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How 2023 marked a renewed push for public power.

Voters in Maine were confronted with an unusual decision when they went to the polls this November. Question three on the ballot asked Mainers if they wanted to eliminate the two private utilities that delivered electricity to 97% of the state. A new, nonprofit utility called Pine Tree Power would take over the service, and it would be overseen by a publicly-elected board.
Though the proposal may sound radical, it’s not unheard of. Since the dawn of the electric grid, communities have periodically decided to municipalize their utilities. The city of Sacramento, California, took over PG&E’s local electric distribution franchise in 1946. Winter Park, Florida, took over electric service from a company called Progress Energy in 2005. But a takeover at the state level has only been attempted by Nebraska, where the entire state’s electric service went public in the 1940s and has remained that way ever since.
Unlike in Nebraska, the campaign in Maine failed. Seventy percent of voters said “no” to question three. But the ballot measure wasn’t a one-off. This year marked a renewed push for public power that’s growing around the country in light of the challenges of tackling climate change.
Investor-owned utilities have used their vast financial resources and political influence to delay and block the transition off of fossil fuels, in ways large and small, for decades. Activists, tired of trying to work within that system, are turning their attention to what they see as the more systemic root cause — the perverse incentives created by having utilities that need to turn a profit.
Americans often refer to their electricity or gas providers as “public utilities.” But only about 15% of the population is served by a government-owned, customer-owned, or member-owned electric utility. The other 85% are beholden to private companies that were granted monopolies to sell electricity decades ago.
What started as a smattering of independent campaigns to change that ratio started to coalesce into a nationally coordinated movement this year. A few weeks before the vote on the ballot measure, some 70 delegates from about 40 grassroots climate groups from around the country convened for a workshop at the Press Hotel in Portland, Maine. For three days, they exchanged notes and strategies for how to get public power on the agenda in their own cities and states, and reform public utilities in places that already had them. By the end, they had cemented a more energized, organized coalition.
The guiding theory behind the push for public power is that public utilities don’t need to generate returns for shareholders, theoretically enabling them to make investments guided by other priorities, like reducing emissions — and charge customers less in the process.
“We’ve seen time and time again that the market is not going to correct this,” Greg Woodring, a workshop participant from Ann Arbor, Michigan, told me. “Public power gives us the ability to choose where our energy is coming from, the ability to directly make that change without having to ask or plead or beg or incentivize a corporate entity that, at the end of the day, is only making a decision based on what’s going to make the most profit possible.”
But public power is divisive in the larger climate movement. While not necessarily ideologically opposed, critics are concerned about wasting time and money. Private utilities don’t go without a fight, and communities can get bogged down in legal battles for years. The city of Boulder, Colorado, famously tried to wrest control over its electric service from the utility Xcel for a decade, and gave up.
In Maine, the Conservation Law Foundation, a prominent environmental group, warned that the cost of a transition to public power was too uncertain, that it could mire the state in litigation, and that having a publicly-elected board could subject critical energy decisions to “partisan political maneuvering.” Instead, the group made a case for strengthening laws and regulations. However, it also conceded that if the utilities don’t meet metrics of affordability and sustainability they should face stiffer fines, or even lose their ability to operate in the state.
Defenders of investor-owned utilities argue that they have advantages over nonprofits when it comes to building the clean grid of the future. “The investor-owned business model enables companies to raise and deploy massive amounts of capital in an efficient and cost-effective manner, and their purchasing power helps to minimize costs to customers,” said Sarah Durdaller, a spokesperson for the Edison Electric Institute, a trade group for private electric utilities. She told me that the organization’s members’ “commitment to delivering resilient clean energy to our customers has never been stronger, and our focus on affordability has never been more important.”
The Maine campaign was not the first time a shift to publicly-owned utilities has been pitched as a climate strategy. One of the main motivations for Boulder’s effort, which started in 2010, was Xcel’s unwillingness to help the city meet its climate goals. But the increased momentum behind public power in 2023 signaled a new direction for climate activism more broadly, which had seemed to stagnate after the rise and fall of the youth-led Sunrise Movement and the election of Joe Biden.
“This is a site where we can practice democracy,” Isaac Sevier, one of the workshop organizers, told me. “I think that’s something that energizes people, it gives them more hope, it gives them something to be a part of and fight for and struggle for in a time when so many people are turning away.”
