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RAFI-USA Public Comments Submitted 2021-2022

RAFI-USA Public Comments Submitted 2021-2022

RAFI-USA’s policy advocacy happens both through legislation (working with Congress to pass laws) and through implementation (working with agencies like USDA to ensure good regulations and that programs are administered equitably and well).  One kind of administrative advocacy is submitting public comments.  We include below several public comments submitted by RAFI-USA as well as written Congressional testimony.

ON PAYMENTS FOR FARMERS WHO HAVE EXPERIENCED DISCRIMINATION IN FSA LENDING PROGRAMS

The Inflation Reduction Act passed by Congress in August 2022 provided, among many other provisions, $2.2 billion for payments to farmers who have experienced discrimination in USDA’s farm lending programs.  On October 14, the USDA’s Office of the Secretary requested input on how the program should be designed and implemented. RAFI-USA’s comment focuses on making the process accessible to farmers, especially those who may have experienced discrimination for which there is little written documentation.

RAFI-USA submitted a comment on November 14, 2022.  READ OUR COMMENT

ON “POULTRY GROWING TOURNAMENT SYSTEMS: FAIRNESS AND RELATED CONCERNS” 

On September 26, 2022, the Rural Advancement Foundation International – USA (RAFI-USA) submitted comments in response to a request from the Agricultural Marketing Service (AMS) of the U.S. Department of Agriculture (USDA) regarding “Poultry Growing Tournament Systems: Fairness and Related Concerns.”  RAFI-USA has a thirty-year history of advocating for contract growers, and in addition to that long institutional knowledge of the system, conducted research in the summer of 2022 with 105 former and current poultry contract growers to inform its comments.

RAFI-USA submitted its comment to AMS on September 26, 2022. READ OUR COMMENT.

ON THE PROPOSED RULE “TRANSPARENCY IN POULTRY GROWER CONTRACTING AND TOURNAMENTS”

Rural Advancement Foundation International USA (RAFI-USA) and the Campaign for Contract Agriculture Reform (CCAR) recently submitted comments to the Packers and Stockyards Division, Fair Trade Practices Program/Agricultural Marketing Service/ U.S. Department of Agriculture pertaining to the proposed rule “Transparency in Poultry Grower Contracting and Tournaments.” Based upon one-on-one discussions and information submitted by livestock farmers, ranchers, and poultry growers, these comments reflect the experiences farmers have had regarding poultry contracts and the tournament system.

RAFI-USA’s comment was submitted on August 23, 2022. READ OUR COMMENT.

ON SEED INDUSTRY COMPETITION AND THE INTELLECTUAL PROPERTY SYSTEM

On June 15, 2022, the Organic Seed Alliance submitted comments in response to a request from the Agricultural Marketing Service (AMD) regarding the state of competition in the seed industry and the effectiveness of the current intellectual property (IP) system. RAFI-USA contributed to and signed on to Organic Seed Alliance’s comment, focusing on the ways that giant companies use their outsized economic, legal, and financial power to call the shots and dictate conditions for farmers, in an intellectual property system which is ultimately not succeeding in serving the public good.
Organic Seed Alliance submitted its comment to AMS on June 15, 2022.  READ THE COMMENT.

ON COMPETITION IN FOOD RETAIL AND DISTRIBUTION MARKETS 

On May 16, 2022, RAFI-USA submitted comments in response to a request from the Agricultural Marketing Service (AMS) regarding “Competition in Food Retail and Distribution Markets and Access for Agricultural Producers and Small and Mid-sized Food Processors.” Our comment highlighted anticompetitive practices used by dominant retailers and wholesalers that specifically harm regionally scaled and BIPOC producers, processors, and community-rooted food retailers, and detailed a range of antitrust interventions and federal investments that could foster more resilient and equitable regional food retail and wholesale sectors. In compiling this comment, we conducted in-depth interviews and surveys with over twenty Policy Action Network food system professionals with relevant expertise.

