National Association of Egg Farmers Offer Rebuttal in LA Times Article

This is in response to the Op-Ed February 10, 2014 in the LA Times by Bruce Friedrich, Farm Sanctuary, “Which Came First, Healthier Chickens or Cheaper Eggs?”  His explanations of today’s modern chicken farm are inaccurate, and his citations from the European Union’s new law provide only part of the story.  The readers of the LA Times deserve better than only part of the story.

It’s true that the Californians voted on November 4, 2008 in support of Proposition 2 that requires chickens producing eggs be able to stand up, lie down, turn around, and fully extend their limbs with touching another chicken or the side of their enclosure.  It was followed by California law AB 1437 on July 6, 2010 requiring all eggs sold in California abide by state law.  Just reading Mr. Friedrich’s op-ed may sound like a good thing to consumers, but today’s modern chicken producing farm allows their chickens to stand up, lie down, turn around, and fully extend their limbs in their modern, cage systems.  The same year that California’s Governor signed AB 1437 into law, Dr. Kenneth Anderson, NC State, published his research findings showing the modern, caged chickens are in healthier conditions as evidenced by 1) a greater number of eggs produced, 2) larger eggs, 3) more grade A eggs, 4) better feed conversion rates, 5) significantly lower mortality rates compared to chickens taken out of cages, 6) higher antibody levels protecting the chickens from poultry-related diseases. The California egg farmers with colony cages extol their virtues in hopes of convincing other egg farmers to make the investments up to $40 per chicken for the new cages, but the initial research from the Coalition for Sustainable Egg Supply, a group of poultry scientists, noted these cages resulted in more leg and wing breakages.  Anyone observing these new colony cages can see why.  The birds race through the cage and run into the perches and injury themselves. Certainly Mr. Friedrich, professing a reverence for animal welfare, would not intentionally want to see more chickens with broken wings or broken legs. 

As to the European Union experience, that new law went into effect January 1, 2012 (Council Directive 1999/74/ED).  When this new law went into effect, European stores reported shortages of eggs up to 20% as a result of the new law with prices increasing a whopping 44%.

Dr. Atoussa Mazaheri, Company Veterinarian with Lohmann Tierzucht in Cuxhaven, Germany reported that the German egg farmers who installed the enriched colony cages in that country regretted it. Dr. Mazaheri stated publicly the animal rights activists were not satisfied and are pressing the retailers to go cage-free altogether. Those “good intentions” by the German Bungestag, reported Dr. Mazaheri, yielded more problems with the re-emergence of poultry diseases that had been previously eradicated since 1998. These included Erysipelas showing a drop in egg production upwards of 15% and mortality of 30%; Blackhead which can only be cured with penicillin, but not allowed in poultry in Germany; and Pox (Fowl Pox) which has a mortality ranging between 10-50%.  Certainly Mr. Friedrich would not want to see an increase in poultry diseases.

The same year of the California egg law, Dr. Impke de Boer, Wageningen University in Holland presented her research on greenhouse gas emissions at an international forum with the modern, conventional cage system at the lowest of any animal.  The chickens in modern systems produced 2.2 kg of carbon equivalent per kilo of eggs, 25% less than other forms of egg production.  

Lastly, Mr. Friedrich, should perhaps re-read his copy of the U.S. Constitution concerning his claims against the lawsuit filed by the Missouri Attorney General.  Article 1, Section 8, clause 3 of that founding document clearly states the power to regulate commerce among the states lies with the Congress.  Some in California claim their state’s rights under the 10th Amendment to the Constitution, however that amendment begins by stating “The powers not delegated to the United States by the Constitution…”  In other words, claiming state rights cannot supercede what is already enumerated in Article 1.

Californians deserve to hear both sides of the debate concerning how eggs are produced and I appreciate the privilege to provide the other side.

Ken Klippen, with two degrees in Poultry Science and more than 30 years in the egg industry, is representing National Association of Egg Farmers.



