AN ANALYSIS OF CONCERNS REGARDING THE USDA/NOP PROPOSED RULE, THEIR IMPACT ON
SMALL BUSINESSES AND PROPOSALS TO ALLEVIATE NEGATIVE IMPACTS ON SMALL
<< From: "S. Moore" <email@example.com>
>To: "BIODYNAMIC MAIL LIST (E-mail)" <firstname.lastname@example.org>,
> "Lawrence London (E-mail)" <email@example.com>,
>Subject: USDA Regulatory Flexibility Analysis
>X-Mailer: Microsoft Outlook 8.5, Build 4.71.2173.0
>In the uproar over the absurdity of USDA's proposed rules I have heard or
>seen very little about the Regulatory Flexibility Act analysis contained
>therein. I believe this could provide a legal pathway for virtually all
>organic growers to seek relief from the insanity that USDA seeks to visit
>upon us. The RFA, as amended in 1996, provides that a small business which
>is adversely affected by agency action is entitled to judicial review of
>agency compliance with certain aspects of RFA. The agency is required to
>prepare an analysis of the economic impact on small entities of its
>regulatory action. All of this appears to me to be a possible legal path to
>overcome one of the worst features of OFPA, mandatory certification.
>However, as with all other aspects of the rule making process, these issues
>probably need to be raised during the public comment period. The comments
>on RFA, which I am submitting personally and on behalf of the BD
>Association, are presented below. I urge other concerned parties to also
>submit comments to USDA on this issue.
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