Before the United States Department of Agriculture, Agricultural Marketing Service 

Milk in the Appalachian, Southeast, and Florida Marketing Areas 

7 CFR Parts 1005, 1006, and 1007 

Docket No. 23-J-0019 

AMS-DA-23-0003 

Office of the Hearing Clerk 

United States Department of Agriculture 

1400 Independence Ave. SW 

STOP 9203, Room 1031, South Building 

Washington, DC 20250-9203 

Brief for Prairie Farms Dairy 

Prairie Farms Dairy, Inc., 3744 Staunton Rd, Edwardsville, IL, 62025 is a qualified Capper-Volstead 

cooperative. Prairie Farms member producer milk is pooled on both Federal Order 5 and Federal Order 

7. The producers are located both inside the Marketing Area of the two Orders and in areas outside the

Marketing Area of the two Orders. Those producers deliver milk to many of the Federal Order 5 and

Federal Order 7 pool distributing plants owned and operated by Prairie Farms. These plants are:

• Hiland Dairy-Order 7- Springfield, MO; Little Rock, Fayetteville, and Fort Smith, Arkansas,

Memphis,TN. Prairie Farms owns 80% of the Hiland plants. Prairie Farms joint-venture partner (a

cooperative that owns the remaining 20%) supplies most of the milk to these plants. Prairie

Farms supplies a small amount to Memphis

• ESJD Hammond, LA-Order 7- Prairie Farms supplies a majority of the milk through independent

non-member(s) marketed by Prairie Farms

• ESJD Kosciusko, MS-Order 7-Prairie Farms supplies a significant portion of milk to this plant, but

the majority is supplied by other cooperatives

• Prairie Farms, Somerset, KY-Order 5-Prairie Farms supplies the majority of the milk

• Prairie Farms, Holland, IN-Order 5-Prairie Farms supplies the majority of the milk

Southeastern United States Milk Deficit 

There has been a milk deficit, especially in the fall, in the Southeastern United States for many years. 

The fall deficit has received much attention over the last quarter century. As that deficit increased, 

efforts were made to find a method to share the supplemental milk transportation costs among the pool 

participants. This led to the transportation credit hearing in 1996. 

Along with a growing deficit in the fall and winter, there also has been a persistent growing deficit 

developing in the spring and early summer. The need for supplemental milk in the southeastern states 

now exists every month of the year. 

Per capita milk production is a method of easily determining the milk supply/ population relationship 

and provided an easy way of comparing milk production changes and population changes overtime. Per 

REC'D - USDA/OALJ/HCO

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capita milk production in the eleven southeastern states in 1997 was approximately 206.2 pounds, 

Exhibit 85. According to the USDA Economic Research Service, national fluid milk consumption was 201 

pounds per capita. Therefore, the annual milk production and annual fluid milk consumption was 

relatively balanced for 1997, provided there is no consideration given to the seasonal nature of southern 

milk production. This relative balance of milk production and fluid demand leaves no excess milk to 

produce non-fluid milk products such as sour cream, cottage cheese, ice cream, etc. throughout the 

year. 

Twenty-four years later in 2021, the per capita milk production had dropped to 98.2 pounds, a 52.4% 

decline, Exhibit 86. According to ERS, national fluid milk consumption had fallen to 134 pounds per 

capita, a 33% decline. The shortfall in per capita milk production when compared with the smaller 

change in fluid milk consumption shows why an ever-increasing volume of milk from outside the 

southeastern states is imported into the area. 

Exhibit 8, page 9 shows the 2019 to 2021 daily average in-area producer milk by month for Order 5 

with a comparison of the daily average distributing plant demand. The producer milk originating in the 

Order 5 Marketing Area in May is, on average, approximately 3.3 million pounds per day short of 

meeting the distributing plant requirements. The shortfall grows in September to 4.9 million pounds per 

day, a 48% increase in the deficit volume. 

While it is difficult to determine the exact distributing plant demand from the graph found in the 

exhibit, the demand appears to be about 12 million pounds. Using the 12 million pound demand as the 

denominator and the 3.3 mill ion pound May shortfall as numerator, the shortfall calculates to be 27.5% 

of the distributing plant demand. In September with the shortfall growing to 4.9 million pounds per day 

and the distributing plant demand approximating 12 million pounds per day, the shortfall is 40.8% of 

total demand. 

