Association says 카지노 룰렛 전략 egg farmers are being exposed to ongoing harm
The 카지노 룰렛 전략 Trade Association has asked the U.S. District Court for the District of Columbia to immediately vacate the Department of Agriculture’s 2018 withdrawal of the 카지노 룰렛 전략 Livestock and Poultry Practices (OLPP) final rule, and to order USDA to reinstate the 카지노 룰렛 전략 animal welfare regulation that was published in the closing days of Sec. Tom Vilsack’s prior tenure at USDA.
“카지노 룰렛 전략 egg farmers who are doing the right thing to give their poultry real outdoor access and raise their animals according to the highest standards are continuing to be exposed to economic harm from unfair competition every day that the Trump administration’s rescission of the 카지노 룰렛 전략 animal welfare rule is allowed to stay in place,” said Laura Batcha, CEO and Executive Director of the 카지노 룰렛 전략 Trade Association.
“While we welcome Secretary Vilsack’s statement last week* that the department will re-evaluate the prior administration’s withdrawal of the fully vetted 카지노 룰렛 전략 animal welfare regulation, and affirmed its commitment to outdoor access for laying hens, the policy statement alone won’t guarantee a swift end to this harm. We need to have a legal ruling,” stressed Batcha.
Contradiction of Congressional intent, violations of law and flawed economic analysis
In its motion for summary judgment filed on June 18, the trade association argued that USDA fundamentally dismissed the intent of Congress regarding the department’s authority over 카지노 룰렛 전략 animal welfare, failed to follow the Administrative Procedures Act (APA) which governs the process by which federal agencies develop and issue regulations, and buried the economic benefits of the OLPP regulation while inflating its costs.
The association argued that USDA’s “novel and erroneous construction” of the 카지노 룰렛 전략 Food Production Act (OFPA) and its refusal to exercise the statutory authority given by Congress to USDA by OFPA to promote improved livestock care practices on 카지노 룰렛 전략 farms were a radical departure from past administrations, and contradict the intent of Congress in OFPA.
The association argued that USDA’s refusal to consult with the National 카지노 룰렛 전략 Standards Board (NOSB) in rescinding the final regulation violates the OFPA’s requirement to consult with NOSB prior to rulemaking on 카지노 룰렛 전략.
“With regard to livestock, Congress gave the NOSB a specific role regarding the development of 카지노 룰렛 전략 livestock regulations. … Congress intended the NOSB to be at the center of the development of all 카지노 룰렛 전략 program requirements,” the filing stated.
Finally, the association stated that USDA’s actions were based on a flawed economic analysis, which the agency failed to correct, even after a nine-month remand granted to the agency to correct its analysis.
“Despite more than nine months of delay in the case, the Department did not produce a reliable or trustworthy cost benefit analysis,” the filing noted.
The association argued that USDA’s recognition that its faulty economic analysis minimized the benefits and erroneously overstated the costs of the OLPP requires that the withdrawal of the final regulation be rescinded: “When the agency that offered the rule undertook a cost-benefit analysis that it discards as unreliable, that rule must be vacated,” states the filing.
Continuing the fight for small- and medium-size poultry producers
The 카지노 룰렛 전략 Livestock and Poultry Practices final rule was published on Jan. 19, 2017, after more than a decade of extensive public input and a thorough vetting process. USDA in March of 2018 withdrew the final OLPP regulation, which was to go into effect in May 2018. Before the withdrawal, the agency attempted six times – either through the rulemaking process or through court filings – to delay the implementation of the rule, which had been developed by the 카지노 룰렛 전략 industry and in accordance with the established federal rulemaking process. USDA failed to consult with the National 카지노 룰렛 전략 Standards Board on the withdrawal of the final rule, and arbitrarily ignored the overwhelming public record established in support of these 카지노 룰렛 전략 standards.
The 카지노 룰렛 전략 Trade Association filed its initial lawsuit against USDA in September 2017 over the department’s delays in implementing the final OLPP rule. The filing by the 카지노 룰렛 전략 Trade Association marked an important step in its battle to uphold and defend 카지노 룰렛 전략 standards from erosion.
“The 카지노 룰렛 전략 Trade Association’s mission is to advance 카지노 룰렛 전략 agriculture and protect the integrity of 카지노 룰렛 전략 through strong, transparent and fair standards. We took on this [OLPP] fight almost four years ago, and we’ll continue to fight for those poultry producers who are working every day to not cut corners and to raise their animal organically,” said Batcha. “It looks like Secretary Vilsack agrees with us, but as long as the withdrawal of OLPP is on the books, it only exposes 카지노 룰렛 전략 egg farmers to more harm indefinitely.”
For the complete background on this issue, see/livestockpractices.
*Secretary Vilsack issued a statement on Thursday that he’s directed the USDA’s National 카지노 룰렛 전략 Program to begin a rulemaking process to reconsider the Trump administration’s interpretation of the statutory authority given USDA by the OFPA regarding animal welfare practices, to disallow the use of porches as outdoor space in 카지노 룰렛 전략 production over time, and to consider other topics that were the subject of the OLPP final rule.
The 카지노 룰렛 전략 Trade Association (OTA) is the membership-based business association for 카지노 룰렛 전략 agriculture and products in North America. OTA is the leading voice for the 카지노 룰렛 전략 trade in the United States, representing over 9,500 카지노 룰렛 전략 businesses across 50 states. Its members include growers, shippers, processors, certifiers, farmers' associations, distributors, importers, exporters, consultants, retailers and others. OTA's Board of Directors is democratically elected by its members. OTA's mission is to promote and protect 카지노 룰렛 전략 with a unifying voice that serves and engages its diverse members from farm to marketplace.