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

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 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


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