Photos and charts courtesy James Maroney
by James Maroney I am a retired organic dairy farmer, the third certified in Vermont in 1989. We milked 125 cows and raised corn, soybeans and alfalfa on about 500 acres, which more than complies with the ideal ratio of one cow for every three acres under management on which that cow’s feed is harvested and her manure is spread.
Even though we made organic milk for six years, there was in those days no market for it; neither Agri-Mark, nor Ben & Jerry’s nor Stonyfield nor the VAAF&M showed much interest in the product. Consequently, our 2M lbs of organic milk, which cost us $22/cwt to produce, all went into the regular supply at prices ranging from $12-15/cwt. I believed that the product would eventually catch on and it was about to; but ironically, our barn burned down in 1996 putting us out of the chase.
All farming in Vermont was ‘organic’ until the early 1950s, when the conventional farming model was introduced. The new model offered farmers cheap chemicals, which would double yields and greatly reduce the costs of crop rotation and time-consuming, mechanical weed control. Conservative Yankee farmers were curiously slow to adopt the model, but their sons were eager to take up Earl Butz’s famous dictum to “plant fence row to fence row” and to “get big or get out.” By the late 1970s the model was approaching 100% penetration all across the country and indeed the world.
The new model was really a no-brainer and for early adopters, conventional farming was delivering as advertised.
But predictably the model was also bringing a few unwanted side effects, chief among them over production, which would depress farm prices, which would in turn drive farm attrition, which would then drive rural economic decay. These conditions were beginning to hurt even the early adopters, known as ‘progressive’ farmers, driving them to expand and consolidate their neighbors, to acquire more land and machinery on which to apply the model.
And if these side effects weren’t bad enough, the application of more toxic fertilizers and the stocking of more cows on increasingly fewer, increasingly larger farms would drive lake pollution, which the federal government was urging Vermont to control.
And there was yet another problem. Legislators were not really concerned about the economics of farming, or rural economic decay, which they regarded as a distant threat. They were scared to death about development, which if left unchecked, was going to make Vermont “look like New Jersey.”
They were also nominally concerned about increasing lake pollution, which if left unchecked would threaten tourism.
All these effects were predicted as early as 1962, when Rachel Carson published Silent Spring. But they were either ignored or hotly denied. So, in 1967 Vermont passed Land Use Regulation followed in 1970 by Act 250, both sold to the public as measures to “save agriculture and protect the lake.” Development slowed down as planned but farm failures and lake pollution both increased.
So, in 1978 the state enacted Use Value Appraisal (“Current Use”); Vermont Housing and Conservation Board (1987); Act 200 (1989); Lake Champlain Special Designation Act (1990) and the Vermont Milk Commission (1991), all intended on their faces to “save agriculture and protect the lake.” Farm failures and lake pollution both continued to increase.
Looking for a way to avoid responsibility for these seemingly uncorrectable problems, in 1993 the legislature with help from the office of the attorney general drew up an MOU that would shift responsibility for lake pollution to the Department of Agriculture, a move that was designed to give those most responsible for the problem the power to fix it. It reminded others of the adage about asking the fox to guard the henhouse.
Whatever its real purpose was, it did not stanch lake pollution or farm attrition.
So, the state adopted the Accepted Agricultural Practices rules (1995); Act 115 (2004); Act 183 (2006); Farm to Plate (2009); Act 142; the Save the Working Landscape Enterprise (2010); Act 138 (2012); Small Farm Certification (2015) and the granddaddy of them all, Act 64 (2016), Vermont’s so-called “Clean Water Act.”
In 2009 the Vermont Council on Rural Development conducted a survey in which 97% of respondents indicated they supported agriculture. VCRD’s question impounded a fairly obvious bias but clearly VCRD knew that the legislature, comprising Vermonters, also believed dairy was important, which bias manifests in the passage of the programs listed above.
But whether they provide sales and/or income tax deferral or exemptions or whether they direct allocations to Current Use, Vermont Housing & Conservation Board, Vermont Sustainable Jobs Fund, Vermont Working Lands Enterprise or dozens of others all intended on their faces to ‘save agriculture and protect the lake,’ these programs are now costing the taxpayers +/-$135,000,000/year, or a staggering $370,000/day.
