Farm Legal Series #3: Selling Bulk Meat? The Legal Side of Livestock Sales.
Welcome to the third episode in Barn2Door's series in partnership with the Farm to Consumer Legal Defense Fund. FTCLDF is a non-profit organization of lawyers supporting Farmers across the country and helping them navigate the unique legal challenges Farmers face. In this episode, we focus on livestock, herd/meat share regulations, how they vary across the country, and the resources FTCLDF has to help Farmers sell their products direct-to-consumer.
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James, Barn2Door: 0:26
Welcome everyone to the Direct Farm Podcast. We've got a great conversation for you today with a Farm to Consumer Legal Defense Fund. This is our third episode in a series of podcasts with the farm to consumer legal defense fund. To help you learn more about the legal ramifications and challenges and how to get over those things that might be facing your farm. In the prior episodes, we dove in on dairy and poultry operations, but today we're going to be discussing livestock. And in particular, we're going to be diving into legal nuances of selling livestock herd shares, direct to market. I'm delighted to welcome back Alexia Kulwiec. She is Executive Director of the Farm to Consumer Legal Defense Fund, and she's a licensed attorney in Illinois and Wisconsin. practiced law there for over 20 years and her experience has inspired her interest in US agriculture and promoting small scale farmers and sustainable farming while helping protect the rights of independent producers like you across America. Welcome back Alexia, thank you for joining me today.
Alexia, FTCLDF: 1:24
Thanks so much for having me.
James, Barn2Door: 1:26
We're delighted to dive in on this topic and I'm sure there's many listeners today who are eager to hear your thoughts for some of the listeners who may have missed the past two episodes. Can you just rewind for us real quick and just help them understand again, who the Farm to Consumer Legal Defense Fund is?
Alexia, FTCLDF: 1:42
Sure. Thank you. So Farm to Consumer Legal Defense Fund is a nonprofit organization that provides legal representation to small, independent farmers and food producers, as well as work on policy to make it easier for small farms and food producers to directly produce their goods and sell it directly to consumers. The focus is really on how. Policy is aimed at regulating large operations. And so it can really be both a challenge and really difficult both to comply with regulations and even figure out what they all are. Because when you have a small farm there's relevant, federal laws, state laws, and then township, county laws also get in the way. So we help folks with consultations. We help them through the regulatory process. In the dairy podcast, we talked about doing herd shares. So folks can provide raw milk to customers and states where the sales of that would be unlawful. So really focusing on any legal representation where government regulation is, what is creating problems for small producers and food producers.
James, Barn2Door: 2:49
Well, I know you guys do fantastic work and as an attorney, I appreciate the complexities that you're dealing with because it does vary dramatically, not just state to state, like you said, but even at the local and county level, just, you know, a lot of ambiguity and for those of you who may want to learn more about the farm to consumer legal defense fund, you can go to their website at FarmToConsumer.org and there you can access a variety of resources. And more importantly, if you want to sign up with them, it's just $125 a year to get free legal consultation on an ongoing basis. And you know, what's great about the work you guys do Alexia, you guys have a whole network of attorneys isn't that correct?
Alexia, FTCLDF: 3:30
We have a core group that really works with folks on a consultation level. When we have actual legal representation and problems that arise, we have a network of attorneys barred in the different states to reach out to provide that representation.
James, Barn2Door: 3:43
So great. I'm so thankful for the work you're doing and delighted to partner with you. Well, let's dive into today's topic and talk a little bit more about livestock herd shares. Some may call them meat shares. We'll just call them herd shares for today's just to avoid going back and forth so many times. Let's talk a little bit about that term specifically, what is a herd share and how is that different from taking livestock to a sale barn? For, instance?
Alexia, FTCLDF: 4:07
So, a herd share is really getting at similar, we discuss it in dairy, is a livestock producer is selling a share in his or her herd to the end consumer looking for meat products. And the idea of being here is establishing a regular relationship between the farmer and the customer whereby the customer can have a portion of the animal or herd. And then that can be brought to a custom slaughter facility. And that's usually meaning that it can be slaughtered and processed for the customer in a facility that is much closer to the producer. It can process them in the way that the customer wants, and it alleviates the yearlong waits that we're currently seeing in federal and state livestock processing facilities, which has really become a problem for small producers. They can't even get into the processing facilities to process meat.
