance works in community with Washington's farmers, gardeners and eaters for a more sustainable, healthy and equitable food future. Our strategic priorities include advancing organic, regenerative, and sustainable growing practices, to increase demand for healthy food grown in Washington using organic, regenerative and sustainable growing practices, and to raise awareness of the critical relationship between food production and climate change. Our membership base is composed primarily of certified organic farmers. We serve our base through advocacy at the state and county level, by providing training opportunities, by directly connecting organic farmers to consumers through the Washington Farm and Food Finder, and by producing an annual conference where organic farmers from Washington can convene to learn, network and socialize.

Melissa Spear has worked at the intersection of conservation and agriculture for the past 15 years. She started out at The Trust for Public Land, successfully protecting several iconic farms in Connecticut. She then spent 9 years as Executive Director of a non-profit organic urban farm and environmental education center serving the city of New Haven, CT. She served as the vice-chair of the Working Lands Alliance in Connecticut, an advocacy organization working to ensure farming remained a viable enterprise in the state. She moved to Seattle and became Executive Director of Tilth Alliance in 2018 where her focus is squarely on promoting and supporting the adoption of organic practices. Under her leadership, Tilth Alliance is leading the formation of a Coalition for Organic and Regenerative Agriculture that will advocate for organic farmers and farming practices both here in Washington and in Washington D.C.



Shawn Peebles, Shawn Peebles Organic Farm LLC, Augusta, AR

Bio/Statement: Our farm is solely organic. I am a third-generation farmer. I started farming early with my dad and branched out on my own about 20 years ago. I switched to organic farming in 2009. We farm approximately 1500 acres. We grow sweet potatoes, edamame, black eye peas, soybeans, and corn. We find it exciting to find new crops to grow and diversify more each year. I handle some of each aspect that goes into a farming operation. I am hands on and fully involved in each decision that goes into the operation. I am currently serving on the USDA's Specialty Crop Committee. I have also served on a dicamba specialty task force. I enjoy speaking at meetings and conventions to share my knowledge and experience with others. I think organic farming is the future and want to see it grow. I will stand tall for my beliefs and advocate for what I believe in.

Southern Region: POLICY COMMITTEE 

Laura Freeman, Mt. Folly Farm, Winchester, KY

Bio/Statement: I own and run Mt. Folly Farm. Mt. Folly includes 1250 acres of pasture, timber, and crop land. About 70% of our crop and hay land is certified organic, making 290 organic acres and one organic high tunnel. I own and run the farm and have since 1982. I am also currently working to certify our cattle. I am also a climate change activist and farm entrepreneur, especially focused on hemp and heritage grains. Our farm is located in Kentucky, which has a nascent organic farming movement, so we are early adopters. Our core group is under 40, representing the future of farming. We are spreading the value of organics in the region by hosting multiple field days each year and connecting with our elected officials--introducing them to organic farming.


Carolina Farm Stewardship Association: Roland McReynolds, Executive Director, NC

Bio/Statement: The Carolina Farm Stewardship Association (CFSA) is a farmer-driven, membership-based 501(c)(3) non-profit organization that helps people in North and South Carolina grow and eat local, organic food by advocating for fair farm and food policies, building systems that family farms need to thrive, and educating communities about local, organic agriculture. Founded in 1979, CFSA is the oldest and largest sustainable agriculture organization in the Southeast. We provide training and technical assistance to farmers on organic farming practices, including: consulting on organic high tunnel production of specialty crops; providing NRCS TSP services for farmers seeking CAP-138 plans (supporting organic transition); hosting numerous workshops throughout the year; running the only organic certified incubator farm in the Southeast, Lomax Farm in Concord, NC; conducting research on organic vegetable production practices at Lomax Farm and other farms; and hosting two annual conferences for organic farmers. We also conduct extensive policy advocacy on issues of importance to organic farmers in North and South Carolina, at the state and federal levels.

