significant support from the Office of the General Counsel. The Department is also aggressively pursuing the Administration's commitment to increased exports of American agricultural products. These efforts produced increasing amounts of legal work with respect to export credit guarantee programs and other programs to encourage exports.

Food Stamp and Child Nutrition Programs. During fiscal year 1983 OGC expects to devote a substantial portion of its resources to activities related to implementation of changes in the food stamp and child nutrition programs as proposed in the President's FY 1983 budget, as well as continuing work on changes enacted during the last six months. This work will include not only the preparation and review of regulations, but also participation in litigation against the government.

For example, eight lawsuits have already been filed in the federal courts challenging various aspects of the implementation of the food stamp amendments contained in the Omnibus Budget Reconciliation Act of 1981. While the Department of Agriculture is not named as a party in all of these cases, they all involve issues that directly affect the Department's ability to achieve the program savings contemplated in the 1981 Reconciliation Act.

Efforts to increase the integrity of these programs has also created demands for additional legal work in handling claims, criminal prosecutions, and appeals from program disqualifications.

PACA. The pattern of recent years has seen annual increases in the number of disputes submitted to the Department for resolution under the Perishable Agricultural Commodities Act. During fiscal year 1980 there were 129 new reparation cases. There were 173 new cases in fiscal year

1981 and on the basis of the first five months of fiscal year 1982, it appears that the number of new cases will be even higher this year.

Food Safety and Inspection and Grading. The Department has a number of major rulemakings under development, including those concerning Mechanically Processed (Species) Product, the Labeling Approval System, and Beef Grading. These involve significant commitments of time to review and litigation is quite possible once the rulemakings are concluded. OGC is working with the agency on proposed legislation concerning "continuous" inspection and food-safety. In addition, there are a number of problems concerning efforts by states to impose labeling requirements which are different from federal requirements, particularly on meat

imports.

Animal and Plant Health Inspection. Quarantines and regulations concerning plant pests (such as medfly), environmental questions raised in connection with treatment programs, and implementation of the endangered species legislation are expected to draw on OGC resources.

Marketing. Implementation of the new fruit and vegetable marketing order guidelines will likely result in proposed amendments to marketing orders and regulations and the need for significant OGC participation in the drafting of rules and in amendment hearings. In addition, the major study of the milk program, including milk marketing orders, which is mandated by the 1981 farm bill will also involve OGC staff.

Packers and Stockyards. Major reviews and revisions of P&S regulations under the regulatory reform directives, and bankruptcies and other problems flowing from current economic conditions will require significant OGC resources.

Farmers Home and REA. Loan servicing problems, bankruptcies of

borrowers, loan fund limitations which put a premium on lending decisions,

and a pending conversion of REA Bulletin's to Regulations will place a

heavy demand on OGC resources.

Natural Resources. Among the major problems that will continue

to require OGC attention are land management plans, oil and gas leases, mineral management, boundary line disputes, small business set asides, water rights in Western states, wilderness issues, and timber sales (where the depressed market creates more defaults and in turn more cases before the Court of Claims and the Board of Contract Appeals).

In closing, Mr. Chairman, we believe we will be ready to meet the challenges facing OGC and the Department, and we believe the increases requested for 1983 are absolutely necessary for this purpose. We appreciate the support that you and the Committee have provided to our office in the past.

Thank you very much for the opportunity to discuss the needs of the Office of General Counsel. I'll be happy to answer any questions the Committee may have.

OFFICE OF THE GENERAL COUNSEL

Purpose Statement

The Office of the General Counsel, prior to 1955 known as the Office of the
Solicitor, was established in 1910 (70 Stat. 742) as the law office of the
Department of Agriculture.

The Office provides all essential and necessary legal advice and services for the Department's ongoing programs, taking into consideration not only immediate needs but future requirements as well.

The Office provides reimbursable services to two principal recipients:

(1) Forest Service relating to the acquisitions of lands and related activities under the Land and Water Conservation Fund Act of 1965 as amended, (16 U.S.C. 4601 et seq.) and (2) Farmers Home Administration relating to Disaster and Related Loans under Agricultural Credit Programs.

Geographic Location. The work of this office is carried out in Washington, D.C. and at fourteen field offices at the following locations:

As of September 30, 1981, the office had 343 employees of which 329 were permanent full-time. There are 199 employees located in Washington, D.C. and 144 employees in the field.