Farm Bureau in the Regulatory Process

Tennessee Farm Bureau's voice is easily recognizable in the Tennessee General Assembly and in Congress, advocating for bills supporting agriculture and against potentially harmful ones. However, an area where TFBF's impact may not be seen but is equally as important is through the regulatory process, specifically by submitting public comments.

The federal government's regulatory process is lengthy. Once an agency is given the statutory authority to issue specific regulations, it develops a proposed rule - a draft proposal for how the agency intends to execute its regulations. This is made public on the Federal Register's website, and the public may provide comments for a pre-determined period - 30 to 120 days depending on the extent of rule. Once completed, the agency is required to read and consider all the comments submitted. The agency then releases a final rule, making any changes needed and responding to all comments provided.

TFBF tracks this process for multiple federal and state agencies, including the USDA, EPA, FDA and others, and provides comments on behalf of our members. After thoroughly evaluating the merits of a proposal, TFBF provides input when necessary, using both existing TFBF policy and by seeking input from commodity advisory committees, farmers and other stakeholders.

In the past year, TFBF has submitted comments or sent letters on more than 30 different regulatory actions. Some examples include:

• Opposing efforts by EPA to impose strict restrictions on pesticides. After receiving many lawsuits about their non-compliance with Endangered Species Act obligations, EPA developed a plan proposing numerous changes to the pesticide registration process and suggesting requirements for pesticide applicators. TFBF is continually monitoring this process, has already provided comments on an herbicide-specific strategy and is evaluating an insecticide-specific strategy.
• Supporting re-registration of 3 over-the-top dicamba products - Xtendimax® by Bayer, Engenia® by BASF and Tavium® by Syngenta. These products' labels were vacated by a Federal court in February 2024. TFBF asked EPA to grant an existing stocks order for the 2024 crop year and supports the registration of these products for the 2025 crop year.
• Supporting improvements to poultry grower pay systems. USDA proposed establishing minimum base pay requirements in production contracts for live poultry dealers and requiring disclosures from live poultry dealers requesting capital improvements.
• Opposing increased restrictions on agriculture in National Wildlife Refuge Systems. The U.S. Fish and Wildlife Service developed a proposal to enact heavy restrictions on agriculture in refuges, and due to resounding opposition from the agricultural community, has slowed action on this proposal.

To access comments submitted by TFBF, click here.