Thursday, March 5, 2020

Agricultural Law Weekly Review—March 5, 2020

Written by:  
Brook Duer—Staff Attorney
Audry Thompson—Research Assistant
The Agricultural Law Weekly Review provides an update of recent agricultural law developments from the local, state, national, and international levels.  Subscribe to the ALWR at pennstateaglaw.com

Invasive Species: Pennsylvania Spotted Lanternfly Quarantine Order Expanded
On March 3, 2020, the Pennsylvania Department of Agriculture announced that, effective March 2, 2020, the following twelve counties have been added by amendment to the geographic scope, and are therefore now subject to the requirements, of the Spotted Lanternfly Quarantine Order of May 26, 2018: Allegheny, Beaver, Blair, Columbia, Cumberland, Huntingdon, Juniata, Luzerne, Mifflin, Northumberland, Perry, and York.  The amendment will be published in the Pennsylvania Bulletin on March 14, 2020. 

Industrial Hemp: USDA Approves Three More State Hemp Production Plans, Including Pennsylvania 
On February 26, 2020, and again on March 3, 2020, USDA’s Agricultural Marketing Service (AMS) updated its official web-based listing of the status of state and tribal hemp production plans submitted for approval as required by the 2018 Farm Bill provisions and the October 31, 2019, Interim Final Rule on Domestic Hemp Production Program. On February 26, 2020, Washington and Wyoming plans were listed as approved and on March 3, 2020, Pennsylvania’s plan was listed as approved.  Nine state plans have now been approved, of the total of forty-five states listed.  However, seventeen states are now listed as “continuing to operate under the 2014 pilot” which means they will not need to submit or receive USDA approval of a state plan at this time.  

Industrial Hemp: USDA Announces Two-Year Enforcement Delay of Two State Hemp Production Plan Requirements 
On February 27, 2020, USDA’s Agricultural Marketing Service (AMS) announced by press release the issuance of “guidance,” titled Enforcement Discretion - Interim Final Rule,” in which USDA states it will delay enforcement of the following requirements contained in the October 31, 2019, Interim Final Rule on Domestic Hemp Production Program: (a) that THC testing labs be registered by the Drug Enforcement Administration (DEA); and (b) that producers use a DEA-registered reverse distributor or law enforcement to dispose of non-compliant plants. Enforcement is stated to be delayed starting with the 2020 crop year and until Oct. 31, 2021, or the final rule is published, whichever comes first.  A separate AMS webpage devoted to acceptable disposal methods illustrates plowing under, mulching/composting, disking, bush mower/chopper, deep burial and burning.  There is no indication that the guidance text will be published in the Federal Register or appear anywhere in an official government repository of regulatory documents. 

Industrial Hemp: Ohio Opens 2020 Hemp License Application Period 
On March 2, 2020, the Ohio Department of Agriculture announced that it would begin accepting license applications on March 3, 2020, for industrial hemp cultivators and processors located in Ohio for the 2020 growing season.  Ohio’s state hemp production plan was approved by USDA on December 27, 2019, and became effective on January 29, 2020.  

Water Quality: Ohio Federal Court Finds Lake Erie Bill of Rights to be Unconstitutional
On February 27, 2020, the U.S. District Court for the Northern District of Ohio ruled that an amendment to the City of Toledo’s municipal code, adopted by referendum vote in a February 2019 special election, titled Lake Erie Bill of Rights(LEBOR), is unconstitutionally vague under the U.S. Constitution’s Fourteenth Amendment and exceeds the legal authority of Ohio municipalities, rendering it invalid in its entirety.  Drewes Farm Partnership and State of Ohio v. City of Toledo, Case No. 3.19 CV 434 (USDC ND Ohio).  LEBOR granted rights to the City of Toledo and any Toledo resident to, for example, file a lawsuit on behalf of the lake against any agricultural producer located in any portion of Lake Erie’s watershed, including neighboring states and Canada, for contributing to nutrient run-off into Lake Erie.  The remedy authorized by LEBOR is simply stated as “the maximum fine allowable under State law.”

