Pastured Poultry News

  • Tue, October 22, 2019 1:47 PM | Mike Badger

    Jacksonville, FL—Nathan Bonds, Lean Management expert will provide in-depth training at the Professional Pastured Poultry Conference in Jacksonville, FL on January 20-21, 2020. By leveraging the principles of Lean, Nathan will help farmers become more efficient, reduce waste, and improve quality across all phases of the farm.

    The systematic approach of Lean will provide customers the three things they want: quality, cost, and service.  Nathan says, “As farmers, we want to meet what our customers want, but we also want to lead them to what they need. Lean is about people. We’re going to focus on the people who focus on the process. It’s about our relationships.”

    Nathan will teach workshops on how to get started improving your processes and strategies for managing your labor force (employees) on the farm. He will also lead breakout discussions and be available as an expert resource on both days of the conference.

    Pat McNiff, Owner of Pat’s Pastured, says, “In only three days, Nathan helped us cut our daily labor moving chicken shelters by half when everyone thought it couldn’t be done.” Nathan’s consultation, methodical approach, and endless passion has been instrumental in the continuous and steadfast improvement of Pat’s Pastured, Maple Wind Farms, and other pastured poultry farms in New England.

    Nathan is a Project Manager with Polaris MEP, a Rhode Island organization that helps companies refine processes, build talent pipelines, and break into new markets. An article summarizing Nathan’s 2019 conference presentation can be read at this link. You can watch Nathan Bonds deliver his “Lean Tip of the Week” on YouTube.

    American Pastured Poultry Producers Association is a member-based trade organization advocating for pastured poultry through farmer specific resources and consumer education. Learn more about the 2020 Professional Pastured Poultry Conference.

    Direct questions to Mike Badger at or 888-662-7772.

  • Wed, October 09, 2019 6:30 AM | Anonymous

    Jacksonville, FL—American Pastured Poultry Producers Association (APPPA) welcomes Resaca Sun Feeds as the “Partner Sponsor” for the 2020 Professional Pastured Poultry Conference in Jacksonville, Florida, on January 19-21, 2020. Resaca Sun Feeds specializes in the production of high quality, pastured-raised poultry feeds using Non-GMO Project Verified ingredients. They are a family-owned feed mill located in Resaca, Georgia.

    Sponsors play a vital role in the Professional Pastured Poultry Conference by helping to create robust conference experiences at affordable registration prices and by providing attendees personal access to industry leaders. APPPA encourages all our sponsors to be involved with the conference programming as participants and contributors. The flexible and spontaneous nature of the conference facilitates a more natural engagement between supporting businesses and the farmer attendees.  

    Andrew Moore, third generation farmer and feed mill manager will lead a session on sourcing feed ingredients and working with feed mills in the “Profitable Pastured Poultry” pre-conference course (January 19, 2020).

    American Pastured Poultry Producers Association is a member-based trade organization advocating for pastured poultry through farmer specific resources and consumer education. For more information about the Professional Pastured Poultry Conference can be found at

    Additional sponsor and exhibitor opportunities remain open through December 1, 2019. Contact Mike Badger at or 888-662-7772 for additional information.

  • Tue, October 08, 2019 7:41 AM | Anonymous

    Jacksonville, FL—APPPA expects international attendance by pastured poultry farmers at the Professional Pastured Poultry Conference, scheduled for January 19-21, 2020, at the Lexington Hotel and Conference Center in Jacksonville, FL. The conference brings independent, family-owned pastured poultry farms together for three days of peer-to-peer learning opportunities. Conference organizers encourage attendees to bring their struggles and their success stories because there’s someone in the room who has solved your problem or needs your help.

    American Pastured Poultry Producers Association (APPPA) has been providing farmer education and networking opportunities to the community since 1997. As the pastured poultry community grew more experienced in the production, marketing, and processing segments, APPPA identified an unfilled need. Experienced community members needed advanced conference programming that went beyond the basic startup and the how-to information provided by the typical conference workshops. The Professional Pastured Poultry Conference fills that need.

    In 2017, the Professional Pastured Poultry Conference was launched in a rodeo arena in Hillsboro, Texas. Those two days flipped the conference script and made the attendees the keynote speakers as several dozen farmers discussed issues in real-time without a single PowerPoint. In 2020, the conference format is expanding to be welcoming and relevant to farmers at all scales and experience; however, spontaneous, attendee-led discussion remains the event’s signature attraction.

    American Pastured Poultry Producers Association is a member-based trade organization advocating for pastured poultry through farmer resources and consumer education. More information about the Professional Pastured Poultry Conference can be found at

    Contact Mike Badger at or 888-662-7772.

