Public Comments

TFBF supports passage of the 2026 farm bill
The Farm, Food, and National Security Act of 2026 (also known as the 2026 farm bill) was introduced by House Agriculture Committee Glenn “GT” Thompson in February 2026. Prior to its debate in the House Agriculture Committee, TFBF sent a letter to Tennessee Representatives Scott DesJarlais (TN-04) and John Rose (TN-06), both House Ag Committee members, supporting the passage of the 2026 farm bill out of the House Agriculture Committee. The bill was passed out of committee with a bipartisan vote of 34-17 on March 5, 2026. (February 20, 2026)

TFBF asks state to repair road critical to row crop commerce in Dyer County
Bunge Road in Dyer County is an important road for successfully transporting row crop commodities to market on the Mississippi River. However, a significant portion of the road is in major disrepair, making movement of these commodities to market increasingly difficult. TFBF sent a letter to Tennessee Department of Agriculture Commissioner Andy Holt asking for Bunge Road to be designated as a state road and for the state to repair and maintain the road in the future to ensure successful movement of commodities to market. (February 17, 2026)

TFBF raises concerns on elimination of prevented plant buy-up coverage
The U.S. Federal Crop Insurance Corporation (FCIC) made changes to reflect updates to crop insurance made in the One Big Beautiful Bill Act of 2025. However, these also included a provision to eliminate the option to purchase additional prevented planting buy-up coverage, which was not part of OBBBA provisions. TFBF opposed this elimination due to increased adverse weather conditions affecting planting dates and the need for the strongest safety net possible for farmers to address this risk. (January 27, 2026)

TFBF provides feedback on creation of the Tennessee Farmland Preservation Program
After passage of the Tennessee Farmland Preservation Program and Fund in 2025, a TFBF priority issue, the Tennessee Department of Agriculture (TDA) requested input from the public and from stakeholders as they developed rules to establish the conservation easement program. TFBF provided feedback on the importance of not limiting farmers in their agricultural pursuits, how funding allocation should unfold, and asked TDA to continue stakeholder engagement following the creation of the program. (February 13, 2026)

TFBF applauds EPA for updating definition of “waters of the United States”
In May of 2023, the Supreme Court of the United States (SCOTUS) overturned the Environmental Protection Agency’s (EPA) rulemaking on the definition of “waters of the United States” (WOTUS) which is used to determine what bodies of water are under the jurisdiction of the federal government, saying EPA overstepped the authority they are given under the Clean Water Act in regulating federal waters. In response, EPA updated their definition of WOTUS to reflect this SCOTUS decision. TFBF provided comments in support of updating the definition and providing landowners with a long-lasting, court-approved definition of WOTUS. (January 5, 2026)

TFBF responds to proposed changes to the Endangered Species Act
The U.S. Fish and Wildlife Service (FWS) proposed changes to 4 different sections of the Endangered Species Act (sections 4, 4(b)(2), 4(d), and 7) related to critical habitat designations, listing requirements for species, protections for listed species, and cooperation between relevant agencies of jurisdiction. TFBF emphasized the balance between the reasonable protection of listed species and the importance of continued efficient production of food, fiber, and fuel and supported changes to streamline regulations related to listed species. (December 19, 2025)

Read ESA Section 4 comments here.

Read ESA Section 4(b)(2) comments here.

Read ESA Section 4(d) comments here.

Read ESA Section 7 comments here.

