PRODUCER EDUCATION IN THE LEGAL ARENA:
THE PROPOSED GIPSA RULE CHANGES
Shannon Mirus, J.D., LL.M.
Jefferson D. Miller, Ph.D.
University of Arkansas
www.NationalAgLawCenter.org
The Proposed GIPSA Rule Changes

Proposed rule from GIPSA
 Includes

significant changes for livestock and poultry
Why address this topic?
 Great
deal of perceived risk for producers
 Large number of inquiries
 Covered in ag press
 Politically contentious
Program Objectives




Provide a better understanding of what GIPSA is
and what it does
Provide a better understanding of the notice and
comment rulemaking process and how producers
can participate
Provide a better understanding of the proposed
GIPSA rule
Provide unbiased information
Planning the Workshops





Proposed rule published on June 22, 2010
Comment period extended to November 22, 2010
August, 2010 - Decision to address this topic
Goal to have all workshops wrapped up by Nov. 1
Planned 3 workshops and 1 webinar originally
Fayetteville, AR
 Russellville, AR
 Nashville, AR


Chosen because of geography of state and
concentration of producers
Key Considerations

Having support of key members of community
 Key


producers
Not having opposition from integrators
Location & Dates
 Easy
access
 Neutral sites
 Avoid community events if possible, all in the evening
 Utilized local extension agents
Publicizing Workshops

Local word of mouth
Connecting with producers
 Local meetings


Integrators


Newspapers


Included in newsletter to growers
Some growers sent the information to local papers
Emails & Listservs

Collected email information for producer groups around the
country to help publicize the webinar
Workshop Content

Who we are
 And





who we aren’t
What is GIPSA
What are regulations
What is the notice and comment process
Substance of rules
Question & Answer
Workshop Delivery



Keep workshops to 2 hours
Multiple presenters to break up the session
Wait until the end to take questions
 Provided
paper and pens for writing questions down
during the workshop


Moderated question & answer session
Several producers had individual questions
afterwards
 We
stayed as long as producers still had questions
Additional Workshops

Success of first two workshops resulted in invitations to
present in other locations

Ruston, LA


Poteau, OK


Oklahoma Cooperative Extension Service & OSU
Booneville, AR


Louisiana Farm Bureau & Dept of Agriculture & Forestry
USDA Dale Bumpers Small Farm Research Station
Inviting organization was responsible for:
Securing location
 Publicizing event

Additional Workshops

Publicity
 Louisiana
 Direct
mailing from Commissioner of Agriculture
 Support from state Farm Bureau
 Oklahoma
 Organized
by Extension
 Promoted locally and regionally by Extension
 Booneville,
 Smallest
AR
turnout
 Hosted because they had received inquiries locally
 Word of mouth & friends
Evaluation Methods


Survey developed using principles from Dillman
16 Questions
 1-7
about the content of the workshop and materials
 8-9 how participants learned about the workshop
 10-13 about their role in ag & production area
 14-16 age, gender & county

Mostly scale or multiple choice questions
 Some
open ended questions
Evaluations

Implemented during 3rd workshop
 Imperfect
information
 Data from 4 workshops + webinar

Distributed at the end of the workshops, after Q&A
session
 Webinar:

Online survey, link provided after Q&A
Analysis
 Frequencies
 Percentages
Evaluation Results
Just the numbers

381 in attendance at 5 workshops

225 responses from all 5 workshops

Response rate of 59%
Evaluation Question #1

I have a better understanding of what GIPSA is and
what it does.
60.00%
50.00%
51.11%
42.67%
40.00%
30.00%
20.00%
10.00%
0.00%
4.44%
1.33%
0.44%
Strongly
Somewhat Neutral
Agree
Agree
Somewhat
Strongly
Disagree
Disagree
Evaluation Question #2

I have a better understanding of the notice and
comment rulemaking process.
50.00%
45.00%
40.00%
35.00%
30.00%
25.00%
20.00%
15.00%
10.00%
5.00%
0.00%
48.00%
43.56%
7.11%
0.78%
Strongly
Agree Somewhat
Agree
Neutral
Somewhat
Disagree
0.00%
Strongly
Disagree
Evaluation Question #3