  • Mon, July 01, 2019 7:38 AM | Anonymous

    Washington joins California and Massachusetts by signing legislation that prohibits eggs from caged hens to be sold within the state. While the Washington law won't be fully enacted until 2023, American Pastured Poultry Producers Association (APPPA) would like to remind everyone that pasture-raised hens always lay cage-free eggs.

    Cage-free pasture-raised eggs are available now throughout the United States using our find-a-farmer directory.

    The clear message for egg producers is that as consumers become educated about industry practices, they reject many of the practices the industry markets as necessary. 

    (H/T Feedstuffs)

  • Fri, March 22, 2019 2:28 PM | Anonymous

    Image of pasture raised chickens at Pastured Life Farm in Florida.

    A recent news release announced the formation of a chicken company that claims to be the only company at scale to raise slower growing heirloom chickens in an integrated pasture-raised model. The American Pastured Poultry Producers Association (APPPA) would like to offer the poultry community a better understanding of what the current pastured poultry community looks like and what it really means to be pasture-raised.

    Pasture-Raised Chicken Is Movement Based

    To provide clarity, pasture-raised poultry describes a farming method that builds on the core idea of outdoor production and flock movement. The simplified version is that the chickens or turkeys are raised outside in portable shelters; the shelters and the flock are moved to fresh pasture regularly, allowing the previously grazed area to rest and regenerate.

    In modern chicken company marketing (and some third-party certifications), you will see terms like “outdoor access” or “access to pasture.” These phrases warn the consumer of a non-pasture raised method of production. Visual inspection provides the verification. If you see a fixed location confinement animal feeding operation (CAFO) style house with a few doors around the building opening into a small fenced in area, you’re not looking at a pastured poultry model. Those types of facilities meet the USDA definition of free range (read more about the difference).

    The distinction among the models must be swift and clear for consumers because it is the movement-based model that puts the birds outside on the grass in the sunshine. This builds nutrition in the chicken and eggs. Movement-based pastured poultry ensures healthy chicken that can be raised without coccidiostats or other antibiotics. The model of regular movement followed by a period of rest regenerates the land by building soil and improving fertility.

    In other words, the difference that consumers expect are a result of the farming model. When chicken and egg companies short-circuit the pasture raised model by not incorporating flock movement or real outdoor production, they short circuit difference. Consumers are left paying the price.

    A Diverse Pasture-Raised Poultry Community

    In January 2019, independent pastured poultry farmers from 36 states, two Canadian provinces, and Haiti attended the APPPA Professional Pastured Poultry Conference in Greenville, TX. At that meeting, you could find farmers who were raising broilers, layers, turkeys, heritage birds and commercial birds. You could find producers at a variety of scales including farmers raising 1,000 birds or 300,000 or any number in between. There were farmers, feed manufacturers, breeders, processors, marketers, and distributors.

    Inside the diverse APPPA membership, we have farmers raising slower growing broilers in a pasture raised model for processing in an on-farm USDA facility. There are on-farm processors working in exempt facilities. Some APPPA members have been refining nationwide mail order shipping as significant sales channels.

    There are APPPA member farms raising fast growing hybrids, heritage breeds, and the slower growing hybrids in between. The diverse configuration of farms that comprise the pasture raised chicken and egg community is too difficult to name inclusively. That diverse community of APPPA farmers, however, is firmly rooted in the movement-based pasture raised model of farming.

    Access to Pasture Does Not Equal Pasture-Raised

    Pastured poultry farmers and members of APPPA have worked hard to cultivate the pasture raised chicken and egg difference over the last 20+ years as an association. The farmers who spend a lifetime perfecting their craft demand that pasture-raised chicken and eggs means more than “access to pasture.” Access alone is not good enough to capitalize on the decades of innovation inside the community.

    American Pastured Poultry Producers Association has been advocating for pastured poultry production, processing, and consumption since its founding in 1997. We encourage farmers to keep the model movement based. We encourage consumers to watch the “Pastured Poultry: Better Way Forward” and view the Pastured Poultry Consumer Buyers Guide.

    For questions, contact Mike Badger, or 888-662-7772.

  • Thu, February 28, 2019 9:21 PM | Anonymous

    In March 2018, the Office of Inspector General (OIG) released a report detailing $1.8 billion in ineligible loans that the Small Business Administration (SBA) guaranteed for contract poultry growers to build barns. Specifically, the OIG reviewed loans to determine if they were compliant with regulatory, statutory, and SBA requirements for eligibility.