TFBF provides feedback on biological opinion for atrazine
As part of the registration process, the Environmental Protection Agency (EPA) and Fish and Wildlife Service (FWS) conducted a biological opinion about the impacts of atrazine on listed species. As a result, EPA has proposed a 15-foot spray drift ground buffer, a 170-foot aerial buffer, and three runoff mitigation points for most species. Of the 530 species evaluated, 28 were found to need an additional 3 runoff mitigation points for proper protection. By implementing these practices, EPA cites a reduction in atrazine exposure to listed species by 90-95%. TFBF encouraged EPA and FWS to make spray drift and runoff mitigation measures workable for farmers. (December 2, 2025)

TFBF supports registration of herbicide epyrifenacil
The Environmental Protection Agency (EPA) sought comments on the new registration of epyrifenacil, a pre-plant burndown herbicide used in canola, field corn, soybeans, wheat, and fallow land as well as non-agricultural uses. During their regular risk assessment process, EPA identified 9 listed species as having a potential likelihood for future jeopardy to epyrifenacil and designated critical habitat for these species. Two are found in Tennessee (Spring Creek Bladderpod and Whorled Sunflower), and EPA proposed increased requirements in these areas prior to application. TFBF supported the registration and encouraged EPA to make any mitigation measures workable for farmers. (December 1, 2025)

TFBF applauds Labor Department on updated H-2a wage rate methodology
The Department of Labor (DOL) proposed positive changes to how they calculate the Adverse Effect Wage Rate (AEWR) for H-2A workers. Key changes include state-by-state wage rates rather than regional rates, immediate reductions in pay rates, adverse compensation adjustment for non-wage costs associated with H-2A labor such as housing and transportation, and reducing the AEWR to only two skill levels. TFBF showed support for the changes while also seeking clarity on some of the details of the proposal for ease of understanding for farm employers. (December 1, 2025)

TFBF asks Governor Lee to support increased funding for the TN Short Line Railroad Program
The Tennessee Short Line Railroad Program has received one-time funding in recent years to improve infrastructure of short line railroads across the state. TFBF encouraged Governor Lee to consider additional, more stable funding for short line rail improvements in his 2026 budget. (November 3, 2025)

TFBF urges importance of agricultural trade in USMCA Review Process
During its regular review process, the Office of the U.S. Trade Representative requested public input regarding the United States-Mexico-Canada Agreement (USMCA). TFBF highlighted the importance of trade deals for agricultural products, asked that any trade deals support approved biotechnologies, and encouraged increased measures to prevent dumping of seasonal fruits and vegetables. (October 30, 2025)

TFBF tells EPA to support increased domestic utilization of renewable energy in 2026-2027 Renewable Fuel Standard Program
EPA proposed revisions to the “Set 2” renewable volume obligations (RVOs), including additional volumes accounting for 100% of the 2023-2025 exempted RVOs. TFBF urged EPA to adopt a full 100% reallocation approach for all exempted gallons for 2023 and thereafter to support increased domestic utilization of renewable energy. (October 29, 2025)