Securities Fraud: Trickling Springs Creamery Owner Pleads Guilty to Federal Felonies
On February 27, 2020, U.S. Attorney for the Eastern District of Pennsylvania announced that Philip Elvin Riehl, majority owner of Trickling Springs Creamery, LLC, located in Chambersburg, Pennsylvania, pled guilty to three federal criminal felony charges.  The crimes are: (a) conspiracy to commit securities and wire fraud; (b) securities fraud; and (c) wire fraud.  United States v. Philip Elvin Riehl, No. 20-048 (USDC ED PA).  According to the U.S. Attorney’s announcement, “Riehl, a Berks County–based accountant, fraudulently solicited tens of millions of dollars in investments, from his accounting clients and others who are mostly Mennonite or Amish, into an investment program that he operated.  Riehl then diverted funds from the program to Trickling Springs Creamery, LLC, a Franklin County–based creamery of which he was the majority owner. Riehl also fraudulently solicited direct investments in Trickling Springs Creamery. [. . .] Investor losses are estimated to be around $60 million, making this one of the largest Pennsylvania-based Ponzi schemes ever.”  Riehl was released on $250,000 bond pending sentencing scheduled for June 5, 2020.  According to the Guilty Plea Agreement, the maximum jail term is 45 years and forfeiture of all Riehl’s assets, in the amount of $59,688,297.97, shall be ordered to satisfy restitution in the same amount. 

From National Ag Law Authorities & Sources: 
Roger A. McEowen, “Reversion to Agricultural Use Classification Not a Taking” (March 3, 2020). 













Penn State Research & News:

AGENCY PRESS RELEASES—STATE/FEDERAL
Pennsylvania Department of Agriculture Press Releases:

U.S. Department of Agriculture Press Releases:

STATE ACTIONS—EXECUTIVE/LEGISLATIVE
Pennsylvania Executive Agencies—Actions and Notices: 
Department of Environmental Protection
50 Pa.B. 1249 “Applications for National Pollutant Discharge Elimination System (NPDES) Permits and Water Quality Management (WQM) Permits” Applications, Actions and Special Notices (Feb. 29, 2020). 
50 Pa.B. 1311 “Sewage Advisory Committee Meeting Rescheduled [Wednesday, June 17, 2020],” Notice (Feb. 29, 2020).

Fish and Boat Commission
50 Pa.B. 1247 “Fishing; General Fishing Regulations,” Proposed Rulemaking (Feb. 29, 2020).

State Conservation Commission
50 Pa.B. 1332 “Action on Odor Management Plans for Concentrated Animal Operations and Concentrated Animal Feeding Operations and Volunteers Complying with the Commonwealth's Facility Odor Management Program,” Notice (Feb. 29, 2020).

Pennsylvania Legislature
H.Res 785 “[D]esignating the month of April 2020 as ‘Prevention of Cruelty to Animals Month’ in Pennsylvania,” Referred to Agriculture and Rural Affairs (Feb. 28, 2020).

FEDERAL ACTIONS—EXECUTIVE/LEGISLATIVE
Federal Executive Agencies—Actions and Notices: 
Agricultural Department
85 FR 11045 “Submission for OMB Review; Comment Request [Rural Economic Development Loan and Grant Program],” Notice (Feb. 26, 2020). 
85 FR 11331 “Submission for OMB Review; Comment Request [Forest Service: Cooperative Wildland Fire Management and Stafford Act Response Agreements,” Notice (Feb. 27, 2020).
85 FR 11332 “Submission for OMB Review; Comment Request [Foreign Agricultural Service: USDA Local and Regional Food Aid Procurement Program],” Notice (Feb. 27, 2020).

Agricultural Marketing Service
85 FR 11312 “Olives Grown in California; Proposed Amendments to the Marketing Order No. 932 and Referendum Order,” Proposed Rule (Feb. 27, 2020). 
85 FR 11330 “Vegetable and Specialty Crop Marketing Orders; Notice of Request for Extension and Revision of a Currently Approved Information Collection,” Notice—Comment Period (Feb. 27, 2020).
85 FR 11830 “Tart Cherries Grown in the States of Michigan, et al.; Decreased Assessment Rate,’ Rule (Feb. 28, 2020).
85 FR 12494 “National Research, Promotion, and Consumer Information Programs; Request for Extension and Revision of a Currently Approved Information Collection [National Sheep Improvement Center; Soybean Promotion, Research, and Consumer Information; Beef Promotion and Research; Amendments To Allow Redirection of State Assessments to the National Program],” Notice—Comment Period (Mar. 3, 2020).

Alcohol and Tobacco Tax and Trade Bureau
85 FR 11894 “Proposed Establishment of the Verde Valley Viticultural Area,” Proposed Rule—Comment Period (Feb. 28, 2020).