There is a comparison of in-area milk production and distributing plant demand for Order 7, similar 

to the comparison for Order 5 in Exhibit 8, page 11. In Order 7, the shortage is 3.8 million pounds per 

day in April. The deficit grows to 6.5 million pounds per day in September, a 71% increase in the deficit 

volume. 

The total distributing plant demand volume illustrated in the Order 7 graph appears to be about 12 

million pounds per day in both April and September. The 3.8 million pounds per day April shortfall is 

31.7% of the distributing plant demand and the 6.5 million pound per day shortfall in September 

calculates to be 54% of distributing plant demand. 

The huge volume of milk required in all months of the year to offset the southeastern states 

production shortfa II demands that the out-of-area milk supplied to the in-area distributing plants~ 

accomplished in the most efficient manner at the lowest possible cost. Unlimited subsidization of inarea milk movements does not contribute to a low-cost solution. 

Location of Producers and Pool Distributing Plants 

The location of pool distributing plants in the southeast has changed over the years as plants have 

consolidated, closed, or changed. The remaining pool distributing plants are often the ones closer to the 

population centers (consumers) than the plants that closed. Unfortunately the remaining distributing 

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plants are also often more distant from the traditional milk supply areas. The Federal Orders do not 

dictate where distributing plants are located. 

During the Hearing, there was testimony from dairy farmers who were first generation dairy farmers 

and also from dairy farmers who represented multiple generation operations. Dairy farms are often 

located dose to the family roots of the owners. This is especially true of farms that pass from generation 

to generation. The location of the markets, in the southeastern states these are primarily pool 

distributing plants, does not drive the current location of these farms. Producers decide to continue to 

produce milk in a certain area or move to a new area for many reasons. Along with tradition and history, 

there are often other reasons that influence dairy farm location. 

Mr. Sumner testified that he started dairying in 1981 at Franklin, TN. He was shipping to Kroger. Then 

he relocated to Paris, TN in 2001. In his current location, his cost for purchased corn, "a big expense in 

our business", is considerably less expensive than in East Tennessee. The area he chose to dairy in gave 

him a lower production cost. He may also have a marketing advantage, "I could get credits to go to East 

Tennessee and compete with that milk over there with their higher costs and I got low cost, it just 

wouldn't be fair." His milk has been going to a ptant that is not a pool distributing plant. 

Producers can choose to move to an area that is closer to the market with reduced hauling costs. 

They can choose to move to an area with lower production costs, as Mr. Sumner did. They can choose to 

move to an area that provides lower production costs and is closer to markets. Predominantly though 

producers will stay where they are and pay the higher hauling costs, either directly or through subsidies 

paid to the hauler by the cooperative or handler. The Federal Orders do not dictate where dairy farms 

are located. 

Producers in the southeastern United States do not have a large choice of plants for the delivery of 

their milk. Most of the plants in the region are pool distributing plants. Since producers generally must 

deliver to a pool distributing plant to have a market, it is also reasonable to assume the producer must 

pay a majority of the cost to get the milk to that market. 

The milk supply dilemma in the Southeast is not just one of a supply and demand imbalance, but 

also one of traditional milk supply locations becoming more distant from the demand locations. The 

Federal Order system should not provide mileage-based compensation to the in-area producer for the 

transportation required to deliver milk to the pool distributing plant demand locations. Nevertheless, it 

is appropriate for the Federal Order system to provide a "marketwide service payment", such as an 

assembly performance credit, that is a uniform flat-rate compensation for all milk delivering to 

distributing plants. 

Payments from the TCBF 

Payments from the Transportation Credit Balancing Fund (TCBF) are made on out-of-area milk 

needed by pool distributing plants during the eight lower production/ higher demand months of July 

through February. Milk within the Order 5 and Order 7 Marketing Areas is ineligible forTCBF payments. 

Additionally, milk outside the Order 5 and Order 7 Marketing Areas is ineligible for TCBF payments if 

more than 50% of a producer's milk during the three-month period of March through May was producer 

milk on either Order 5 or Order 7, or if the dairy farmer was a "producer" on either Order 5 or Order 7 

for more than 45 days during the three-month period of March through May. These requirements would 

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not be burdensome if Order 5 and Order 7 did not have such a drastic ongoing year around need for out 

of area milk to supply the distributing plants. 

Exhibit 8, referenced earlier, illustrates a need for 3.3 million pounds per day to supplement the inarea production and meet the Order 5 May pool distributing plant demand. Exhibit 8 also illustrates a 

need for 3.8 million pounds per day to supplement the in-area production and meet the Order 7 April 

pool distributing plant demand. 