TFBF urges caution on broad definition of “ultra-processed foods”
FDA sought information from the public about how to define the term “ultra-processed foods,” which is referenced many times within the Make America Healthy Again (MAHA) movement and corresponding reports. TFBF urged FDA not to consider processes which aid in the growing, harvesting, storage, flavoring, shipping and preservation stages of food products as ultra-processed.
(October 6, 2025)
TFBF highlights importance of drone use on farms
The Federal Aviation Administration (FAA) proposed new regulations regarding Unmanned Aircraft Systems (UAS), aka drones, used at low altitudes beyond a visual line of sight. TFBF urged FAA to carefully consider imposing additional regulations on farms and cautioned FAA against regulating practices outside of their scope (i.e. pesticide use). 
(October 2, 2025)
TFBF provides feedback on Brazil trade policies
The office of the United States Trade Representative (USTR) conducted a hearing on the initiation of a Section 301 Investigation into Brazil’s acts, policies and practices and requested feedback from the public on the impacts of these trade decisions. TFBF expressed concerns including decreased ethanol exports, increased beef imports and increased investment in Brazilian infrastructure by China.
(September 10, 2025)
TFBF Urges Need for a Flexible Label for Over-The-Top Dicamba
TFBF emphasized the need for a flexible, easy-to-understand label for dicamba while also highlighting concerns with the practicality of some of the proposed mitigation requirements. (September 5, 2025)
TFBF provides agricultural perspective on Barrens darter proposed listing
FWS received feedback on the proposed Endangered Species listing of the Barrens darter, a small fish species endemic to the Collins River watershed in Cannon, Coffee, Grundy, and Warren counties. (September 2, 2025)
TFBF supports DOL decision to rescind overburdensome Worker Protection Rule
In 2023, DOL proposed increased requirements for temporary agricultural workers within the H-2A program. DOL has recently proposed rescinding this rule, and TFBF shared support for its revocation. (August 28, 2025)
TFBF provides feedback on USDA reorganization proposal
On July 24, 2025, USDA released a Secretary Memorandum announcing plans to relocate a large portion of its employees out of the National Capital Region and across 4 regional “hubs” around the country. (August 26, 2025)
TFBF supports changes to the Renewable Fuel Standards for 2026 and 2027
EPA proposed updates to the renewable fuel standard program for 2026 and 2027. TFBF supported these changes and their priority on American-grown feedstocks. (Aug. 7, 2025) 
TFBF supports TDEC Animal Feeding Operations General State Operating Permits
TFBF joined other statewide protein commodity organizations in asking the Tennessee Department of Environment and Conservation for minimal changes to the current State Operating Permit process for Animal Feeding Operations (CAFOs). (July 17, 2025) 
TFBF asks for consistency in TDEC Triennial Review of Water Quality Standards

Every three years, the Tennessee Department of Environment and Conservation updates their Water Quality Standards. This year, TFBF offered support and the regulations which are already in place and proven. Emphasizing Tennessee farmers have a long-standing and deepened interest in protecting the environment, TFBF asked any changes to Water Quality Standards be minimal and low impact to the farm and business community. (June 17, 2025) 

TFBF asks Trump Administration to prioritize American-grown tomatoes

The U.S.-Mexico Tomato Suspension Agreement has unsuccessfully attempted to curtail the dumping of imported Mexican tomatoes, flooding the domestic market and putting U.S. tomato producers at a disadvantage. Earlier in 2025, the Trump Administration terminated the agreement, imposing duties on imported tomatoes and providing a better market for domestic tomatoes. in response, the Mexican government has requested renegotiation of the agreement, and TFBF wrote in opposition in order to maintain duties on imported tomatoes and improve the market for U.S.-grown tomatoes. (June 6, 2025) 

TFBF supports registration of broad leaf herbicide diflufenican

As part of its pesticide product registration process, the Environmental Protection Agency (EPA) sought comments regarding the registration of diflufenican, a preplant and pre-emergence herbicide used to combat broad leaf weeds such as waterhemp, Palmer amaranth, and other pigweed species impacting corn and soybeans. EPA proposed mitigation measures to protect endangered and threatened species in correspondence with the Endangered Species Act work plan, and TFBF asked EPA to ensure those measures are workable and cost-effective for farmers. (June 6, 2025) 

TFBF Supports New Pest Control Option for Honeybees

EPA is proposing the registration of Vadescana, an insecticide active ingredient seeking to help beekeepers protect their honeybee colonies from Varroa mites (Varroa destructor). TFBF submitted comments to EPA supporting the registration of Vadescana dsRNA to better protect honeybees from Varroa mites. (May 30, 2025) 

TFBF tells APHIS to rescind 2024 Horse Protection Act rulemaking 

In response to recent court decisions finding 2024 Horse Protection Act (HPA) rulemaking exceeded its authority, the USDA Animal and Plant Health Inspection Service delayed the effective date of the rule and reopened a comment period seeking feedback on the rule. TFBF urged APHIS to rescind the 2024 HPA Rule and work with stakeholders to achieve science-based oversight of soring in horses. (May 20, 2025)