The workshop in Maine was convened by a handful of national organizations, including the Climate and Community Project, a progressive think tank, Lead Locally, a group that works to elect progressive candidates, and the Democratic Socialists of America’s Green New Deal Campaign Commission.
The DSA has been a major force behind the recent surge in interest in public power. At the start of this year, it kicked off a new campaign called “Building for Power” focused on trying to strengthen public institutions at the local level. In addition to public power, DSA is advocating for green public housing and transit, and improved public spaces.
“We want to rebuild, and in some cases, build anew, public sector capacity,” Matt Haugen, one of the organizers of the workshop, told me. “Through decades of neoliberalism, the public sector has been hollowed out in the U.S., and we’re seeing in all these areas that it’s clear the private sector just cannot meet these human needs.”
Many of the participants at the workshop were DSA members, but there were also local organizers affiliated with national environmental organizations, like 350 and the Sierra Club, and others from smaller, grassroots groups. There was a freshman in college, a seasoned activist in his 80s, and many ages represented in between. While almost everyone there was from a left-leaning city, they hailed from every corner of the country, including California, Montana, Michigan, Tennessee, Puerto Rico, and Washington, D.C.
Some, like Woodring of Ann Arbor, were from cities that were already in the early stages of considering a public power takeover. His group had convinced the city council to complete a feasibility study on municipalization. Others, like Marta Meengs, from Missoula, Montana, were trying to figure out how to win smaller battles, like the right to have community-owned solar farms. Others wanted to reform existing public power agencies, like Amy Kelly from Tennessee, where the federally-owned Tennessee Valley Authority runs the grid — but is investing heavily in natural gas, and offers few avenues for civic engagement.
One such group had already seen some success. The New York chapter of the DSA passed the Build Public Renewables Act earlier this year after four years of campaigning. The law directs the New York Power Authority, an existing state-owned power provider, to shut down all of its fossil fuel plants by the end of 2031, and expands its mandate to include building renewable energy projects. Most residential customers in New York are actually served by private utilities, but proponents saw the law as a way to get more clean energy built, faster, and with high labor and equity standards.
The Inflation Reduction Act, the climate law signed by President Biden last year, is one reason the tides turned for the New York campaign. It enabled government agencies and nonprofits to take advantage of tax credits for renewable energy projects for the first time, improving the economics of public power.
“It really opens up a huge amount of additional space for public power to be a part of the answer,” Johanna Bozuwa, executive director of the Climate and Community Project, told me.
Though few of the participants had ever met or even heard of each others’ campaigns, the stories that led them to advocate for public power shared a number of common themes: Worsening power outages due to extreme weather. Alarm over the insufficient pace of emission reductions. Outrageously high bills. But perhaps most of all, frustration with constantly coming up against utilities wielding money and influence to fight clean energy.
Woodring, of Ann Arbor, cited a 2022 analysis that found that more than 90% of sitting legislators in Michigan at the time took money from groups and individuals affiliated with DTE, the biggest utility in the state. The company was also tied to more than $200,000 in donations to Governor Gretchen Whitmer, who’s responsible for appointing the state’s utility regulators. As a result, according to the workshop participants from Michigan, the company has been able to restrict the growth of residential solar, which would eat into its profits.
Mikal Goodman, a 23-year-old city councilmember from Pontiac, Michigan, told me his interest in public power stemmed from DTE’s high rates and failure to invest in modernizing its transmission system. Some of its poles and wires dated back to before World War II, he said. Last winter, storms knocked out power to hundreds of thousands of households in southeast Michigan, leaving some families in the dark for over a week. But the day after one especially bad storm in February that left 450,000 people without power, DTE’s CEO Gerardo Norcia bragged to Wall Street analysts about the company’s “strong financial results” due to budget cuts and delayed maintenance.
In Pontiac, Goodman said, outages are life-threatening. He described the city as a donut hole — a poor, majority minority community surrounded by much wealthier, whiter towns. Most Pontiac residents don’t have the resources to run backup generators, replace rotting food, or flee to hotels if they need to, like many of their well-off neighbors, he said.
The idea that energy is a human right, and should not be treated as a commodity, came up repeatedly at the workshop. Many of the participants were drawn to public power by the desire to see an energy transition that benefits everyone, not just those who can afford clean energy.