Out-of-area milk accounted for over 25% of the milk delivered to Order 5 pool plants in March, April, 

and May 2022. Milk originating in states or portions of states that were immediately adjacent to the 

Marketing Area accounted for 28.8% of the March 2022 total producer milk receipts at pool plants. 

Exhibit 98. This surrounding milk supplied 27 .8% of producer milk receipts at pool plants in April 2022, 

and for May, it was 26.8%. 

Out of area milk accounts for an even larger portion of the Order 7 pool plant volume in March, April, 

and May 2022. Milk originating in states or portions of states that were immediately adjacent to the 

Marketing Area accounted for 42.7% of the March 2022 total producer milk receipts at pool plants. 

Exhibit 100. This surrounding milk supplied 39.6% of producer milk receipts at pool plants in April 2022, 

and for May, it was 37.1%. 

As shown, there is not enough in-area producer milk to supply the March, April, and May needs of 

the pool distributing plants. Much of the supplemental milk comes from areas adjacent to the Marketing 

Area of Order 5 or Order 7. This is logical since that would be a least freight cost solution. Using this 

producer milk with the least-cost freight in the spring could also result in this milk being ineligible for 

transportation credits during the current eight-payment month TCBF payment period. 

Proposal 9 and 10, Order 5 and Order 7 respectively, would eliminate the transportation credit 

ineligibility imposed by §1005.82(c)(2)(i) and §1007.82(c)(2)(i). With these sections removed, the closest 

out-of-area milk could be used to supply Order 5 and 7 pool distributing plant needs in March, April, and 

May, and still allow this nearby out-of-area milk to be used to supply the pool distributing plant needs in 

the fall and winter. If §1005.82(c)(2)(i) and §1007.82(c)(2)(i) are not removed from the Order language, 

handlers will use different producer milk to supply the fall needs. This different producer milk will often 

come from greater distances and have a higher transportation credit cost. Exhibits 94 and 95 show 

possible changes in delivery patterns to allow maximum transportation credits when the closer 

(ineligible) milk is "swapped" with milk that is more distant. While the miles travelled in the examples 

used showed smaller increases, the transportation credit increased significantly. The smallest 

transportation credit increase due to milk swapping and rerouting, Exhibit 24, was $273.73. This is a 94% 

increase from the $290.03 that would exist if §1007.82(c)(2)(i) was eliminated. 

Exhibit 95 shows a transportation credit of $265.20 when milk from Sulphur Springs, Texas is 

delivered to Lafayette, LA. When the milk from Sulphur Springs is "swapped" with milk from Dalhart, 

Texas, due to the restrictions of§ 1007.82(c)(2)(i), the transportation credit for the Dalhart milk 

delivering to Lafayette is $1,207.46. This is a $942.26 increase, a 355 % increase, just because closer milk 

is ineligible for the transportation credit if it delivered in the March, April, and May period. 

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Using the more distant milk to supply pool distributing plants and achieve a transportation credit 

means there will be an increased negative environmental impact since more miles will be travelled and 

more fuel will be used. 

Eliminating §1005.82(c){2)(i) and §1007.82(c)(2)(i) would allow in-area and out-of-area milk to move 

in the most efficient, coordinated manner possible. It would no longer be necessary to swap milk loads 

among delivery locations with the resulting increase in transportation credits. The transportation credit 

calculations would continue the adjustment for shipping zone and receiving zone values. The offset for 

diverted milk would continue in place. 

Assembly Performance Credits 

The proposed assembly performance credit (APC) would help offset the costs involved in getting milk 

from the producer farm to the pool distributing plants. The APC would apply to all producers delivering 

milk to a pool distributing plant. The APC would promote the least-cost transportation solution since it is 

not a mileage -based payment. Without a mileage-based cost reimbursement, the cooperatives and 

pool distributing plants would make every effort to move milk from the dairy farm to the pool 

distributing plant in an efficient manner. There would be no effect on the payment rates if cooperatives 

and other handlers continued to use inefficient routing. 

Using an APC to cover the cost of assembling and moving producer milk to distributing plants is not 

new. Federal Order 30 has had an assembly credit for years. It is not a mileage-based credit. In addition 

to the assembly credit, Order 30 does have a mileage-based transportation credit. It partially 

compensates the movement of milk from pool supply plants to pool distributing plants. The Order 30 

assembly credit was instituted to help attract milk to pool distributing plants from alternative delivery 

locations. 

