Farm Legal Series #6: Can't Believe it's Raw Butter - The Legal Battle for Raw Food

 
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Welcome to the sixth episode in Barn2Door's series in partnership with the Farm to Consumer Legal Defense Fund. FTCLDF is a non-profit organization of lawyers supporting Farmers across the country and helping them navigate the unique legal challenges Farmers face. In this episode, we cover the Campaign for Raw Food, and the concerns that have been raised over regulations on raw butter.

https://www.farmtoconsumer.org/
https://www.farmtoconsumer.org/campaign-for-raw-food/

 
 
  • [00:00:00] James: Hey welcome everyone to the direct farm podcast. We've got a great conversation for you today with the Farm To Consumer Legal Defense Fund or the FTCLDF, they are a nonprofit organization made up of lawyers, serving farmers by protecting, defending, and broadening the rights and viability of independent farmers, artists, artisinal food producers and their consumers.

    [00:00:20] This is the 6th episode in a series of podcasts we've done with the Farm To Consumer Legal Defense Fund, each highlighting a different farm product and some of the legal challenges associated. Today, we're going to be discussing a very hot topic. We're going to be diving into the campaign for raw food and the legislation around it, which has some big ramifications affecting the entire US food system. I'm delighted today to welcome Alexia Kulwiec. She is a lawyer and she's the Executive Director of the Farm To Consumer Legal Defense Fund. She's a licensed attorney in Illinois and Wisconsin, and she's practiced law for over 20 years.

    [00:00:55] And her experiences inspired her interest in us agriculture, promoting small-scale farmers in sustainable farming and helping protect the rights of independent producers across this country. Welcome Alexia. It's great to see you again.

    [00:01:08] Alexia: Yeah, thanks so much. It's lovely to be here. Thanks for having me.

    [00:01:11] James: I always look forward to having a chance to speak with you. It's always so educational for me. And I know our listeners are reacting to this podcast series quite well. Today we have another really hot topic, but before we dive into it, and this might be the first time for some listeners to listen to a really important topic that has far reaching effects.

    [00:01:29] Can you just take a couple of steps back for any new listeners and give them a little brief overview of the Farm To Consumer Legal Defense Fund.

    [00:01:36] Alexia: Yes, thank you. As you stated we are a nonprofit organization and we provide legal services to our members. So we are, membership-based very low membership rates for farmer members and homesteaders and consumers. And then we provide legal services. Mostly when it comes to the government regulatory system of food production.

    [00:01:57] And so we are very concerned with government overreach and helping growers and producers be able to grow their food and sell it directly to consumers. Despite the level of regulation that we oftentimes see in the system. And so sometimes that includes representing them through a regulatory agency proceeding, sometimes litigation. And we also try to do some policy work and advocacy work on improving the regulatory system, which really can be daunting for a small producer.

    [00:02:23] James: Today, we're going to be diving into something that could become a very controversial and very big topic. Now, and then big topics come up that, capture America's attention. And this certainly seems to be one that could surface and become, again, a far reaching topic that affects a lot of farmers and a lot of consumers across the country.

    [00:02:44] So today we're going to dive into what's called the Campaign for Raw Food. This is a current lawsuit that the Farm to Consumer Legal Defense Fund is actively involved with that has potentially very large consequences, specifically under direct to consumer farming as a whole. It started with a ban of raw butter, but now there is the premise and the possibility that this may be extended to include other raw foods. And that's shocking, right? At least when I read the case and read the summary, I was a little bit alarmed at some of the rationale. So maybe to help our listeners get a little bit understanding of just that the premise behind the lawsuit, can you tell us how this lawsuit came to be filed with Raw Farm LLC?

    [00:03:23] Alexia: Sure, thank you. So yes, and I just want to say, I know we will get to it. It all did begin with an action regarding the prohibition on the interstate sales of raw butter, but the way the litigation has unfolded in some of the comments and rulings from the judge has concerned us that this can apply to really any raw food or other foods as well, frankly. And so that has what has encouraged us to try to increase publicity and start the campaign for raw food.

