United Poultry Concerns is a national nonprofit organization that promotes the compassionate and respectful treatment of domestic fowl. We respectfully submit to your attention our response to your call for final comments on husbandry standards for organic poultry. We oppose labeling birds raised in intensive confinement buildings "organic."

Birds labeled "organic" should be raised in a clean, outdoor environment, preferably in a rotational system to avoid the build-up of manure and pathogens. The birds should have ample opportunities to perform their natural behaviors including foraging, dustbathing, sunbathing, perching, and (if adults) nesting. They should be provided with shaded areas in the form of bushes, trees, and/or other shelters from heat and summer sun. They should have continuous access to clean fresh water and food, including grass and/or other greens such as cabbages, kale, Romaine, collards, and other green leafy vegetables. The birds should have predator-proof housing for roosting at night and, perhaps ideally, a predator-proof outdoor range with overhead netting. They should have plenty of room to move about freely.

We submit these comments with a view to reducing the welfare abuses to which birds raised for meat and egg production are subjected including filthy litter, excretory-ammonia permeated buildings, lack of activities suited to the normal behavior patterns of gallinaceous birds, lack of natural sunlight, and deprivation of the outdoors. "Organic" poultry should never be debeaked or subjected to the food deprivation practice known as forced molting.

Please do not hesitate to contact United Poultry Concerns for further information at 757-678-7875. Thank you for your attention.

United Poultry Concerns, Inc. PO Box 150 Machipongo, VA 23405-0150 757-678-7875 FAX: 757-678-5070 www.upc-online.org (UUPC Comments to USDA Re: standards for organic poultry )

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