Since the APC is not mileage based, milk delivering to a pool distributing plant from a close by area 

has a higher portion of the assembly and delivery costs covered than milk delivering from an area 

further away. This is no different than currently exists with the Order 30 assembly credit. Additionally 

since a higher portion of the assembly and delivery cost is covered for the closer milk, it should incent 

milk production in the close by area. 

The proponents of the Distributing Plant Delivery Credit (DPDC) declare that the PDPC is needed 

since the Southeast Marketing Area, Order 7, is a geographically large area. The Upper Midwest 

Marketing Area, Order 30, is also a geographically large area, as shown by the map of Marketing Areas 

on the Order 5/ 7 website. The $.08 per hundredweight assembly credit is sufficient to help attract milk 

away from plants in the Order 30 area that are not pool distributing plants and to pool distributing 

plants. The proposed $.SO APC should be sufficient to do the same in Order 7 and in Order 5. There are 

very few plants in the southeast, other than pool distributing plants, receiving producer milk. 

The APC assessment of $.50 is collected on only the Class I deliveries to pool distributing plants. Since 

the pool distributing plant receipts include Class II, Ill, and IV milk in addition to Class I, the distribution 

on the producer milk will be less than the assessment rate. Exhibit 9, pages 7, 8, and 9 show the 

estimated APC distribution for Orders 5, 6, and 7. Since the Market Administrator used both pool 

distributing plant pounds and pool supply plant pounds when calculating the distribution credit, the 

actual distribution calculation would not include the pool supply plant pounds. Therefore, the 

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distribution would actually be a little higher than shown. The APC distribution varies by Order and by 

month. For Order 5 the low is $.39 and the high is $.45; for Order 6 the low is $.44 and the high is $.46; 

and for Order 7 the low is $.36 and the high is $.43. DCMA Exhibit 44 uses a $3.67 loaded mile base rate 

and a $.209 per loaded mile fuel adjustment, for a total loaded mile rate of $3.879. Using a 50,000 

pound load, this would calculate to $.00758 per hundredweight per loaded mile. Based on the above, 

the APC would provide close-to-total compensation for approximately SO to 60 loaded miles of 

transportation. The producer, cooperative, or other handler will need to pay the rest. Remember, the 

producer generally does not have nearby alternative markets such as cheese plants or butter powder 

plants. Often the pool distributing plants are the only markets. The Federal Order system should not 

provide compensation for the majority of the delivery cost. 

Covington stated in response to questioning, "Yes, you look at individual loads, you don't want to 

lose money on anything" and "But you've got to look at the total picture. We might lose money on 5 

loads of milk or 10 loads of milk, but by losing money on that, we're making money for the dairy farmers 

on that other hundred loads by keep the customers, it's important, you got to look at the big picture." 

Page 432, lines 9-17. While this was not about the APC, it certainly is applicable. The APC does not cover 

the assembly and delivery costs for delivery miles on more distant milk at the same ratio as closer milk. 

The total picture would suggest that the combination of these differences would leave a balanced 

outcome. You have to look at the big picture. 

The APC does not need to consider diversions to other plants. There is no mileage-based payment to 

gain by moving distant milk to pool distributing plants, while moving less distant milk to plants that are 

not pool distributing plants. 

A concern raised at the Hearing was that the combination of the APC on a year-round basis and 

transportation credits during the fall and winter was double dipping. Prairie Farms does not agree with 

this characterization. Transportation credits partially reimburse the costs of transporting more distant 

milk to pool distributing plants during the fall and winter, while adjusting that reimbursement for 

mileage and Federal Order differentials. Assembly performance credits are a year-round partial 

compensation for assembling and moving milk to pool distributing plants without consideration for 

mileage, Federal Order differential differences, and specific producer and plant locations. In our view, 

transportation credits and assembly performance credits are complementary credits that create the 

most efficient movement patterns. 

Changes in the proposed language can be made if USDA decides that Assembly Performance Credits 

and Transportation Credits on the same milk is truly double-dipping, There can be regulations put in 

place that would require that milk could only receive the Transportation Credit or the Assembly 

Performance Credit during the months the Transportation Credit is operational. Another alternative is to 

deduct the APC credit from the Transportation Credit Balancing Fund credit. 