    [00:03:52] But first the litigation, I will take a step back and say that the Farm To Consumer Legal Defense Fund and Mark McAfee of Raw Farm LLC had petitioned the FDA back in 2016 to exempt raw butter from the FDA prohibition on the interstate sales of raw milk.

    [00:04:13] And I'll take one more step back in history. In 1987, the FDA required pasteurization of all milk and milk products and prohibited the interstate sales of raw milk, so across state lines. But when it did that, it did so pursuant to a previous litigation that required the FDA to do so essentially, but the evidence that it was derived from was all based on raw fluid milk. And there was no discussion of raw butter in the previous litigation. And then the court said FDA, you've got to require pasteurization of any raw milk product, essentially. And that's what the FDA did. What's interesting with butter is that unlike a lot of foods, Congress had specifically previously defined butter and it did not authorize the FDA to regulate raw butter across state lines, and there's a fascinating history that's really supporting dairy farmers versus margarine and those that sort of history you could dig into. But in any case, it's clear that in fact, Congress intended to exclude regulation of raw butter, really from the Food, Drug, and Cosmetic Act, which is the law that gives the FDA its authority.

    [00:05:26] So Farm To Consumer Legal Defense Fund, along with Mark McAfee and Raw Farm file petitions to the FDA in 2016, to have the FDA point out this exemption for raw butter, that it should not be included in the prohibition of interstate sales. The FDA did not respond to the petition for a good three years, despite a number of attempts to receive a response.

    [00:05:52] And finally, we had to file a lawsuit against the FDA to just get a response to the petition that we filed with the FDA to exempt raw butter from the interstate prohibition of sales of raw dairy across states.

    [00:06:07] James: This is a very big deal, right? Cause I think all of us recognize the fact that obviously Congress, can't get into the minutia of everything by any means. That's the whole purpose of creating regulatory agencies is that the, is that Congress will authorize an agency to promulgate regulations, which have effectively become law to, to govern certain areas and topics.

    [00:06:29] Litanies of regulations that govern everything in our lives, because Congress doesn't have time. However, where Congress, to your point, expressly does not include the authorization or expressly makes something that's contrary to that, and doesn't give the agency, this authority that becomes a real question of government overreach, right? The regulators are not elected. So this could potentially have some big impacts, right? Cause I just want to slow down here, so our listeners really understand this. Which is nothing wrong with an agency going forward and doing what they've been asked to do, but when they'd go beyond the scope of what they've been asked to do, that's the concern here is that correct? Is that they are now going beyond the scope of what they've been authorized by Congress.

    [00:07:13] Alexia: And I would argue, not only did they go beyond the authority of Congress, but that they contradicted specific acts of Congress. And what I say by that exactly is not only does it not authorize them to do this, but that in separate legislation, Congress had defined butter, and when the FDA decided to regulate the interstate sales of raw butter, it was in effect creating a new definition of butter and deciding how it should be regulated that contradicted what Congress had already determined. You're right, Congress wouldn't normally get into this level of detail and minutia, but with butter, it did. And it's not, it doesn't do so with many foods, usually will let the FDA make these decisions, but Congress did choose to define butter.

    [00:08:01] And then the FDA, in my opinion, did not have the authority then to change that and to regulate it beyond what Congress had already set forth.

    [00:08:09] James: That's a great point. And I'm really curious, love to hear your thoughts, right? Cause butter's not milk, right? It's made for milk, but it's not milk. And if Congress has authorized at the FDA to regulate milk, great, go do the work that Congress has asked you to go do, but now to expand that again, creates concerns around government overreach.

    [00:08:28] So let's talk about a little bit, what's the reasoning for the FDA's ban on interstate sale for all butter to begin with. Why do they even care? Why are they picking this fight and why they're trying to implement these regulations?