    The bottom-line result, as stated in the report, was that the “loans made to growers did not meet regulatory and SBA requirements for eligibility. The large chicken companies (integrators) exercised such comprehensive control over the growers that SBA Office of Inspector General believes the concerns appear affiliative under SBA regulations.”

    SBA loans can be made for up to $5 million to fund startup costs, expansion, equipment purchases, and other uses. The SBA guarantees the loans, which means U.S. taxpayers are ensuring that the lenders will have loan repayment. It’s a subsidy by U.S. taxpayers to fund a production model that primarily benefits the integrator by offloading the risky grow out portion of production to the farmer and to the public through the subsidy.

    At the heart of this discussion is the determination of affiliation. SBA in it’s public recommendations to update the loan program, is proposing that small businesses must meet an affiliation test. If more than 85% of a small business’ revenue comes from another business, then that small business would be affiliated with the other company and not an independent small business. Note that this has nothing to do with legal structures of the business. Instead, this is assessing the relationship between the contract poultry grower and the integrator.

    If you want further reading of the OIG’s report, look up the report titled “Evaluation of SBA 7(A) Loans Made to Poultry Farmers.”

    As you might imagine, this affiliation test is deeply opposed by the large chicken companies because funding the grower houses is expensive and high risk (that’s why they need to be guaranteed by the federal government).

    APPPA submitted comments in support of the affiliation test being proposed by SBA in the Federal Register on Friday, September 28, 2018. APPPA responded to these parts:

    SBA proposes to expand the principle of affiliation arising from “identity of interest” to include common investments and economic dependence through contractual or other relationships between any two or more individuals or businesses, reinstate the “newly organized concern” rule, reinstate the “totality of the circumstances” analysis when determining affiliation between an Applicant for financial assistance and other entities, and clarify affiliation based on a franchise or license agreement.

    If a small business Applicant derived more than 85% of its revenue from another business over the previous three fiscal years, SBA would find that the small business Applicant is economically dependent on the other business and, therefore, that the two businesses are affiliated.

    Our comments follow.

    The American Pastured Poultry Producers Association (APPPA) welcomes the Small Business Administration’s (SBA) attempt to establish and enforce an affiliation test for contract poultry farmers. Recognizing affiliations in the 7(A) loan applications protects the farmers, the public, and a fair marketplace.

    APPPA is a non-profit membership-based organization that provides educational resources to pastured poultry farmers who are operating small businesses in rural America. The association represents approximately 1,000 member farms. APPPA was formed in 1997 to support a renewed interest in pastured poultry.

    The growing pastured poultry industry does not rely on single grower contracts to produce chicken, eggs, turkey and other poultry; it instead relies on regional, decentralized, and direct-to-consumer markets. The pastured poultry business model stands in stark contrast to the consolidated and disconnected model of the contract poultry farmer.

    The Office of Inspector General (OIG) report “Evaluation of SBA7(A) Loans Made to Poultry Farmers” (report number 18-13) from March 6, 2018, is clear in its finding that “7(a) loans made to growers did not meet regulatory and SBA requirements for eligibility” because the poultry integrators exercised complete control over how and when contract growers raised poultry.

    The OIG details $1.8 billion in guaranteed funds that were loaned to pay for single use facilities designed for the needs of one “customer.” In a contract poultry environment, the farmer doesn’t even own the birds. The contract grower makes the facility available to house flocks from the integrator through short-term contracts and often with no contractual assurances that the grower will have flocks to pay for the facility in the future. While poultry integrators may be able to find contract growers to hold up as successful examples, the aggregate findings of the OIG paint a bleak economic picture and business model.

    Based on the OIG reporting, APPPA has the position that by approving 7(A) loans for contract poultry, SBA is:

    1. Allowing the American taxpayers to assume substantial risk and cost to raise the poultry while allowing the poultry integrators to become the primary beneficiary of a tightly integrated business model.
    2. Perpetuating a decline in the rural American economy by encouraging high risk business practices through the approval of 7(A) loans for contract poultry growers.
    3. Facilitating a competitively disadvantaged marketplace in favor of poultry integrators who can keep costs low by shifting the riskiest part of poultry production onto family farms. Those risks are guaranteed by the public.

    Affiliation Rules

    Regarding the Summary of Proposed Changes to Affiliation Principles for the Business Loan, Business Disaster Loan, and Surety Bond Guarantee Programs (Section II B), APPPA supports the proposed affiliation principles outlined in Section 121.30.

    This is an opportunity to make SBA aware of commercially viable poultry farming businesses that do not follow the contract grower model. Pastured poultry businesses, as a guiding principle, rely on a diverse number of customers to reduce risk from the loss of any single source of revenue. In addition, pastured poultry farms build infrastructure to be as multi-purpose as possible, so that the farm can be responsive to growth opportunities and market changes while proactively leveraging previous investments.