Animal and Plant Health Inspection Service
85 FR 11045 “Availability of an Environmental Assessment for Field Testing of a Vaccine for Use Against Bursal Disease and Marek's Disease,” Notice—Comment Period (Feb. 26, 2020). 
85 FR 11833 “Establishment of Regulations for the Evaluation and Recognition of the Animal Health Status of Compartments,” Rule (Feb. 28, 2020).
85 FR 12207 “Lacey Act Implementation Plan: De Minimis Exception,” Rule (Mar. 2, 2020). 
85 FR 12250 “Notice of Availability of an Environmental Assessment; Cogongrass Control Efforts in Alabama, Georgia, Mississippi, and South Carolina,” Notice (Mar. 2, 2020).
85 FR 12495 “Notice of Request for Revision to and Extension of Approval of an Information Collection; Swine Health Protection,” Notice—Comment Period (Mar. 3, 2020).
85 FR 12441 “Importation of Phalaenopsis Spp. Orchid Plants for Planting in Approved Growing Media From the Republic of Costa Rica Into the United States,”  Proposed Rule—Comment Period (Mar. 3, 2020).

Commodity Credit Corporation
85 FR 10959 “Supplemental Agricultural Disaster Assistance Programs,” Rule (Feb. 26, 2020). 
85 FR 11946 “Announcement of Future Competitive Grant Funds Availability for Higher Blends Infrastructure Incentive Program (HBIIP) for Fiscal Year 2020,” Notice (Feb. 28, 2020).
85 FR 12213 “Noninsured Crop Disaster Assistance Program,” Rule (Mar. 2, 2020).

Delaware River Basin Commission
85 FR 12276 “Adjudicatory Hearing and Additional Written Comment Period [Gibbstown Logistics Center Dock 2],” Notice—Comment Period (Mar. 2, 2020).

Environmental Protection Agency
85 FR 12224 “On-Site Civil Inspection Procedures,” Rule (Mar. 2, 2020).
85 FR 12244 “EPA Plan for the Federal Certification of Applicators of Restricted Use Pesticides Within Indian Country; Proposed Revisions; Notice of Availability and Request for Comment,” Proposed Rule—Comment Period (Mar. 2, 2020).
85 FR 12288 “National Pollutant Discharge Elimination System (NPDES) 2020 Issuance of the Multi-Sector General Permit for Stormwater Discharges Associated with Industrial Activity,” Notice—Comment Period (Mar. 2, 2020).
85 FR 12285 “Pesticide Experimental Use Permit; Receipt of Application; Comment Request [lavandulyl senecioate],” Notice (Mar. 2, 2020).
85 FR 12285 “Pesticide Product Registration; Receipt of Applications for New Uses (December 2019),” Notice—Comment Period (Mar. 2, 2020). 
85 FR 12287 “Pesticide Product Registration; Receipt of Applications for a New Active Ingredient (December 2019) [Repellent—Sheep fat],” Notice—Comment Period (Mar. 2, 2020).
85 FR 12553 “Pesticide Product Registration; Receipt of Applications for New Uses (January 2020),” Notice—Comment Period (Mar. 3, 2020). 
85 FR 12551 “Pesticide Product Registration; Receipt of Applications for New Active Ingredients,” Notice—Comment Period (Mar. 3, 2020).
85 FR 12552 “National Water Reuse Action Plan: Collaborative Implementation (Version 1),” Notice (Mar. 3, 2020).
85 FR 12454 “Receipt of a Pesticide Petition Filed for Residues of Pesticide Chemicals in or on Various Commodities (January 2020),” Proposed Rule—Comment Period (Mar. 3, 2020).

Executive Office of the President
85 FR 11273 “Developing and Delivering More Water Supplies to California,” Presidential Document (Feb. 26, 2020). [see “Department of Interior Directs Water Increase to California Central Valley,” Agricultural Law Weekly Review - February 28, 2020]

Federal Emergency Management Agency
85 FR 11295 “Suspension of Community Eligibility [Alabama],” Rule (Feb. 27, 2020).
85 FR 11378 “Changes in Flood Hazard Determinations [AL, CO, FL, LA, NC, SC, TX],” Notice (Feb. 27, 2020). 
85 FR 11377 “Proposed Flood Hazard Determinations [Iowa, Nebraska],” Notice (Feb. 27, 2020).
85 FR 12571 “Changes in Flood Hazard Determinations [AZ, CA, FL, ID, IL, NV, TX, WI],” Notice (Mar. 3, 2020).