Sevier, who has done a lot of work related to decarbonizing buildings, was frustrated that other advocates in the field were ignoring the growing energy affordability crisis. One in six households are behind on their utility bills, according to the National Energy Assistance Directors Association, and gas and electric utilities are increasingly disconnecting customers that are in arrears. A January report from Bailout Watch, a nonprofit watchdog of fossil fuel companies, estimated that the 12 utilities that perpetrated the vast majority of shutoffs between 2020 and the fall of 2022 could have forgiven the debt with just 1% of their spending on shareholder dividends.
“If we require that everything in your life become electric, but at the same time, we don’t transform a system that guarantees that everyone actually can have electricity,” Sevier told me, “then I ask, who are we building this ‘electrify everything’ system for?”
Other advocates questioned a system where the public is often forced to pay for a company’s mistakes, but which the public has no say over. Travis Gibrael, an organizer with a group called Reclaim Our Power in northern California, which is working on a public takeover of PG&E, described the hypocrisy of the state’s relationship with the company. Governor Gavin Newsom’s administration helped the company emerge from bankruptcy after it was found responsible for wildfires that destroyed whole towns and killed more than 100 people. Now the company is raising rates by 13% to pay for wildfire prevention measures like burying power lines.
“They burn down the state, they kill a bunch of people. And yet all of those liabilities are just put on us, including the people who lost family members,” Gibrael told me. “It’s like, we’re already paying for the cost of the system and all the crises that are coming from it. So for us to just own it, because we’re already paying for it, makes sense.”
Reclaim Our Power has allies in the city government of San Francisco, which is in the early stages of trying to purchase the local electric grid from PG&E.
In some ways, Maine seemed to be an ideal testing ground for such sweeping reforms. Central Maine Power and Versant, the two private electric companies in Maine that would have been ousted, are consistently rated the worst for customer satisfaction in the Northeast. CMP has faced multiple investigations and fines over its billing system, customer service, and delays connecting new solar projects to the grid. Mainers additionally hate the company due to a controversial power line it is building to deliver hydropower from Canada into the U.S.
Advocates also appealed to nationalist views by highlighting the fact that both companies have “foreign owners,” and that they are funneling ratepayer dollars out of the country rather than back into Maine’s communities. (CMP is owned by Iberdrola, a Spanish company. Versant is owned by Enmax, a Canadian company owned by the city of Calgary.)
Public power advocates attributed their loss largely to the nearly $40 million the incumbent utilities spent fighting the campaign. “They outspent us 37 to one,” Lucy Hochschartner, the deputy campaign manager for Pine Tree Power, told me. “We were persuading people one by one, as they were getting absolutely inundated by messaging on the television, in their mailbox, on the radio, over digital.”
But she also said the campaign was successful in that it got a lot more people talking about the issue — it made national headlines for weeks — which could make it easier for future campaigns.
Reflecting on the loss, John Qua, a campaign manager at Lead Locally, told me it showed that running a ballot initiative is probably one of the most difficult ways to win public power. Another path is to try and win an electoral majority to enact legislation. “While it takes longer, you can cement a stronger, usually progressive majority in support,” he said.
Workshop attendees were clear-eyed about the fact that public ownership would not, in itself, be a silver bullet. They were quick to acknowledge the shortcomings of many existing public institutions, and that a publicly-owned utility will only be as strong as public participation in elections and decision making — a tall order when so few people today even understand the basics about where their energy comes from. Grace Brown, a researcher at the University of Glasgow in Scotland who studies public power movements, said it’s a much harder proposition in the U.S. than in Europe, where people are used to relying on the government for services, and socialism isn’t such a dirty word.
“That’s not just about winning votes, it’s about changing the mindset of this whole country,” she told me. “It’s trying to change these huge ideological ideas of how this country understands what the state should be and what the government should do.”
Public power isn’t the only idea out there for breaking the inertia and corporate capture of the energy system. This year, Colorado, Connecticut, and Maine passed laws that will prevent utilities from charging ratepayers for their lobbying efforts. Several states are experimenting with new, performance-based regulations, whereby utilities’ compensation is tied to specific goals, including emission reductions.
There’s also evidence that the existing channels for democratic engagement with the energy system aren’t totally broken. California and Michigan both recently made big strides on the climate and equity issues that public power advocates care about. This summer, the Golden State passed a law requiring utilities to design progressive rates tied to customers’ incomes. Michigan passed a law requiring utilities to use 100% clean energy by 2040.