James, Barn2Door: 5:01
Yeah, I know there's a lineup for many proteins producers just to get their kill dates on the calendar. It's not just like months in advance, but like you said, sometimes beyond a year,
Alexia, FTCLDF: 5:11
Yeah, it's beyond a year now and it's just cost prohibitive for a small producer to carry some of those animals for that time period, right. To maintain, and to feed, and to care for them for longer than they were planning on.
James, Barn2Door: 5:21
That's unfortunate. Hopefully we can see some of those things loosen up and certainly great to hear the herd shares, provide another avenue for producers who might have some of those limitations in their state. Might be looking for another avenue to sell direct to consumer. So let's talk a little bit more about that. What are some of the bigger legal challenges that farmers face when selling herd shares direct to market specifically? Like what's it take for them to get this set up? What's the rationale behind the regulatory framework?
Alexia, FTCLDF: 5:49
Yeah. So the one thing that I'd like to, I'm gonna, I think I have to take a step back for it to all make sense, right. Which is the regulatory context that this is in is the federal meat inspection act requires that any livestock that is then processed and the meat is sold to consumers, has to be brought to a federal inspection facility or to a state inspection facility. And so what livestock producers can't do for example is just raise a small number of livestock slaughter and process that meat and sell it to consumers. So the whole idea, and I'm sure some of your members are already familiar with the idea of sharing an animal, right? And that you can buy a quarter of an animal, and then it's brought to custom slaughter. It can be processed for the customer and not brought to one of those larger facilities. The difficult. The real challenge with that is that meat that comes from a custom facility as opposed to a federal or state facility can not be sold. In other words, you have to bring an animal to the facility. The processor processes it for the customer, but it can't be sold or resold. So the big legal challenge, I think for livestock producers is to how best get locally healthy, produced meat into customer's hands on a timely basis. By doing the meat share, I almost hate the idea of saying selling meat shares, or herd shares, but you are, is you're selling then an actual portion of the herd, right? And so what's going to be needed legally. If you're doing that is both a bill of sale and then presuming that the customer doesn't actually want to take some of the herd to their backyard or their apartment to raise it. They're going to need some kind of a boarding and maintenance contract or agreement with the producer. So legally you need those contractual documents. You will need a bill of sale. You will need a boarding agreement, but then what happens is as opposed to having to worry about selling meat, that hasn't been brought to an inspection facility, the customer is an owner of the herd and will now be able to have meat processed at a custom facility for their own use and the use of their personal families. They can't resell it, but they can use it for themselves. So it's a way to make that process smoother for everyone.
James, Barn2Door: 8:08
So I'm going to try to what you just said and based on heard and try to put in layman's terms, Right, So essentially you're getting around the notion of, harvesting the animal, then selling the products that have been cut and packaged. Essentially what you're doing is you're selling the rights or interest in the live animal that then are harvested, cut and packaged, right. So you're not selling the cut package, you're actually selling the interest in the animal, right. So it's a nuanced legal difference. But to your point, because there, because of these subtle differences, it does require. Like you said at bill of sale, a maintenance agreement for boarding and maintaining and caring for that animal. The good news is that farmers who worked with the Farm to Consumer Legal Defense Fund and with Barn2Door, we can help automate some of these things that make this turnkey for your farm. So, okay. Let's, let's talk a little bit more about the regulatory aspects. So first off, how do I even know what the regulations are in my state, does every state require a herd share agreement, or is it just a handful of states? And where would I go to, figure it out?
Alexia, FTCLDF: 9:13
Couple of responses, first of all, first and foremost, where to go to see if it applies to you of course, as to come to the Farm to Consumer Legal Defense Fund. And what I just want to say is on our website, if you go under resources, there is a red meat map. That explains some of the nuances between the states.