    The very nature of the poultry contract model is one of continued consolidation with farms growing larger in terms of animal concentrations and loan requirements (Figure 6: Growth in Annual Average 7(A) Poultry Loan Size, FY 2012-2016 of OIG Report). This consolidation of ineligible loans ultimately reduces the availability of SBA loans to competing businesses, such as pastured poultry farms, thereby enabling an unnatural competitive advantage in favor of the poultry integrators.

    Regarding proposed affiliation principles in Section 121.30, APPPA recommends:

    1. SBA determine that two businesses are affiliated if one business (e.g., contract poultry grower) receives more than 85% of its revenue from the other business (e.g., poultry integrator).
    2. SBA provide clarity to lenders by stating that the relationship between a poultry contract grower and an integrator is an affiliation, and that the poultry contract grower is not acting as an independent small business when applying for loans to build a single purpose facility to receive revenue from one source. According to the OIG’s report, the contract grower’s facility loses between 62% and 94% of its value without a contract from the Integrator (Table 1 from Office of Inspector General (OIG) report “Evaluation of SBA7(A) Loans Made to Poultry Farmers”).


    APPPA encourages the SBA to enact the affiliation thresholds and clearly define the relationship between poultry grower and poultry integrator as a dependent business relationship. In so doing, APPPA believes the SBA will do its part to remove unequitable subsidies that create unfair pricing advantages for the consumer while unburdening the taxpayers from guaranteeing these poultry contract grower loans.

  • Thu, December 07, 2017 1:59 PM | Anonymous

    Grady Phelan and Greg Gunthorp at 2017 Producers conference.Of all the things I like about the pastured poultry community, the diversity of business models is perhaps one of my favorites.

    In 2017, APPPA assembled a group of producers to have a meeting about pastured poultry. We primarily sought people who were “scaled up” or in the process of scaling up.

    Two things struck me coming out of that meeting. First, the idea of scale is ambiguous. Every person will have a different idea or a caveat.

    Second, was the diversity of business models, and this is my favorite thing. We had a producer in his retirement years cranking out a total of 3,000 broilers a year and loving life. His claims were more profit, better lifestyle, and an off-season, to name a few.

    He was turning each chicken into $30-$40 through a value-added product approach. He had been raising and selling poultry for something like 30 years. He did the scaled-up numbers thing through wholesale and retail outlets. Now, I guess you could say he was scaled up in experience.

    What I want you to see is the contrast. There are people plugging away with larger numbers, hiring people, creating generational businesses, and making the vision work.

    We admire larger farms because they’re unmistakably entrepreneurial, and they’re often driving necessary change in the marketplace.

    But in our community, these larger producers are operating alongside the people who are intentionally and deliberately finding ways to be make pastured poultry a successful part of a farm business with modest scales.

    At any pastured poultry conference where we’re tackling the issues of the day, I want both groups of people; experienced and scaled up. The challenge is speaking to people in a way that gets experience and volume in the same room. Often, those two characteristics end up being inversely related.

    That’s why I think in terms of “professional” pastured poultry producers. That’s not a term I derived. I think Grady Phelan used it to describe the meeting we held in 2017.

    When we start thinking in terms of “professional,” some of these things come to mind:

    • You have a livelihood at stake.
    • You associate with peers because those relationships enhance your business.
    • You consistently invest in your education, your business, and your community.

    That’s the heart of who we want to attend the Professional Pastured Poultry Conference in Fayetteville, AR, in January. We'll have producers with experience, producers with scale, and producers who have both. 

    At any rate, now is the time to register for the Professional Pastured Poultry Producers Conference in January.

  • Tue, October 31, 2017 11:10 PM | Anonymous

    Pastured poultry goes beyond labels; it’s a community and a movement of farmers and eaters who intentionally choose to support a better way of raising chicken, eggs, and turkey.

    American Pastured Poultry Producers Association (APPPA) is pleased to release “Pastured Poultry: Better Way Forward,” a short film documenting pasture-raised poultry as a better method of production for everything involved. The land. The chickens. The people.

    The problem with poultry production today (aside from the actual production) is that the claims of free range, organic, antibiotic-free, cage free, and natural are nearly indistinguishable from the commodity options consumers are trying to avoid in the first place.

    The “Better Way Forward” video and companion Buyers’ Guide equip consumers with much needed information that will help them find and purchase the truly unique poultry products they seek.