The revitalized push for public power is about more than clean energy. To proponents, it’s about shaping this new, green energy system in a way that benefits a wider public. Whether or not they see more victories, the questions they are raising about who decides when and how we transition to this hypothetical clean energy future are already infiltrating the wider climate discussion. And as past public power movements, like the one in Boulder, have shown, even when the campaigns fail, the threat they pose to utilities is usually enough to get the companies to change their approach.
If there’s one thing I took away from the workshop, it’s that the movement is just getting started. Expect to see more high-profile campaigns — perhaps in San Francisco or Ann Arbor — in the coming years.
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Chatting about win-win solutions with the Abundance Institute’s Ryan Norris.
This week’s conversation is with Ryan Norris, senior fellow for energy policy at the Abundance Institute. The libertarian-leaning institute — whose name cleverly shortens to AI — is a new-ish entity with increasing relevance in energy and tech spaces. As Norris and I discussed, it’s starting to help shape policy on data center development and the generation that’ll power it all, especially in Republican circles. Norris himself previously worked with Americans for Prosperity, a right-wing political organization. I reached out to him and asked if we could chat because I wanted to know more about the institute’s work within the energy space. He wound up saying a lot more than I expected. So let’s dive into it.
The following conversation was lightly edited and abridged for clarity.
So let’s start with what you’re working on. What’s on your desk these days?
Here at Abundance, we sit at the juncture of emerging technology and the energy they need to bring that new technology to bear to impact life positively. We are always in a constant state of learning and researching what the latest thoughts and feelings are around certain policies, particularly around AI and data centers, and then energy technology. How do they feel about nuclear? Geothermal? Solar and battery arrays?
A lot of what I’m working on is Project Gigawatt, a body of policy that fits into permitting, generation, the grid, transmission, and then market and demand. Policies that we believe will generate more, transmit more, and as much of a free market approach as possible. Knowing that a lot of states have regulated utilities, when the state utility can’t produce what the state can potentially actually generate or would need to in order to accommodate large loads, we think there needs to be other opportunities to either bring that power or purchase it in a different way.
When it comes to this policy set, how are you taking into account the intensifying backlash to data center and AI infrastructure, as well as the energy attached to it?
As everyone can sense, things are moving rapidly, and there is a natural inclination to question how fast we’re going. I think these concerns need to be addressed seriously and respectfully. You can’t just say negative things about people who care about water quality or impacts to their local economies. Those are valid. I’ve lived through those. I come from a rural place in Arkansas that had oil and gas plays. And I’ve seen there needs to be conversations with people living in those areas too.
We cannot discount the backlash. When you take the legitimate concerns and pair them with the opportunities coming, I think there’s actually a chance to set up win-win solutions. It shouldn’t be a win-lose scenario here. They have skepticism about AI in the short and long term — that’s a natural inclination and not a negative, per se. But educating people and policymakers about data centers, that’s important.
What is your approach to the rise in land use regulation around data centers and energy infrastructure, moratoria and restrictive ordinances?
As much as possible, you want the infrastructure and cost allocation to be borne by the business causing it. That’s the motivation behind a lot of colocation partnerships happening right now, like the Kilby project in Texas, with natural gas powering a Microsoft hyperscale.
To us, it’s about setting up the opportunity for private property owners to sell to those hyperscalers and those generating the energy. Setting up situations where you’re not stopping people from benefiting. A lot of the “bring your own power” concept, we really like that. Maybe having it where power purchase agreements are more in the mix, things along those lines. That’s where I see things.
The energy increases to our utility bills, people are concerned about it, and that’s a bread and butter issue. That’s the approach: We know we need grid upgrades and want to have the most cost effective versions of those as possible, but you want those needing the power paying for it and not putting it on the backs of residents.
I’m curious, what’s you and your organization’s approach to the rise of gas infrastructure built for AI and the potential impacts that could have on climate change?
I don’t discount the issue of climate change.
Let’s say we’re not able to decarbonize enough to reverse the effects of warmth. We know we’ll have to create energy. We know we have other options for energy that need to be in the mix — more nuclear, which now even some of those who are climate-minded understand is an abundant energy source. I’m also interested in new technologies in geothermal where it can be viable in more places than we thought. You can drill down and tap hot rocks, a basin of water, turn a turbine, and that’s more acceptable for those who care about the climate. And states are looking at it, including my state of Arkansas. I bring these up because I also care about sources that provide firm, consistently available power.
