USDA Weekly Egg Price and Inventory Report, April 20th 2023

Market Overview

The average wholesale unit revenue values for Midwest Extra-large and Large sizes were lower this week by 24.7 percent on average, representing a reversion to relative seasonal post-Easter value and following the decline from the previous week. Mediums were down 20.7 percent with a higher price differential from Large, indicating restoration in the balance between supply and demand in this size. This past week shell egg inventory was up a noteworthy 10.3 percent, consistent with sharply lower prices and presumably lower demand with prevailing high shelf prices. Over the coming two weeks the volume of retail purchases will be influenced by lower seasonal post-Easter demand. If chains reduce margins consistent with prevailing wholesale prices, higher demand can be anticipated. Eggs should still be highly competitive in price against the comparable costs for other protein foods. Availability and hence prices have been influenced by depletion of close to 44 million hens in 22 large complexes in eleven states extending from the last week in February through mid-December 2022 with the producing flock down on average by 20 million hens during 2022 and now by 19 million since flocks are only slowly restored, to their pre-HPAI complement.

• Total industry inventory was up by 10.0 percent overall this past week to 1.83 million cases with a concurrent 8.9 percent increase in breaking stock attributed to less diversion but with flagging post-Easter demand last week from food service and industry. This is suggested by stable to lower prices for egg products. Wholesale prices contrast favorably with 2020 and 2021 characterized by low ex-plant unit revenue but are now lower than for the corresponding week in 2022.

• It is now apparent that the inventory held by chains and other significant distributors may be more important over the short term in establishing wholesale price than the USDA regional inventory figures published weekly. This is probably the reason for the two consecutive weekly increases in stock with only a small decline in the size of the national flock and with sharply falling wholesale prices.

• Despite the depletion of flocks as a result of HPAI, relatively low unit revenue compared to pre-HPAI will now be a reality into May 2023. Sporadic outbreaks of HPAI are now less likely given the seasonal Spring migration of waterfowl is completed. The number and extent of outbreaks cannot be assessed until more information is available concerning the molecular and field epidemiology relating to cases. The USDA has yet to identify modes of transmission for the 2022 epornitic including airborne spread. There have been no case-control studies released on possible deficiencies in biosecurity on affected complexes that presumably demonstrated specific risk factors.  APHIS has been remiss in evaluating available data and providing timely practical guidance on prevention as evidenced by releasing a backdated report during the first week of March that was devoid of recommendations to prevent HPAI infection in flocks.

• The current relationship between producers and chain buyers based on a single price discovery system constitutes an impediment to a free market. The benchmark price amplifies both downward and upward swings as evidenced over the past six months. The benchmark possibly functions to the detriment of the industry over the long term. A CME quotation based on Midwest Large, reflecting demand relative to supply would be more equitable. If feed cost is determined by CME ingredient prices then generic shell eggs should be subject to a Midwest Large quotation.

• According to the USDA the U.S. flock in production was down 0.5 percent or 1.4 million hens to 295.9 million hens during the week ending April 19^th. The flock in production includes about 3.0 million molted hens that resumed lay during the past week plus 4.0 million pullets attaining production.

•  The ex-farm price for breaking stock was down 30.4 percent this past week to 131 cents per dozen. Checks delivered to Midwest plants were down 26.8 percent to 120 cents per dozen. Prices for breaking stock will remain high over the period of recovery from HPAI until replacement flocks reach maturity.

The Week in Review

Prices

According to the USDA Egg Market News Reports released on April 17^th the Midwest wholesale price (rounded to one cent) for Extra-large was down 24.6 percent to $1.69 per dozen. Large size was down 24.8 percent to $1.67 per dozen; the Medium price was down 20.7 percent to  $1.42 per dozen as delivered to DCs. Prices should be compared to the USDA benchmark average 6-Region blended nest-run cost of 91.5 cents per dozen as revised by the EIC during March 2023. This excludes provisions for packing, packaging materials and transport, amounting to 50 cents per dozen in mid-2022, according to the EIC but now probably closer to 55 cents per dozen. The progression of prices during 2023 to date is depicted in the USDA chart reflecting three years of data, updated weekly.

 The April 17^th 2023 edition of the USDA Egg Market News Report documented a USDA Combined Region value rounded to the nearest cent, of $2.29 per dozen delivered to warehouses for the week ending April 9^th 2023. This average price lags current Midwest weekly values by one week.  The USDA Combined range for Large in the Midwest was $2.22 per dozen. At the high end of the range, the price in the South Central region attained $2.35 per dozen. The USDA Combined Price last week was approximately $0.25 above the 3-year average. This past week Midwest Large was approximately $0.60 below the corresponding week in 2022 elevated by losses due to HPAI.

