OTA presented a strong data-driven case presented that proves USDA's economic analysis remains flawed.

May 28, 2020

2 Min Read
Organic Trade Association again refutes USDA claim that costs of animal welfare rule exceed benefits

The Organic Trade Association on May 26 soundly invalidated the Department of Agriculture's economic analysis of the benefits of the Organic Livestock and Poultry Production (OLPP) final rule, proving multiple flaws in USDA's analysis that demonstrated a concerted pattern by the department to skew and cherry-pick statistics in order to support its withdrawal of the organic animal welfare rule. 

In official comments filed in the Federal Register, the Organic Trade Association and an expert economist's report revealed numerous errors in the USDA's report and identified a pattern of erroneous manipulation of economic variables that intentionally understated the benefits of the OLPP Rule and overstated the costs. The association's economic analysis targets and refutes specific data points used in USDA's cost-benefit calculation for organic egg production that USDA had intentionally changed so that the cost-benefit calculation would result in higher costs and lower benefit.

To further refute USDA's manipulated variables, the Organic Trade Association collected organic flock production records for 5.6 million organic hens to show that actual productivity is higher and mortality rates are lower than what USDA proposed in its report. Despite the short 30-day comment period, the association developed a strong data-driven case that proves that benefits of the OLPP Rule clearly exceed the costs, and that USDA's withdrawal of the OLPP rule is unsubstantiated. 

USDA published its Economic Analysis Report in response to a court order in March that agreed with the Organic Trade Association's lawsuit against USDA that the OLPP final rule was withdrawn based on a flawed economic analysis. Finding that USDA had voluntarily conceded the Organic Trade Association charges rather than proceed to judgment, the court ordered the matter returned to USDA for a 180-day period for the agency to correct its errors. 

The trade association said USDA's published economic analysis of the OLPP  was so deficient that "as currently written it cannot be a ground for substantiating the Withdrawal Rule." 

The association also renewed its request that USDA extend its comment period to its analysis, saying that "the principal problem of the Department's approach these last 38 months has been the persistent lack of meaningful opportunity for the affected parties and the public to provide comment." 

Source: Organic Trade Association

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