James, Barn2Door: 9:32
That's farmtoconsumer.org and then you navigate to the resources tab, and then I see it right now. I'm navigating right.
Alexia, FTCLDF: 9:39
Yeah.
James, Barn2Door: 9:39
Website right there. You have a whole variety of fantastic maps, raw milk map, cottage, food map, poultry map. And there it is red meat nation, right. So that's the one you say it's going to be updated by January of 2022.
Alexia, FTCLDF: 9:52
Correct. Hopefully very soon. And so what I want to point out before getting into the details of states that have these, herd shares statutes, which a couple have very specific statutes is the general idea, when you purchase a share in an animal or a share in a herd the animals are brought to custom slaughter facility and process for the customer. What the chart is getting into and one of the legalities you need to worry about is what limitations may exist state by state for custom slaughter processing, in other words, there is an exemption that allows producers to sell live animals, a portion of a live animal, or portion of a live herd. And then the animals brought to the custom slaughter facility, but certain states may have tougher restrictions on the custom slaughter requirements. So some limit how many people can own the animals, some limit who can slaughter the animal to bring it to custom processing. So there's a number of things that state by state get delineated. So it is important in those states to understand if there's any limitations to the custom slaughter exemption.
James, Barn2Door: 10:59
That's really important, because like you said, you certainly don't want to run a foul of these rules. Right? So what happens if you do run a foul of these rules, like how stiff are the penalties? Can you give us any sense? I mean, obviously it's going to vary state by state, but what are the, what are the impacts for a potential farmer?
Alexia, FTCLDF: 11:15
It varies, but honestly, more so than a penalty. What is so damaging is that the state department of Ag and it usually is state at this point will shut down the operation and may even confiscate products. So they think you're selling products that has been unlawfully has not been inspected or unlawfully brought to custom slaughter for resale or something along those lines. They will confiscate the product and not allow the producer to then, you know, be able to benefit from that. So while the producer may have sold a portion of the live animal, if the customer then can never get the meat from that animal, I think then you're going to have a real legal battle. Right. And so it's more what they've lost in terms of potential sales. You know, beef cattle they're large animals. There's a lot of profit in that animal. So, I mean, I think some states do have a variety of penalty and fines in place, but honestly the biggest detriment is getting your business shut down or getting the product confiscated that has a lot bigger economic consequence than anything else.
James, Barn2Door: 12:12
Well, this is a great call to action again, for all of our listeners to go to farmtoconsumer.org and go sign up for a membership with Alexia and her organization. It's literally just $125 a year, and that gives you access to not only to Alexia and her team, but also to a hotline. If you have questions in addition to all the other resources online. Back to your point too, it's super important to document these things. I know having visited many processing facilities that, you know, not just obviously the USDA and state inspected facilities, very routinely, you see inspectors there all the time, but custom processing facilities often have inspectors coming by on a routine basis. So you want to make sure that you've got the proper documentation there. That there's no question whatsoever. like you said, even just one live animal. Most times we see a cow that's going to be going for somewhere between $3,500-$4,500. In terms of total retail value. $125 for a Farm to Consumer Legal Defense fund membership. It's just a drop in the bucket in terms of profit. So take the precaution that's needed, get the agreements, put in place, get some sound legal advice. And then make sure you have comfort and confidence that you can conduct businesses as you need to. Well, let's talk a little bit about what it looks like in terms of how do you get things set up and how do you make a herd share you know, consumable by a consumer, right. This notion of hanging weights, and what's a quarter cow and half a cow, right. These are novel terms for many people. What's it look like? What are, what are the steps that somebody should be thinking about when they want to get started setting up a herd share and making this available to prospective consumers?