TFBF encourages voluntary, incentive-based protection of Monarch Butterflies 

U.S. Fish and Wildlife Service (FWS) sought feedback on the proposed listing of the Monarch Butterfly. TFBF highlighted statewide voluntary and incentive-based programs to protect the monarch, its habitat and other pollinators and concern with the continuation of these programs in the event of a proposed listing. (May 19, 2025)

TFBF tells EPA to adhere to SCOTUS decision on WOTUS rulemaking 

Following the Supreme Court decision in Sackett v. EPA, EPA is proposing new rulemaking surrounding waters of the United States (WOTUS). TFBF encouraged EPA to consider multiple suggestions. (April 23, 2025)

TFBF provides feedback on 45z Clean Fuel Production tax credit

The IRS requested feedback on the 45z Clean Fuel Production tax credit, which provides tax credits to companies utilizing feedstocks to produce biofuels. TFBF urged IRS to prioritize domestic feedstocks for participation in this tax credit and to make it workable for American farmers to participate in. (April 10, 2025)

TFBF urges Trump Administration to prioritize domestic tobacco production 

TFBF joined other state Farm Bureaus, state departments of agriculture, and tobacco grower groups to USDA Secretary Brooke Rollins, EPA Administrator Lee Zeldin, and White House leadership encouraging support of domestic production of tobacco by requesting reallocation of the tobacco tariff rate quota. (March 25, 2025)

TFBF opposes EPA proposal to revoke most crop uses of chlorpyrifos 

During the risk assessment of chlorpyrifos, EPA outlined risks to humans from exposure to residues in drinking water. EPA is now proposing removing almost all tolerances of chlorpyrifos, meaning the approved uses of chlorpyrifos on most crops would be revoked. TFBF highlighted the conservation practices farmers utilize to reduce runoff and emphasized the numerous benefits chlorpyrifos provides. (March 24, 2025) 

TFBF provides feedback on biofuel production  

USDA requested feedback on guidelines for quantification, reporting, and verification of GHG emissions associated with feedstocks used for biofuels. TFBF highlighted issues with the 45z tax credit, encouraged consideration of winter oilseeds, and highlighted data privacy concerns with this type of reporting. (March 17, 2025)

TFBF encourages cooperative approach to PFOS/PFOA

EPA assessed risk of exposure to Perfluorooctane Sulfonic Acid (PFOS) and Perfluorooctanoic Acid (PFOA) in sewage sludge to humans, animals, and the environment. TFBF highlighted the importance of the use of biosolids for fertilizer and asked EPA to require testing at wastewater treatment plans before giving biosolids to farmers. (March 14, 2025)

TFBF encourages Duck River Agency to include agriculture in water use strategies

The Duck River Agency (DRA) sought feedback from water use stakeholders along the Duck River as they prepare their Water Use Efficiency Program. TFBF urged DRA to consider agricultural needs of water and to include farmers when discussing plans to address water use in the Duck River. (February 28, 2025)

TFBF responds to registration review of atrazine 

During the process of re-evaluating the registration of atrazine, EPA has proposed implementing mitigation strategies based on their Endangered Species Act Workplan, including requiring applicators to acquire up to 6 mitigation points to combat runoff. TFBF raised concerns with increased restrictions on farms relying on atrazine and its role in maintaining the food supply. (February 12, 2025)

TFBF asks FWS to work cooperatively with agriculture when considering listed species and their habitats
The U.S. Fish and Wildlife Service (FWS) has released two proposals related to endangered species and their critical habitat. One is related to the Eastern hellbender and the other is related to 4 listed freshwater mussel species. (Feb. 10, 2025)
TFBF Highlights Complications with OSHA’s Proposed Heat Illness Standards

The Occupational Safety and Health Administration (OSHA) is proposing updates to its heat injury and illness prevention standards for outdoor work settings. Specifically, the proposal establishes a heat trigger of 90-degrees Fahrenheit, requiring employers to provide mandatory breaks. TFBF shared concerns with disrupting workflows and productivity during peak planting and harvest seasons and asked OSHA not to create a one-size-fits-all standard given farmers’ reliance on weather conditions. (January 14, 2025) 