Roland Reynolds is an attorney and has served as the Executive Director of the Carolina Farm Stewardship Association (CFSA) for almost 14 years. His experience in the areas of environmental and agricultural law gives him a thorough understanding of the regulatory issues related to natural resource conservation in agriculture. He has led CFSA’s government relations activities on behalf of sustainable agriculture stakeholders, served on a variety of state and national boards and committees, and provided information to state and federal elected and administrative officials. In his work on the USDA’s Fruit & Vegetable Industry Advisory Committee, Reynolds led the committee to unanimously call for increased USDA funding for public plant breeding programs, which is a high priority of the organic community. He is effective at resolving conflicts; influencing government agencies, businesses and industry organizations; and establishing and strengthening working relationships with outside entities. Reynolds has built bridges with ‘conventional’ farmers and farm organizations, and has strengthened CFSA’s relationships with colleges and land grant universities in the Carolinas, serving on a number of departmental and college-level advisory boards and helping those institutions better serve the region’s organic producers and the goals of environmental stewardship in agriculture.


Northeast Region: GOVERNING COUNCIL 

Eve Kaplan-Walbrecht, Garden of Eve Organic Farm & Market, Riverhead, NY

Bio/Statement: Eve Kaplan-Walbrecht and her husband Chris founded Garden of Eve organic farm in 2001, dedicated to providing delicious organic vegetables, fruits and beautiful flowers and to “making changes in the world by living them.” Invited to sell some extra produce from their garden (zucchini!) at a local farmers market they made $40 and were launched on their farming career. In the 20 years since then, they have expanded and now grow 60 acres of certified organic vegetables, flowers, raise 1500 pastured laying hens, and oversee a team of 20 at the height of the season. Garden of Eve sells produce through a large on-farm Market, 3 farmers markets, and nearly 1,000 households participating in their Community Supported Agriculture (CSA) programs at 20 locations in New York City and on Long Island. Eve holds a BA from Harvard in Environmental Science and a MS in Conservation Biology and Sustainable Development from the University of Wisconsin, Madison. She has also worked as a land preservation advocate with the North Fork Environmental Council and as Principal Planner for the Town of Southampton. In Eve's over 20 years of operating a family-scale organic farm, She has been constantly challenged to overcome the innumerable challenges that farmers face, as well as the ways that the chemical farming industry overrides the interests of real farmers in national policy. She is a longtime supporter of several OG watchdog groups and has seen how "Big Food" continues to try to water down the organic standards that the rest of us work so hard to uphold. She is well qualified for the OFA Governing Council with her skills in advocacy and lobbying, through her longtime involvement in land planning and farmland preservation on the North Fork of Long Island. She has worked with groups both inside and outside of local government to help secure the preservation of large tracts of vulnerable land including what became the Hallock State Park; North Fork County Park, and farmland that has now been preserved for perpetuity through Purchase of Development Rights.


Northeast Organic Dairy Producers Alliance: Edward Maltby, Executive Director, Deerfield, MA

Bio/Statement: Ed Maltby served on the founding OFA Steering Committee and Advisory Committee. NODPA started in 2001 and is the largest grassroots organization of organic dairy producers. It has remained true to its original goal of advocating on behalf of producers, regardless of who they sell their milk to, for a sustainable pay price plus protect the integrity of the USDA Organic regulations. NODPA is governed by organic dairy producers who meet regularly by conference call and annually in-person as either Board members or State Representatives. NODPA has a very active and committed Board and team of State Representatives that work together with NODPA staff to fulfill the mission of the organization. NODPA Bylaws protect the integrity of the organization and ensure that organic dairy producers control the association rather than any one brand, advocacy group or individual. NODPA represents organic dairy producers in the east of the country and has an active involvement with its sister organizations in the Midwest and the west which ensures that it can always remain connected to and controlled by its members.

