Source: NATIONAL COUNCIL OF FARMERS, 9/12/11

The National Council of Farmer Cooperatives (NCFC) today called on Congress to enact a two-year moratorium on all discretionary, non-essential regulatory action that would increase the cost of agricultural production and processing in the United States. NCFC, the national organization representing over 2,500 farmer co-ops across the country, outlined its proposal in a letter to House and Senate agriculture committee leadership.

“A broad range of regulatory actions—both pending at federal agencies or in the pipeline and coming soon to a farm near you—have the potential to increase the costs and reduce the margins of co-ops and their farmer and rancher member-owners,” said Chuck Conner, president and CEO of NCFC. “Whether the regulations deal with the environment, immigration and labor, food safety, or financial reform, they create an uncertainty that threatens to hold back investment and growth across the agricultural sector.”

“Make no mistake, this is a jobs and employment issue just as much as it is an agricultural policy issue,” Conner continued. “Some 21 million jobs across the country are directly or indirectly dependent on agriculture. If our agricultural sector can preserve its competitiveness in the global marketplace, we can grow this number and be an important part of an economic recovery. However, if we are weighted down with costs imposed by regulations of doubtful value, we will lose market share to our competitors and undo the hard work of millions of Americans.”

The proposal calls for a two-year moratorium on these measures, although the it could end sooner if GDP and employment return to robust growth. This ensures that it remains in effect until the U.S. achieves a sustained, substantial economic recovery. It would apply only to what are known as “significant rules and guidance documents” that are subject to review by the Office of Information and Regulatory Affairs of the White House Office of Management and Budget. Any legislation should also include a limited reach-back to capture rules that have been proposed, but have not yet taken effect.

“We believe that this proposal offers a workable, well-reasoned and sensible plan for Congress to enact,” said Conner. “Ensuring that the cost of production is dictated by market forces not government fiat is especially important as the work of the Joint Select Committee on Deficit Reduction begins its work and calls are made to reduce spending devoted to farm and agricultural conservation programs. We hope that the leaders of the House and Senate agriculture committees include this proposal in their recommendations to the Select Committee, which are due in mid-October.”

Actions by all federal agencies would be covered by a moratorium. While not an exhaustive list, the examples below come from regulations being proposed by the Environmental Protection Agency (EPA), which has been very active in the past few years in imposing new requirements on America’s farmers and ranchers:
• Revisions to PM-10 NAAQS that would make the regulation of coarse particles like farm dust more stringent;
• Revisions to livestock reporting requirements that would require livestock and poultry producers to submit detailed information about their operations and to make that information available to the public in a searchable database on the internet;
• EPA and Corps of Engineers Guidance on Identifying Waters of the United States under the Clean Water Act.

For addition background, NCFC has posted an explanation of the proposed moratorium on its web site at http://bit.ly/mQSdQ8.  NCFC’s letter to the agriculture committees is also available online at bit.ly/qhyn0p.