Flock Size 

The USDA adjusted the estimate of flock size to reflect depopulation of more than 31.1 million hens through June 6^th 2022 as a result of the spring wave of HPAI with subsequent depopulation of approximately 14 million additional hens in Ohio, Colorado, Iowa, Oregon and South Dakota during the fall wave ending late-December. According to the USDA the number of producing hens reflecting April 19^th (rounded to 0.1 million) was down 1.4 million (0.5 percent) to 295.9 million. The total U.S. flock includes about 3.0 million molted hens due to return to production with approximately 4.0 million new pullets reaching maturity each week based on USDA chick hatch data. The increase is offset by routine flock depletion in addition to past losses during 2022 due to the HPAI epornitic. Based on inventory level and prices the hen population producing eggs should now be in mild oversupply relative to consumer demand. Industrial and food service off-take although increasing, has not reverted to pre-COVID levels. Prices will continue to fluctuate, now expected to trend downwards into May 2023. Prices of shell eggs and products will also depend on any future incident outbreaks of HPAI offset by the contribution of new pullets and of molted hens to supply.

According to the USDA the total U.S. egg-flock on April 19^th was down 1.5 million hens (0.5 percent) to 303.5 million including second-cycle birds and those in molt. Any difference between hens in production and total hens is an approximate figure but denotes that many molted hens resumed production in mid-March to meet Easter demand. At present there are now at least 18 to 20 million fewer hens in both the total and producing flocks with the difference equivalent to about five percent of the pre-HPAI national flock of 325 million hens.

INVENTORY LEVELS

Cold storage stocks of frozen products in selected centers on April 17^th 2023 amounted to 2.402 million pounds (1,092 metric tons) of frozen egg products, up 0.7 percent from the inventory of 2.386 million lbs. on April 1^st 2023. The monthly USDA Cold Storage Report below quantifies a reduction in the actual total stock level.

The most recent monthly USDA Cold Storage Report released on March 23^rd 2023 documented a total stock of 26.1 million pounds (11,862 metric tons) of frozen egg products on February 28^th 2023. This quantity was down 6.7 percent from the February 28^th 2022 value of 28.0 million pounds.  February 28^th 2023 frozen egg inventory was down 9.1 percent from the previous month ending January 31^st 2023 despite depletion of 44 million hens over 2022. Compared to February 28^th 2022 yolks were up 0.3 percent to 788 million lbs. on February 28^th 2023.

A total of 85.3 percent of combined inventory (22.2 million lbs.) comprised the categories of “Whole and Mixed” (43.0 percent) and “Unclassified” (42.3 percent). The lack of specificity in classification requires a more diligent approach to enumerating and reporting inventory by the USDA

Shell Inventory

The USDA reported that the national stock of generic shell eggs effective April 17^th 2023 was up a noteworthy 10.0 percent continuing the trend of the previous week. The relative movement of stock over the previous week suggests decreased consumer demand inconsistent with a sharp seasonal fall in price. Combined with breaking stock, the total inventory of shell eggs in the industry is now at 1.83 million cases (1.66 million last week and 166,300 cases higher). The U.S. population of laying hens at this time is influenced by the number of hens previously culled due to HPAI, and includes the population unaffected by HPAI, flocks retained after molting (with an anticipated increase in this category depending on available housing capacity) and started pullets from chick placements in early November 2022. Going forward, older hens will assume a larger proportion of the national flock as more flocks are molted especially as many “at risk” pullet flocks were depleted due to HPAI.

All six USDA Regions reported lower stock levels this past week. The regions are listed in descending order of stock: -

• The Midwest Region was up 13.9 percent compared to the previous week to 493,600 cases.
• The Southeast Region was up 0.5 percent to 295,400 cases
• The South Central Region was up 15.6 percent to 294,600 cases

• The Southwest Region was up 12.3 percent to 156,600 cases.
• The Northeast Region was up 9.7 percent to 167,700 cases
• The Northwest Region was up 7.2 percent to 73,800 cases