    Pastured poultry farmers have long ago learned to embrace the positive animal welfare and nutritional benefits of sunshine, fresh air, and green grass. The constant movement under the sun and through the grass creates a dynamic, regenerative system that builds soil and protects the environment while creating uniquely nutritious and great tasting products.

    Compared to the static alternatives, the movement-based approach of pastured poultry inherently creates a difference you can taste. There’s more flavor and a firmer texture to the meat and eggs. The birds are healthier and don’t rely on antibiotics and coccidiostats.

    If you want to know the farmer who raises your poultry and eggs, the best option is to seek out local pasture-raised options. The “Better Way Forward” video and buyers guide is available at

    The pastured poultry method of production was brought into modern agriculture in the early 1990’s by pioneering farmer Joel Salatin as a way to describe a more natural farming method that incorporated technological innovations. APPPA launched in 1997, as a non-profit trade association that encourages the production, processing, marketing, and purchasing of poultry raised on pasture.

  • Thu, October 26, 2017 6:52 AM | Anonymous

    In a world where organic birds stay confined to the barn and free range chickens never see sunshine or grass, figuring out what pastured poultry means can challenge a conscientious eater's best intentions.   

    Terrell Spencer, APPPA President and farmer at Across the Creek Farms sums up the challenge nicely, "Other people portray themselves as us. We don’t do a good job of marketing who we are. The ones who don’t do what we do, do a good job of marketing that they do it like us." 

    The American Pastured Poultry Producers Association (APPPA) hears the challenge and sees the larger poultry industry putting on their sheep's clothing. But we see the wolf clearly. 

    As a first step in taking our message mainstream, we're publishing a short film with supporting web content that will help consumers understand what pastured poultry is and then help them find it. 

    We call it "Better Way Forward" and the full film is coming in early November 2017.

    Here are some ways you can get involved and help spread a positive message about pastured poultry. 

    1. Like our Facebook to see updates or better yet, subscribe to our free email list.
    2. Share this trailer and then the final film when published.
    3. Become an APPPA member and join forces with a growing community of farmers who see pastured poultry as a better way forward.

    Stay tuned. 

    Contact Mike Badger, with questions.

  • Wed, July 12, 2017 8:27 AM | Anonymous

    The American Pastured Poultry Producers Association (APPPA) recognizes the United States Department of Agriculture’s (USDA) Agricultural Marketing Service’s (AMS) effort to make the organic label address consumers’ expectations with regard to animal welfare and husbandry practices. While the proposed “National Organic Program: Organic Livestock and Poultry Practices” rule makes some beneficial strides toward improving the animal welfare of organically certified poultry, it stops short in several critical ways.

    APPPA is a non-profit membership-based organization that provides educational resources to pastured poultry farmers and represents approximately 1,000 active member farms. APPPA was formed in 1997 as a clearing house of ideas to support a renewed interest in pastured poultry.

    Pastured poultry embodies a few key tenets of production: the birds live a significant portion of their lives outside on vegetated pasture; the birds are rotated to fresh vegetation often in a managed way; flocks are housed in lower stocking densities to ensure the birds can express their natural behaviors without stress and injury to themselves or other birds; in addition to the forage offered via pasture, the birds eat a nutritionally balanced feed that is appropriate for the species and age of the flock; slaughter is typically done in small-scale or exempt facilities by hand in a way that respects the life of the animal.

    In practice, pastured poultry farmers employ different production models typically identified as daily move, day-range, and free range systems. In a daily move system, poultry are confined inside a movable shelter that typically accommodate groups of 50 to 600 birds per shelter; however, the birds have direct access to the soil and pasture while inside these well ventilated shelters.

    In day range systems, the birds are allowed to access an outdoor area independent of the housing area. Birds typically range inside temporary paddocks created by portable electric fencing and the housing, if left stationary, will have bedding and may have flooring and roosts. At regular intervals, the house and the paddock are rotated to areas of fresh vegetated pasture.

    A free-range model places birds on range without fences and relies on longer distance pasture rotations to keep the birds on fresh pasture; though this free-range concept offers the most idyllic view of outdoor poultry production, it offers the least amount of predator protection and is difficult to make work on small acreages.

    A majority of pastured poultry producers will use either daily move or day range systems. Producers typically favor day range for laying flocks, waterfowl, and finishing turkeys. The daily move system is often used for broilers, young turkeys, and maximum predator protection for laying hens.

    Ranging out of a fixed building is not commonly done on a pastured poultry farm because it’s difficult to manage the outdoor area in a way that does not result in degradation of the quality of soil, pasture, and forages. If the producer is stocking the fixed house paddock in a way that does not degrade the pasture, then the birds are not efficiently utilizing the range. This is the conundrum AMS has with trying to fit the intent of organic poultry production into the confined animal feeding operation model. The current proposal fails to solve the conundrum.

