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The Honorable Thomas J. Vilsack 
Secretary, U.S. Department of Agriculture 
Jamie L. Whitten Building  
1400 Independence Avenue, SW  
Washington DC, 20250 
 
Docket: AMS-NOP-21-0073  
  
RE: National Organic Program; Organic Livestock and Poultry Standard Proposed Rule
Dear Secretary Vilsack, 

Thank you for the opportunity to provide feedback on the USDA National Organic Program’s proposed rule on Organic Livestock and Poultry Standards (OLPS). We strongly support this rule and your leadership in advancing animal welfare standards for organic livestock during your tenure at USDA spanning multiple administrations. Issuing a final rule on OLPS will improve animal health, strengthen consumer confidence in the organic label, and ensure clear, consistent, and enforceable regulations for the organic livestock sector. Requiring all certified organic livestock operations to meet the same standard will reduce competitive harm in the marketplace. 

The OLPS proposed rule will create clear standards for outdoor access for organic poultry, set minimum indoor and outdoor space requirements for poultry, and further clarify living conditions, healthcare, transportation, and slaughter practices to support animal welfare for all organic avian and mammalian livestock species. Most importantly, the rule will clarify that screened-in, enclosed porches do not qualify as sufficient outdoor space for organic poultry. This proposed rule is long overdue and reflects more than a decade of input from stakeholders, which is why we support a swift implementation timeline of no more than five years for currently certified operations to comply. 

Outdoor access has always been a core tenet of organic livestock production. The organic regulations require certified organic livestock farms and businesses to provide year-round access to the outdoors, shade, shelter, exercise areas, fresh air, clean drinking water and direct sunlight for all livestock. Producers are also required to create an environment that allows animals to express natural behaviors and implement preventative healthcare practices to reduce the likelihood of illness. In 2010, USDA issued a final rule that created clear standards for grazing and access to pasture for organic dairy and cattle. The OLPS rule further advances animal welfare by doing the same for organic poultry.  

The Organic Foods Production Act grants USDA authority to set federal standards for the production and handling of all organic products certified to the USDA Organic label in order to facilitate interstate commerce. As a voluntary regulatory program, having clear, consistent and enforceable standards is paramount for the organic sector to not only maintain consumer trust but to ensure that farms and businesses of all sizes have a fair shot of competing in the marketplace by meeting a minimum set of standards. We agree with USDA’s assertion that the lack of clarity on outdoor access requirements for organic poultry has created competitive harm and market failure for the organic egg sector. The OLPS proposed rule will create a more level playing field and expand market opportunities for organic dairy, meat, poultry, and eggs which make up 15% of the overall organic market with a current value of nearly $10 billion.
Lastly, finalizing the OLPS rule will help maintain consumer confidence and trust in the USDA Organic seal. Recent research commissioned by the Organic Trade Association shows that 75% of Americans are concerned about the treatment of animals by the meat and dairy industry. Animal welfare and outdoor access are core value propositions for organic shoppers, and they are willing to pay more for these benefits. 87% of consumers expect the organic standards to be updated to reflect evolving understandings about soil, climate, health, and animal welfare. The implementation of this rule is critical to reduce consumer confusion in the marketplace and increase consumer trust in organic. If consumers can’t feel confident that the organic eggs they purchase come from chickens that have access to pasture, they will continue to seek other third-party private certifications outside of organic and question the value of the organic label, harming the entire sector.  

Organic represents one of the fastest-growing food and farming sectors in the U.S. and global marketplace, reaching over $63 billion in U.S. annual sales. The benefits of organic are numerous. Organic provides economic opportunities for farmers, creating jobs and lifting rural economies, while also utilizing sustainable farming practices that are proven to help mitigate the threat of climate change. Organic provides a safe, healthy choice to consumers, who are increasingly seeking out the trusted USDA Organic seal on the food and products they purchase for their families. Again, we strongly support the Organic Livestock and Poultry Standards proposed rule and urge its swift implementation.

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