    [00:08:40] Alexia: So I think really what happened is when the FDA prohibited the interstate sales of raw milk. It was relying on some. Alleged evidence at the time of the potential safety hazards of raw fluid milk, which is not butter. And while I'm getting pretty legalistic in this particular podcast because of what I feel the court has done in this case, understand your point is really well taken, which is that butter is not.

    [00:09:07] And in fact, the opposite thing with milk is that because butter has such a low moisture content and high fat content that the spread of in growth of pathogens or bacteria, the risk of that and butter is very low as opposed to raw fluid milk. But instead of making that distinction in 1987, the FDA just said, we're going to require pasteurization or prohibit interstate sales of raw milk and raw milk products. The problem I have with that is back then when they passed it, you said, why are they doing this? They relied just on evidence of potential problems with raw fluid milk, so I think they weren't even paying attention, again this is commentary, to the issues with raw butter when they originally passed the regulation. In defending the regulation, they have made some allegations of concerns of pathogen growth or of illness that could be caused by raw butter.

    [00:10:04] We had to sue to get a decision out of the FDA. When they did respond to us, which was in February of 2020, they denied the petition. And in doing so, they did attach a chart, alleging some illness related to raw butter, none of which was commercial raw butter. In other words, some of the cases were so long ago that we don't have any idea whether it was raw butter. And when I say so long ago, as back into the 1800's, they were relying on alleged cases.

    [00:10:34] James: Holy smokes! They're reaching pretty far back to try to find a reason to implement these restrictions.

    [00:10:39] Alexia: And most of the cases that they relied on they could not establish whether it was raw or pasteurized butter. We know that you can have pasteurized butter, so it didn't really prove anything. And there was not one commercial case involved. There was some, one person that did something at a school that somebody once got sick from.

    [00:10:57] There really was not a good, strong rationale based on evidence, but rather just based on a supposition that like milk, someone could get sick from pathogen growth if the butter had not been made from pasteurized milk. I'm not very convinced with that argument by the way, but that is what they said in their response to it.

    [00:11:15] James: This is very disconcerting to me. Not just as a consumer, but more importantly, and somebody who works with farmers and, wants to ensure that farmers have the independence that they have to not only sell milk, obviously, subject to federal regulations as applicable, but also to sell other milk derived products, right? And so the question I have for you is this creates real concerns around overreach, right? If they're authorized to regulate milk, how much further does this go? Now they're reaching to butter. What about cheese? Cheese, honestly, like there's a very big difference between a young cheese and an old cheese, right?

    [00:11:48] Different densities, arguably it's a slow moving fluid. Arguably glass is actually a fluid. If you look at a hundred year old glass, it's slowly moving. But it's just moving very slow. The point is where does the government's overreach stop?

    [00:12:00] And how much further is the FDA going to jump with this regulation to start impacting other raw foods?

    [00:12:05] Alexia: We're very concerned about that because what we at Farm To Consumer Legal Defense Fund had gathered from FDA filings in this case is basically they're saying, in my opinion there is no limit. And I want to explain again, I know it's a little legalistic and maybe you can help me with it, but the FDA's enabling statute. In other words, the statute that gives them authority to regulate food products is the Food, Drug and Cosmetic act. Congress did put in some limitations and some requirements in that law for the FDA to then promulgate regulations. But what the FDA said in response to our raw butter petition was that it had the authority under a different law to regulate raw butter here, and that being the public health services act, and the district court in this case then used that rationale to uphold the FDA's decision and say, "Oh yeah, you have this right under this other law to regulate food to make sure people are safe."

    [00:13:02] And the huge concern with that is that was not the intention of that law. It's not the law that gives the FDA, their authority. And it's just a very broad law about preventing the spread of communicable disease, which is different than pathogen growth, but putting that aside. So now we have a court decision suggesting, basically, you can regulate any food you want in any manner you want. If you're just going to slap a, "For health and safety purposes" on.

    [00:13:30] James: What couldn't you regulate in public health, safety, and welfare would cover everything that anyone would consume.

