Hi Isaac:

I clicked on the link you provided in your comment, and it took me to a web site where you can pay someone to write an essay for you. I don’t really understand what you are trying to say. Do you think I have poor writing skills and need the help of this service you are recommending?

Thanks,
Matt Miller

I am very concerned about how the proposed animal welfare regulations will affect organic farmers here in Iowa. My concerns are as follows:

1. The additional paperwork and inspection requirements. There are many wonderful aspects of organic farming, but the required paperwork is something that nearly everyone dreads. These proposed regulations are very prescriptive, and the documentation required to verify that they are being met will be quite burdensome. Not only will it be lots more work for the farmer, but the certification program and inspector will have a lot more work to do. This means considerably higher certification and inspection costs. The AMS is estimating inspection time to increase by 30%. This means each inspector will not be able to do as many inspections. More organic inspectors will need to be attracted to this field of work. Higher pay rates will be needed to accomplish this. The end result will be more hours of inspection time and a higher billing rate per hour.

2. There are already animal welfare certification programs that have been developed. The standards are not consistent between the various animal welfare certifications. There is debate about whose program is best. I don’t think it is necessary to try to reinvent something that is already available to organic farmers if they want it. General animal welfare standards are already part of the organic regulation. By adding more extensive and prescriptive standards, there will be increased debate about the details, just like there is debate between the various animal welfare programs that exist already. Cornucopia has already labeled the NOP proposed animal welfare program as a “hodgepodge.”

3. In the research material provided in the Federal Register, it states that, “AMS estimates that up to 90 percent of organic aviaries may transition to cage-free egg production due to marketing opportunities and challenges of complying with the outdoor space requirements.” Therefore, AMS “project[s] that this production, which accounts for 45 percent of organic egg production, would likely transition to the cage-free egg market.” This impacts organic farming in Iowa. Iowa is among the top 5 states in organic egg production. Iowa leads all states in the production of organic corn and organic soybeans which are the two main ingredients in organic poultry feed. Poultry is the largest consumer of organic corn and soybean meal. Significantly less organic poultry will decrease the demand for organic corn and organic soybeans. These market forces will translate into fewer acres under organic management in the state of Iowa. This is bad for Iowa’s environment, bad for rural communities, and takes away opportunities for young and beginning farmers.

4. The material provided in the Federal Register also states that the retail prices for organic milk, poultry, meat, and eggs will need to increase in order for producers to pay for the extra expenses required to comply with the new regulation. This is not good for consumers as it will now be less affordable to purchase organic food. Some organic products already have animal welfare certifications, so consumers have the choice to purchase these products already.

Those are some of my general thoughts. I would like to know what you think. IOA is planning to post a comment on these regulations. We encourage you to post your comments too.