Maine Organic Farmers and Gardeners Association
National Organic Program Proposed Pasture Rule

Publications \ The Maine Organic Farmer & Gardener \ Winter 2008-2009 \ Pasture Rule

by Diane Schivera, M.A.T.

The long awaited proposed pasture rule addition to the National Organic Program (NOP) was published on Oct. 24, 2008. Most of the 90-page document is a preamble giving the history, background and rationale for the proposed rule. The last two and a half pages are the actual proposed rule changes. Many places in the preamble ask for comments and ideas for corrections. The document is posted at here under the news for Oct. 24.

I attended a listening session about the rule during the Northeast Organic Dairy Producers Alliance Annual Field Days. Many organic dairy farmers from the Northeast were present, along with two from the West and one from the South; and representatives from NOFA-VT, Organic Valley and Horizon Organics.

Every person who commented prefaced any negative comment with a thank you to Richard Mathews, Chief, Standards Development and Review Branch of the NOP, for writing this proposed rule. Many just expressed gratitude that the rule was finally published. Mathews thanked folks for their positive reaction and was open to concerns. He frequently asked people to submit written comments and include possible wording, background or information relating to the concerns. Everyone was pleased with the 30% dry matter intake requirement during the pasture season, which the whole organic dairy industry wanted.

A few parts of the rule were considered possibly problematic. The most significant is that dairy cows must be on pasture 365 days each year, 24 hours each day, except for milking and other minor exceptions. This would be difficult if not impossible for dairies in the Northeast – especially in snow like Maine had last winter. Some of this can be managed with a “sacrifice pasture”: a pasture or pastures within the pasture system, of sufficient size to accommodate all animals in the herd without crowding, where animals are kept for short periods during saturated soil conditions to confine pasture damage to an area where potential environmental impacts can be controlled. This pasture is then deferred from grazing until it has been restored through active pasture management. Sacrificial pastures are located on soils that can tolerate a lot of traffic, are well-drained, have low risk of erosion, have low or no potential for manure runoff, are surrounded by vegetated areas, and are easily restored. A sacrificial pasture is land used for livestock grazing that is managed to provide feed value and maintain or improve soil, water and vegetative resources; it is not a dry lot or feedlot.

The other major concern is the use of 3% of body weight as the basis for the dry matter requirement for all ruminants in all stages of production. This is not a realistic assessment of the dry matter requirement. It will have to be adjusted for differences in type and age of ruminant and stage of production.

The listening session was recorded by a federal secretary and will be available at under the comment section. You can also submit comments by Dec. 23, 2008, using the process described in the beginning of the rule.

Diane Schivera is MOFGA’s organic livestock specialist. You can contact her at 568-4142 or

MOF&G Cover Winter 2008-2009
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