And if that number doesn’t cause you to gasp perhaps it would if you knew that according to Vermont State Auditor Doug Hoffer between FY16 - FY18 inclusive Vermont Department of Environmental Conservation undertook 1,423 projects within the Lake Champlain Basin at a total cost of nearly $77 million in state funds that were intended to capture an average of 2,962 kg phosphorus annually during their lifespans. However, according to Hoffer, 95% of all state clean water expenditures did not yield any measurable reduction in phosphorus.
The legislature justifies these programs and expenditures because, to quote the words of a study by the Vermont Dairy Promotion Council, the dairy industry is the “backbone of our rural economy;” it “brings $3M/day in ‘economic activity’ into our economy;” it is “producing our food;” “agriculture keeps the land open;” “Vermont’s agricultural sales are the highest in New England;” “Vermont dairy products bring $2.6B/year into the Vermont economy;” “Vermont agricultural sales have increased 64%,” etc., etc. But the VDPC is pedaling disinformation, what today is called “alternative facts.”
Putting momentarily aside good intentions, the legislature ignores these simple, unassailable facts: sixty-five years of laws, rules and programs—including the much vaunted Act 64—all intended on their faces to “save agriculture and protect the lake” have cost taxpayers $3B (60 years x $50M/year = $3B) and have not made the dairy industry either profitable or non-polluting. All these laws have empirically failed because the legislature is attempting to serve two masters, and in the process, it mistakes the symptoms of the problem for its cause.
And since conventional farming is the major cause of farm attrition and lake pollution, and since conventional farming is the prevailing farm modality, since the legislature and VAAFM are willfully blind to the harm conventional farming does to the economy, the environment and to the farm industry itself, the Vermont legislature is still with one hand feeding the problem it repeatedly and blithely taxes it citizens with the other to stanch.
Unspoken but residing near the heart of these laws and programs is the belief, very widely held, that lake pollution is attributable not to systemic practices of the conventional dairy industry as a whole but to a few rule breakers.
Irrespective of data that would indicate the fallacy of this belief the legislature codified the AAPs with these words: “Persons engaged in farming, who follow these rules, shall be presumed to be in compliance with water quality standards.”
Some would undoubtedly argue with the accusation that the legislature has been “willfully blind.”
But how else to account for the fact they did not see these trends occurring right under their noses:
- As the number of farms in Vermont decreased, lake pollution increased
- As the number of cows in Vermont decreased, lake pollution increased
- As the number of cows/farm in Vermont increased, lake pollution increased
- As milk production/cow in Vermont increased, lake pollution increased
- As total milk production in Vermont increased, lake pollution increased
- As the AAP’s were implemented (1995) lake pollution increased
- As the RAPs were enacted (2015), lake pollution increased
The State of Vermont implicitly and explicitly supports the practices listed above without bothering to notice that they all correlate with rising lake pollution, which to clean up the state appropriates more money from the taxpayers. This is an excellent illustration of the incompatibility of trying to simultaneously support conventional dairy and attain clean water. We cannot have both!
Back in 2013, Eric Smeltzer told us that the lake can absorb about 500 tons of nutrients but it is presently taking in about 817, which is 317 or 36% too much. He also told us that 200 tons of that overload or 65% is coming from agriculture. We all agree on these metrics.
Yet Act 64, the new ‘clean water law’ ignores the 40,000 tons of petroleum-based NPK fertilizer imported annually by the conventional dairy industry, which includes 5% phosphorus or 2,000 tons.
The clean water law also ignores the 600,000 tons of feed supplements imported by the conventional dairy industry, which includes 1% phosphorus or another 6,000 tons. Act 64 does not mention let alone constrain these practices and because the law states that it is necessary to balance efforts to attain clean water with the interests of the dairy industry, the law willfully ignores them.
Here are the real very ugly facts: the Vermont dairy industry produces about 2.3B lbs of milk or barely 1% of the national supply, which is about 20B lbs in surplus and rising. In a good year the industry brings about $500M (gross revenue) into the Vermont economy, or 2% of Vermont’s GDP, hardly its backbone. This past year (2019) because the price of milk was about $16/cwt, gross sales came in at about $400M; the industry in 2018 lost $100M and in 2019 it lost about $138M.
The industry’s coping mechanism for the last two generations has been to convert state support to more capacity, to expand and consolidate, to boost production on many fewer, much larger farms.
Yet, in spite of these dreadful numbers, between 1944 and 2016, with one tenth as many farms, half as many cows and increasing state regulations all intended on their faces to ‘save agriculture and reduce water pollution,’ the conventional Vermont dairy industry boosted statewide milk production by 50% and production per cow by an a whopping 240%.
