Attn:
Given the terrible flooding in the state and the damage, this is a poor time to make this announcement, but it must be made.
The Department of Ag (Chris Ferro) has filed emergency rules for the Herdshare law which will render the law entirely useless.
http://apps.sos.wv.gov/adlaw/csr/readfile.aspx?DocId=27626&Format=PDF
You can read the EXTENSIVE list above. Read this, get angry and act fast or we've wasted years of our time, and many of you already in operation will be forced to stop your share program already.
Keep in mind, the Dept of Ag "MAY" propose rules through the Department of Ag. Rule Making at the legislature can reject every rule set for in this document when they make final rules.
I am still trying to determine if these rules can be rejected or if they are now in effect until final rule making. I will let you all know when I am certain.
Keep in mind, when you read the above rules, they are OUTSIDE what the law allows, in my opinion. The law says,
"The Commissioner of Agriculture, in consultation with the Department of Health and Human Resources, may propose rules for promulgation in accordance with the provisions of article three, chapter twenty-nine-a of this code in compliance with raw milk dairy industry standards."
What these rules suggest are outside the Herdshare industry standards, and while the language says "Raw Milk Dairy" standards, since these are not sales, the industry in question MUST be the herdshare industry, and no such rules exist like are being set forth in the USA anywhere.
From my source:
"These are the emergency rules that people will be under until the legislative rules are adopted and approved by legislature."
Email every single person on Rules now:
http://www.legis.state.wv.us/committees/interims/committee.cfm?abb=RMR
Tell them you strongly oppose these emergency rules. Tell them you know they will make the law defunct. Explain they are, you believe, outside the parameters of the what the law allows.
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