The National Grange wrote to Federal Communications Commission Chairman Julius Genachowski expressing deep concerns that the Commission’s policy focus is shifting from developing a National Broadband Plan encouraging universal deployment and adoption of broadband services to underserved rural, farming, and tribal communities, to a policy focused on regulating broadband network management practices.

The National Grange believes that deployment and consistent access to broadband for all Americans, especially underserved rural Americans, is clearly the most pressing national telecommunications policy objective. Any attempt by the Commission to preemptively define reasonable network management practices by broadband network operators faces the challenge of defining a fixed solution for the ever-evolving problems that will arise on the internet. It potentially disenfranchises millions of currently underserved Americans, especially those who live in rural areas, from the contours of a national debate about the appropriate level of regulation regarding a technology they have little first hand knowledge using. Technology is simply moving too fast and critical service applications are simply too important to be encumbered by a burdensome regulatory process, while at the same time, the social and cultural barriers to wide spread adoption are naturally receding at an expanding pace in the face of dynamic competition among various internet technology applications and platforms.

In light of overwhelming national evidence of dynamic competition in the broadband industry, emerging successful collaborative efforts to accurately map underserved citizens across the nation, a plethora of policy drive internet based applications that can address pressing problems facing rural, farming, and tribal communities such as telemedicine, telecommuting, tele-education and tele-public safety, and rising levels of social and cultural acceptance of the internet as a keystone personal growth technology of the 21 st century. The National Grange is baffled by the Commission’s decision to fast track, with little record or evidence of immediate need, the policy discussion regarding an appropriate national network management regulatory regime.

The National Grange believes that issuance of a Notice of Proposed Rulemaking on net neutrality at a time when the Commission is making significant progress in gathering the factual information to develop a National Broadband Plan is grossly premature and demonstrates an insensitivity to the grassroots perspectives of Americans living in underserved rural, farming, and tribal communities. The Commission could have easily used the process of an Advanced Notice of Proposed Rulemaking or a Notice of Intent, similar to the NOI released to develop a National Broadband Plan, to create a full and complete record of the demonstrated need, or lack of need, for “net neutrality,” which we would define as a comprehensive regime to define the rights, privileges, responsibilities, and obligations of various parties who utilize, manage, or provide services via the internet. The National Grange is concerned that without a comprehensive record, as the basis for current regulatory action, net neutrality regulations threaten continued investment in the physical components of the national internet network.

A lack of a deliberative public record will also potentially stifle the benefits that broadband and the internet bring to rural, farming, and tribal communities by making it unclear whether or not the Commission’s actions will address the real life issues faced by current and future internet users. For example, the grassroots concerns raised by Grange members from across the nation and reflected in our Blueprint for Rural America 2009 telecommunications policy statement concerning protecting children from inappropriate materials and reducing the incidents of fraud, spam, and loss of privacy through unregulated internet based applications is an area that is not addressed by the NPRM. There is little intuitive intellectual support for an argument that corporations that dominate the ownership and management of the physical property and infrastructure critical to the functioning of the internet should be subject to stringent regulatory oversight while equally dominant corporations that control and manage the intellectual property based infrastructure critical to the functioning of the internet should not be subject to similar affirmative regulatory expectations of serving the public interest. However, this is the twisted path the Commission has unambiguously elected to take. The National Grange believes that the Notice of Proposed Rulemaking on net neutrality must be handled in the same transparent and collaborative manner as the National Broadband Plan inquiry. If the Commission feels it must address net neutrality at this time, the more prudent action would be to begin with a Notice of Inquiry to develop a full record so that policy decisions can be made based on a full review of all the facts and a full review of the rights, privileges, responsibilities and obligations of all major participants in the internet infrastructure.

Broadband and the internet, both in the form of the physical infrastructure and the intellectual property infrastructure inherent in its success, are tools for economic growth. The National Grange urges you to keep broadband access and adoption the Commission’s number one priority. We welcome the opportunity to continue to work with the Commission on development of the National Broadband Plan. Rural broadband deployment and adoption are vital to delivering information, services, and products in America’s agricultural, rural, and tribal communities. The Commission should not force an expedited and truncated national debate on narrowly defined aspects of “net neutrality” that would detract from the more important goal of developing a National Broadband Plan that provides incentives for companies to invest in rural broadband infrastructure, including both physical and intellectual property, that enables rural, farming, and tribal communities to receive all of the economic and social benefits available to citizens in urban and suburban communities.

Despite changes made to the bill in a House Energy and Environment Sub-Committee the National Grange still opposes the Chemical Facility Anti-Terrorism Act of 2009. This legislation will still have detrimental ramifications to the nation’s security and economic stability. The Grange and other groups distributed a letter to members of the House Energy and Commerce Committee voicing concerns.