    APPPA clearly differentiates between certified organic production and pastured poultry production. They are not equivalent, even though some pastured poultry producers are certified organic. In publishing standards, in marketing, in education, and in discussions AMS should take care to ensure that they clearly communicate that the organic certification does not necessarily mean the birds have been pasture-raised. In the final rule, we would like AMS to acknowledge that while some locally available organic chicken may be pasture-raised, organic certification does not mean the birds have been raised on pasture.

    The proposed rule falls short of the typical animal welfare measures provided in the management of commercial pastured poultry flocks in terms of low stocking densities, living outdoors for significant portions of life, and managed and planned pasture rotation.

    Based on a 2014 APPPA survey of pastured poultry producers, the number of certified organic layer flocks (as self-reported) was 8% certified organic and 7% Animal Welfare Approved (AWA). The number of certified organic broilers was 9% and 7% AWA.

    The relatively low incidence of pastured poultry producers seeking organic certification has two primary causes.

    First, most pastured poultry producers serve direct markets where trust is earned through direct contact with the consumer–the epitome of “know your farmer.”

    Second, the organic poultry and egg standards, as currently enforced, place confinement organic poultry and organic pastured poultry operations as equals in the marketplace; in reality, however, they are different. Producers know it and more consumers are realizing it. Pastured poultry answers the consumer calls that the commercial (as defined by USDA) organic poultry industry ignores: local production, less densely stocked flocks, husbandry practices that leverage the birds’ natural behaviors, and beneficial impacts to soil health and fertility.

    With regard to distinguishing pastured poultry from organic poultry production, APPPA recommends:

    1. AMS clearly state that certified organic poultry does not imply pasture-raised and organic certification does not connote the principles of pasture-raised poultry as outlined by the American Pastured Poultry Producers Association in this response.
    2. AMS acknowledge that pasture housing (daily move, day range and free range) are acceptable production models with regard to the organic regulations, as long as those housing models meet the minimum standards as published in the final rule.

    Outdoor Access and Stocking Density

    The recognition that porches do not constitute outdoor access is obvious, and AMS should follow through on its proposal to disallow porches. The allowance of porches skirts the existing outdoor access requirement in organic poultry production by providing a thinly veiled appearance of compliance.

    The natural bird response to being confined in large numbers on the floor prevents all birds from moving around as freely as expected and therefore prevents many of them from accessing the door. The birds’ response in these houses is to gather in groups that stay in one area; the birds do not circulate and move freely around the entire floor. That means the birds don’t use the porch and other outdoor access areas in any meaningful way. Commercial poultry producers see this hierarchy at play each day when a negligible number of birds take advantage of their outdoor access.

    When the government has to define the meanings of “soil” and “the outdoors,” it’s clear that the intent of organic poultry production has become adulterated. APPPA feels strongly that outdoor access requires provision of areas with 90 to 100% vegetative cover. Such vegetative cover requires soil, sun, and planned rest from grazing to grow. This access to vegetative cover in the outdoor area is a principled point of differentiation between pastured poultry production and the AMS’s organic standards. Consumer feedback to pastured poultry producers repeatedly indicates that they expect organically raised poultry to live a significant portion of their lives outside on pasture; compliance with the proposed rule will not meet that expectation.

    Specifying outdoor stocking densities without consideration of pasture rotation, including planning for forage regeneration, creates an incomplete understanding for producers. This represents another major differentiation between pastured poultry and the proposed organic standard. A key to successfully producing poultry on vegetative pasture is the managed rotation of the birds to fresh vegetation at frequent intervals, sometimes multiple times a day. Disconnecting the flock rotation from outdoor stocking density runs the risk of denuded outdoor paddocks, which leads to health risks to the flock and decreased soil health. The size of the outdoor area is predicated on the pasture management plan, which includes consideration of the quantity and quality of the vegetation in the pasture, as well as the amount of time the birds will be on the ground. The size of the outdoor area cannot be accurately predetermined without consideration of those and other unique factors, such as geography and seasonal variations.

    The movement of the birds away from their own waste, via regular movement and rotation of housing areas, creates the healthy environment needed to rear flocks without the reliance on antibiotics. The proposed standards do not clearly articulate the relationship between stocking densities and pasture rotation.

