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If you are involved in the sheep industry then chances are you have heard something about the proposed rule changes governing the H-2A Sheepherder program.  Whether it has been an email from ASI Executive Director Peter Orwick, a post in the weekly ASI email bulletin or a written  plea of support from your local sheep association, you should by now know the H-2A topic is garnering a lot of buzz and with the June 1st public comment deadline looming only a couple of days away, it is certainly turning into a hot topic that has a number of folks fearing the long term impact it could have on our sheep industry.

If you raise sheep and the H-2A topic isn’t at the forefront of your conversations and thought process this weekend, then it should be.  You might ask yourself, does this really affect me?  The answer in one word is…YES!

Unfortunately for many of us, we don’t think this news affects us.  As a busy small purebred producer, hobby fiber farmer or club lamb enthusiast we might be quick to dismiss this proposed policy change as yet another commercial man’s problem, which on the outside it is.  Really in reality, how many of us weekend warrior, carhartt wearing sheep enthusiasts employ imported labor to care for our twenty acres of bliss?  The answer is very few to none!

Chances are if you are like me, a small scale producer that doesn’t employ these workers you might be asking yourself, is all of the time invested delving deeper into this complicated issue and writing an email to the US Department of Labor by June 1st going to fix anything?  Heck, for that matter how do I write the email and which facts do I put into it?

While ultimately there is no guarantee a truckload of comments turned in by industry members will make a change in the current direction of the proposed policy change, however an on-slot of opinions will certainly be on record to point out clearly what those leading this crusade already know.  The fact is this proposed policy change was created by publicly paid bureaucrats who chose not to engage stakeholders in yet another governing process!

Outside of the fact that good legislation or policy should always be the result of collaborative efforts from all parties involved, why is this piece of policy which on the outside appears to affect such a small percentage of our industry important to everyone?

The answer can simply be summed up in two words, “Industry Infrastructure”.  Without industry infrastructure we will fail to have a sheep industry and quite honestly unless you are part of the small minority of producers who markets their lambs, fleeces and bi-products direct to the consumer bi-passing any and all of the traditional harvesting and marketing channels then you will be affected if the changes are implemented as proposed.

Like putting together a jigsaw puzzle, to get a better view of how all of this fits together we must first look at the individual pieces to the puzzle .

1. What is the H-2A Sheepherder Program and how does it currently affect the infrastructure of our sheep industry?
2. What are the proposed changes and what affects will they have on our industry?
3. How can we help?

What is the H-2A Sheepherd Program and how does it affect the infrastructure of our sheep industry?

The H-2A Sheepherder program is a longstanding arrangement overseen by the US Department of Labor.  This program provides a number of our industry’s larger operations with the opportunity to employ skilled workers on work visas from South America and other countries to tend to their flocks, herd their sheep/cattle and engage in the direct production of livestock.

As a small flock producer, the proposed rule changes don’t really have a significant direct impact on us.  I don’t employee workers, I have no need to increase wages and fill out more paperwork, however this ruling has a huge effect on the larger producers and in the long run this truly does affect me!  Why?

Simple, according to a data document provided by Dr. Julie Shiflett, a consultant to the American Sheep Industry office, 38% of our industry’s breeding inventory is managed under this scenario.  Thirty eight percent sounds like a small number until you realize this thirty-eight percent of breeding stock produces a great majority of the lambs and wool providing a steady stream of inventory being fed into the traditional supply chains that feed our lamb feeders, wool supply houses and harvest facilities.

This steady stream of supply from these H-2A herded flocks is what enables our large nationally based harvesting facilities and wool warehouses to continue to offer their customer base a consistent volume of product.  In fact in a recent comment letter made public by ASI, Mountain States Lamb Cooperative clearly noted, “Approximately 65 % of the lambs marketed through our cooperative come directly from ranchers using H-2A open range livestock herders”.  Simply put folks that is two-thirds of their inventory volume comes from operations who will be negatively impacted by the proposed regulations!

Without this ready supply of resources, these steady supply chains risk the threat of starting to dry up and facilities may ultimately lack the inventory to continue at current production levels thus having to  downsize their operations or even shutter their doors.

These are the same entities who have been  investing hundreds of thousands of dollars into our industry to encourage growth via the ASI Let’s Grow program and supporting the American Lamb Board.  If supply channels dry up and money slows down, there is a good chance these funding opportunities to promote lamb and drive our state and local  sheep associations into the future will also dry up.