Alexia, FTCLDF: 13:45
You know, the one thing that I'll point out is that there is not a requirement that a producer necessarily use a particular weight or measure in terms of figuring these things out. And as a matter of fact, what's really a better way of a producer thinking about it is determine whether it's an animal or herd, how much is one share worth, so to speak. And then what's neat about the herd share, as opposed to a single animal is then, you know, you don't have to sort of redo. I don't think all of these documents, every time you bring an animal to slaughter, whereas if you're buying a portion of a single animal, you have to make sure that that's the animal. But in any case it's really a percentage basis and then you would bring an animal for slaughter. You know, and it's, it's, you're going to have to end up as a consumer with a particular volume of product. And you may or may not be able to end up with ordering specific cuts of meat, because not if you have eight owners, you can't all get the exact same cuts of meat. And that's something that the parties will need to work out and, and instruct the processor on. So, but what I will say is I mean, I have seen producers reference hanging weight, but it's usually just a percentage base of live animals because you are selling them while they are live. Right. And so I think that is really the key
James, Barn2Door: 15:01
I would love to just add to this, because I know we work with many farmers who do sell it by quarter, half, and whole. And Andy who use many of the herd share agreements that you guys have assembled for them. What's great. So we can make those effectively like a click wrap agreement as part of the purchase, which is fantastic. But the big thing, like you said is just simplifying the cuts and making it simple, such that you're not giving any certainty or promises per se out to everyone. We find that if you can just say, Hey look. You know the animal, we expect that the hanging weight to be, you know, between these ranges and you're going to get a mix that may look like this versus saying, it will be this, say, it may look like this. It'll probably be a mix of these types of cuts and these types of bundles of this much burger. You know, guess what your consumers today, by the way, they want to support you as a farmer. And they're going to be flexible. Save yourself some time. right. The person who wants, finicky and wants that one cut of steak, guess what? There's a hundred other people who will gladly just take whatever you give them. You don't have to get so caught up with all these different things. So I appreciate that. Go ahead.
Alexia, FTCLDF: 16:05
If I can, I do want to one thing about what you just said that I would like to clarify in that is when folks join, and we do encourage it, right. We will do agreements for folks. We'll draft the bills of sale and we have templates and it's not a very arduous process, but we do like to meet one-on-one with our members because they're all in different states. The custom slaughter rules are different. And then a couple of states, which I think we should discuss at some point have now specific meat bills, Wyoming, Colorado, and Nebraska have very clear legislation about what's required to do this. And Wyoming was really the first state. In large measure, we used that statute and their legal requirements as a model for what we draft and provide to our members when they want to do this kind of work.
James, Barn2Door: 16:50
You make a great point, right. Which is even within a state like Colorado or Wyoming, there could be variation from one county to the next or one location to the next, so all the more important to get legal counsel to give you advice on what pertains to you specifically in your area. And I think we were talking before this podcast even got started is first off you guys, as part of being a member to consumer Defense Fund, they'll get consult one-on-one with you or somebody on your team. And then in addition to that, then you'll get an agreement a herd share agreement that is specific to that farmer ranch in their locality, Right, Because like you said, one county might have a different set of overlaying rules that are in addition to the state. So, let's, let's take a step back. Talk about the states. You mentioned a few Colorado, Wyoming what are the big three to five states that really kind of constantly are raising their hand and needing a lot of work versus if I'm a rancher in another part of the country, where is less of a concern, I'd love to hear your thoughts on that.
Alexia, FTCLDF: 17:47
Well, one thing I want to say, I'm seeing farmers and ranchers want to do this kind of sales of animals or sales of a heard share more frequently just about everywhere. We've definitely had some in the more upper east coast, some down in Texas, some in the Southeast the couple of states that I mentioned, aren't so much the states where people are needing attention, but those are the states that have chosen to make it crystal clear in their state statutes that this is a permissible practice. So we've had more activity in those three states, not because they're problems, but actually those are the states where the legislatures have made crystal clear that it is permissible to do this. I think I said to you before we started recording that when Colorado passed its meat share law, just this year in 2021, there was some discussion in the legislature that well, I don't see anything that would stop a producer from doing this already, right? The whole why do we need a law if it's already permitted and I take that view while some states have custom slaughter limitations, the mere idea of selling a portion of an animal or selling a portion of a herd and doing it under contracts and bringing it to custom slaughter, I think is perfectly legitimate under the federal exemptions. And you, you do have to pay attention to specific state laws. What some of the folks in Colorado said was, yeah, we agree that we don't really need it, but some inspectors in certain areas disagree with that. So we see no reason not to make it crystal clear and put it on the statute book. Outside of those states, there's a tiny risk because it's not crystal clear, but the way you read the federal exemption says to me, that is perfectly fine but I have come across individual inspectors who are not keen on the practice, then we'll push back. Right.