We attended the American Legislative Exchange Council, and one of the things we do, we’re voting members on the energy, environment, and agriculture task force. We’re pro letting the market decide what they need. So we took opposite stances from what people typically consider normal standards on the center-right about banning “net-zero” for local governments. It did pass as model legislation but if we believe “all of the above” is the approach, we also want to be principally correct to ourselves that it doesn’t mean banning wind or solar where it’s viable.
My last question: What’s your thought on the future of politics around AI infrastructure and energy generation for it?
There’s definitely headwinds to those in that industry. I think the sense is, they understood what they wanted and didn’t see any barriers to the way they’d go about it. That’s causing ripple effects in our politics at the local level, including here in Arkansas, where I live in Pulaski County. I think it’ll stay important particularly as it connects to affordability concerns around energy. We know we need more energy, but we want it at the lowest cost possible to the residential side. If people are feeling like data centers are driving the demand for the energy and aren’t on the hook for it, that’s going to position them to be more negative towards the technology.
But we have to expand the conversation. There are folks out there talking about 3D printing for homes, using proprietary cement mixes to build homes in a few weeks when they took months. Agriculture is using robotics in lieu of pesticides and herbicides. Advanced manufacturing is improving the quality of medical equipment. No one completely understands the end goal of new energy to fuel the data centers and AI to get us where there’s a net benefit to them.
Plus more of the week’s biggest development fights.
1. Shelby County, Alabama — The Trump administration’s widening effort to intervene in rural energy project fights is facing an early test: What happens if companies don’t take it seriously?
2. Ozaukee County, Wisconsin — Speaking of walls, we just saw the political power of the data center resistance hit one in the Badger State.
3. Everywhere in Texas — Texas Governor Greg Abbott is getting a lot of love for his data center standards, with major developers rolling out press statements claiming they’ll comply.
4. Herkimer County, New York — Something weird is going on in upstate New York with a monastery, a wind farm, and the Trump administration. I’m not sure what to make of it yet.
Renewable and pipeline companies alike have come out against the administration’s attempt to leverage an obscure Cold War-era law.
The Trump administration is considering changing its interpretation of an obscure law related to farmland ownership to transform it into a national security instrument with profound impacts for U.S. renewables projects — and fossil fuels. U.S. energy developers and their trade groups are ringing alarms about the plan, arguing that Trump may be about to undermine their relationships with international investors in allied nations.
For the past week, I’ve been hearing anxious rumbling from contacts in D.C. about a proposed regulation from the Agriculture Department published on June 26. The plan has gotten little attention so far outside of energy trade publications and wonk analysis. Pay no mind to the relative quiet — anyone working in energy development needs to know what’s at stake. Explaining why this is sending D.C. energy lobbyists into a tizzy gets complicated quickly, so bear with me. But the easiest way to sum it up is a fear of death by a thousand cuts.
The administration’s proposal would morph USDA’s approach to the Agricultural Foreign Investment Disclosure Act of 1978, often referred to in legal circles by the acronym AFIDA. This Cold War-era statute created a system for collecting information on farmland owned by people or entities born, headquartered, or otherwise governed by laws outside of the United States, requiring people or companies labeled “foreign persons” to disclose land holdings and transactions to the federal government.
As I reported Monday, Senate Democrats claim the department is proposing to expand the definition of “agricultural land” to include all solar and wind projects, as well as pipelines. I’ve since confirmed this is true, as stated in a supplemental document released by USDA. But there’s a lot more causing companies headaches. The plan would drastically expand the pool of entities and people required to report to USDA by lowering the minimum foreign investment threshold for reporting, compel information on rights of ways when it wasn’t asked for before, and force companies to do detailed geospatial mapping of farmland.
You may not have heard of AFIDA, but security hawks in D.C. and the most affected multi-national companies have been agitating to reform the law for years. Their concerns have focused primarily on Chinese firms and the agriculture sector. In 2022, Republicans in Congress anxious about Chinese companies purchasing farmland near military bases requested an independent Government Accountability Office audit of AFIDA compliance. Two years later, the watchdog office found the law was falling significantly short of its stated objective to track relevant land transactions.