    With regard to outdoor access and stocking density, APPPA requests that the final rule:

    1. Disallow covered porches as the only outdoor access area.
    2. Provision for outdoor areas to have 90 to 100% vegetative cover.
    3. Ensure producers plan for the appropriate pasture space, stocking density, and rotation to ensure the health and natural behavior of the birds while not resulting in the degradation of the soil, pasture, and forages. Outdoor area must minimize the spread of parasites and diseases and the build-up of excess nutrients.

    Indoor Stocking Density

    The proposed indoor stocking densities as set forth in the proposed rule set a low standard. The indoor housing recommendation of 4.5 pounds per square foot (1 square foot per laying hen) for a pasture housing type will only work if the birds are also ranging on pasture. In a winter, or indoor, housing environment, that stocking density will create a stressful environment.

    There is a simple test to ensure that stocking densities are correct. If debeaking or beak trimming is required to keep the flock from pecking each other, then the stocking density is too high and, consequently, the animal welfare is too low. One common cause of pecking is caused by environmental stressors, such as crowding.

    The proposed indoor stocking densities continue to enable producers to violate consumer expectations by permitting multi-story aviary production models for laying hens. Multi-story laying houses should not be permitted in organic production. The rule is going to create a clear double standard in organic production based on housing type and more production will move to the multi-story houses, creating economies of scale that further water down the organic egg market and further violate consumer expectations and reduce animal welfare. Houses that encourage birds defecating on each other are not a vision most consumers have of organic egg production. It’s also not a healthy way to raise laying hens.

    Indoor stocking densities also need to make considerations for the season, the weather and the access to the outdoors. In a pastured housing model, a laying hen may be content with 1.5 to 2.0 square feet of indoor space if allowed access to a rotated pasture. However, when a laying hen is confined in the winter, lower stocking densities provide less stress and less ammonia build up.

    With regard to indoor stocking density, APPPA recommends:

    1. The use of multi-story houses is discontinued in organic production.
    2. Indoor stocking densities are lowered. When birds are withheld from outdoor areas or when birds are housed in a daily move pasture shelter, APPPA recommends the following stocking densities across all housing types: 3 sq. ft. per laying hen (1.5 lbs. per sq. ft.); 1.5 sq. ft. per broiler (4 lbs. per sq. ft.); 7 sq. ft. per turkey (4 lbs. per sq. ft.).
    3. Organic production disallows beak trimming and debeaking as defined in the proposed rule. The burden of managing the physical behaviors should revert to the producer employing husbandry practices that complement the natural bird behaviors.

    Indoor Confinement

    APPPA feels strongly that organic poultry producers are permitted, by the current and proposed rules, to overreact and confine flocks too easily. The organic confinement model poultry industry continues to use the fallacious threat of disease for denying outdoor access.

    When organic producers are allowed to repeatedly and continually confine the flock based on the threat of a disease, it further erodes the confidence of the organic label. We point to the recent Highly Pathogenic Avian Influenza (HPAI) outbreaks in the United States as evidence. At the time of comments (June 2016), many organic flocks are still permitted to be confined and have been confined since the beginning of 2015 based on the perceived threat of HPAI and a risk assessment that does not match the observed data from prior outbreaks.

    To illustrate, we’ll cite the USDA’s own assessment of the risk of HPAI as published in Docket ID: APHIS-2015-0061. Conditions for Payment of Highly Pathogenic Avian Influenza Indemnity Claims. This excerpt is taken from the proposed biosecurity exemption for smaller facilities (less than 100,000 broilers annually, 30,000 turkeys annually, and commercial table egg facilities with less than 75,000 birds): "[T]he smaller facilities that we are exempting from the requirement are less likely to have HPAI outbreaks than are the non-exempt ones. On smaller facilities, birds density tends to be less which minimizes overall viral load. Additionally, if a smaller facility was identified with HPAI the disease is less likely to spread outward to other premises because there are fewer birds, vehicles, pieces of equipment, and employees moving onto and off of the smaller, exempted facilities when compared to the larger, non-exempted ones."

    In light of APHIS’ stated correlation between stocking density and viral load to HPAI, APPPA believes strongly that both indoor and outdoor stocking densities play an important role in the health and management of the flock. AMS should decrease the stocking densities for both indoor and outdoor access and recognize that appropriate stocking density is a key factor in healthy poultry husbandry.

    With regard to HPAI, the evidence is also clear that the virus is susceptible to heat and sunlight. Yet, current organic production regulations – and hence practices - support continued disregard of that data.

    More and more consumers see through the shortcomings of the organic label, which propels them to pasture-raised poultry, a craft production system that focuses on managing symbiotic relationships, working with the natural tendencies of the poultry, and ensuring animal welfare.