James, Barn2Door: 19:36
All right. So let's, let's just, again, just let me restate what I heard just in layman's terms. So there's a set of federal requirements that appears this exemption is, is a common exemption or common practice, pretty much across the country. Right. I know we have farmers pretty much in every single state that do this. Sell by quarter, half and whole. No question about it. So, but what you're saying is in the absence of an express authorization, there could be some perceived overreach maybe in at the state or county or local level. Where people might be maybe it's your local department of agriculture, or ecology who are looking for these types of, clarification's. right. And so in those cases, you're saying there are some states that have gone to that step to make it crystal clear to get farmers certainty, right? Cause obviously this is a big investment. It's a large valued product. So you want to have some degree of certainty. So makes sense. And by the way, I agree with you too. You know, I'm just looking at, we wrote an ebook earlier this year called skip the sell barn and sell direct. And it just looking at the numbers right now, it's only been out for six months and we literally have thousands of downloads of that. Clearly this is a issue that's top of mind with many like you said, who are constrained by the access to the state and USDA processors. Are there any recent changes that you've seen that are limiting or constraining herd share?
Alexia, FTCLDF: 20:56
Wyoming last year in 2020 had passed its meat share agreement in Colorado and Nebraska made it easier this year. I have not yet seen any state take any action to make it more difficult to do this. However, I will say that the SSIS within the USDA had brought a proposal to a national advisory committee on meat and poultry. The idea that perhaps they should put more limitations on the custom slaughter process. It's not even a proposed regulation, like in the federal notice requirements, but it was brought to this national advisory committee and the proposals were to limit how many numbers of individuals can own an animal or herd share, how many, and pointing out that a group can not be the owner of the animal, you know? So when people want to come together, but be purchased like as an institution and then having more record keeping requirements.
James, Barn2Door: 21:53
I hate to say this, but that sounds very un-American. And certainly unpopular at this time when there's such constraints on our global food system. If anything you'd think would be encouraging loosening of any type of regulatory oversight here and, encourage people to purchase locally, right from if I know you and you're the rancher down the road from me, and I've known you and our kids played together school on soccer or whatever, or a baseball team. I see at church every week, I know how you take care of those animals. Why, why shouldn't I be able to purchase my from you?
Alexia, FTCLDF: 22:27
Yeah. It's a perfect example of how consumers, like you say, want to purchase directly from their local farms or ranches, and then the regulations make it more difficult to do so, now this one did not become law. It's something that we're watching, but it was fairly recent, which to your point, we know consumers want this. We saw the detriment of the vulnerability of our food system as COVID hit and processing plants shut down. Why would this be the proposal? Right. It makes no sense and is disturbing. So, there are a couple other things that are just kind of out there and have been introduced at the federal level that I wouldn't mind touching on, but I haven't seen much at the state level. So at the federal level, this is not a new law. It's been reintroduced a number of times with the PRIME Act that would allow folks to actually sell meat that's been processed at a custom slaughter facility. So that has been introduced a number of times. And I think, I just want to say your members will know, but the custom slaughter facilities are still regulated by the federal government. The only difference is that there's not an inspector on site for each and every slaughter of animals. Right. And PRIME Act would allow those facilities to be used and then sell that meat.
James, Barn2Door: 23:43
I found it it's called the Processing Revival in Intrastate Meat Exemption Act. The prime act makes a lot of sense to me, right? So like you, said, why not there, you're not selling it across state lines. It's intrastate inside the state, and, you know, would provide an express exemption, allow people to do that. It seems to make a lot of sense, common sense. We'll see. I'm going to add it to my prayer list. Cause I really hope this goes through. It certainly would help many farmers across the country and, and consumers who would like to be able to purchase.
