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COMMENTS AND TESTIMONY

ALL COMMENTS AND TESTIMONY

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ARA Signed WAC Comments to EPA on Proposed Rule Defining Scope of Federal Regulations

Jan 17, 2020

ARA signed Water Advocacy Coalition (WAC) comments to EPA Science Advisory Board on the proposed rule defining the scope of waters federally regulated under the Clean Water Act.

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Chemical Safety Board Comments

ARA Sends Comments to CSB on Accidental Release Reporting Proposed Rule

Jan 13, 2020

ARA sent comments to the Chemical Safety and Hazard Investigation Board (CSB) related to its proposed "Accidental Release Reporting" rule. ARA's comments recommend the CSB should rely on existing reporting systems such as the National Response Center to meet reporting obligations to avoid any new duplicate requirements for covered facilities.

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Water Stream Beside Trees

ARA Sends Comments to EPA on Water Quality Trading

Dec 19, 2019

ARA sent comments to the U.S. Environmental Protection Agency (EPA) addressing "baseline" issues in watersheds with EPA-approved total maximum daily loads (TDMLs), where policy makers seek to pursue water quality trading as a regulatory option for National Pollutant Discharge Elimination System.

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ARA Sent Comments to EPA on Paraquat Dichloride Registration Review

Dec 16, 2019

ARA sent comments to the U.S. Environmental Protection Agency (EPA) regarding the registration review process for paraquat dichloride because many of the new EPA requirements will make it very restrictive for agricultural retailers to purchase and apply paraquat products.

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Rail STB Transportation

ARA Signs Comments to Surface Transportation Board on Demurrage Charges

Nov 06, 2019

ARA signed comments sent to the Surface Transportation Board (STB) from the National Grain and Feed Association. The letter calls for STB to consider evaluating the reasonableness of demurrage and accessorial rules and charges.

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Truck Highways

ARA Submits Comments to FMCSA on Driver HOS

Oct 24, 2019

ARA submitted comments to the Federal Motor Carrier Safety Administration (FMCSA) on its proposed reform to the hours of service (HOS) regulations.

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ARAPAC meeting

ARA AND TFI SUBMITTED COMMENTS ON THE HOS AG COMMODITY DEFINITION

Sep 27, 2019

On Sept. 27, ARA and The Fertilizer Institute (TFI) submitted comments on the Advanced Notice of Proposed Rulemaking (ANPRM) focused on the current definition of an agricultural commodity as it relates to the hours of service (HOS).

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Three people discussing at sunset

ARA SUBMITS COMMENTS ON H-2A Process

Sep 24, 2019

The H-2A application process extends several burdens to employers making the program complicated at best and often unworkable. The agriculture industry is missing out on numerous opportunities because of labor shortages in addition to the program's complexities and limits. ARA applauds the Department of Labor's step towards addressing these shortfalls and creating a modem process that improves the program while maintaining protections for the United States' workforce.

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Person playing with soil

ARA CO-SIGNS GROUP COMMENTS TO USDA ON BIOTECH PROPOSED REGULATIONS

Aug 02, 2019

On behalf of the farmers, ranchers, processors, cooperatives, and other interests represented by the organizations listed below, we appreciate the opportunity to comment on the United States Department of Agriculture (USDA) Animal and Plant Health Inspection Service’s (APHIS) proposed “Movement of Certain Genetically Engineered Organisms” or “SECURE” rule, Docket Number, APHIS-2018-0034

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agricultural vehicles

ARA COMMENTS TO EPA OPPOSING PETITION TO BAN GLYPHOSATE ON OATS

Jun 05, 2019

On June 5, ARA submitted comments to the U.S. Environmental Protection Agency (EPA) opposing the petition from the Environmental Working Group (EGW) and other groups requesting that the agency modify the tolerance and product labels for glyphosate used in or on oats.

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