These remarkable gains were primarily driven by the shift in the 1950-60s from a forage-based ration to one based on grain, which required the importation of increasing amounts of nitrogen, phosphorus and calcium into the watershed. The state has never regulated this activity and indeed, the state willfully supports it. Willfully because Act 64, the new “Clean Water Act” and the RAPs scrupulously fails to regulate it.
And without regulating it, Act 64 cannot reduce lake pollution from agriculture at all, let alone reduce it by 65%, the EPA target.
As it now stands, Act 64 will charge the taxpayers $1.4B half of which will pay for storm water and wastewater improvements, which must be undertaken. But it will also allow conventional dairy to continue to expand and consolidate as usual. I can’t say if this schizophrenia is consistent with legislative intent but addressing one half the cause of lake pollution while ignoring the other is like saying you want to get sober so you’re going to stop drinking scotch and bourbon but not gin.
Perhaps I should not accuse legislative intent as being schizophrenic. Perhaps imputing to it the attempt to ride a horse in two directions at once would be better?
In 2016, the Vermont senate circulated a bill that would “encourage” farmers to engage in soil regeneration. Joining was not compulsory and it offered farmers no incentive to join. Nothing happened because Vermont conventional farmers saw no incentive to “engage in soil regeneration.”
I propose that to induce the farmers to reduce pollution the state must pay them to stop using phosphorous fertilizer and imported grain.
From the state’s point of view, the justification is simple: that half of Act 64 dedicated to cleaning up agriculture is projected to cost $35M/year but as we just saw Act 64 can make no improvements to the lake. So if the state were to pay the farmers $35M/year to stop using phosphorus fertilizer and imported grain, everybody would win.
To encourage farmers to get on board, the state would offer farmers a choice: either join the plan and receive benefits or pay a 100% excise tax on NPK fertilizer, imported grain in excess of 4 lbs/head/day and the housing of more than one cow for every three acres under management on which that cow’s feed is harvested and her manure is spread. The state is justified in making this offer because cleaning up the lake is a higher public good than adding a new subsidy to the $50/70M the conventional dairy industry is already allocated under Current Use and VHCB.
Here is another example of the legislature’s or perhaps the VAAFM’s bias toward conventional dairy. I heard former Secretary of Agriculture Chuck Ross say on many occasions that lake pollution is a community problem and that we must be “all in” to fix it. Sounds fair. He went on to say the problem has three contributors: (1) stormwater (2) antiquated or inadequately designed municipal wastewater plants…and (3) ‘agriculture.’
There are 625,000 persons in Vermont so cleaning up the mess attributable to MWWTPs and storm water will come to $56/person or $168 for a family of three. And since these 625,000 persons are not going to stop driving, are not going to stop using the bathroom and it is not going to stop raining, 100% of Vermonters must be “all in” to fix this half, no argument. But the other half of the problem is caused by just 650 conventional dairy farmers and their families and suppliers or shall we say 3,000 persons or one half of one percent of the population. Cleaning up their half of the problem will come to $11,666 per person or $35,000 for a family of three.
Maybe since not all farms are the same size, it would be fairer to charge farmers $253/cow or $25,300/year for a farm milking 100 cows, which would be $253,000 for a farm milking 1,000.
Of course, rain also falls on farmers and they also use the bathroom and the roads so they must certainly be “all in” for their share of the first half. But no matter which way the conventional dairy industry’s obligation for their half is apportioned, Act 64 does not ask farmers to pay anything because they are getting $5-7.00/cwt less for the milk they are producing than it costs them to make. On top of which they have no money.
So Treasurer Beth Pearce is haranguing the legislature to convince them that it is reasonable for the taxpayers to pay for the first half and the second. My earlier estimate of $56/citizen for ‘saving agriculture and protecting the lake’ just doubled to $112/person or $336/year for a family of three.
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In February of this year—which is to say prior to the arrival of the coronavirus—the Vermont dairy industry comprised only 650 farms, of which 450 were ‘conventional’ and 200 were organic. The organic farmers were then getting +/- $35/cwt and the conventional were getting +/-$16/cwt.
But only the organic farmers were cash flowing; the conventional cost of production was about $20/cwt meaning that 450 conventional Vermont dairy farmers were losing $4/cwt or almost $100M per year, and they had been operating under these same unfavorable conditions for four years before this one.