TFBF highlights importance of science-based labeling of meat and poultry

USDA Food Safety and Inspection Service (FSIS) published an update to its guidance on documentation needed to support voluntary labeling of animal-raising or environment-related claims on meat and poultry products. TFBF highlighted the importance of consumer-friendly and science-based labeling of agricultural products providing consumers with useful information concerning the ingredients and nutritional value of the product, while also emphasizing that labels should not be required to contain information on production practices not affecting nutrition or safety of the product. (November 12, 2024) 

TFBF opposes EPA’s proposed restrictions on agricultural insecticides

As part of their Endangered Species Act (ESA) Workplan, EPA has proposed stricter restrictions on future registrations of pesticides in order to remain compliant with ESA obligations. This insecticide-specific strategy establishes a runoff/erosion mitigation point system and spray drift buffer distances farmers must follow before applying insecticides. TFBF voiced strong opposition to the proposal, citing its complicated, overburdensome, and unworkable nature. (September 23, 2024) 

TFBF supports continuation of TDEC Biosolids General Permit

TDEC’s Biosolids General Permit is up to be reissued, and TFBF voiced support of its reissuance. The Biosolids General Permit allows for land application of biosolids, which serve as a viable alternative to traditional fertilizer for farmers. TFBF encouraged TDEC to consult with the University of Tennessee Institute of Agriculture regarding agronomic application of biosolids. TFBF also addressed the presence of perchlorate and per- and polyfluoroalkyl substances (PFAS), encouraging TDEC to consider EPA guidance for dealing with PFAS and require wastewater management facilities to test for PFAS before giving farmers access to biosolids. (September 20, 2024) 

TFBF feedback on proposed changes to the Federal Milk Marketing Order System

Following a series of public forums and hearings, USDA-AMS has proposed changes to the dairy Federal Milk Marketing Order system, which sets prices for different classes of dairy products. Since the 2018 farm bill, the formula for determining Class 1 milk, or fluid milk, has been the average of Class 3 (cheese) and Class 4 (butter and powdered milk products) plus 74 cents. This formula has caused dairy farmers to lose significant amounts of money. Dairy farmers across the country recommended reverting back to the “higher of” Class 3 and Class 4 prices, and USDA has answered that request. TFBF supports this change, but provided some concerns, including establishing updates to make allowances for processors and others. (September 13, 2024) 

TFBF suggests USDA competition rules be species-specific

USDA proposed revisions to address unfair practices and harm to competition in the beef, pork and poultry sectors. Although some changes are favorable for poultry growers, others would increase the risk of consolidation in the beef and pork sectors. Because of this, TFBF asked USDA to create species-specific rules in order to address unfair practices and harm to competition directly impacting the differences in the beef, pork and poultry sectors. (September 10, 2024)

TFBF Comments on Designation of Critical Habitat for Barrens Topminnow
USFWS is proposing to designate 1.5 acres of spring pool and 11.4 miles of spring run in Cannon, Coffee, Dekalb, Franklin, Grundy and Warren counties. TFBF highlighted the importance of establishing specific areas rather than entire county or multi-county areas for critical habitat in order to allow for production agriculture. FWS also asked what areas should be considered for exclusion from critical habitat designation, and TFBF asked them to consider agriculture and cultivated land as exclusions. (September 3, 2024) 

Tennessee Farm Bureau supports improvements to poultry grower pay systems
The United States Department of Agriculture (USDA) proposed changes to poultry pay systems, requiring live poultry dealers (or integrators) to establish minimum base pay requirements in production contracts and provide poultry growers with disclosures requesting any desired capital improvement projects. TFBF generally supported this proposal while also providing additional considerations for USDA. (August 5, 2024) 

