In some cases, a narrow, grassless strip outside the vast barns where the animals were kept was considered "pasture" because some hay had been spread there. In addition, National Organic Standard Board (NOSB) regulations that allowed companies to keep cows and their very young calves indoors for a short period after birth were twisted to include all milking cows being kept inside 24/7 for 310 days a year.

Just take a quick glance at these photographs from Cornucopia and draw your own conclusions about whether this method of farming looks organic.

Either through bureaucratic lassitude or willful neglect, USDA officials helped the big producers every step of the way. "Between 2000 and 2008, they basically sat back and did nothing," Kastel said in an interview.

Well, maybe not exactly nothing. After being prodded by Cornucopia, the USDA finally declared that the Aurora Dairy Corp. of Boulder, Colorado, which milked as many as 19,000 cows, was in "willful" violation of 14 tenets of the federal organic standards—the milk it was selling as organic was actually conventional. Aurora was allowed to modify its methods and continue selling milk that passes for "organic."

Naturally, the handful of huge CAFOs milking in excess of 2,000 cows each, with their economies of scale, drove down the price of organic milk and increased their share of the market to at least 30 percent. Combined with a drop in demand, it was a disaster for this country's nearly 2,000 family-operated organic dairies. These businesses typically tend between 60 and 100 milking cows and actually have pastures, and many of them had gone to the expense of converting to organic when the bottom fell out of the market for conventional milk. "Today we have small organic farmers going out of business all the time," Kastel said. He tells a tragic story of one desperate dairyman who went into his barn, shot all of his cows, and then committed suicide.

After years of official haggling, the USDA has finally produced a new set of regulations for organic milk production. The exact terms remain undisclosed, but Miles McEvoy, the newly appointed deputy administrator of the USDA's National Organic Program, has assured Kastel that the new rules will be in line with the understanding organic producers arrived at by consensus in the early 2000s. Milk cows will have to graze on pasture for the entire growing season, or for at least 120 days in areas of inclement weather, getting 30 percent of their food from pasture.

That ruling now awaits OMB approval. Both the Cornucopia Institute and the Organic Consumers Association have initiated write-in campaigns to persuade the administration to make sure organic dairy cows in this country continue to do what cows do best: convert fresh grass into wholesome milk. And guess who has also been lobbying hard to "sway the Obama administration," according to the Organic Consumers Association? None other than Aurora Dairy (whose chairman Mark Retzloff and his wife, Theresa, contributed $4,600 to the 2008 presidential campaign of Thomas Vilsack, the current head of the USDA, according to Campaignmoney.com). "That level of donor historically buys access," Kastel said.

He added, "Our biggest fear is that they will water this thing down. We're really at a watershed point. We've spent 10 years battling about this point. Now it's all up to the stroke of a pen."

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