The causes of low milk prices were said to be related to numerous factors, among them out-of-date Federal Milk Marketing Order rules and/or unfavorable trade regulations, the high cost of unemployment insurance, grain, fuel and labor. But the fundamental cause was inarguably over production. And yet with every passing year US dairy farmers produce more.
In March of this year the coronavirus entered the picture making an excruciatingly difficult economic outlook for Vermont conventional dairy far worse. The price of milk is now predicted to fall to $12/cwt, which means that Vermont’s remaining 450 conventional dairy farmers will be selling 23M cwts at $8/cwt below their cost of production, which means an industry-wide loss from operations of $184,000,000. And because they can’t sell it—and because they won’t reduce production—Vermont’s dairy farmers are now dumping milk into their manure pits.
Three weeks ago, Governor Scott proposed to allocate to agriculture, which essentially means the conventional dairy industry, $50M from a $1.2B relief package Vermont received from the CARES Act. Fifty million is a great deal of money but it will not save Vermont dairy. In fact, $50M is $134M short of helping Vermont conventional dairy break even.
And since this federal money is undoubtedly a one-time payment, and assuming the price of milk stays at $12/cwt, the injection of $50M into the disastrous economy of the conventional Vermont dairy industry this year leaves it $184M short next year, and the year after that.
As it turns out, someone in the legislature apparently thought $50M was too much to give to dairy and so the grant was pared down to $25M, $19M of which will go to dairy farmers, $1M will go to processors and $5M will be divided up between Vermont’s approximately 6,350 farmers who are not milking cows.
But since there is almost no market for Vermont commodity milk and since Vermont dairy farmers are therefore dumping much of their production into their manure pits and since Vermont’s 650 conventional dairy farmers are burning $9.5M/month, $19M will last them just two months, or until November.
I do not suggest that conventional Vermont dairy farmers are not hurting or deserving of community support. But Vermont has many institutions more deserving of $19M in relief, institutions that serve tens of thousands of people, like the Vermont State Colleges, our beleaguered hospitals and public schools to name only three.
I am suggesting that it is time for Vermont to question the validity of the myths surrounding dairy. I am suggesting that it is time for Vermont dairy to face some extremely hard economic facts. Perhaps you might have a look at Tom Evslin’s article “Corona Broke Things Already in Trouble” appearing in VT digger in which he says:
“Neither recovery energy nor recovery money should be aimed at resurrecting [failing industries] or protecting others like them who will likely fail soon. Their demise makes room for new businesses and new business models just as winter clears the deadwood to make room for spring growth.”
Evslin is saying that Vermont should not grant conventional dairy farmers $19M in ‘relief,’ because they will use the money to maintain production, which means they will be indirectly dumping our money into their manure pits.
Governor Scott, calling for their continued state support, recently said that “our dairy farmers face an uncertain future.” No, they don’t. With or without $19M in relief they face certain, economic collapse.
I propose that some of this money be spent to help our dairy farmers understand the provisions of Chapter 12 federal bankruptcy protection, which is another form of public support but one that is contingent upon recipients accepting change.
Scott also believes that a shrinking population is the root of all our problems. To reverse this trend, he suggests that we need to think “outside the box, present bold ideas and discard old solutions that once seemed right but haven’t worked.”
We all know that Vermont has a long agricultural history and that since the late 19th century the principal product has been commodity milk and that Vermonters overwhelmingly support farmers. But the taxpayers have spent $80-100M/year for the past fifty years to clean up the lake and support the dairy industry, and in spite of this, the industry is on track to lose another $100M from operations this year on top of the $100M it lost last year.
Everyone I speak to on this subject seems to know that the dairy industry is still the leading cause of pollution in Lake Champlain, and that the legislature is asking for an additional $35M/year, or $700M over twenty years, to fund that half of Act 64 intended to address pollution attributable to agriculture.
But few seem to understand that the legislature is asking the taxpayers to once again throw good money after bad. Conventional Vermont dairy is under duress right now due to low milk prices caused by a combination of factors out of their control. But the most important of these is unquestionably over supply.
No one wants to mention another important fact: steadily falling consumer demand for commodity milk. But to control supply and demand, Vermont dairy must not continue doing business as usual. It must change both its methodology and its product.
I propose that the state redirect that $700M/year now allocated to Act 64 to pay its +/-525 small and medium conventional dairy farmers to convert to organic.