RAFI-USA’s comment was submitted on May 16, 2022. READ OUR COMMENT

ON THE MODERNIZATION OF ENFORCEMENT OF ANTITRUST LAWS REGARDING MERGERS

On January 18, 2022, The Federal Trade Commission and Antitrust Division of the Department of Justice sought public comment on how the agencies can modernize enforcement of the antitrust laws regarding mergers. A key overriding question is how effectively the current guidance documents capture the competitive issues raised by mergers today and whether these documents adequately equip enforcers to identify and proscribe unlawful, anticompetitive transactions. RAFI-USA submitted written comments to the Chairperson of the U.S. Federal Trade Commission and the Assistant Attorney General of the Antitrust Division of the U.S. Department of Justice on badly needed improvements to fair competition and antitrust enforcement in today’s food system.

RAFI-USA’s comment was submitted on April 21, 2022. READ OUR COMMENT.

ON THE IMPACTS OF CONCENTRATION ON POULTRY & LIVESTOCK FARMERS

On January 19, 2022, the Subcommittee on Antitrust, Commercial, and Administrative Law or the Committee on the Judiciary of the U.S. House of Representatives held a hearing entitled, “Reviving Competition, Part 5: Addressing the Effects of Economic Concentration on America’s Food Supply.” RAFI-USA submitted written testimony on the impacts of corporate concentration (including monopsony power) on farmers; the harms of the contract poultry “tournament” payment system, the unfair practices and retaliation contract growers can face, and our recommendations for legislative and regulatory policy changes.

RAFI-USA’s testimony was submitted on January 19, 2022. READ OUR TESTIMONY.

ON DATA COLLECTION IN LENDING

On October 8, 2021, the Bureau of Consumer Financial Protection published for public comment a proposed rule to require covered financial institutions to collect and report data on applications for credit for small businesses including farm businesses. Based on our work advocating for and with farmers who are experiencing financial crisis and helping them access credit, and the discrimination we have seen in the course of that work, RAFI-USA submitted a comment in support of the increased accountability this proposed rule would bring.

RAFI-USA’s comment was submitted on January 6, 2022. READ OUR COMMENT.

ON EXPANDING MEAT & POULTRY PROCESSING INFRASTRUCTURE

On July 16, 2021, The USDA sought public input to develop strategies that support President Biden’s Executive Order on Promoting Competition in the American Economy and enhance competitiveness in the meat and poultry processing sector, specifically on how to invest an estimated $500 million of American Rescue Plan funds to improve infrastructure, increase capacity, and hasten diversification across the processing industry. 

RAFI-USA’s comments were submitted on August 30, 2021. READ OUR COMMENT

ON RACIAL JUSTICE & EQUITY AT USDA

On June 16, 2021, the USDA sought public input on how USDA could advance racial justice and equity for underserved communities as part of its implementation of Executive Order 13985, Advancing Racial Equity and Support for Underserved Communities Through the Federal Government. 

RAFI-USA’s comments were submitted on August 14, 2021. READ OUR COMMENT

ON FOOD & AG SUPPLY CHAIN RESILIENCE

On February 24, 2021, President Biden issued an Executive Order on “America’s Supply Chains,” which directs several Federal agency actions to secure and strengthen America’s supply chains. The USDA requested comments to help inform a report to the President that assesses the supply chains for the production of agricultural commodities and food products. They also requested comments on how stimulus relief programs and spending can help to increase durability and resilience within the U.S. food supply. 

RAFI-USA’s comments were submitted on June 17, 2021. READ OUR COMMENT

ON TACKLING THE CLIMATE CRISIS

On January 27, 2021, President Biden issued an Executive Order on Tackling the Climate Crisis at Home and Abroad. The USDA sought input from the public on a climate-smart agriculture and forestry strategy. 

RAFI-USA’s comments were submitted on April 29, 2021. READ OUR COMMENT

ON GRANTS AND LOANS TO SMALL / MID-SIZED PRODUCERS, MARKETS, & PROCESSORS

USDA’s Agricultural Marketing Service sought feedback regarding the possible development of new grants and a new food purchase program. RAFI-USA submitted our comment on March 31, 2021. We also share guidance on how to comment and invited comments from stakeholders. READ OUR COMMENT