(In response to the Cedar Rapids, Iowa Gazette’s Editorial on Sunday, April 27)
Your Iowa readers need to learn there are dissenting opinions to the Gazette’s “Eggs-Acting Demands” in yesterday’s editorial. Iowa is the leading egg producing state and exports approximately 30% of California consumer needs for eggs. Iowa Governor Terry Branstad is to be commended for looking out for Iowa’s egg farmers and the state’s economy by supporting the Missouri lawsuit against the California egg law. The state has the right to enact laws or regulations governing the production of eggs in their state, but it cannot specify production standards in Iowa. By doing so, California is assuming the role of determining the commerce of eggs which is a violation of the U.S. Constitution Article 1, Section 8, Clause 3 granting the U.S. Congress the power to regulate commerce between the States. California Title 3 Section 1350 requires out-of-state egg farmers selling eggs in California to implement that state’s food safety regulations that go beyond the federal regulations under FDA’s food safety standards for eggs [21 CFR Part 118], “Production, Storage, and Transportation of Shell Eggs”.
The Gazette’s suggestion to support one national federal standard for egg production would actually have led to the smaller egg farmers throughout the country including those in Iowa actually going out of business. Whereas the larger egg complexes could gradually make the transition suggested by the Gazette over a 15-year period, the smaller egg farmers would not be able to because of the egg processing capabilities on those smaller farms. Those smaller egg farmers would be forced to make the conversion in one step leading to an economic disadvantage leading to insolvency for them. As to the organizations representing 90% being in favor of this national standard, there was never a survey done of the egg industry. Instead a handful of companies made the decision and their egg cooperative carried out the dictates.
The implied claims of increasing space for hens leads to better welfare is incorrect. Consider the facts. The American Veterinary Medical Association (AVMA) in 2010 released a report on the welfare implications of various kinds of housing. (www.avma.org/issues/animal_welfare/cage_noncage_systems.asp) The report concluded consumers need to balance the hen’s freedom against exposure to potential hazards such as disease vectors and the cannibalism caused by pecking. Certainly cannibalism and pecking are welfare issues, and in conventional cages where the number of chickens is minimized, these concerns are also reduced compared to other systems. Dr. Kenneth Anderson, NC State University, presented his research findings to delegates at the 2010 Midwest Poultry Federation Convention March 16-18, 2010 where he noted that chickens reared in conventional cages had significantly greater numbers of Grade A eggs, significantly greater numbers of total eggs produced, and significantly better feed conversion rates (meaning a lower carbon footprint), and a better immune response (meaning better able to resist disease). Certainly these are indicators of a healthier chicken and thus better welfare.
The National Association of Egg Farmers, representing egg farmers throughout the nation, remains committed to opposing one national standard and allowing U.S. egg farmers to produce eggs for the consumers in their markets without the dictates of a national law. We have learned the mistakes in the European Union and their egg law (EU Council Directive 1999/74/ED). This article from Farming UK (see website below) demonstrating the suffering resulting in Europe as a result of implementing their national egg law on January 1, 2012. The Germans moved even quicker than the whole of the European Union and implemented a new national law in 2010.
The article quotes an international economist who predicts that 30% of the German egg farmers will likely become insolvent by October. This same sort of disaster will occur in Iowa and elsewhere should one national standard become law.
Iowa egg production is providing jobs and food for the nation’s consumers in addition to the consumers in the state. For these reasons, the people in Iowa should send their compliments to their Governor Terry Branstad for his courage in supporting the Missouri AG’s lawsuit against the misguided effort by California and the misinformation from the media. I'm sending this dissenting opinion to Governor Branstad along with my thanks.