The total USDA six-area stock of commodity eggs comprised 1,828,700 cases, up 10.0 percent, of which 81.0 percent were shell eggs (80.8 percent last week denoting similar demand as the previous week). The inventory of breaking stock was up 8.9 percent to 347,000 cases. Shell egg inventory was up 10.3 percent attaining 1,481,700 cases. The higher level of breaking stock over the past week is attributed to less diversion to the shell egg market and lower demand for liquids by industry, food service and consumers. The average price for Midwest checks and breaking stock combined was 74.0 percent of the average value of Midwest Extra-large and Large shell eggs (last week 78.9 percent) consistent with sharply lower prices for shell eggs. The differential can be compared to 80.0 percent in April 2022 reflecting the initial period of high demand for both shell eggs and breaking stock after the onset of HPAI. This past week the wholesale Midwest Extra-large and Large shell egg prices were lower by an average of 24.7 percent compared to breaking stock and checks combined that were down by 28.6 percent on average from the previous week. This demonstrates the respective demands for shell eggs and egg products. There is interconnectivity of the packing and breaking segments of the egg industry under circumstances of extreme disturbances in either supply (HPAI in 2022) or demand (COVID in 2020). The price for breaking stock and for checks is influenced by the relative demand for generic shell eggs and contract obligations with breakers.

On April 17^th 2023 the inventory of other than generic eggs amounting to 435,000 cases (up 11.1 percent from last week at 391,600 cases) among three categories (with the previous week in parentheses) comprised:-

• Specialty category, up 9.7 percent to 50,900 cases. (Was down 1.3 to 46,400 cases)

• Certified Organic, up 4.4 percent to 85,700 cases. (Was down 0.5 percent to 82,100 cases)
• Cage-Free category, up 13.4 percent to 298,400 cases. (Was down 8.5% to 263,100 cases)

Demand for cage-free product will not increase materially while generic eggs from caged flocks and some surplus down-classified cage-free eggs are on the shelf at $2.00 to $2.50 per dozen during normal supply conditions over the long term. This is supported by the findings of the comprehensive review relating to the transition from cages to alternative systems.* Existing and proposed individual state legislation mandating sale of only cage-free eggs will support most of the anticipated transition from cages but total re-housing will not be completed by the beginning of 2025, less than 20 months away and ultimately never by many observers. The constitutional status of Proposition #12 was considered in oral arguments presented to SCOTUS on October 11^th 2022 with specific reference to the Dormant Commerce Clause relating to interstate trade. Many chains are reneging on or extending their time commitments to achieve an acceptable transition to cage-free eggs. With the current proportion of non-caged flocks, cage-free eggs are surplus to demand in some areas and are becoming a commodity in many markets subjected to the same price pressures as generic eggs from caged hens. Growth in demand for organic product has been static for months.

Long-term demand for cage-free eggs is influenced by the relative shelf prices of the category in comparison with generic white-shelled eggs from caged flocks. At the other end of the price range, consumers will purchase less-expensive brown cage-free product over organic eggs when there is a differential in price greater than about $1.20 per dozen under normal balance between supply and demand. Similarly, consumers will traditionally purchase white-shelled generic eggs in preference to brown-shelled cage-free with a differential of over $1.20 per dozen.

*Caputo,V. et al The Transition to Cage-Free Eggs. February 2023

A comprehensive structured market research project on cage-free eggs has provided an indication of consumer willingness to pay for this attribute. The industry requires a study on other aspects including shell color, GM status and nutritional enrichment. Above all agricultural economists should evaluate the impact of disruption in supply and demand arising from large-scale depopulation following HPAI in 2015 and the ongoing 2022-2023 HPAI epornitic.

RELATIVE PRICES OF SHELL-EGG CATEGORIES

USDA-AMS posted the following national shell egg prices as available, for April 14^th 2023 in the Egg Markets Overview report for dozen cartons with comparable prices in parentheses for the previous week: -

Retail

Large, in cartons generic white:        $3.24     down 1.5 percent      ($3.29)

Large, in cartons cage-free brown:   $3.99     up 14.3 percent        ($3.49)   

Large C-F, California in Cartons:      $3.06     down 10.6  percent  ($3.98)

Wholesale

National loose, (FOB dock):              $1.23      down 14.6 percent   ($1.44)

NYC in cartons to retailer:                 $1.77      down 25.0 percent   ($2.36)

Midwest in cartons to warehouse:     $2.23      down 27.1 percent   ($3.06)

RELATIVE ADVERTISED PRICES OF SHELL-EGG CATEGORIES

USDA Certified Organic, Brown, Large:              (none)       (none)   