Ed Maltby is a producer with over 45 years of experience managing conventional and organic dairy, beef, sheep and vegetable enterprises on a variety of different farms in Europe and the United States. For the past 20 years, Ed has worked with regional farms to cooperatively market their products into mainstream markets, ranging from direct marketing of lambs and organic produce, to establishing a cooperative of dairy farmers who direct market their own brand of milk in Western Massachusetts. Since 2005, Ed has worked as Executive Director of NODPA. He also developed a national umbrella organization, Federation of Organic Dairy Farmers (FOOD Farmers), to provide a national voice for organic dairy family farms. Ed served on the USDA Dairy Industry Advisory Committee to advise the Secretary of Agriculture on dairy policy. In 2006 when one of the last two remaining USDA slaughterhouses in MA was destroyed by fire, Ed worked with the family-owned Adams Farm Slaughterhouse to rebuild. The plant opened in November 2008 and in March 2009 Ed was asked to provide management assistance which later turned into a contract as General Manager.

Northeast Region: POLICY COMMITTEE 

Luke Gianforte, Gianforte Farm LLC, Cazenovia NY

Bio/Statement:  Gianforte Farm has been certified organic since 1998 and currently operates 600 acres of grains and row crops in Upstate New York. The farm currently grows small grains for the food grade market as well as corn, soybeans, and dry beans. I returned to the farm in 2014 after graduating from Cornell University and serve as the managing partner. Since returning to the farm, I have focused on adopting new technology relevant to organic agriculture and developing new markets for the farm's products. In 2016, Gianforte Farm won the Conservation Farm of the Year through the Madison County Soil and Water Conservation District.

I was raised on my family's farm that started transiting to organic when I was five years old. I always had a deep passion for agriculture and knew I wanted to be a farmer. After high school I attend Cornell University where I had the chance to visit and learn about all types of farms all over the world. After graduation I returned home to the farm full time. I have been active in the local agricultural community through serving on the FSA County Committee and on the board of a non-profit which serves the refugee community through agriculture. I am also currently in the LEAD-NY agricultural leadership development program which has already proven to be a strong networking and personal development opportunity. As a young farmer I believe it is critical to be actively involved in the conversations regarding agricultural practices and policy decisions, especially when it comes to the Organic program. Agriculture is constantly changing, and as organic producers we need to ensure the intentions of the Organic label remain sound while continuing to move forward. Consumers are facing more food choices than ever before, making it more critical than ever to preserve the meaning of the Organic label.

Bringing Equity to Organic

November 2020

National Organic Standards Board member and First Nations leader examines how certifying Grower Groups, and other changes, could increase both black, indigenous, and people of color farmers and consumers

By A-dae Romero-Briones        Photographs by Joan Cusick Photography

Tribal Nations have grown food systems for millennia. In deserts. Along coastal and inland waterways. In low mountains. In high mountains. And in some of our most fertile and infertile lands across this country. Today, despite massive loss of land (which, ironically, some of which is certified organic farmland now), loss of animal and plant diversity, and limitations on access to traditional hunting and gathering grounds—Indigenous people continue to grow their food systems. And yet, we see few in the organic community. According to the Union of Concerned Scientists, Black, Indigenous, and other people of color makeup nearly one-quarter of the population—but operate only 5% of farms nationwide. The USDA’s organic integrity database, with approximately 19,400 U.S. farm certifications, lists less than ten Tribal farm organic certifications. In the 2012 Agricultural census, 95.42% of all organic farms were white-owned and operated. Presently, we see the disruptions of societal institutions that have been created or implemented to serve primarily the white community, and so we should also evaluate who the organic community is serving and how.