I do not for a moment underestimate the difficulty of such a change. But to rationalize continuation of conventional Vermont dairy means a buyer must be found willing to pay $30/cwt for 2.6B lbs of Vermont milk when the same product is available elsewhere for $15/cwt.
It means accepting that Act 64 will actually clean up that portion of lake pollution attributable to agriculture when patently Act 64 imposes no material constraints upon the dairy industry’s methodology or its cheap, commodity product.
Business as usual means that after another twenty years and another $700M gone, conventional dairy’s contribution to lake pollution will remain the same, its product and revenue stream will remain the same, the number of active Vermont dairy farms will have shrunk to fewer than 100, all milking in excess of 1,000 cows, all importing increasing amounts of high phosphorus feed supplements, all applying increasing amounts of NPK fertilizer to corn land along our rivers and streams, and all planning to consolidate their neighbors and expand.
The Economics of Conventional Dairy and of Conversion to Organic in Broad Outline:
Vermont presently has +/-650 dairy farms, of which 36 are large (over 700 cows); of which +/-164 are classified as medium (200-699) and of which +/-450 are classified as small (<200 cows). About 200 of the farms in the small category, housing about 15,000 cows producing about 2M cwts are already certified organic. We look first at the economics of conventional farms and then add the organic farms back in at the end.
Vermont’s +/-450 conventional dairy farms house +/-120,000 cows producing 23M cwt, which results in a net loss to the industry year in and year out:
• Gross sales (23M cwts at $15/cwt): $345,000,000
• Cost of production (23 M cwts at $20/cwt): -$460,000,000
• Net Profit (loss): ($115,000,000)
Vermont’s 36 large and 164 medium farms (200 total) house +/- 60,000 or roughly half the state’s cows. But farms over 200 head cannot comply with the National Organic Program (NOP) so conversion of the state herd to organic would send 60,000 cows to slaughter out of the watershed, and with them the manure they produce and the grain imported and grown to feed them. Conversion to organic is, however, possible for the remaining 250 small conventional farms, which with +/-45,000 cows had been producing 19,000 lbs/cow or 8.6M cwts with the following results:
• Gross sales (8.6M at $15/cwt): $128, 250,000
• Cost of Production (8.6M at $20/cwt): -$172,000,000
• Net Profit (loss): ($44,250,000)
Conversion to organic for these 250 farms will entail a loss of production of 20%. These 250 farms would then produce not 19,000 lbs/cow but 15,000 lbs or 6.7M cwts. Conversion would also raise unit cost of production by 25% from $20/cwt to $25/cwt. But conversion to organic also raises gross sales from $15/cwt to $35/cwt. These same 250 farms, if converted to organic, would then have these numbers:
• Gross sales (6.7M cwts x $35/cwt): $234,500,000
• Cost of Production (6.7M x 25/cwt): -$167,500,000
• Net profit (loss): $76,000,000
Adding the 200 certified organic dairy farms with 15,000 cows to the 250 farms recently converted would create a Vermont dairy industry comprising 450 farms and 60,000 cows producing 9M cwts with these numbers:
• Gross Sales (9M at $35/cwt): $315,000,000
• Cost of Production (9M cwt at $25/cwt): -$225,000,000
• Net Profit (loss): $90,000,000
In sum, converting Vermont’s entire dairy industry to organic would in the second year reduce the industry’s contribution to lake pollution by 50%, reduce state support for the industry by a like amount and convert an industry losing $115M/year into an industry making taxable profits of $90M/year earned from the in-state sale of raw milk to their own coop.
Organic farming will be resisted by those farmers with deeply ingrained and understandable fears of backing off on higher herd averages, greater corn acreage and steady production gains, all goals they have fought so hard to achieve in order to remain competitive.
Yet, these goals are the very reasons that commodity milk has lost its value.
Moreover, continuing to resist organic in the face of $35cwt, is hard to rationalize. And we could spend years contesting the large farm/small farm thing and do nothing about $15/cwt milk payments for Vermont’s 250 small to medium-sized conventional, dairy farmers as they disappear one by one. This, however, is incontestable: if they will but transition to organic, Vermont dairy farmers could have what amounts to a monopoly on the state’s brand name. But they need state support.
We all know that the market for Maine lobsters is wider and richer out-of-state than in, just as in Florida the greater, richer market for oranges is realized by adding value and exporting.
In Idaho, this is true for potatoes; in Maryland it is true for crabs; in Botswana it is diamonds and in Friedrichshafen, Germany it is Zeppelins.