Cage-Free White, Large:                                     $3.87        ($3.49)

Omega-3 Enriched Specialty, White, Large:       $3.99        ($3.99)

Generic White, Large Grade A                            $2.74*      ($3.74)

Generic White, Large Grade A (Feature price)    $2.74*      ($3.29)

* Based on a small sample with few advertised promotions

The advertised price this week for Large white grade A was $2.74 per dozen, down $1.00 per dozen or 26.7 percent from the previous week. Shelf prices will influence demand for generic categories given their availability and the comparison with higher advertised and actual shelf prices for specialty and cage-free brown eggs. Current supply was higher than demand this past week as independent producers continue to divert fewer shell eggs from breaking. Large integrated companies and packers continue delivering to DCs at lower volumes as chains held back on orders in anticipation of lower benchmark prices despite the need to replenish inventory.

For the current week the USDA were unable to document a benchmark-advertised retail price for certified organic. Three weeks ago USDA posted an advertised price of $3.50 per dozen for cage-free brown with cage-free white advertised at $3.89 per dozen during the past week. Large week-to-week fluctuations can be expected in the stock of specialty and organic eggs based on the small base of these categories. 

Retail demand will continue to be supported by home cooking and baking and reinforced by seasonal dining out as COVID is now ignored. Eggs and product purchases will be limited among some demographics by their disposable incomes and inflation.

There was insufficient USDA data on shelf prices this week to calculate retail margins. Demand will increase as chains pass on any reduction in wholesale price for generic eggs.

The inability of the USDA to consistently post retail and promotional prices and the evident disparity between their weekly data and actual shelf prices suggests deficiencies in their systems of price discovery that should be addressed.

 Omega-3 enriched comprised 18.6 percent of features compared to 25.2 percent last week. Cage-free represented 27.6 percent of features. The remainder features comprising 53.8 percent was divided among Extra large at 10.4 percent and Large at 43.4 percent. This confirms that retailers promote generic categories if available in excess of demand.

USDA Cage-Free Data

According to the latest monthly USDA Cage-free Hen Report released on April 3^rd 2023, the number of certified organic hens during March 2023 was up 4.8 percent from February 2023 to 17.6 million.

The USDA reported the cage-free (non-organic) flock in March 2023 to be 4.1 percent higher than in February 2023 to 102.2 million

According to the USDA the population of hens producing cage-free and certified organic eggs in March 2023 comprised: -

Total U.S. flock held for USDA Certified Organic production = 17.6 million (18.0 million in Q4 2022).

Total U.S. flock held for cage-free production                          = 102.1 million (88.5 million in Q4 2022).

Total U.S. non-caged flock                                                        =119.7 million (106.5 million in Q4 2022).

This total value represents 36.9 percent (last month 35.5 percent) of a nominal 324 million total U.S. flock pre-HPAI (but 38.9 percent of the national flock after HPAI mortality to a March complement of 308 million). Hens certified under the USDA Organic program have decreased in proportion to cage-free flocks since Q1 of 2021.  

The accuracy of individual monthly values is questioned given a history of either sharp changes or no change in successive months as documented over the past two years. Precise quarterly reports would be more suitable for the industry in planning expansion and allocation of capital.

Processed Eggs

For the processing week ending April 15^th 2023 the quantity of eggs processed under FSIS inspection during the week as reported on April 19^th 2023 was up 4.7 percent compared to the previous processing week to a level of 1,513,876 cases, (1,445,477 cases last week). The proportion of eggs broken by in-line complexes was 51.9 percent (52.2 percent in-line for the previous week) indicating relatively stable proportions of contract and purchased eggs broken. The differential in price for shell sales and breaking will determine the movement of uncommitted eggs. This past week 67.5 percent of egg production was directed to the shell market, (69.1 percent for the previous week) responding to the differential in prices paid by breakers and packers. Breaking stock inventory was up 8.9 percent this past week to 347,000 cases despite diversion to shell-egg markets. Increased demand from QSRs and casual dining, with apparent continued demand from baking and eat-at-home has contributed to higher inventory of breaking stock. During the corresponding processing week in 2021 (during COVID recovery) in-line breakers processed 54.1 percent of eggs broken.

For the most recent monthly report for week ending April 1^st 2022, yield from 7,007,366 cases  (5,799,495 cases last month) denoted a slight increase in demand for liquid over the period February 26^th through April 1^st 2023.  Edible yield was 41.8 percent, distributed in the following proportions expressed as percentages: - liquid whole, 63.9; white, 22.3; yolk, 11.1; dried, 2.6.