Admittedly, the organic community is but a small part of a larger national, and global, food system that has insidious roots in the exploitation of BIPOC communities—Black, Brown, and Indigenous with little distinction. In 2020, we should be well aware of those historical wrongs, or at the very least, be observing the mass protests and toppling of historical markers that glorify these wrongs, essentially creating a status quo that serves but a fraction of our society. In many ways, the organic movement has always challenged the establishment. The organic movement has deep roots in combating extractive capitalism and corporate domination of our food system, lands, and rural community. We are the people’s food system; the alternative to chemical farming and mass production that leads to exploitative practice. In the organic community, we do purport to know and do better, be more responsive, be more inclusive and better food (and lifestyle) choice for consumers and society. But are we?

First, when I speak of organic, I am referring to the little green label that designates a product as grown and produced according to practices sanctioned under the USDA National Organic Program. To many in the organic community, organics is much more than that. It is a lifestyle. It is a promise and a representation of what our food world should be. While I agree we are much more than our labels, it is clear we are limited by them. As much as we want to extend our organic relationship to society, it is in fact a market—subject to market forces, communicates (and deviates) through price variations, and is regulated (protected by those within the market and government actors who recognize the market).  The limitations and weaknesses of our capitalist markets are embodied even in organics. We are only as strong as our roots—which in the organic case includes exploitation, exclusion, and an undercurrent of hyper-individualism. All markers of the dominant American retail food system.

In accordance with market values, organic certification is aimed at individual landowners. In dominant food systems, this individual landownership is extended to corporations recognized as persons. Even the most basic of understandings of agriculture and food systems begins with inequality—land ownership. Discussions in the organic world revolve around the practices of individual farmers, their certifications and inspections, and their place in the organic marketplace.

From 2012 to 2014, white people comprised over 97 percent of non-farming landowners, 96 percent of owner-operators, and 86 percent of tenant operators. They also generated 98 percent of all farm-related income from land ownership and 97 percent of the income that comes from operating farms. Organic farming is almost a mirror reflection of the mainstream food system in organic farm ownership and operation. As a result, conversations in the organic community are centered on the understandings of white landowners and their understandings of their landholdings, farming practices, and an anthropocentric worldview. Yet, human dominion over land is the pedagogical base that is failing us and our environment. How do we become an organic community that is inclusive, responsive, and in a better relationship with our environment, given the limitation of capitalism?

In the organic world, we often think about our food system in binary conversations—organic agriculture and conventional agriculture. Yet, there are many communities, people, consumers, and producers, who are systematically omitted from each of those conversations, intentionally and unintentionally.

On the consumer side, there are conflicting studies on who eats more organic food. But, in a study of organic consumers, the Economic Research Service of the USDA reported that African American households are less likely than Caucasian households to buy organic. Additionally, one of the primary consumer considerations in the purchase of organic products was the percentage of household income spent on food. Households with lower incomes were least likely to buy organic products. Considering that many federal feeding programs, such as the commodity supplemental food program which serves seniors, the WIC Program (Women, Infant and Children), or the summer lunch program, serve households with lower incomes, organic produce should be offered in these programs allowing access to households with lower incomes. Currently, organic products are not eligible for federal procurement in many institutional programs, effectively excluding access to the organic community by virtue of income—often excluding Black, Brown, or Indigenous people. In short, organic consumer is most likely white.

When we think about what is required for organic certification—from the certificates that give an individual person dominion over their plot of land, to the application for paperwork that begins the process of certification, to the markets where these products are sold, and even the consumer who seeks out the little green seal at that market—we are operating in a food supply chain that is leaving out large groups of people in this country and serves a privileged few. I count myself as one of those privileged. How can we change this? How do we increase the number of Black, Brown, and Indigenous organic producers and consumers? Perhaps, most importantly, why is this important?

One, the organic community has its roots in challenging the status quo. Without the will and breadth of organic leaders like J.I. Rodale challenging nationally accepted industrial production systems, and many others who lend their time and fight for organic, we would not have an alternative to corporate agriculture. Imagine lending that same fight and passion to challenging the tenure, thereby, roots of the anthropocentric agriculture altogether. This means lending time and passion to critically examining land ownership, its benefits to both conventional and organic agriculture, and the continued exclusion of Indigenous, Brown, and Black people owning land. In conversation with a farmer in Appalachia, she said, “If you only hang out with people who agree with you, you’re never going to grow as a person or a farmer.” Similarly, if we are a nation or community of white landowners we can’t really expect for organic agriculture to reach more than just our small community of organic advocates.