I have a better understanding of how I can
participate in the notice and comment rulemaking
process.
60.00%
55.11%
50.00%
40.00%
37.33%
30.00%
20.00%
10.00%
7.11%
0.44%
0.00%
Strongly
Agree Somewhat Neutral
Agree
Somewhat
Disagree
0.00%
Strongly
Disagree
Evaluation Question #4

I have a better understanding of the proposed
GIPSA rules.
60.00%
52.23%
50.00%
40.00%
37.05%
30.00%
20.00%
10.00%
7.59%
2.68%
0.00%
0.45%
Strongly
Agree Somewhat Neutral
Agree
Somewhat
Disagree
Strongly
Disagree
Evaluation Question #5

I am more likely to submit a comment expressing my
option on the proposed GIPSA rules.
45.00%
43.95%
40.00%
35.00%
30.00%
26.01%
25.00%
26.91%
20.00%
15.00%
10.00%
5.00%
2.69%
0.00%
0.45%
Strongly
Agree Somewhat
Agree
Neutral
Somewhat
Disagree
Strongly
Disagree
Evaluation Question #6

I feel that the material was presented without bias
for or against the rules.
90.00%
80.89%
80.00%
70.00%
60.00%
50.00%
40.00%
30.00%
20.00%
10.00%
0.00%
15.56%
3.56%
0.00%
Strongly
Agree Somewhat
Agree
Neutral
Somewhat
Disagree
0.00%
Strongly
Disagree
Evaluation Question #7

I feel that the materials provided helped further my
understanding of the proposed GIPSA rules.
60.00%
51.56%
50.00%
41.78%
40.00%
30.00%
20.00%
10.00%
0.00%
4.89%
0.89%
Strongly
Agree Somewhat Neutral
Agree
Somewhat
Disagree
0.44%
Strongly
Disagree
Sources of Pre-Workshop Publicity
Source
Frequency
Percentage
University Cooperative
Extension Service/Agent
41
29.3%
Family & Friends
40
28.6%
Agriculture Special Interest
Groups (Farm Bureau,
Women in Ag, NASDA)
23
16.4%
Dept of Ag & Forestry
22
15.7%
Commodity Groups (Cattle
Assn, NPPC, Poultry
Federation, Cattlemen’s)
6
4.3%
National Ag Law Center
4
2.9%
Integrator
3
2.1%
GIPSA
1
0.7%
Media Used to Learn About
the GIPSA Workshops
Type of Media
Frequency
Percentage
Newspaper
40
26.7%
E-mail
32
21.3%
Direct Mail
29
19.3%
Public Meeting
12
8.0%
Organizational Web Sites
12
8.0%
Newsletter
11
7.3%
Radio News
4
2.7%
Word of Mouth/Telephone
3
2.0%
Facebook
3
2.0%
Twitter
1
0.7%
Other
3
2.0%
Conclusions
Conclusions

Objectives were met
 Remaining
 80%+
 Most
unbiased was our #1 goal
felt we presented unbiased information
felt they learned about:
 GIPSA
 Notice
& Comment Rulemaking
 Substance of the proposed rule
Conclusions

Producers will participate in workshops that provide
information on complex topics
 State
wide workshops are successful with 75
participants
 These were regional workshops averaging 76.2
participants

We were sought out in several cases to present in
other locations
 Demand
for information was nationwide
Lessons Learned

Plan to evaluate from the beginning

Follow up surveys for further research
 Did
you actually submit a comment?
 Why or why not?

Survey questions are more likely answered if
options are presented
Lessons Learned

Important to indentify key community leaders and
get them on board
 Credibility
 Word

of mouth
When maintaining a position in the middle, be
prepared for fire from both sides.
 Credibility
of the Center hinged upon remaining neutral
and unbiased
Questions?
Thank You!
Shannon Mirus, J.D., LL.M.
smirus@uark.edu
Jefferson D. Miller, Ph.D.
jdmiller@uark.edu