Alexia, FTCLDF: 24:11
Yeah. And I will say that it's gotten a lot more support this year. I don't know exactly where it is if it's sitting in committee, but you know, I think the first couple of times, people, other legislators from non- ranching states were very leery of this idea. And now I think the general public is starting to understand more that how this would help smaller producers and help consumers purchase from their neighbors, right. So that would be good. There's a couple of statutes that are aimed at providing some additional monies to increase capacity of processing facilities or to fund new custom flatter facilities, but all of that is really gonna take some time. And there is, there's also one new pending federal suggestion called new markets for state inspected meat and poultry act. That's a mouthful, but basically saying that if it's if your meat has been slaughtered and processed at a state inspection facility, instead of a federal one that you can sell interstate,
James, Barn2Door: 25:09
Hm,
Alexia, FTCLDF: 25:09
Currently at a state facility has to be in only within the state in which that facility is. Which really is silly because the federal law says all meat has to be inspected at a federal facility or state facilities that are as strict or stricter than federal facilities. So why limit a state facility sale to being intrastate again, doesn't make a
James, Barn2Door: 25:32
I know. I I was actually on the phone with a compliance officer for one of the states, which will remain unnamed. And we were talking about how silly this was, because literally you can be in the state adjacent to it. And this, by the way is a true story. It happens to be one of our, our farms that we support who uses a state inspected facility. We talked with the compliance officer. They sell to some businesses across state line. But they have to simply have an audit trail to prove that the pickup is intrastate. So the sale actually occurs in the state.
Alexia, FTCLDF: 26:05
In their state.
James, Barn2Door: 26:06
We have documentation. We prove where the pickup location is and sure enough, the business comes across state lines purchase, picks it up, goes right back across the state line, 15 miles away to their restaurant and uses their grass fed steak and meat to serve the restaurant. Great. So that's completely legal. Why you know, they couldn't deliver it for them across that state line to your point. Makes no sense to me, all right. Hopefully more common sense will come about as there's, I think more focus on you know, access and improving our food distribution or resources here. So that's, that's good news. if I'm a rancher, that's never done this before. I want to get started a herd share agreement with you guys. I go to your website. What's it look like?
Alexia, FTCLDF: 26:48
Sure. So I would say that someone should either go to farmtoconsumer.org website. Someone could, by the way, choose an old fashioned phone call which is (703) 208-3276. Either way, they would be applying to become a member and member services would walk them through that and answer any questions, et cetera. And then once they've joined, if they identify that what they want to do right away is do a meat share. Then actually we have a process in place that immediately we will send them a meat share questionnaire which starts getting really just down and dirty into all the details of their business. So that when we first speak with them, which will be quickly, you know, within a couple of days will be an initial contact. And as soon as we get it back, we'll start drafting an agreement and reach out and talk through.
James, Barn2Door: 27:36
That's awesome. What a great service. What Intel, tell me a little bit more about the hotline too.