Second, infrastructure directed at marginalized communities is needed to participate in our existing organic system. Grower group certification (included in the most recent USDA rule, Strengthening Organic Enforcement) would create a path to infrastructure development for not only many Indigenous/Tribal growers but for marginalized small-scale growers. Grower groups are meant to create centralized management, marketing, and inspection systems for smaller groups of growers that have geographic proximity and uniformity of product. Appalachian Harvest, based in Duffield, Virginia, is one of the only certified organic growing groups in the United States. With no prohibition on grower group certification within the U.S., domestic organic certifiers site lack of guidance on applicability to livestock or produce, limitations of the number of growers within the group, and inspection expectation of grower members as some of the reasons there is a reluctance to certify grower groups. A focus or willingness from one certifier to embark on more grower group certification in the United States could carry this conversation and certification into marginalized communities—expanding the reach, and hopefully, diversity of organic growers. The conversations and infrastructure development in marginalized communities with producers is not easy, but then again, those who find themselves in the organic community understand any action worth undertaking takes care, time, and a whole lot of work.

It is these values that have called us all in some way to improve our homes, our bodies, and our relationships through the organic movement. We constantly argue for the betterment of the land, biodiversity, and community (microbial, animal, and human). While we want to talk about the microbial communities that make up healthy soil and determine what chemicals are weakening and killing the beneficial communities, we are shy to talk about who ultimately owns the land, how those land deeds begin in the first place, and why the organic community remains largely white. If we value biodiversity, we should be a reflection of that in our own meetings and conversations, in our own certified operations, and human community. If we want to expand the reach and breadth of the organic movement, we must start by including those who have been systematically left out.

A-dae Romero- Briones (Kiowa/Cochiti), JD, LLM was born and raised in Cochiti Pueblo, New Mexico and comes from the Ware Family from Hog Creek, Oklahoma on the Kiowa side. Mrs. Romero-Briones works as Director of Programs-Native food and Agricultural Program for First Nations Development Institute.


Dettman, Rachel (2008). Organic Produce and Who is Eating it? A Demographic Profile of the Organic Consumer. Can be accessed here: file:///C:/Users/abriones/Downloads/467595.pdf
Horst, Megan (2019). How Racism Has Shaped the US Farming Landscape. Can be accessed here:
Union of Concerned Scientists (USC) and HEAL Food Alliance (2020). Leveling the Fields: Creating Farming Opportunities for Black People, Indigenous People and Other People of Color.

This article was written for New Farm Magazine, the magazine of the Organic Farmers Association.  All OFA Members receive a complimentary issue of New Farm annually.  Join Today!

November Policy Update

By, Patty Lovera, Policy Director

November 2020

Election 2020: What It Means for Organic

It probably shouldn’t surprise us that in 2020, like everything else, the election did not follow the normal routine. While there are still some results that are not yet clear and some ongoing recounts, as of the afternoon on November 11th, here is what we know so far about the what the election means for organic policy.

Transition to a Biden Administration – It looks likely that in 2021 we will be dealing with a Biden administration. Which means that many jobs at USDA will be filled with new people that influence the organic program, including the Secretary of Agriculture, the Under Secretary of Marketing and Regulatory Affairs, and the Administrator of the Agricultural Marketing Service. It will likely be later in the fall before we know for sure who the new administration is nominating for these roles. But there will be lots of scuttlebutt and speculation about potential choices leading up to the actual announcements.