    [00:13:35] Alexia: Yeah, I would think so. And that's why we had this nitty gritty concern about there's a difference between milk and butter and they shouldn't be prohibiting butter. That was a concern, but once we saw these rulings about reliance on a different law, and the FDA has not indicated any end to that regulation that they can do whatever they want if they say that what they're doing is trying to protect health and safety. And so we don't see an outer bound there and that's what gives us and our farmer members very great concern. They could step into regulating any raw food. Are they going to tell us how we can eat our meat? Are they going to start regulating raw fish and shellfish, oyster products. These are things that people purchase raw intending to eat raw that the FDA could suddenly say, "We're going to start regulating entire kinds of food based on public health and safety." And so we're very concerned about that development.

    [00:14:32] James: Yeah, we've all heard concerns about activist judges, but now we're talking about activist regulators, right? And that would be really concerning because these are not people you can vote out of office. You're really stuck with people who are regulators. And if you have activist regulators that are going beyond the scope of authority that Congress has given them, what's our repercussions?

    [00:14:48] You have to file lawsuits. And that just seems really challenging. And especially for farmers out there who are listening to this, you should be concerned, right? This is something you need to be involved with and to ask yourself like, "Hey, how can I support this campaign?" And we'll talk a little bit about that in a few seconds.

    [00:15:05] Again, government overreach is a concern here. If they're going to go beyond, like you said, not just raw milk and raw milk derived products, who's to say that they're not to hit other raw consumables, right? I, jeez, like I love raw oysters and I know Taylor Shellfish Farms here in Washington state, and oysters is a huge industry in Washington state, they ship raw oysters all across the country. I'm sure they must be concerned about this too. So what can you share with the listeners? When you're thinking about organizing this campaign and the work that you're doing for this lawsuit, what can they do to support your organization and maybe tell folks a little bit more about this Campaign for Raw Food. What is it intended to do altogether?

    [00:15:44] Alexia: Yeah, thank you. As I stated, these rulings suggesting that now the FDA has unlimited authority essentially. That grew this concern that these rulings can impact regulation of any food and specifically any raw food, really. And so that has led to the creation of the Campaign for Raw Food. And really what we're doing with that campaign is we'd like to, we want to publicize and educate folks about the impact of the court decisions and the raw butter case. And then frankly, be prepared to provide defense if FDA begins to regulate some of these other industries like oysters or sushi, any other raw food. Will they step away from the Food, Drug, and Cosmetic act and say under this other law, they can regulate anything they want.

    [00:16:28] James: What about raw vegetables? Come on. Who doesn't want to eat a carrot out of the ground, and they can start implementing additional regulations about a carrot that a farmer wants to sell. It's just seems silly. Like where does it end? It's a very slippery slope.

    [00:16:39] Alexia: It's a really slippery slope. And so the campaign is to really gain attention that the litigation that we started is not about butter at this point. It's really about government overreach and it's about regulation of raw food. And so far we have still focused a lot on the butter litigation, but we're also branching out to let our members know we've reached out to our farmer members to educate them about the potential impact of these rulings.

    [00:17:08] We're starting to build awareness of the potential that this could have against other raw foods and start, frankly, collecting donations so that we're prepared to provide legal defense in other cases that are going to be similar to the raw butter cases. And as we see potential policy issues arise specific to raw foods, I think we want to expand the action alerts in this potential policy pushback that we would ask people to do in response to other regulations that we see coming out.

    [00:17:39] So it will really be tracking, educating, and following the potential regulation of raw foods.

    [00:17:46] James: Yeah, for listeners who don't know about the Farm to Consumer Legal Defense Fund, you can go to farmtoconsumer.org and go sign up for their newsletter, and follow these action alerts that Alexia is sharing about. More importantly, I would encourage you to sign up and become a member of Farm to Consumer Legal Defense Fund. And there's a lot of value in membership that you can get with the organization in terms of legal representation and support and consultation across all 50 states. It's fantastic. But this Campaign for Raw Food, if you go to campaignforrawfood.org, you can actually go donate to this campaign specifically. I know I went online earlier today and made a hundred dollar donation to Alexia and her team's efforts to support this case. This is really important, so I'd encourage all of our listeners, again, to go to thecampaignforrawfood.org and make a donation today. So you can continue to support this fight because we need to protect farmer's rights to, to grow and harvest and sell raw foods.