Distributing Plant Delivery Credits 

Proposals 3, 4, and 5 are an admirable effort to partially recover the costs of delivering producer milk 

to pool distributing plants. However, these proposals are deeply flawed. The proponents of the 

Distributing Plant Delivery Credits {DPDC) propose that the DPDC operates in a similar fashion and for 

the same purpose as the Transportation Credit Balancing Fund (TCBF), with the only difference being 

that the DPDC is for in-area milk and the TCBF is for out-of-area milk. Hollon testified "It is time to 

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address this year-round marketwide service with order provisions that compensate deliveries to 

distributing plants in a fashion similar to the system which has compensated handlers for imports of 

supplemental milk.'1 The Southeastern orders have never provided transportation compensation for the 

service of obtaining in-area milk for Class I needs on a year-round basis. Although out-of-area milk is 

needed on a year-round basis by pool distributing plants, the proponents do not offer any method of 

obtaining year-round transportation assistance on this out-of-area-milk. The assistance provided by the 

TCBF is not year-round, and only provides seasonal assistance on the out-of-area milk. 

As proposed, the DPDC will only be available to producer milk originating within the Marketing Area 

ofthe respective Orders and some selected out-of-area counties. This is discriminatory since some outof-area counties supplying producer milk to pool distributing plants can participate in the DPDC, while 

other out-of-area counties that consistently supply milk to pool distributing plants cannot participate in 

the DPDC. 

Hollon stated, "For Order 5, the in-area deliveries account for 54% of needs; for Order 6 in-area 

production meets 82% of needs and for Order 7 in-area production supplies 44% of needs. Obviously, 

the converse percentage of these numbers is drawn from other areas, negotiated for and partially paid 

for with the assistance of the existing transportation credit system." The existing transportation credit 

system only provides seasonal assistance, not the year round assistance envisioned for in-area milk 

through the DPDC. 

Approximately half of the milk utilized at pool distributing plants in Order 5 and 7 originates from 

areas outside the respective Marketing Areas. Except for a few specified counties, the proposed DPDC 

would not be available to any milk from outside the Marketing Area, although this milk provides a 

significant portion of the pool distributing plant needs. Most, if not all, of this out-of-area milk has 

alternative market opportunities within the Federal Orders where the milk originates. The southeast inarea milk, for the most part, does not have alternative markets. The in-area milk generally must deliver 

to pool distributing plants since other markets in the area are limited. 

Milk generally moves from areas of lower Class I differentials to areas of higher Class I differentials. 

However there are times that milk moves "against the grain"'i.e., from areas with higher Class I 

differentials to areas of lower Class I differentials. Milk will, at times, move with no change in Class I 

differential between the producer location and the plant location. The proponents of the DPDC assert 

that compensation is needed for these milk movements. The described milk movements are nothing 

new and have been going on for years, both within the southeast and throughout the Federal Order 

system. There is no reason for the DPDC, as proposed, to provide compensation for these movements. 

Again, options for markets in the southeast, other than pool distributing plants, are limited. 

The last page of Exhibit 82 shows the various types of movements referenced in the above paragraph 

for Georgia milk in 2022. While a number of delivery destinations are shown, testimony from Covington 

and Herting suggest that the lion's share of the Georgia milk was delivered in Georgia, Florida, and South 

Carolina. Tona k testified that in selected periods of 2022 very little of the milk delivering to Hammond, 

LA originated in the Southeast Order, with most of the milk delivering from Texas. Of the Hammond milk 

from the Southeast Order, most came from Georgia with very little from the area around Hammond, 

Louisiana. The Order 7 Market Administrator statistics show that the largest milk producing area in 

Louisiana is adjacent to Hammond--yet the majority of the Order 7 milk delivered to Hammond came 

from Georgia. 

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The DPDC may actually encourage inefficient movements. The opportunity for backhauls exist in the 

southeast. As an example, moving excess cream from distributing plants to other plants can reduce the 

overall transportation cost, especially when milk is moved from the cream delivery area to the 

distributing plant originating the cream, especially if the DPDC is used to offset a portion of the milk 

transportation cost. It will be difficult for the Market Administrator to monitor the backhauls and other 

types of offsetting milk movements. These movements can still take place with the APC, but the credit 

received will not be mileage-based. 

The proponents of the DPDC suggested that locally produced milk should be on a better footing, i.e. 

receive added compensation, due to the DPDC payment than out-of-area milk. This might be 

understandable if out-of-area milk was not required year-round to make up the in-area shortfall. 