National Association of Egg Farmers Offer Science-Based Production Guidelines

While many in the egg industry press forward in support of the enhanced colony cage, the science behind the amount of space offered each chicken is lacking.  National Association of Egg Farmers has science-based production guidelines available on a voluntary basis to its members.  Below are the science-based research articles behind the production guidelines:

  1. 1.Adams, A.W. and M.E. Jackson,Effect of cage size and bird density on performance of six commercial strains of layers.  Poultry Sci. 49:1712-1719.
  2. 2.Anderson, K.E. and A.W. Adams,Effects of rearing density and feeder and waterer spaces on the productivity and fearful behavior of layers.  Poultry Sci. 71:53-58.
  3. 3.Anderson, K.E., A.W. Adams, and J.V. Craig, 1989. Behavioral adaptation of floor-reared White Leghorn pullets to different cage densities, cage shapes during the initial settling-inPoultry Sci. 68:70-78.
  4. 4.Anderson, K.E.,Welfare implications of cage density, population, and feeder space.  2001 Midwest Poultry Federation Convention, Touchstone EnergyâPlace at River Center, St. Paul, Minnesota, March 14-15, 2001, pp. 164-170
  5. 5.Anderson, K.E.Final Report of the Thirty-Fourth North Carolina Layer Performance and Management Test: Production Report.  North Carolina Extension, Raleigh, NC Vol. 34, No. 4. November 2002.
  6. 6.Anderson, K.E., G.S. Davis, P. Jenkins, and A.S. Carroll. 2004. Effects of bird age, density, and molt on behavioral profiles of two commercial layer strains inPoult. Sci. 83:15-23.
  7. 7.Anderson, D.P., G.W. Beard, and R.P. Hanson,The adverse effects of ammonia on chickens, including resistance to infection with Newcastle Disease virus.  Avian Diseases 8:369-379.
  8. 8.Anderson, D.P., R.R. Wolfe, F.L. Cherms and W. E. Roper,Influence of dust and ammonia on the development of air sac lesions in turkeys.  Am. J. Vet. Res. 29(5):1049-1057.
  9. 9.Al-Rawi, B. and J.V. Craigt,Agonistic behavior of caged chickens related to group size and area per bird.  Applied Anim. Ethol. 2:69-80.
  10. 10.Appleby, M.C.,Life in a variable world: Behavior, welfare and environmental design.  Appl. Anim. Behav. Sci. 54:1-19.
  11. 11.Agriculture Canada. 1990. Recommended code of practice for the care and handling of poultry from hatchery to processingAgriculture Canada Publication 1757/E.  Communications Branch, Agriculture Canada, Ottawa, Canada.
  12. 12.American Veterinary Medical Association.2000 Report of the AVMA Panel on Euthanasia. J. AVMA 218:669-696.
  13. 13.Bell, D.D., and D.R. Kuney. 2004. Farm evaluation of alternative molting procedures. J. Appl. Poult. Res. 13:673-679.
  14. 14.Bell, D.D., and W.D. Weaver, Jr.Commercial Chicken Meat and Egg Production. (5th Ed.) Kluwer Academic Publishers, Norwell, MA.
  15. 15.Biggs, P.E., M.E. Persia, K.W. Koelkebeck, and C.M. Parsons. 2004. Further evaluation of non-feed removal methods for molting programs. Poul. Sci. 83:745-752.
  16. 16.Brannigan, P.G. and J.B. McQuitty,The influence of ventilation on distribution and dispersal of atmospheric gaseous contaminants.  Canadian Agricultural Engineering 13(2):69-75.
  17. 17.Burnett, W.E. 1969. Odor transport by particle matter in high density poultry houses. Poul. Sci. 48:182-185.
  18. 18.Carlile, F.S., 1981. Ammonia in poultry houses: A literature review. World’s Poul. Sci. 1:99-113.
  19. 19.Carpenter, G.A. 1986. Dust in livestock buildings-review of some aspects. J. Agric. Engng. Res. 33:227-241.
  20. 20.Craig, J.V. and A.M. Guhl, 1969. Territorial behavior and social interactions of pullets kept in large flocks. Poul. Sci. 48
  21. 21.Curtis, S.E. and J.G. Drummond, 1982. Air environment and animalIn CRC Handbook of Animal Productivity. Reichicigl, M. Ed. Vol. II, 107-118.