TFBF supports registration of three vacated dicamba products for use in 2025 crop year
Since a federal court vacated the label for three dicamba products earlier this year, each of the manufacturing companies – Bayer CropScience, BASF, and Syngenta – have submitted registration requests for Xtendimax®, Engenia®, and Tavium® to be available for use in 2025. TFBF submitted comments supporting the re-registration of each of these products and highlighted their importance for cotton and soybean producers. (Summer 2024)

TFBF urges USDA to prioritize U.S. commodities for domestic biofuel production 
The United States Department of Agriculture (USDA) published a Request for Information (RFI) from industry on use of domestic agricultural commodities for use as feedstocks for biofuel production. TFBF stressed the importance of prioritizing American farmers and their products for biofuel tax credits, highlighted data privacy when working with farmers, and emphasized the need to recognize the vast diversity of agricultural practices across the country and discouraged a one-size-fits-all approach. (July 25, 2024)

TFBF tells EPA not to vacate use of acephate 
In a Proposed Interim Decision (PID), the Environmental Protection Agency (EPA) proposed vacating almost all approved uses of acephate, an insecticide used on soybeans, cotton, tobacco, specialty crops, nursery crops, sod, and turf. The PID proposes to vacate all approved uses of acephate except for use in tree injections, based on results of human health and drinking water risk assessments. TFBF urged EPA to reconsider this PID and highlighted the importance of acephate for farmers in Tennessee. (July 11, 2024)

TFBF supports registration of Glufosinate-P 
Glufosinate-P is an isomer of the currently registered herbicide glufosinate and kills plants by inhibiting photosynthesis. It offers flexible application timing, allowing for post-emergence weed control for over-the-top use of glufosinate-tolerant crops and early season use in non-tolerant canola, cotton, corn and soybeans. Due to identified ecological risks, EPA proposed mitigations to reduce off-target exposure. TFBF supported the registration of glufosinate-P and encouraged EPA to ensure mitigations are workable for farmers. (June 7, 2024)

TFBF voices concerns about proposed coyote night hunting season 
TFBF raised concerns regarding a proposal by the Tennessee Fish and Wildlife Commission (TFWC) to create a night hunting season for coyotes, citing safety concerns of people and livestock on working farms and challenges of properly enforcing trespassing. (April 15, 2024)

TFBF provides input on proposed effluent limitations guidelines for meat and poultry processing 
The Environmental Protection Agency (EPA) announced proposed revisions to its effluent limitations guidelines for meat and poultry processing facilities, including establishing more stringent limitations for nitrogen and phosphorus, adding E. coli bacteria limitations for direct dischargers, and extending coverage to include indirect dischargers. TFBF highlighted multiple issues with the proposed revisions. (March 22, 2024)

TFBF tells EPA to make OTT dicamba products available for the 2024 crop year 
In February 2024, an Arizona Federal court ruled to vacate the label for three over-the-top dicamba products. Given this was long after farmers had already made their input decisions for the 2024 crop year, TFBF joined ag organizations asking EPA to grant an Existing Stocks Order throughout the 2024 crop season. In response, EPA granted the order just one week after the federal court issued its decision. (February 8, 2024)

TFBF supports continuation of treated article exemption under FIFRA 
The Environmental Protection Agency (EPA) sought information about the use of the treated seed exemption and the impact of potentially registering pesticide-treated seed. Currently, pesticide-treated seed is exempt from Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) regulations under the treated article exemption, and TFBF submitted comments supporting its continuation. (February 8, 2024)

TFBF joins ag groups raising concerns on SEC’s Natural Asset Company proposal  
The Securities and Exchange Commission sought public comment on whether it should approve a proposal by the New York Stock Exchange to adopt a new listing standard for Natural Asset Companies to be listed on the exchange. TFBF posed multiple questions and asked for points of clarity, and, after receiving lots of negative feedback, the SEC and NYSE rescinded this proposal. (January 16, 2024)