Conventional Vermont milk, by comparison, is almost entirely (95%) shipped, in raw form, out of state where others add value, brand it, and reap profits.
At present, the words “organic milk” are linked to no particular region or state: the phrase is available. If Vermont wants to attract workers, to strengthen its brand name, boost its land values and its appeal to tourists, the state should assist our farmers to:
- Convert to organic production
- Organize under a Vermont Organic coop that owns a brand
- Raise capital
- Build infrastructure and distribution
- Offer affluent, east coast consumers a line of dairy products that will forever link in their minds the word “Vermont” to the words “Organic Milk.”
If the farmers were to add to those words the phrase “Fair Trade” and “glass bottled” the product would speak clearly and loudly to urban consumers—the most prosperous demographic in the world lives within a 300-500 mile radius of Vermont—all familiar with, and eager to buy, products thus described and thus supplied.
And, because farmers in New York, New Hampshire, Pennsylvania, Maine, California, Texas, Florida or Wisconsin cannot make Vermont Certified Organic Fair Trade Milk, the product can come from nowhere else.
If 450 of Vermont’s remaining dairy farmers will but take it—and if our chronically, ossified Agency of Agriculture would reorganize itself and lead them to it—a share of the market for organic milk is theirs to claim and theirs to exploit.
Irrespective of the compelling economics of converting to organic, Vermont’s conventional dairy farmers (and their coops) will offer strenuous objections. I address the three I hear most often here:
Conventional Vermont Dairy Farmers are Attempting to Sell what they Produce instead of Producing What They Can Sell!
Converting Vermont dairy to organic would be the first step in a state-supported farm reform plan. The second would be to organize Vermont farmers into a coop and the third would be to grow demand for their product. A very broadly described plan for achieving these three goals can be found at this link:
Bankruptcy as a Solution for Large and Medium Farms:
Vermont’s 36 large and 164 medium dairy farms (those milking over 200 cows) face the prospect of imminent bankruptcy, which is due to a combination of factors over which no one in Vermont has control: free market mechanisms inherent in a capitalistic economy; federal agricultural policies in effect since the 1930s that encourage conventional agriculture while disregarding over production, farm attrition, rural economic decay and water pollution; continuously falling consumer demand for milk and steadily rising farm debt to asset ratios.
Those farmers who find themselves in dire financial straits should find the provisions of Federal Chapter 12 Bankruptcy Protection extremely helpful:
James Maroney holds a BA (Art History) from Columbia University (’71), an MBA from UMass/Amherst (’99) and a Masters in Environmental Law & Policy (Vermont Law School, ‘12). He is the owner of Oliver Hill Farm in Leicester, VT the third and very much the largest certified organic dairy farm in Vermont (NOFA 1989). Maroney has published numerous articles in vtdigger on the problems associated with conventional dairy and its contributions to lake pollution and rural economic decay. He is also the author of “The Political Economy of Milk: Reinvigorating Vermont’s Dairy Farms” (Gala Books, Ltd, 2008.)
 Doug Hoffer, Vermont State Auditor, “Report to the Governor, the Vermont Legislature and the Clean Water Board: Where’s the Money Flowing? Cost-Effectiveness of Lake Champlain Clean Water Efforts.” July 15, 2019
 “Milk Matters: The Role of Dairy in Vermont.” Vermont Dairy Promotion Council, (2015)
 Ross did not ever mention that conventional dairy housing 135,000 cows on 1,250 farms and importing virtually 100% of the artificial fertilizer and the lion’s share of the grain imported into Vermont was the prevailing modality. Neither did he ever acknowledge that organic dairy, numbering around 200 farms housing only 15,000 cows, importing almost no grain and none of the artificial fertilizer, and virtually unknown as a modality until the 1980s could not possibly be the cause of 45-50% of the pollution measured in the lake since the 1960s.
 Nothing would be gained by allowing some conventional dairy farms to exist along with some organic farms: consumers would continue to favor the less expensive conventional milk, which would not reduce over production, low milk prices, farm attrition or lake pollution. The situation is analogous to the addition in the early twentieth century of tetra ethyl lead to gasoline, which is cheaper to produce and causes leaded gasoline to perform like high octane fuel. It was known at the time it was introduced that tetra ethyl lead produces a poisonous gas. Still consumers and producers were not going to give it up unless and until the federal government became convinced that the externalities outweighed the benefits, which did not happen until the late 1970s.