  22. 22.Consortium. 1999. Guidelines for poultry husbandry. In: Guide for the Care and Use of Agricultural Animals in Agricultural Research and Teaching. Federation of Animal Science Societies, Savoy, IL.
  23. 23.Denton, J.W., F.N. Reece, B.D. Lott. Effect of atmospheric ammonia on laying hen1982 Poul. Sci. 61:1815-1817.
  24. 24.Dearstyne, R.S., and P.H. Kime, 1943. Grazing crops for poultry. Extension Circular No. 239. NC Agricultural Extension Service, North Carolina State College of Agriculture and Engineering, Raleigh, NC.
  25. 25.Feddes, J.J.R., J.J. Leonard, and J.B. McQuitty, 1982. Heat and moisture loads and air quality in commercial broiler barns in Alberta. Research Bulletin 82-2, Dept. of Ag. Eng., Univ. of Alberta, Edmonton, Alberta, T6G 2G6, 82 pp.
  26. 26.Feddes, J.J.R., and J.B. McQuitty, 1983. Heat and moisture loads and air quality in commercial poultry laying houses in Alberta. Final Report for Engineering and Statistical Research Institute, Contract File No. OSU81-00304. Agriculture Canada, Ottawa, Ontario. 77 pp.
  27. 27.Jalal, M.A., S.E. Scheideler and D. Marx, 2006. Effect of bird cage space and dietary metabolically energy level on production parameters in layingPoul. Sci. 85:306-311.
  28. 28.Janni, K.A., P.T. Redig, J. Newman, and J. Mulhausen, 1984. Respirable aerosol concentrations in turkey grower buildings. 1984 Winter Meeting, ASAE, Hyatt Regency, New Orleans, LA, Dec. 11-14, 1984. Paper No. 84-4522.
  29. 29.Jones, T.A., C.A. Donnelly, and M.S. Dawkins, 2005. Environmental and management factors affecting the welfare of chickens on commercial farms in the United Kingdom and Denmark stocked at five densities. Poul. Sci. 1155-1165.
  30. 30.Jones, W., K. Morring, S. Olenchock, T. Williams, and J. Hickey. 1984. Environmental study of poultry confinement buildings. Am. Ind. Hyg. Assoc. J. 45(11):760-766.
  31. 31.Jull, M.A., 1951. Poultry Husbandry, 3rd Ed. McGraw-Hill Book Co., Inc. NY, NY
  32. 32.Kinder, Q.B., A.B. Stephenson, 1962. Floor space requirements of S.C. White Leghorns. Poul. Sci. 41:1394-1400.
  33. 33.Kling, H.F., and C.L. Quarles, 1974. Effect of atmospheric ammonia and the stress of Infectious Bronchitis vaccination on Leghorn males. Poul. Sci. 53:1161-1167.
  34. 34.Koelkebeck, K.W., C.M. Parsons, P. Biggs, and P. Utterback. 2006. Non-withdrawal molting programs. J. Appl. Poul. Res. 15:483-491.
  35. 35.Kristensen, H.H., and C.M. Wathes. 2000. Ammonia and poultry review: A review. World Poul. Sci. J. 56:235-245.
  36. 36.Lee, C.L., 1949. Profitable Poultry Management, 1949 ed. The Beacon Milling Co., Inc. Cayuga, NY, pp 106-119.
  37. 37.Loomis, E.C., J.R. Anderson, and A.S. Deal, 1980. Identification of common flies associated with livestock and poultry. Leaflet 2506. Univ. of California Cooperative Extension.
  38. 38.NRC. 1994. Nutrient Requirements of Poultry (9th rev. ed.). National Academy Press, Washington, DC. Water consumption of poultry (US gal/day/1000 birds).
  39. 39.Occupational Safety and Health Administration, US Department of Labor - Permissible Exposure Level for Ammonia, 29 CFR Sec. 1910.1000 Table Z-1 Limits for air contaminants.
  40. 40.Scheideler, S.E., and M.M. Beck. 2002. Guidelines for a non-fasting feeding program for the molting of laying hens. Univ. of Nebraska Coop. Ext. Bull. G02-1482-A.
  41. 41.Sohail, S.S., M.M. Bryant, S.K. Rao, and D.A. Roland, 2001. Influence of cage density and prior dietary phosphorus level on phosphorus requirement of commercial Leghorns. Poul. Sci. 80:769-775.
  42. 42.Stadelman, W.J., V.M. Olsen, G.A. Shemwell, and S. Pasch, 1988. Egg and Poultry-Meat Processing. VCH Publishers. NY, NY.





