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public comment on proposed changes to sheep program

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If you care about having access to grass fed, pastured lamb and sustainable fashion — like domestically made wool fabric, clothing and yarn — please submit a public comment against proposed changes to the H-2A sheepherder program by June 1, 2015.

Sometimes, regulations with the best of intentions show a lack of connection to the land, and do more harm than good to land stewardship and agricultural businesses. This is the case with the Department of Labor’s (DoL’s) proposed amendments to the H-2A sheepherder program. Nearly 1/3 of U.S. sheep flocks are shepherded by H-2A workers, which means hundreds of sheep operations and the survival of many, already tenuous lamb and wool businesses is seriously threatened.

man on horseback with hundreds of range sheep on mountain

A way of life at risk due to proposed changes to the H-2A sheepherder program. Image from Library of Congress.

Here are some points you may wish to include in your public comment:

  • Ask that the DoL retain the Special Procedures that have worked well since the 1980s.
  • Ask that the public comment period be extended to July 15, 2015 to give shepherds, shearers and ranchers time to respond. One month is not enough time to respond during lambing, calving and shearing season, the busiest time of year.
  • Ask that the DoL not change the definition of “range.” The DoL wants the new definition of “range” to exclude fenced land, but fences, including moveable ones, are necessary to prevent sheep from eating poisonous plants, to manage intensive and rotational grazing, and to protect animals from predators and heavy traffic on public roads (much of which comes from the oil and gas industry, in these areas).
  • Point out that the DoL wage calculations are flawed and show a lack of understanding of shepherding and sheep shearing practices. The base wage used by the DoL includes the need for workers to pay for rent, food, clothing and transportation expenses. Shepherds do not have these expenses because it is standard practice for ranchers and wool producers to cover all of them. Wool producers do not have enough profit margin to pay twice for all of these things.
  • Express concern for increased fires in a time of severe drought. Many Western sheep graze on crop residue and in suburban and urban areas, as forage reduction for fire prevention. This sort of grazing requires the livestock to be watched and under the care of an H-2A shepherd. A lack of H-2A shepherds would, indeed, lead to increased fire risk.

Additional talking points and background are available in this PDF.

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