Public Comment on H-2A Sheepherder Regulations

When I get political on this blog, I promise that it’s on topic and about sheep and wool. Promise!

The public comment period on proposed amendments to H-2A sheepherder regulations has been extended to June 1, 2015. In short, nearly 1/3 of the U.S. sheep production is herded by H-2A workers. The proposed changes to the H-2A program threaten the existence of hundreds of sheep operations and the survival of many, already tenuous lamb and wool businesses (some of whom are my customers).

Here is my complete comment, should you wish to use any of it to craft your own to similar effect. Please consider submitting your own public comment (click the Comment Now button at upper right). Here is additional background on the issue.

I am a certified sheep shearer and Level I wool classer. Though I am not a wool producer myself, wool producers are my customers. I am a U.S. born and raised American citizen and currently reside in California.

Speaking as a shearer myself, I know firsthand that there is a dire shortage of shearers and shepherds both in the U.S. and the world. I am a small flock shearer and I am overwhelmed with job requests I cannot fulfill, from word of mouth referrals alone. I do not advertise. Shearing is critical to keeping sheep healthy and grazing (as Savory has shown us) benefits the land and provides fire mitigation in the drought stricken West. But grazing, rangeland sheep require shepherds. Wool producers struggle enough to find good help as it is, and do not need any additional challenges in that regard.

The American sheep and wool industry (what little remains of it after the elimination of the Wool Incentive Program in 1992) is already under great strain. Items in the proposed Trans Pacific Partnership trade agreement may add more nails to the coffin of the sheep and wool industry, if a yarn forward rule is not adopted and the Berry Amendment no longer honored. Now, there are the proposed amendments to H-2A Sheepherder regulations as well, another possible nail.

I ask the Department of Labor to withdraw the wage proposal and reply with a common sense approach. Tripling the wages as proposed will force my customers out of business (and thus, by extension, cut down on my business and that of other shearers, wool classers and ranch hands). Wool producers pay more than fair wages already, because shearers and shepherds are in short supply and demand is high. It’s a competitive market already, I promise you.

Special procedures have proven critical to the successful H-2A sheepherder program and need to be retained, specifically the special procedures in place since the 1980s.

The changes to the definition of open range are almost more worrisome. I don’t understand where the Department of Labor got the idea that livestock grazing only takes place away from fences. Have they been out to see any sheep grazing operations in the American West recently? This is unrealistic, magical thinking that is not practical for grazing. Even when grazing on large allotments of land, herders rely on fences (some of them moveable) to keep the livestock in a manageable area. Heck, I rely on certain kinds of fences to assist me in catching and herding sheep before shearing them. Somehow, my use of fencing negates the fact that I’m on an open range? Sure looks like open range to me when I’m standing out there all alone with some sheep. I fail to understand how the presence of a fence somehow nullifies the definition of rangeland.

As a resident of severely drought stricken California, I am also troubled that the proposed amendments could make fire prevention and mitigation MORE difficult at a time when fire risk is so high. Many sheep ranchers in the West graze their sheep on crop residue and close to suburban and urban interfaces (i.e. explicitly as part of forage reduction for fire prevention). This *requires* the livestock to be watched and under the care of an H-2A sheepherder employee. So, in a time when we are threatened with terrible fires exacerbated by drought, we’d also become more threatened by forage building up due to a lack of H-2A shepherds. Why on earth would we do such a thing?

I ask the Department of Labor to consider the wider reaching effects of their proposals given the reality of the American West today, which includes a serious shortage of shearers and shepherds (of any and all kinds), an already struggling sheep and wool industry, and heightened fire risk due to drought.

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