AFBF envisions itself as agriculture’s autocratic, autonomous entity.  Yet agricultural market players compete in a Free-Market system.  Like all competitors in other sectors, AFBF’s research and development is self serving.  

It takes little effort to recognize the contentious elements of science within other industries.  The science-based evidence for lead-acid battery manufacturers is entirely different than Lithium-Ion.  Microsoft’s science is different than Apple.  John Deere’s science is different than Case/IH and Agco.  Like the aforementioned Ford/Tesla comparison, some industry competitors rely on foundationally different science yet still supply their end product to the same categorical consumer demand.  Above all is the recognition that no single market player in any other sector possesses the power to mandate just one branch of science with indifference to all others.  

All of these fields are “science-based”:  Physics, Chemistry, Earth Science, Ecology, Oceanography, Geology, Meteorology, Astronomy, Biology, Zoology, Botany, Mathematics, Statistics.  Is the AFBF claiming expertise in all of these fields?  

Back to Rachel Carson:  The AFBF is a specialist in the science of chemically-curative agriculture, with indifference or intolerance to the larger picture in which it fits.  The AFBF demonstrates at best, a subordinated role of the Biological, Ecological and Earth Sciences.  

In a Free- Market economy, how is it that the AFBF has been allowed to mandate the scientific template by which all others must follow?  Imagine cell phones with lead-acid batteries.  Imagine Apple with no Microsoft counterbalance.  Imagine the stifling of innovation if all tractors where one color.  Imagine Henry Ford in 1919 - where you can have any color you want as long as it’s black - possessing the same autocratic power as the AFBF has demonstrated in 2019.  Henry Ford had captured the market in 1919, yet unlike the agricultural market in 2019, the auto market was free and competitive in the 1920’s.  Within just a few years, upstarts Chevrolet and Dodge put some color into the market.  Consumer demand determined the legitimacy of marketing programs.  Then as now in the auto industry, if Chevrolet dropped bricks through Ford’s truck bed and some consumers still bought the Ford, the free market speaks for itself.  Did Chevy make Ford trucks “look bad”? - absolutely.  Did Ford obtain government sanctioned authority to undermine Chevy - because Chevy’s brick trick was nothing more than a marketing program? - absolutely not.  

Our entire economy is based on comparative marketing from automobiles to cell phones right down to the farm paper advertisement asking you “which rafter is better for your herd”?  For reasons yet exposed by anyone, the agricultural market functions independent and separate as a despotic anomaly more in stride with the supply and demand effects of a protection racket than a free market.  

 

DATCP bias is revealed through it’s regulatory philosophy of one-size-fit-all.  In all fairness, the DATCP has put forth separate rulings for Wisconsin residents wishing to raise hobbyist levels of livestock.  This critique is focused on the regulatory obstructions - and the DATCP’s scientific philosophy inherent to those regulations - which prevent an individual from earning a living farming at any scale other than large.  

DATCP demonstrates this bias by enacting chemical curative criteria, stridently dismissive of preventative biological vectors attributed to volume, density, duration or environment. Regulations are one-size-fits-all with indifference to utilization.  Perhaps most alarmingly, DATCP appears compelled to fill a vacuum with prejudicial regulations where no apparent need exists.  

As iterated in the editorial, the DATCP has drafted regulations limiting on-farm livestock processing volumes to hobbyist levels:  999 chickens; Zero of other livestock; 150 laying hens.  Anything beyond these levels requires a food processing plant license.  Effectively, these DATCP regulations force farmers to a crossroads - get big or remain content accepting the paltry 15 cents of the consumer dollar relegated to farmers who don’t/can’t participate in the 85 cent processing/retailing club.  

The farmers decision to get big is revealed by simple economics.  The farmer may have wanted to raise and process a few thousand chickens a year yet the regulatory expense incurred necessitates the facility to be fully utilized in order to capture a return on investment.  Hence, the farmer may have to decide if he/she may need to quit farming in order to fully utilize the processing facility, or, hire managers and employees to operate the food processing plant.   The proportioned cost of licensing and construction costs are severely biased against small scale operators.  

Recognize that the DATCP is not applying biological science to it’s regulatory decision making process.  In the biological world - the very world in which the DATCP is authorized to mitigate food safety concerns - volume, density, duration, diversity and environment - all influence biological potential.  In DATCP’s one-size-fits-all philosophy, the biological ramifications of a small farm processing  a few thousand chickens on intermittent days over several weeks in a clean, family operated facility induces the same biological potential as an industry facility processing 200,000 chickens a day, 24/7/365.  This violates all the biological science society has learned since John Snow’s Broad Street Pump revelation right up through the latest Cruise Ship epidemic.  In much the same way as 17th Century Rome indicted Galileo for upsetting the politically disruptive belief of a geocentric world,  the DATCP is expecting 21st Century Wisconsin farmers to fall in line - ignore what can be proven to be obvious.

All of this - AFBF/Organic methodology and DATCP regulatory principles - can be parsed into two different ways of thinking:  Chemically Curative or Biologically Preventative.