The proponents also state that the "locally produced milk will travel fewer miles to milk plants than 

imported milk, and as such, the lower travel miles are more supportive of a healthy environment." This 

of course is true, local in-area milk will travel less miles than out-of-area milk; but it is true with or 

without the DPDC. It is difficult to understand how the proposed DPDC will more efficiently and 

effectively attract milk to distributing plants in the southeast. The DPDC does not encourage producer 

farms to move closer to the distributing plants, since it will, in fact subsidize the movement of milk from 

the existing producer locations. This DPDC subsidy does not encourage added production from dairy 

farmers close to distributing plants. 

The distributing plants in the southeast receive almost all of the milk produced in the southeast 

already. Because of this, the DPDC is not able to encourage more in-area milk to deliver to pool 

distributing plants; the milk is already delivering to the pool distributing plants. Really, the only source of 

additional milk for the southeast comes from outside the Marketing Areas. Moreover, the DPDC is not 

available to most of this out-of-area milk. 

If the Secretary decides to adopt the DPDC proposal for the southeast Marketing Orders, out-of-area 

milk that regularly supplies Order 5, 6, and 7 pool distributing plants should be included. Without an 

expansion of the eligible DPDC area to include the states and portions of states surrounding the 

respective marketing areas, there will not be any additional milk, as suggested by the DPDC proponents, 

to supply the distributing plants. Alternatively, the DPDC could be made available to alt milk that delivers 

to an Order's pool distributing plants. 

SUMMARY 

Proposal 3, 4, and 5, concerning year-round Distributing Plant Delivery Credits for in-area milk delivering 

to pool distributing plants should not be adopted. The Proposals will not result in additional supplies of 

milk to southeast pool distributing plants. The Proposals will not reduce miles travelled or reduce 

delivery costs, but will in effect subsidize current in-area hauling costs, and possibly lead to inefficient 

milk movements. 

Proposals 6 and 7, concerning Transportation Credits for out-of-area milk delivering to pool distributing 

plants should be adopted. The Proposals would allow out-of-area milk that delivered to southeast pool 

distributing plants with a majority of the spring milk to receive transportation credits in the fall. This 

results in the most efficient movements of the out of area milk. 

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Proposals 8, 9, and 10 concerning year-round Assembly Performance Credits for all milk delivering to 

pool distributing plants should be adopted. The Proposals would provide uniform compensation for all 

milk delivering to pool distributing plants. 

The proposal should be adopted on an expedited basis. The current situation in the southeast is 

critical for dairy farmers and the pool distributing plants they supply. 

Prairie Farms expresses our gratitude to the Secretary for allowing us to present our views and 

reviewing this matter on a timely basis. 

Submitted on behalf of Prairie Farms by: 

Dennis Tonak 

Senior Director, Federal Order Markets 

Prairie Farms Dairy, Inc 

3744 Staunton Road 

Edwardsville, IL 62025 

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CERTIFICATE OF SERVICE 

Appalachian and Southeast Federal Milk Marketing Orders Hearing 

Docket No.: 23-J-0019 

Having personal knowledge of the foregoing, I declare under penalty of perjury that the information 

herein is true and correct, and this is to certify that a copy of the POST-HEARING BRIEF FOR 

DAIRY COOPERATIVE MARKETING ASSOCIATION (DCMA), POST-HEARING BRIEF OF 

SELECT MILK PRODUCERS, INC., MILK INNOVATION GROUP'S BRIEF AND PROPOSED 

CONCLUSIONS OF LAW, and BRIEF FOR PRAIRIE FARMS DAIRY has been furnished and 

was served upon the following parties on April 20, 2023 by the following: 

USDA (OGC) – Electronic Mail 

Brian Hill, OGC 

Brian.Hill1@usda.gov 

Michelle McMurtray, OGC 

Michelle.McMurtray@usda.gov 

Donna Erwin, OGC 

Donna.Erwin@usda.gov 

Carla Wagner, OGC 

Carla.Wagner@usda.gov 

USDA (AMS) – Electronic Mail 

Erin Taylor, Director 

Order Formulation and Enforcement Division 

Dairy Programs 

Erin.Taylor@usda.gov 

____________________________________ 

Eliuth Morón, Assistant Hearing Clerk 

USDA/Office of Administrative Law Judges 

Hearing Clerk’s Office, Room 1031-S 

1400 Independence Ave., SW 

Washington, DC 20250-9203 

Phone: 202-720-4443 

Respectfully Submitted, Digitally signed by ELIUTH ELIUTH MORON 

Date: 2023.04.20 MORON 13:51:54 -04'00'