The OFA policy committee is drafting a list of recommendations to the “transition team” being assembled to guide the new administration’s arrival at the USDA. We will urge them to prioritize enforcement of existing organic standards (and oversight of how certifiers interpret the standards) and finishing up the regulations we need to make the standards better, including the Origin of Organic Livestock (OOL) rule, the Organic Livestock and Poultry Practices (OLPP) rule, and the Strengthening Organic Enforcement (SOE) rule.

Transition to a New Congress – There will be a lot of changes for agriculture in the new Congress. In the House, Rep. Collin Peterson (D-MN), the long-running top Democrat on the House Agriculture Committee, lost his race for reelection. That means we will have a different chair of the House Agriculture Committee next year. The top contenders at this point are Rep. Marcia Fudge (D-OH), Rep. Jim Costa (D-CA), and Rep. David Scott (D-GA). The top Republican on the committee will also be changing because the current ranking member Rep. Conaway (R-TX) is retiring at the end of this Congress. The contenders for ranking member are Rep. G.T. Thompson (R-PA), Rep. Austin Scott (R-GA), and Rep. Crawford (R-AR.) We should know more about the leadership of the House Agriculture Committee later in the year. First, the members of the House caucuses (Democrats and Republicans) will hold leadership elections in mid-November. Committee chairs and membership of committees will start to shake out after those leadership elections.

We may need to wait longer to know who will control things on the Senate side. Two open Senate seats in Georgia will go to a runoff election in January (because no candidate exceeded 50 percent of the vote.)  The outcome of these races will determine which party controls the Senate (and therefore which party chairs committees.) Both parties will likely prepare their lists of who will serve on and chair committees, but it may take longer to be official if we need to wait for those runoff elections to determine the control of the Senate. If the Democrats control the Senate, it is expected that Sen. Stabenow (D-MI) will be the chair. Because Sen. Roberts (R-KS), the current chair, is retiring at the end of this Congress, there will be a change in the top Republican on the committee, most likely Sen. Boozman (R-AR).

National Organic Standards Board Fall Meeting

The USDA’s National Organic Standards Board held its fall meeting online during the last week of October. The meeting had a very ambitious agenda and the board took over 70 votes, primarily about whether specific materials would be allowed for use by organic operations. The transcript and list of votes from the meeting will eventually be posted on USDA’s website here.  Here are a couple of highlights:

Paper Pots:  The board has for several meetings discussed paper-based crop planting aids, which includes paper pots as well as seed tape and other paper-based products like cloches. Many farmers have urged the board to figure out a way to set standards for paper pots that allow them to continue to be used by organic farms, while addressing concerns about the source of paper and the chemical components of adhesives. In our comments, OFA urged the board to move forward with a recommendation to allow paper pots. The board discussed a proposal from the crops subcommittee and voted to send the proposal back to the subcommittee for more work to address concerns about whether new requirements for the source of the paper and adhesive will be feasible for materials reviewers to evaluate. The board does seem to understand that many small farms depend on paper pots and is working to craft a recommendation that will set clear standards that will allow them to continue to be used.

Fenbendazole: The board considered a proposal to allow the emergency use of a parasiticide called fenbendazole for laying hens. In our comments, OFA urged the board not to approve this recommendation, based on concerns about residue levels remaining in the eggs laid by treated hens, the absence of a clear definition of what defines an emergency, and how allowing this drug is compatible with good management practices that provide adequate outdoor access for birds. The board had a robust discussion about this drug and ultimately voted against allowing it for emergency use in laying hens.

Ammonia Extract: Another hot topic was ammonia extract. The board was considering a petition seeking a prohibition on non-synthetic ammonia extract. Both synthetic and naturally-derived (non-synthetic) forms of ammonia can be used as a nitrogen fertilizer, and while synthetic ammonia is prohibited for organic use, non-synthetic sources of ammonia are not explicitly prohibited by the organic regulations. The petition expressed concerns about the impact of ammonia extracts on soil health and suggested that it was not feasible to determine whether ammonia extracts were derived from synthetic (prohibited) or non-synthetic (not explicitly prohibited) processes. This topic received a lot of discussion, during both public comments and the board meeting, covering soil health and the various production processes for ammonia extract. We would like to hear from OFA members about whether they use ammonia extract on their operations. You can weigh in on our 2021 policy priorities survey here.