The National Grange strongly objects to the Inherently Safer Technology (IST) provisions of the legislation that would allow the Department of Homeland Security (DHS) to mandate that businesses employ specific product substitutions and processes. These provisions would be significantly detrimental to progress of existing chemical facility security regulations and should not be included in the legislation. DHS should not be making engineering or business decisions for chemical facilities around the country when it should be focused instead on making our country more secure and protecting it from terrorist threats. Decisions on chemical substitutions or changes in processes should be made by qualified professionals whose job it is to ensure safety at our facilities.

The National Grange is also concerned that forced chemical substitutions could simply transfer risk to other points along the supply chain, failing to reduce risk at all. Because chemical facilities are custom designed and constructed, such mandates would also impose significant financial burden on facilities struggling in the current economic recession. Some of the proposed changes are estimated to cost hundreds of millions of dollars per facility. Ultimately the National Grange fears that these facilities will be unable to bear the expense.

The Killingly Grange in Connecticut received a sign designating their building as “Local Historic Properties.” The Historic District Commission presented the sign to the Grange marking its meeting hall as a historic property. Commission chairwoman Teresa Barton said Killingly Grange became the first town in Connecticut to establish a local historic property. Barton said the designation offers the individual sites the same protection given to properties within the historic districts. This allows them to be placed under the jurisdiction of the Historic District Commission thus preserving structures of local historical importance.

During the annual Illinois State Grange Conference, a bountiful number of Ag-related products were displayed and later sold at auction. The display included samples of food and products that Illinois ag­riculture produces each year for use within the United States and for the demands of our ever-growing world markets. Illinois farmers produce vegetables, fruits, grain, and flowers of high quality and attract buyers of the world trade markets.

Ohio Livestock Care Standards Board is Approved by Voters
Lisa Tharp, Legislative Director

The Ohio House of Representatives and the Ohio Senate voted to approve Amended Senate Joint Resolution 6. This resolution allowed Ohioans the opportunity to vote on November 3 rd to create the Ohio Livestock Care Standards Board. By passing this ballot measure, Ohio voters took an important step forward in continuing a major investment in our future farm economy. This board will consist of the Director of the Ohio Department of Agriculture as chair, three family farmers, two veterinarians (one would be the state vet), a food safety expert, a representative from a local humane society, two members of a statewide farming organization, the Dean of an Ohio agriculture college, and two consumer representatives.

The Ohio Livestock Care Standards Board is charged with establishing and implementing livestock and poultry care standards, with enforcement by the Ohio Department of Agriculture. Governor Strickland, along with many agricultural organizations and commodity groups, including the Grange, supported this ballot measure because livestock practices will be in the hands of Ohio animal care experts and not led by out of state interests such as Humane Society of United States (HSUS). Sponsors of the resolution believe that Ohio’s farmers have always practiced the best care for their animals and work to maintain a high level of standards for food safety.

Maryland Grange asks Legislators to “Read Before You Vote”
Allen Stiles, Legislative Director, Maryland State Grange

In a letter to the Maryland Congressional delegation, MD State Grange Legislative Director, Allen Stiles, asked each of Maryland’s Members of Congress to be sure to read important pieces of legislation before casting their final vote.

“There is growing concern in this country about massive bills that are passed quickly with little debate and even less time for individual members of the Congress and Senate to read and understand the provisions contained in them.

This is not a new problem. The ‘Stimulus Package’ was voted on with members having only 13 hours to see its 1,100 pates. The Troubled Asset Relief Programs (TARP I & II) were passed in a similar manner. When members of Congress complained loudly about the recent AIG bonuses it was discovered that some of those members had added a provision to the bill, making that practice acceptable.

The problem has been bi-partisan in nature; both parties are guilty of committing these problems. In the last election, the American people voted for a fundamental CHANGE in the way that Washington conducts business. We were looking for a new, more open and transparent way of doing your business. Several groups: liberal, conservative, and libertarian are proposing that members of Congress sign a pledge to actually read any bills before they vote for them. The concerns and the solution are both non-partisan in nature.

One of the first things that a prospective doctor is taught is, “First do no harm.” The rule in Washington seems to be: it doesn’t matter if it works or not. We must do something even if it is the wrong thing.

Sifting through difficult legislation to understand it is the main job that your constituents have elected you to do. We respectfully ask that you refuse to vote for a bill until you have the opportunity to read and understand it.”

State Representative Dykema Addresses 137 th Annual MA Grange Session
Warren Chamberlain, Legislative Director

Massachusetts State Representative Carolyn C. Dykema addressed the 137th annual Massachusetts State Grange Convention on October 23, 2009, speaking of the need to support the agriculture economy in the Commonwealth. “Local farming is part of our history and our future. We need to work for policy that balances our need for housing and development with our need to protect a sustainable and safe food supply. As demand for locally grown products increases, it’s even more important that the voice of agriculture is heard at the State House,” Representative Dykema told the assembled Grange members.

Rep. Dykema is a member of the Massachusetts Legislature’s Joint Committee on the Environment, Natural Resources and Agriculture. She told the Grange members that she recently submitted testimony in opposition to legislation that would open the door to increased local government regulation of farms that, in turn, would make it more difficult for farms to remain economically viable.