In addition, this may open up the door for these larger entities to turn to foreign raised lamb to help offset the loss in volume from American producers.

Still not convinced?  Ask yourself where your lambs and wool are ultimately processed.  Think about the benefits, primarily paid for through the dollars of these large producers, the American Lamb Board’s efforts have created for all of us over the past several years.  Think about the amount of money our large warehouse wool buyers have contributed to the OSGA Scholarship fund over the years.   Finally, take count of the number of supporting industries from pharmaceutical and supply companies to transportation and service providers  that will be impacted by a significant decline in sheep numbers.

What are the proposed changes and what affects will they have on our industry?

If you have taken a moment to wade through the proposed policy information that has been sent out, you might be scratching your head and wondering about the key points which have so many folks deeply concerned about the proposed changes.   Ultimately, how do these specific proposed changes impact the future of our industry.  Luckily for all of the  political laymen, ASI, NLFA  and the Oregon Sheep Growers Association office has been working feverishly to simplify the points.  According to documents recently released from ASI, the major issues at the heart of the matter are:

1. The proposed rules would triple the wages paid to H-2A workers.

2. The proposed job description insists that livestock grazing takes place away from fences and, further half of the herders’ year must be away from the ranch headquarters and livestock facilities.

Let’s all face it, unless you are really lucky or an extremely skilled businessman, it is hard to get rich raising sheep.  We have all faced this conversation as we speak with a consumer regarding the cost of lamb on the retail shelf.  As we guide them through the costs and steps to producing these critters our mind can easily start to see just how slight the profit margin is in our industry.

Add to that unforeseen weather issues, predator problems and the rising cost of feed and fuel and on most years we are pushed to the limit.  This proposed Department of Labor policy would triple the cost of paying for labor.  Statistics recently released by ASI point out currently in most operations, hired labor can be figured in as 24 percent of an outfit’s total operating costs.  It doesn’t take a mathematician to quickly decipher the effects of tripling this wage and ultimately calculate the crippling outcome it could have on most operations.

While significantly increasing worker’s wages does have the prospect of being financially debilitating for a number of operations in our industry, the slamming door for a number of the folks directly impacted by these changes will be the ability to stay within the herder’s job description as outlined in the new proposal.

As most of us already know the sheep industry is diverse.  Because of our adaptability and the adaptability of the critters we raise, we can utilize a lot of different landscapes to raise a natural and wholesome product for the consumer.  In some cases this is utilizing federal permit land for summer grazing and in other instances it is helping to manage forage in a sustainable manner such as grazing the grass seed fields of the Willamette Valley.

In either scenario, the production herd will spend some of their time in a fenced scenario and need the careful eye of these trained shepherds to watch over them thus providing for their safety and well-being.

One argument I have heard from some in our industry is the new language in the proposed policy may provide an opportunity for producers to utilize more home-grown labor and force us to stop relying on imported labor resources to do the job.  While in theory this argument sounds wonderful, however in reality it might be another story.

To see the reality check of hiring local labor over imported labor one needs to look no farther than an article from October of 2011 appearing in The New York Times.  The article entitled, “Hiring Locally for Farm Work Is No Cure-All” outlines the hardships farmers from Olathe, Colorado faced when they tried to hire local labor for farm work a few years back.  This was when unemployment was at a high in recent years, so one can only imagine the results in today’s new and improved economy.

How can we help?

1. Go to the American Sheep Industry’s Issues and Programs Legislative Action Center page.
2. Read through the information provided to familiarize yourself with the issue.
3. Click on the “View Posted Comments” link to get some inspiration and see others who have taken the time to give input.
4. Click on the “Submit Comments Online” button to provide your input.

This issue is a bit like dealing with a wormy, runny sheep.  We all have choices, we can deworm the sheep and cure the runs or we can wait until things heat up and deal with the fly strike.  We are certainly capable of dealing with either one, the big questions are how much time do you want to invest and how much money do you want to lose!

If you have taken the time to read this post through and I have piqued your interest, then take the time to jot down a few comments.  Ultimately, we can either choose to be part of the solution or part of the problem.  Which choice are you going to make?

“Life is about choices.  Some we regret, some we are proud of.  Some will haunt us forever.”

Graham Brown