Representatives from the energy sector tell me the actual proposed changes would create a severe red tape headache for developers of all stripes.
Over the past week, almost every major industry trade group in renewables and fossil fuels has filed a comment excoriating the plan, with even some oil and gas allies such as the Western Energy Alliance calling for it to be thrown onto the trash heap. The American Petroleum Institute and Interstate Natural Gas Association of America told the USDA that the plan would “chill foreign investment in U.S. energy infrastructure and increase the cost of capital for pipeline projects with no benefit to national security.”
Meanwhile, renewable energy industry representatives seemed particularly frightened by the proposal given existing financial relationships with investors, parent companies, and business partners in U.S.-aligned nations. American Clean Power said it would burden “good faith, low-risk filers from allied countries,” while the Solar Energy Industries Association said the proposal warranted “a full withdrawal” as it had “unintended national security consequences and [would] unnecessarily expose business sensitive information.”
So far, only one large publicly-traded renewables company has commented with criticisms of the proposal: EDP Renewables North America, a subsidiary of a Portuguese company. “We respectfully urge USDA to carefully weigh the compliance burdens imposed by each proposed change against the incremental national security benefit it provides,” wrote Tom LoTurco, an executive vice president for EDP Renewables North America.
Those calling for reform have wanted to streamline the filing process, not add even more bureaucracy. “Solar and wind, they’ve long been considered agricultural land users. But under this rule, costs are going to go way up,” Jeff Hunter, an attorney with Kelley Drye and Warren LLP, told me. “It’s going from a manageable material cost to something that’s going to have a meaningful effect on the bottom line.” Hunter represents the AFIDA Modernization Coalition, an ad hoc coalition of companies that routinely file under the law. Hunter said the coalition includes founders Invenergy and Doral Renewables, both of which have substantial renewables investments in the U.S. as well as investment originating from other countries.
“It’s going from a manageable material cost to something that’s going to have a meaningful effect on the bottom line.”
Many large renewable energy companies have substantial foreign investment because of the European trend towards ESG-minded financing practices, Hunter added. The law was already on developers’ radars, but this proposal presents a wholly different regime.
As Trump re-entered office, it was reasonable to expect his administration would attempt to “protect farmland” from renewable energy development given the issue’s salience in deep red rural pockets of his supporter base. Still, when the Agriculture Department last May released a “National Farm Security Action Plan” stating that it would change AFIDA regulations, I didn’t think much of it. The plan didn’t mention the energy sector at all.
In December USDA solicited public comments on ways to change the rules, but it was a sleepy affair with little conflict involving renewables or anything else. Even the Center for Regulatory Freedom, a conservative policy shop created by the political organization CPAC, sought changes while emphasizing the “United States benefits from foreign capital in agriculture, renewable energy, and rural development, and AFIDA should not become a blunt instrument that discourages lawful and economically beneficial transactions.”
All this is to say, nobody seemed to anticipate the bomb USDA suddenly dropped on the energy industry.
The plan may change between proposal and implementation. But so far only one organization I know of is focused on ensuring that solar and wind are targeted under the new rulemaking: the America First Policy Institute, a Trump-aligned think tank co-founded by Brooke Rollins, the current Secretary of Agriculture. In comments filed by AFPI’s Adam Savit, the conservative think tank recommended the government preserve “the inclusion of solar and wind generation on agricultural land” because it “prevents the conversion of reportable land into unreportable land through a change in use.” The group’s comments did not address the rule’s references to pipelines.
I asked AFPI to ask if it had any additional comment on the rulemaking, and specifically if it had any view on the new definition for agricultural land. In a statement provided by the think tank, its senior director for China policy Piero Tozzi told me that “the proposed change is necessary to address who owns the land and what control it gives the owner.”
“The current reporting framework for foreign acquisition of American farmland before land was understood as a potential strategic perch for foreign adversaries,” Tozzi said.
The Agriculture Department rarely comments on public input received on proposed rulemakings and did not respond to a request for comment for this story. On Monday, the agency sent me the following statement in response to the Senate Democrats’ claims: “As Secretary Rollins has noted before, the regulations governing the Agricultural Foreign Investment Disclosure Act of 1978 are extremely outdated and need to be updated to better reflect today’s conditions. USDA looks forward to considering all public comments before finalizing the rule.”