Oregon Tilth would like to thank the National Organic Program for their work on the Origin of Livestock proposed rule change. We support continued efforts to ensure strong, consistent standards for organic dairy production; this is critical to maintaining credibility, improving transparency, and ensuring a level playing field for all certified operations. We urge swift finalization of the rule and implementation effective immediately upon publishing, with the only exception being for currently certified producers with animals in transition being allowed to complete the transition as approved by their certifier.