At 11:41 PM 4/26/98 -0400, Sprinkraft wrote:
>
>To: Steve Moore: OFMA undertook an analysis of the RFA in 1996. Eric Kindberg
>was the lead author. Cecilia Bowman in Indiana also served as research
editor.
>The OFMA analysis of the Proposed Rule also covers some of those concerns.
The
>RFA analysis is a year and half old, but still useful. I hope that it is of
>some service. Please refer to
<http://www.iquest.net/ofma>http://www.iquest.net/ofma. The RFA analysis
>link is half way down the page.
>
>Steve Sprinkel
>OFMA
>Austin
>
>10/24/96
>
>AN ANALYSIS OF CONCERNS REGARDING THE USDA/NOP PROPOSED RULE, THEIR IMPACT ON
>SMALL BUSINESSES AND PROPOSALS TO ALLEVIATE NEGATIVE IMPACTS ON SMALL
>BUSINESSES
>
><< From: "S. Moore" <sfmoore@earthlink.net>
> >To: "BIODYNAMIC MAIL LIST (E-mail)" <bd-l@biodynamics.com>,
> > "Lawrence London (E-mail)" <london@sunsite.unc.edu>,
> > <organic-certification@listserv.oit.unc.edu>
> >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.
> >
> >Steve Moore
> >Moore Ranch
> >Carpinteria, CA
> >sfmoore@earthlink.net
> >================= >>
>
>To Unsubscribe: Email majordomo@ces.ncsu.edu with "unsubscribe sanet-mg".
>To Subscribe to Digest: Email majordomo@ces.ncsu.edu with the command
>"subscribe sanet-mg-digest".
>
An organic growers homepage check out
http://www.rain.org/~sals/my.html
To Unsubscribe: Email majordomo@ces.ncsu.edu with "unsubscribe sanet-mg".
To Subscribe to Digest: Email majordomo@ces.ncsu.edu with the command
"subscribe sanet-mg-digest".