Fish and Wildlife Service
85 FR 11238 “Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for Black Pinesnake,” Rule (Feb. 26, 2020).
85 FR 11098 “Endangered and Threatened Wildlife and Plants; Draft Recovery Plan for the Eastern Massasauga Rattlesnake,” Notice—Comment Period (Feb. 26, 2020). 
85 FR 11096 “Endangered and Threatened Species; Receipt of Recovery Permit Applications,” Notice—Comment Period (Feb. 26, 2020).
85 FR 12323 “Endangered and Threatened Species; Receipt of Recovery Permit Applications [Rusty patched bumble bee, Gray bat, Northern long-eared bat, Ozark big-eared bat, Virginia big-eared bat, Indiana bat],” Notice—Comment Period (Mar. 2, 2020).
Food and Drug Administration
85 FR 11369 “Standardized Medicated Feed Assay Limits; Draft Guidance for Industry; Availability,” Notice—Comment Period (Feb. 27, 2020).
85 FR 11893 “Laboratory Accreditation for Analyses of Foods; Extension of Comment Period,” Proposed Rule—Comment Period (Feb. 28, 2020).

Forest Service
85 FR 11041 “Conveyance of Small Tracts,” Proposed Rule—Comment Period (Feb. 26, 2020).

National Institute of Food and Agriculture
85 FR 12252 “Notice of Intent for Reinstatement, Without Change, of a Previously Approved Information Collection for Which Approval Has Expired [Children, Youth, and Families at Risk],” Notice—Comment Period (Mar. 2, 2020).
85 FR 12251 “Solicitation of Input From Stakeholders on Agency Services,” Notice (Mar. 2, 2020).

National Labor Relations Board
85 FR 11184 “Joint Employer Status Under the National Labor Relations Act,” Rule (Feb. 26, 2020).

Rural Business-Cooperative Service
85 FR 11947 “Notice of Solicitation of Applications (NOSA) for the Strategic Economic and Community Development Program for Fiscal Year (FY) 2020,” Notice—Comment Period (Feb. 28, 2020).

U.S. Codex Office
85 FR 11047 “Codex Alimentarius Commission: Meeting of the Codex Committee on Contaminants in Foods,” Notice (Feb. 26, 2020). 
85 FR 11046 “Codex Alimentarius Commission: Meeting of the Codex Committee on Pesticide Residues,” Notice (Feb. 26, 2020). 

U.S. House Agriculture Committee Actions: 
S.2107 “Protecting America's Food and Agriculture Act of 2019,” Presented to President (Feb. 20, 2020). 
H.R.5435 “American Public Lands and Waters Climate Solution Act of 2019,” Committee Hearings Held (Feb. 26, 2020). 
H.R.5859 “Trillion Trees Act,” Committee Hearings Held (Feb. 26, 2020). 
H.R.5986 “To restore, reaffirm, and reconcile environmental justice and civil rights, provide for the establishment of the Interagency Working Group on Environmental Justice Compliance and Enforcement, and for other purposes,” Referred to Committees on Energy and Commerce; Natural Resources; the Judiciary; Transportation and Infrastructure; Agriculture; and Education and Labor (Feb. 27, 2020).
H.R.5998 “To make the National Parks and Federal Recreational Lands Pass available at no cost to members of Gold Star Families,” Referred to Committees on Natural Resources and Committee on Agriculture (Feb. 27, 2020).
H.R.6023 “To amend the Food Security Act of 1985 to require the designation of composting as a conservation practice and conservation activity, and for other purposes,” Referred to House Committee on Agriculture (Feb. 28, 2020).
H.Res.882 “Recognizing the importance of the blueberry industry to the United States of America and supporting the designation of July 2020 as ‘National Blueberry Month,’” Referred to the House Committee on Agriculture (Mar. 2, 2020).
H.R.6067 “To amend the Packers and Stockyards Act, 1921, to provide for the establishment of a trust for the benefit of unpaid cash sellers of livestock, and for other purposes,” Referred to the House Committee on Agriculture (Mar. 3, 2020).

U.S. Senate Agriculture, Nutrition, And Forestry Committee Actions: 
S.3357 “A bill to amend the Child Nutrition Act of 1966 to enhance State efforts to cross-enroll participants to improve nutritional outcomes for pregnant women, postpartum women, and young children, and for other purposes,” Read twice and referred to the Committee on Agriculture, Nutrition, and Forestry (Feb. 27, 2020).
S.3354 “A bill to amend the Child Nutrition Act of 1966 to establish a community health partnership grant program,” Read twice and referred to the Committee on Agriculture, Nutrition, and Forestry (Feb. 27, 2020).

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