All eggs broken during 2022 attained 76.22 million cases, 2.0 percent less than 2021. Eggs broken in 2023 to date amounted to 21,423,434 cases, 6.9 percent less than the corresponding period in 2022. This is attributed to decreased demand for egg liquids from retail, food service and QSRs and casual dining restaurants despite restoration of service as COVID restrictions are successively relaxed.

PRODUCTION AND PRICES

Breaking Stock

The average price for breaking stock was down 30.4 percent this past week to an average of 131 cents per dozen with an extreme range of 118 to 143 cents per dozen delivered to Central States plants on April 17^th. Checks were down 28.6 percent this past week to an average of 120 cents per dozen over the most frequent range of 119 to 121 cents per dozen suggesting that the market for breaking stock will continue to decline through the remainder of April.

Shell Eggs

The USDA Egg Market News Report dated April 17^th 2022 confirmed that Midwest wholesale prices for Extra-large and Large sizes were down by 24.7 percent on average compared to the previous week. Mediums were down by 20.7 percent. The trend of consecutive sharp lower prices coupled with rising stock suggests continuing declines through the remainder of April  with a bottom hopefully at the end of the month. The following table lists the “most frequent” ranges of values as delivered to warehouses*: -

*Store Delivery approximately 5 cents per dozen more than warehouse price

The April 17^th 2023 Midwest Regional (IA, WI, MN.) average FOB producer price, for nest-run, grade-quality white shelled Large size eggs, with prices in rounded cents per dozen was down 28.9 percent from last week, (with the previous week in parentheses): -

         EL. $1.49 ($2.08), (estimated by proportion):  L. $1.45 ($2.04): M. $1.20 ($1.59)

The April 17^th 2023 California price per dozen for cage-free, certified Proposition #12 compliant Large size in cartons delivered to a DC, (with the previous week in parentheses) was down 18.0 percent from last week.

         EL. $2.65 ($3.20); L. $2.51 ($3.06); M. $2.25 ($2.62)

(See the text, tables and figures and the review of production data and prices comprising the USDA Report for March 2023 in this edition and the 3^rd Quarter FY 2023 results for Cal-Maine Foods under the Statistics Tab)

Shell-Egg Demand Indicator  

The USDA-AMS Shell Egg Demand Indicator for APRIL 19^th was down 10.7 points from the last weekly report to -17.9 with a 10.0 percent increase in total inventory and a 10.3 percent higher shell inventory from the past week as determined by the USDA-ERS as follows: -

Note 1: USDA Flock numbers were adjusted after incident cases of HPAI in mid-May 2022. The latest estimate of hen population takes into account the depletion of approximately 44 million hens in 22 large complexes (holding over 500,000 hens) in addition to smaller units in eleven states.

Dried Egg Products

The USDA extreme range in prices for dried albumen and yolk products in $ per pound was released on April 14^th 2023. Data posted by the USDA is incomplete but available values are depicted for the previous week and past months to illustrate the trend in prices influenced by HPAI depopulation and subsequent repopulation:-

Frozen Egg Products

The USDA range in prices for frozen egg products in cents per lb. on April 14^th 2023 compared to the previous week were on average lower but indicating a balance between available products and demand from the manufacturing and retail sectors: -

                                   1. extreme range

Liquid Egg Products

The March 2023 averages for non-certified truckload quantities are tabulated (cents per lb.) with February 2023 values in parentheses are: -

Whole,   203c (160c);   Whites, 149c (135c); Yolks, 307c (309c). 

The USDA has not released a report on dried egg inventory since March 13^th 2020 due to inability to obtain data from producers, and will not issue reports for the immediate future.

COMMENTS

The pattern of HPAI outbreaks as expected during the first quarter of 2023 did not materialize. For reasons yet to be understood only a few outbreaks were recorded among turkeys and backyard farms. Cases diagnosed in the Maritime Provinces followed by Quebec and Ontario of Canada with risk of extension along the four North American Flyways through May. It is evident that some wild domestic birds continue to shed virus based on cases in backyard flocks. This situation requires more intensive monitoring including surveys of wild domestic birds and small mammals. Given the risks and consequences of infection it will be necessary to maintain high levels of structural and operational biosecurity.