    [00:18:43] Can we talk a little bit more about like, where do you think this case is headed? Where are things going to go? I know you have upcoming oral arguments. Can you give the listeners a little bit of a status update on where the litigation is today?

    [00:18:55] Alexia: So after we Sue to get the FDA to respond to us, we then continued the litigation to challenge the FDA's ruling to deny the exemption of raw butter to the prohibition across state lines and the district court upheld the FDA's ruling in that case.

    [00:19:14] So in other words, the district court and this was a district court federal court in Washington, DC said the FDA was fine to use this public health services act to regulate sales of raw butter across state lines. We have since filed an appeal of that decision in the DC circuit court of appeals, and that has been fully briefed and we are presenting arguments on that, on this case on April 8th. Probably by the time listeners hear or see this, the arguments will have been done and they can download the streaming version of the argument that will be made before the court. And then we'll be waiting for the court of appeals to issue a decision in the case.

    [00:19:52] James: And you expect that the decision to come down, what, three to four months after oral arguments?

    [00:19:57] Alexia: Yeah. It's always hard to predict, but I would say a couple of months, at least after oral argument in April.

    [00:20:03] James: And can you remind listeners, the DC district court, what circuit is that in?

    [00:20:07] Alexia: It's the DC circuit court of appeals, so it is the federal appellate court.

    [00:20:12] James: As these issues come up across the country, right? The importance of being able to continue to contest these, that, the potential for litigation, if we don't get a ruling in our favor in this case, there's a potential that decision could be influential, but not necessarily binding on other districts around the country.

    [00:20:30] And so my point is like really important for farmers who are listening, regardless of where you're at in the country. If you see any attempt of overreach in this type of manner, you could certainly potentially bring suit in another district that might, might be more favorable, who knows, hopefully this district will arrive at the right conclusion and we can just remand this issue.

    [00:20:49] Alexia: Certainly of course I'm absolutely hoping that, and I think we have very strong, legal arguments that we touched on in the beginning about how Congress had regulated and allowed for the sale of butter. What I will say is that the DC circuit commonly reviews, actions of federal agencies. And so I do think that there's a concern here that if they uphold say the FDA's authority then the FDA can exert that authority everywhere.

    [00:21:18] James: Yeah, it's going to be very influential.

    [00:21:20] Alexia: Unlike some cases, you're not just limited to that region because it's actually looking at that federal agencies authority. So I think it could have ramifications broadly across the country, which is why we're trying to extend the campaign and have people see the importance of this ruling.

    [00:21:36] James: Absolutely. I totally agree with that. I'm thinking along the lines of you can very well see a scenario where the DC court, if they land in an unfavorable ruling that then the FDA goes forward and they start legislating or actually regulating zealously across the country that may lead to additional suits across different districts.

    [00:21:56] In which case you could then have some confusion around what you could do perhaps in the ninth circuit versus the seventh versus the fourth. And then that would inevitably lead to the Supreme court at some later point to, to resolve the issue. I just hope we never have to go that far.

    [00:22:09] There's just seems to be a lack of common sense in activist regulators, and unfortunately it sounds like some activist judges who are trying to pull any other legislation out to try and give authority to the FDA to regulate these things. Outside of dairy, where do you believe are, the other kind of like the most potentially vulnerable, is it sound like seafood might be the other area that might be the most vulnerable for potential regulation in this scenario?

    [00:22:34] Alexia: I think in this area of raw food generally, but particularly seafood would be at issue. And the reason I say that is simply the legislation that we're looking at this prohibition on the sale of raw butter across state lines is very specific to raw butter as opposed to pasteurized butter.