National Association of Egg Farmers File Comments on EPA Proposal for Ethanol

National Association of Egg Farmers, a coalition of farmers producing eggs from coast-to-coast, appreciates the opportunity to comment on the EPA proposed the 2014 volume requirements and associated percentage standards for the RFS program. The proposed 2014 standard for corn ethanol is 13.1 billion gallons, a reduction of 1.4 billion and equal to the 2013 consumption.  While members of the egg industry have questioned the use of corn for fuel, we support cellulosic biofuel and biomass-based diesel in the renewable fuel program. So this reduction in corn for ethanol production is supported by National Association of Egg Farmers.

National Association of Egg Farmers position on issues has consistently maintained that market forces are the best because they allow consumers to decide what goods and services they prefer instead of implementing federal regulations or new laws by Members of Congress.  Involvement in the market place by the federal government, although well-intentioned, can create a negative impact on certain businesses and the ethanol mandate is an example.  The U.S. ethanol mandate is responsible for claiming 37% of total corn production in the U.S. and 15% of total world corn production.  This is devastating to the end-users of corn in feeding animal agriculture including chickens producing eggs.  When any commodity is reduced, the corresponding effect on price catapults in the opposite direction.  When there was a small downward adjustment to the expected harvest in corn production, the corn prices jumped almost 18%.  The Federal law requires that fuel suppliers blend more and more ethanol into gasoline, until the annual total rises from 9 billion gallons of (ethanol) EtOH in 2008 to 36 billion in 2022.  Removing more corn from the commodity markets simply increases the price of corn, hurting consumers who buy animal products such as meat, milk and eggs which must be increased to offset the increased cost of production.  In the egg industry, the cost of feed is nearly 60% the cost of the egg produced with corn being the most widely used feed grain.  There is no other feed grain that provides the same quality nutrients needed by chickens in producing eggs to feed this nation.

Problems With Ethanol and Why EFA Opposes E15

* Ethanol costs 3.5 times as much as gasoline to produce, but contains only 65% as much energy per gallon as gasoline.

* The more ethanol there is in gasoline, the more often consumers have to fill up their tanks, the less value they get, and the more they must deal with repairs, replacements, lost earnings and productivity, and malfunctions that are inconvenient or even dangerous.

* Ethanol burns hotter than gasoline. It collects water and corrodes plastic, rubber and soft metal parts. Older engines and systems may not be able to handle E15 (15% ethanol) or even E12 (12% ethanol), which could also increase emissions and adversely affect engine, fuel pump and sensor durability.

* Corn growers will benefit from a higher ethanol use, however government mandates mean higher prices for corn.  Thus, eggs, beef, pork, poultry farmers must pay more for corn-based feed; grocery manufacturers face higher prices for grains, eggs, meat and corn syrup and overall grocery bills go higher.

Environmental Concerns

* Ethanol has only two-thirds the energy value of gasoline – and it takes 70% more energy to grow and harvest corn and turn it into EtOH than what it yields as a fuel. There is a “net energy loss.”

* Analysts also calculate that growing and processing corn into ethanol requires over 8,000 gallons of water per gallon of alcohol fuel.

* Ethanol blends do little to reduce smog, and in fact result in more pollutants evaporating from gas tanks, says the National Academy of Sciences.

Grow Grain for Food Not Fuel

Michigan State University scientists concluded, after examining 17 years’ worth of data, "It's 36 percent more efficient to grow grain for food than for fuel," said Dr. Ilya Gelfand, MSU.  "The ideal is to grow corn for food, then leave half the leftover stalks and leaves on the field for soil conservation and produce cellulosic ethanol with the other half." The results are published in the April 19, 2010 online issue of the journal Environmental Science & Technology.

National Association of Egg Farmers appreciates this opportunity to comment urging EPA not to expand usage of a food to convert it into a fuel.   We oppose E15 for the damaging effect it will have on feed costs to animal agriculture and the damage it will do to older model engines and its effect on the environment. 


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