Fwd: Regulatory Flexibility Analysis
Fri, 01 May 1998 07:07:54 -0700
>From: "S. Moore" <email@example.com>
>To: "Sal Schettino (E-mail)" <firstname.lastname@example.org>,
> "BIODYNAMIC MAIL LIST (E-mail)" <email@example.com>
>Subject: Regulatory Flexibility Analysis
>Date: Thu, 30 Apr 1998 18:59:17 -0700
>X-Mailer: Microsoft Outlook 8.5, Build 4.71.2173.0
>>4/26/98 -0400, Daniel Worley wrote:
>>>Sal and the BD List;
>>> I hate to throw cold water on such a good idea, but the $5,000.00 gross
>>>income limit is not a proposed part of the rules. It is already codified
>>>in the OFPA and therefore I believe excempt from the RFA rules.
>>> In this particular point, the USDA has no choice but to follow the law
>>>(OFPA), although I personally don't think they were unhappy about that
>>> The only way I know of to increase the gross income allowed in the
>>>definition of a small operator (farmer or handler) is to convince your
>>>Congress Critter to change the law.
>The $5000 gross income limit exemption has little or nothing to do with the
>RFA analysis issues that USDA is required to address. USDA attempted to
>circumvent their responsibility in this manner by arbitrarily redefining the
>meaning of "small entity", but their ploy can be seen for what it is , a
>sham, as is the rest of their proposed rules.
>For a cogent legal comment on the proposed rules see Aleen
>Rothschild-Seidel's submittal to USDA on behalf of Demeter at:
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