    In the information we’ve gathered, neither a well-managed pastured flock nor a certified organic flock has been infected with HPAI. That’s different than saying there is no risk; we can never eliminate the risk of HPAI in a poultry flock, but we can manage it. 49.7 million birds were affected by HPAI in the 2014/15 outbreak in the U.S.

    The HPAI 2014/15 Confirmed Detection report by APHIS shows that less than 4,000 of the birds affected were spread across 20 backyard flocks; APHIS reports an additional game bird flock of 5,830 pheasants that it counts as a backyard flock. That means that more than 49.6 million intensely confined birds were killed either by the virus or destroyed by regulators as a part of the outbreak response.

    Of the effected backyard flocks, we do not know the husbandry practices of those flocks (at least not publicly). Backyard poultry is also not synonymous with pastured poultry, even though the current categorization by the USDA equates these practices, not differentiating between backyard flocks, hobby flocks, poultry ranging and pastured poultry.

    The indoor stocking densities tie into the proposed change in measuring ammonia levels in the house. APPPA and its board routinely cite 10ppm and 25ppm as the warning levels of ammonia exposure. At ammonia levels of less than 10ppm the birds’ ciliary function and immune system are negatively affected and at 25ppm, the level at which the human nose can detect ammonia, there is already damage being done to humans and animals - creating welfare problems for the poultry and the people. Ammonia exposure is non-existent in a well-managed pasture rotation.

    Stocking density will affect the ability to keep the bedding dry and keep ammonia levels down. For example, market age Cornish cross broilers stocked at approximately one square feet per bird (5 pounds per square foot) will require constant bedding management in order to keep the ammonia levels under dangerous levels. Decreasing the stocking densities for all the poultry species will not only provide a low stress living environment that doesn’t require beak trimming, it will provide a way for all producers to manage ammonia levels.

    With regard to indoor confinement, APPPA recommends:

    1. Organic production requires natural sunlight to enter the indoor living space.
    2. The final rule promotes lower stocking densities as a means to lower the viral load in the house and thereby reduce the risk of disease as stated by the USDA.
    3. AMS should maintain the proposed ammonia standards and further clarify the standards by requiring ongoing measurement of the ammonia levels (e.g., ammonia test strips). The human nose is not sufficient to reliably detect dangerous ammonia levels.


    In terms of slaughter, APPPA believes strongly that the PPIA poultry processing exemptions need to be maintained for all poultry producers, including pastured and organic flocks. USDA should remove obstacles to make exempt processing more accessible to more producers. Many beginning farmers turn to pastured poultry production as their inaugural farming venture, but access to adequate processing is an obstacle that needs to be addressed. There is a lack of accessible inspected processing facilities throughout the United States; the poultry processing exemptions allow farmers to test poultry markets and businesses and to serve direct markets in a way that wouldn’t be possible without the exemptions.

    Limited access to legal processing options that enable farmers to move their products in open commerce is a competitive disadvantage. Ambiguity and misinterpretation of the poultry processing exemptions at the federal, state, and local levels of government suppresses the growth of small businesses that want to raise pastured poultry, which also affects independent producers who want to be organically certified.

    Some of the proposed slaughter requirements make sense and should be obvious. Specifically, not scalding live birds or shackling lame birds is sound welfare guidance. However, APPPA would like to state emphatically that humane poultry slaughter is not synonymous with stunning or controlled environmental suffocation. Stunning, especially when automated at high speeds, has the potential to be one of the most inhumane actions possible. Otherwise, AMS would not need to codify common sense welfare positions, such as only scald dead birds and don’t hang lame birds by their legs on high speed shackle lines.

    The proposed standard mentions that small producers are permitted to use killing cones and non-stunning exsanguination. The use of killing cones and exsanguination should be allowed in all poultry slaughter operations, including organic and at all size operations. APPPA would like to see the organic standards unequivocally reflect an acceptance of the use of killing cones and exsanguination without stunning regardless of facility size.

    With regard to poultry slaughter, APPPA recommends:

    1. The federally regulated poultry processing regulations remain as a legal and acceptable option to put birds into commerce for all types of poultry producers, including pastured and organic.
    2. Slaughter not be limited to stunning and include other methods, such as the hand slaughter of birds in killing cones by way of exsanguination.


    In closing, APPPA applauds this effort and strongly emphasizes the need to clarify the distinctions of pastured poultry. As the welfare realities of pastured poultry production and the minimum standards of organic poultry production draws closer, we are confident that more pastured poultry producers will find value in organic certification, especially in lieu of lesser known, competing third-party welfare programs. We are available to help provide a pastured perspective, as needed ( or 888-662-7772).

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