Alexia, FTCLDF: 27:40
That's really intended for when folks have issues right before then that they need to respond to so, common reasons for needing the hotline would be there's an FSIS inspector at the farm gate and a member is concerned about how to handle that. Sometimes I've seen in the dairy side of our membership, maybe an animal has tested for an illness or disease and there's an agency that's going to confiscate everything. That goes well beyond perhaps what should be a problem. Right. What will happen is we will have someone from the team get in touch right away. It's it, you know, if it's the middle of the night might be a message, but we'll get it. We'll get right back to ya. And you know, walk it through and if we need immediate outside counsel, we will find it. If we can reach out to an agency and help talk through it, we will do that. But it's things like that where someone's getting cited right away. Usually it involves inspection or some kind of, you know, testing of animals that's problematic. Sometimes it might be a state agency suggesting that a member can't do a certain part of their business for something, if they don't have the right license or there's some other issue for livestock inspection, that kind of thing. And they're saying until we get it worked out, basically you gotta shut down. That yields a lot of calls too, because as you know, for a small producer, two days out of business is going to be a real problem for their financial sustainability, right? Yeah,
James, Barn2Door: 29:00
The animals aren't going to stop producing in those two days or a week. What have you? So, and by the way, just for our listeners too. Just understand the value of working with the Farm to Consumer Legal Defense Fund and having an attorney that can represent and work with you. It's a big deal because it you another avenue to be able to have someone who's on your side. It's also going to ensure that whether it's an inspector or whatever agencies coming to you, that they're going to have to actually follow the book. And that your, your rights are going to be protected. And that's something that's guaranteed and protected are under our constitution that we enjoy. As in terms of our liberty in this country, is that your rights as a private citizen and as a business owner should be protected. So don't feel at all bad about calling an attorney to help represent you and support you when you feel that your business might be harmed. Cause that's the whole purpose of this organization is to come alongside you and give you the strength and the support that. To be able to address these issues. Before we shut things out and, and, and think about the next podcast we're going to have. Are there any other issues that right now that are in the docket that you guys are looking ahead to 2022? I know there's obviously a lot of things in the current administration without getting political, to dealing with climate change. I know there's a lot of funny statements made about how cattle are contributing to global . Warming, all these things that sound great and from a political standpoint, but are these things that ranchers and farmers should actually be concerned about, or is it still just, you know, political speak.
Alexia, FTCLDF: 30:23
What we see is a lot of government regulation in everything that farmers and ranchers do. And, and I see continued action along those lines. I'll say it that way. Right. And your reference to calling us, say if there's an inspector or something, I also just want to say that we experience overreach on a regular basis. Inspectors. Just say, you got to do X, Y, and Z when, by the way, you don't. So I just wanted to throw that in there. But I, you know, other things that we are hearing rumblings about our electronic RFID cards are for tags rather for livestock. There was something proposed and then withdrawn, but there there's still rumblings that they're going to reintroduce it properly, which was the problem the first time. But you know, so that's something that could happen. There's been discussions about if for vegetable growers you know, about sort of having to have GPS coordinates for where your crops are. Not good for a regenerative farm that doesn't even have great access to internet that's rotating on a regular basis. Right. So yeah, you know, some of these things are real and real proposals. And so, I think it is, I don't want to be doomsday, but I do think some of these things are things for farmers and ranchers to be aware of. The one thing I really believe is that our food system has proven itself to be vulnerable. And I think the American public understands that better today. I think that our legislators understand that today a little bit better. And I think we may see additional legislation open things up. And I guess one thing I'll just say, and it's not about livestock, but for example, we saw at least. I don't know a good number of maybe eight or 10 states passed new cottage food regulations this year. Allowing for more production of food on farm in your home kitchen and selling it directly to consumers. So of course there's a lot of limitations. My point being is that I think we may see better more helpful legislation going forward than we will negative because folks are starting to understand that these small producers are the answer and that regulating the heck out of them is a real problem for everyone.
James, Barn2Door: 32:30
I think that's a great note to end on. Let's be hopeful for 2022. And to your point, there is massive consumer demand out there for the products that small producers provide to their local communities. I know I support my local farmers and ranchers. And I know that over 80% of all Americans now would like to buy a sustainably produced product and are willing to pay more for it. And 94% of all Americans would like to buy from a small business. Right. So it's just really great to see just the, again, encouragement and positive sentiment in our society right now to support local farmers and ranchers. So take heart, let's be hopeful for 2022. And with that, I want to extend my thanks to Alexia and everyone at the Farm to Consumer Legal Defense Fund, who are serving farmers all across the country tune in next time to hear from Alexia, when we'll dive into the nuances and loss associated with selling produce to wholesale buyers. And for more information on the Farm to Consumer Legal Defense Fund, please visit FarmToConsumer.org that's Farmtoconsumer.org and to learn more about Barn2Door including access to numerous free resources and all the best practices for your farm. Go to Barn2Door.com/resources. Thank you so much for tuning in today, and we hope to see you again next week. Take care and have a wonderful day. Bye-bye.
Alexia, FTCLDF: 33:51
Thank you.