    [00:22:51] So the FDA has taken this stance essentially against raw food. And so we're really thinking that the next threatened production is really production of any raw food. And I would agree with you that could include vegetables because there is some potential contamination on the farm of your vegetables, right?

    [00:23:09] That's why federal policies stepped in to regulate vegetable production as well. But the foods that you see sold raw on a regular basis, that we could see the FDA wanting to step in and regulate. I think seafood is certainly one. That's why way up there. We certainly have concerns about could restaurants or stores, can you no longer have a restaurant sell very rare meat, for example? That could be something...

    [00:23:31] James: You gotta be kidding me. Where am I going to get? Where can I eat sushi and tartar? Geez, who doesn't like a good beef tartar?

    [00:23:37] Alexia: And a concern for our members who are, grassfed beef of the best quality selling to local restaurants. That's the kind of beef, frankly, you want to eat rare. I don't want the government telling me I got to cook it more to kill some pathogens that I know my farmer hasn't allowed to get in there.

    [00:23:54] James: Hey, and guess what? I'm an adult. Why can't I take the risk of, I know the farmer who raised that animal and I buy from that farmer directly. What's the government's business for stepping between me and my relationship with the farmer to eat the food that I so choose.

    [00:24:10] I'll be the first one to tell you I've gotten food poisoning before. It happens. Guess what? I'm willing to take that risk though. And I don't think it's the government's right or its place to step between me and my food producers. And I'm sure many of the farmers who are listening to this would agree with me and I'm happily their customer. But hey, if anything, hopefully this is calling to attention why this is such a vital and important issue for you as listeners to to support really encourage you to please share this podcast with other people, you can literally hit a share button on there, post it to your Facebook page, share it in your emails, share a link to the campaignforrawfood.org, and please go donate today. This is again, a potentially very significant decision that could have far reaching impacts that if we don't get to the right outcome, could lead to years and years of litigation and unfortunately, more government overreach.

    [00:25:04] Alexia, is there other things that you think farmers who are listening today should be aware of as they think about these things are things that they should be looking for in their own localities.

    [00:25:13] Alexia: I think what I would say, and this is a little beyond raw food, but also applicable to what we're concerned about in the Campaign for Raw Food. But I just am constantly aware of this disconnect between consumers and average people wanting to support our local farms and really having an increased demand for local foods and for what our local farms are doing.

    [00:25:35] But then from government agencies and say local townships and municipalities, I feel that we are seeing real pushback and increased legislation and regulation of food production. So I feel that policy is in great contrast to where our average consumer is today in that we want relationships with our farmers and want to buy directly.

    [00:25:57] So I would say it's really important for farms and food producers for that matter. To keep your eyes open of any new potential legislation that's being passed, whether at the federal level or at the state or local levels. I also see state and local agencies similar to this case, frankly, enforcing the laws in a way that we believe contradicts what's on the books.

    [00:26:22] In other words, agencies taking steps to really try and enforce their interpretation of a law, which may not be what we think state Congress, for example, had intended. I feel that's been really common these days. We're seeing agencies come down on producers and in ways that I think definitely is an overreach beyond what's written in the books.

    [00:26:44] And we're seeing some laws, making things more difficult for our local producers. So I do think it's really important for folks to monitor that. If you see something and are interested in policy work on it to please contact us at Farm to Consumer Legal Defense Fund. We are trying to fight back those kinds of changes and enforcement actions all the time.

    [00:27:05] And yeah, it's important to fight back when we see those changes.

    [00:27:08] James: Absolutely. We need to stand up for our rights and we need to make sure that we're standing up for our freedoms in this country. Which seem to be encroached on all sides at this time. For listeners who, again, may not know about the Farm to Consumer Legal Defense Fund. Can you talk a little bit about what membership might entail?

    [00:27:23] Cause I know as a lawyer myself, when I heard about your organization, obviously, I was very thrilled to start developing a partnership with you. But secondly, when I learned about the value that you have to offer farmers, it's just amazing. So can you just share with farmers who might be hearing this for the first time, what does membership in the farm to consumer legal defense fund look like and how do they take next steps if they want to support you?