EPA List 4 “Inert” Ingredients: Another complicated topic the board tackled is how the organic standards should treat the synthetic ingredients contained in many organic inputs -- commonly referred to as “inert” ingredients. So-called “inert” ingredients are not typically disclosed on product labels and are added to provide some function or improved effectiveness for the active ingredients in a formulation – such as chemicals added to pesticides to make them more soluble or extend their shelf-life. The problem is that the organic standards have relied on a list from the Environmental Protection Agency (EPA) to determine which of these ingredients were allowed in formulations approved for organic. But the EPA stopped maintaining this list in 2004 and there are growing concerns that some of the chemicals on this list are more hazardous than previously known. Many organic certifiers and others have raised concerns that prohibiting these ingredients without an orderly process to identify replacements will abruptly remove product formulations currently being used by organic operations. The board members and the NOP staff had a very detailed and thoughtful discussion about this issue, and there is widespread agreement that there is an urgent need to find a new process to review and approve these materials without disrupting organic operations. The board did approve relisting this list of materials as allowed synthetics for 5 more years (through the sunset review process). But they also passed a resolution urging the NOP to come up with a new system for evaluating these materials in a way that addresses health concerns but also minimizes disruption for organic operations.

Origin of Organic Livestock Rule

Unfortunately, another update at the NOSB meeting delivered some very frustrating news about the status of the long-delayed origin of organic livestock rulemaking. Earlier this summer, the National Organic Program missed a deadline set by Congress to finalize a rule about how livestock are transitioned into organic production. Congress set a deadline of mid-June for NOP to finish this rule in the 2020 appropriations (spending) bill for USDA.

Unfortunately, the NOP not only failed to meet that deadline, but explained that they believe there are significant problems with the proposed rule they have been working on since 2015 that need to be addressed before they can finish it. At the NOSB meeting in late October, NOP announced that they plan to write a new proposed rule, rather than adapt the 2015 version.

OFA is going to continue to push NOP to finish this process as quickly – but completely – as possible. We need an origin of livestock rule which the agency actually enforces, to create a level playing field for all organic dairy producers and close the loopholes in existing regulations that are being exploited by large operations.

Organic Certification Cost-Share

OFA continues to advocate for restoring the funding for the organic certification cost-share program. This summer, the USDA’s Farm Service Agency (FSA) announced that due to an unexpected shortfall in funding they were lowering the reimbursement rate to 50 percent of the certified organic operation’s eligible expenses, up to a maximum of $500 per scope. This is reduced from a rate of 75 percent of the certified organic operation’s eligible expenses, up to a maximum of $750 per scope in previous years (and the level that was specified for this program in the last Farm Bill.)

Congress’ failure to pass new spending bills on time (the new fiscal year for the federal government started on October 1st) means that the federal government is currently running under an extension of last year’s budget. This makes it more complicated to quickly get Congress to provide more funding for the cost-share program. But we are going to keep working to try to get the reimbursement level restored. In the meantime, it does help for members of Congress to hear from organic farmers about why the cost share program is important. You can find out how to take action on cost-share here.

Covid-19 Program – December Deadline

On September 21st, the USDA started accepting applications for the second round of the Coronavirus Food Assistance Program (CFAP), which is the program to give direct payments to farms impacted by the pandemic. This round has different rules for which crops and farms are eligible for payments, which are an improvement over the first round (which did not really address the needs of most organic farmers.) We have more detail on the second round of CFAP here. The application period ends on December 11th. Even if the first round did not make sense for your farm, it may be worth it to check out the new requirements to see if this new round is a better fit.