Emergency Rulemaking Petition to USDA
BEFORE THE UNITED STATES DEPARTMENT OF AGRICULTURE PETITION FOR EMERGENCY RULEMAKING ANIMAL LEGAL DEFENSE FUND, ANIMAL EQUALITY, ANIMAL OUTLOOK, ANIMAL PLACE, ASSOCIATION OF IRRITATED RESIDENTS, CENTER FOR BIOLOGICAL DIVERSITY, COMPASSION IN WORLD FARMING USA, FARM FORWARD, FARM SANCTUARY, THE HUMANE LEAGUE, JOHNS HOPKINS CENTER FOR A LIVABLE FUTURE, MERCY FOR ANIMALS, PEOPLE FOR THE ETHICAL TREATMENT OF ANIMALS, WORLD ANIMAL PROTECTION, and WOODSTOCK FARM SANCTUARY, Petitioners. Docket No._____________ Filed With: SONNY PERDUE in his official capacity as Secretary, United States Department of Agriculture. Photo Credit: The Intercept 1 EMERGENCY RULEMAKING PETITION I. INTRODUCTION For the first time in history, the animal agriculture industry is mass-killing healthy farmed animals not in slaughterhouses, but in the concentrated animal feeding operations (CAFOs) where they are confined for the duration of their short lives. To protect its profit margins, the industry is using exceptionally cruel methods to carry out these mass-killings: ventilation shutdown and water-based foam. The United States Department of Agriculture (USDA) has the power—and the responsibility—to act. The undersigned organizations petition USDA—pursuant to the First Amendment1 and the Administrative Procedure Act (APA)2—to address COVID-19 related “depopulation”3 by (1) preventing USDA COVID-19 relief funds, resources, and/or any other forms of support from facilitating or compensating for the costs of animal “depopulation” by ventilation shutdown or water-based foam;
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