To date approximate losses in commercial flocks with confirmed HPAI and updates  include:-

•   2,900,000 broilers on 18 farms in 7 states For 2023 to date losses are 450,000
•      330,000  broiler breeders on 11 farms in 6 states.
•   9,800,000  turkeys including a few breeder flocks on 229 farms in 7 states. For 2023 to date losses are 127,000
• 44,000,000  egg-production hens in total with 95 percent on 22 large complexes above 0.5 million in addition to 1,070,000 pullets with a total of 41 locations in 11 states. Pullet mortality does not include “at risk” replacements depleted on affected complexes with contiguous pullet rearing.

For calendar 2022 through March 28^th 2023, 323 U.S. commercial U.S. flocks were infected with five  during March.  In addition there were 493 diagnosed backyard flocks with 34 during March. Losses of among commercial species have totaled 58.6 million commercial birds. (WOAH reported). To date 47 states, involving 400 counties have recorded at least one case involving wild birds, backyard flocks, commercial farms or their combination.

Mexico has depopulated 5.5 million commercial poultry, predominantly egg-producing flocks. One million have been depleted year-to-date

From April 2022 through mid-April 2023, Canada recorded 309 outbreaks in commercial flocks in nine Provinces and has depopulated 7.3 million commercial poultry including hens, turkeys and broilers. In addition numerous confirmations of HPAI were made in backyard and subsistence flocks.

During April 2023 16 cases of H5N1 with Eurasian genes were diagnosed in either raptors or waterfowl in eight states extending from Oregon East to New York and from North Dakota south to Arizona denoting widespread dissemination of HPAI H5N1virus. Isolation of H5N1 avian influenza in wild birds and backyard flocks is a function of surveillance intensity

Collectively the USMCA nations have depopulated approximately 70 million birds in at least 700 flocks.

France and Holland are evaluating AI vaccines. Mexico and Egypt have introduced vaccination. An International conference on vaccination against HPAI took place in Paris on October 25^th and 26^th and considered trade barriers to implementation of vaccination.

Backyard flocks that are allowed outside access will continue to be at risk of infection in the U.S. These small clusters of birds in suburban areas are of minimal significance to the epidemiology of avian influenza as it affects the commercial industry. Backyard flocks serve as indicators of the presence of virus among free-living birds as evidenced by ongoing outbreaks in commercial poultry flocks across the U.S.

The level of biosecurity in commercial egg production complexes and broiler farms is appreciably higher than in 2015 when the U.S. experienced an epornitic along the Mississippi Flyway The response of state and federal authorities since this time has been rapid and effective both in diagnosing and depleting affected flocks.  To date, all  floor-housed flocks that were infected were depopulated using foam. Euthanasia of egg production complexes involved various combinations of VSD+ applying heat or carbon dioxide or conventional kill-carts flushed with carbon dioxide.

The role of migratory waterfowl in introduction and subsequent dissemination of H5N1 HPAI virus is indicated by the close proximity of infected complexes and their counties with major waterways, lakes, wetlands or reservoirs during the spring and fall months of 2022. There is now limited subjective evidence of aerogenous transmission of HPAI over short distances with virus (possibly shed by wild endemic and migratory birds) becoming entrained in dust and introduced into ventilation inlets by powered ventilation systems.

It would have been of practical and financial benefit for APHIS epidemiologists to have reported on their findings from the questionnaires completed following outbreaks on commercial farms during the first quarter of 2022. Given the costs to the private and public sectors and to consumers priority should have been extended to the first seven large egg complexes affected. Case-comparison studies against representative unaffected complexes should have been performed using specific and relevent questionnaires. This would have provided advice to producers on risk factors. The industry should have been advised of likely routes of infection including possible aerogenous spread and whether any obvious defects in structural or operational biosecurity contributed to outbreaks. This would have facilitated appropriate preventive action and allocation of additional resources to intensified biosecurity.

A preliminary opinion with guidance during mid-April 2022 concentrating on large egg complexes was not an unrealistic request. This is especially the case since large egg complexes in Northwest Ohio and in Colorado were infected during September, in Iowa in October and again in November and in Oregon and South Dakota during early December 2022. This suggests ongoing exposure from wild domestic birds and possibly mammals in addition to migratory waterfowl as evidenced by the increasing incidence in backyard flocks that effectively serve as sentinels. An interim report was released during the first week of March 2023, inexplicably backdated to July 2022. This document, lacking either conclusions or recommendations was critiqued in a special edition of EGG-NEWS on March 8^th.