    [00:27:45] Alexia: As you said, first and foremost, they can join by going online farmtoconsumer.org. And we do have farmer memberships, artisanal food producers, as well as consumer and homesteader memberships. So I do encourage folks to take a look at that. What I would say is we're membership based, but we're also nonprofit. So our rates are very reasonable. And what you will receive from that is we do a lot of work with local farms and drafting contracts to sell foods directly to their consumers. So for example, drafting for farmers, herd share arrangements so that they can provide raw milk through legal mechanisms to consumers who demand it.

    [00:28:24] We'll help local farmers sell live animals, and then bringing live animals or a share in a live animal and then have them slaughtered at an appropriate custom slaughter facility, we'll help with the bill of sale and making sure that sale is done in such a way that our farmer members won't have problems say with the meat inspection regulations, right? We will defend our members in agency actions that have been filed against them. Again, helping farmers through the regulatory process, which can often just be really cumbersome for a small producer. So we will provide unlimited legal consultation after six months to our members, and then we will provide legal representation as long as it is squarely within our mission of protecting and defending farmers rights to produce food and sell directly to consumers.

    [00:29:14] So we really are focused on the government regulation of the food production process, but in that limited mission, we will defend our members when there is government overreach.

    [00:29:24] James: And for farmers listening, Alexia's team, they have representation in all 50 states, so regardless of where you are located someone with Alexia's organization is ready to step up and support and counsel you. And I could just tell you as an attorney for $125 a year, that is a screaming great deal. It's fantastic that they've got benefactors that believe in what you do as independent producers. And so thank God for those benefactors who are continuing to lean in, but the goal here is again, is to make it accessible and affordable to farmers everywhere who again, need good legal counsel to protect themselves from this type of government overreach.

    [00:30:00] So Alexia, thank you again so much for your heart, your mission, the great work that you and your entire team are doing to help defend our freedoms and defend our access to food from these great farmers that we get the support. I wanted to extend my thanks to Alexia and everyone at the Farm to Consumer Legal Defense Fund, who support and serve farms again, all across the country.

    [00:30:21] I encourage you to continue to tune in next time to hear from Alexia, as we dive into nuances and laws and costs associated with being a direct to consumer farmer, as we're going to dive into more, what's it look like to sell direct to consumer? And for more information, again, go to farmtoconsumer.org.

    [00:30:36] There you can, again sign up for the newsletter. You can sign up to become a member. If you have a ambition, and I encourage this, please match my donation of a hundred dollars over to the Campaign for Raw Food. You can do that at campaignforrawfood.org. And there you can, again, support the great legal work that Alexia and her team are doing to try and protect again from government overreach and keep the FDA within the confines of its of its mission.

    [00:31:01] To learn more about Barn2Door of course you can go to Barn2Door.com/resources. There you can go and subscribe for our podcast where you can hear a whole litany of different conversations Alexia and I have had on a variety of different food topics.

    [00:31:13] Alexia, anything else that you would like to share before we sign off?

    [00:31:17] Alexia: Yeah, I will just say, first of all, thank you, James. We are so grateful for the support of Barn2Dooor I think it's really been a lovely partnership and we're really grateful and we know that you have a lot of great farmer members out there and I just want you all to understand, we know that a smaller, independent farm can't necessarily afford legal representation, and that's why we're here.

    [00:31:38] So we do while I would absolutely encourage you to join and support the Campaign For Raw Food, which is one of our priorities at the moment. Do just go check us out in general and think about joining as yourself as a member.

    [00:31:51] James: Awesome. Thank you again, Alexia. I'm really looking forward to our next conversation. And again, thank you for listening. Please share this podcast and this important topic with your friends, with your neighbors, on social media because it is really important that we raise awareness around the campaign for raw food. Take care and have a wonderful day.

    [00:32:07] Bye bye.

    [00:32:07] Alexia: Great. Thanks so much.

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