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I am submitting this comment on behalf of
According to our "virtual" 2021 listening session, the most widely held concern among family-scale farmers in
As the industrial dairy industry grows, family-scale farms are displaced in favor of mega-dairies that house thousands of cows in confined spaces and create outsized climate impacts.
Instead of promoting factory farming schemes, we urge
1. Support family-scale regenerative farming systems and practices that improve soil health and carbon sequestration.
2. Restore the Organic Livestock and Poultry Practices (OLPP).
The integrity of organic standards is of utmost concern. The Organic Livestock and Poultry Practices rule is critical to maintain the integrity of the National Organic Program by ensuring that all organic producers are held to the same set of basic standards. The rule's removal undermines legitimate efforts to leverage organic agriculture as a climate-smart farming approach. We urge
3. Encourage a shift away from factory farming and the false promises of biogas, toward regenerative, family-scale farms.
As mentioned above, the toll of mega-dairies on the rural economy is significant.
Now more than ever,
Unlike these mega-dairies, independent, family-scale dairy farms allow cows to graze on pasture and do not maintain dangerous quantities of liquid waste that then must be disposed of. These operations also do not use large manure lagoons that increase methane production.
4. End subsidies to chemical-intensive commodity crops.
The range of direct and indirect public supports for the largest, most intensive and environmentally destructive farming operations is a key contributor to the false dichotomy of "cheap" food that isn't actually cheap if the environmental and other externalities were accounted for. Climate-resilient agriculture efforts should serve to shift public support to biodiverse, sustainably-grown foods.
5. Level the playing field for small farmers.
Public policy and financial support for agriculture in
Right-to-farm laws rarely help the small organic farmer. We strongly believe that a family-farm centered system, with more farmers on the land, is best suited to revitalize rural communities, produce a healthy and sustainable food supply and respond to climate change. We urge
Equitable implementation will require that
Amy M Wong
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The notice can be viewed at: https://www.regulations.gov/document/USDA-2021-0003-0001
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