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USDA Weekly Egg Price and Inventory Report, October 30^th 2024.

Market Overview

• The average wholesale unit revenue values for Midwest Extra-large and Large sizes were up 36.0 percent on average this past week. Medium size was up 26.8 percent. The 5-day rolling National wholesale price for graded loose on October 28^th was $3.66 per dozen up 37.6 percent from $2.66 last week. This value was approximately $2.16 above the 3-year average of $1.50 per dozen and up $2.66 from the corresponding week in 2023 at $1.00 per dozen. This past week shell egg inventory was up 1.9 percent, almost reversing the rise of 5.9 percent during the previous week. During the past week the NYC wholesale price increased sharply after a market plateau with the immediate prospect of increases in coming weeks. The rise in inventory with an escalation in wholesale price denotes higher demand relative to supply predicting higher margins for producers through the 4^th quarter despite replacement of depleted flocks. Relatively higher prices compared to 2023 are attributed to previous losses due to HPAI in 2024 reducing the national flock by 17 to 19 million hens with increased seasonal demand.
• Although there are predetermined weekly transfers of mature pullet flocks to laying houses, the size of the producing flock is constrained by depopulation due to HPAI. During April 2024 almost 8.4 million hens were depopulated with an additional 5.7 million during May and 3.0 million in July. With 2.8 million hens depopulated in October, as the first incident cases of the fall 2024 wave there is currently a deficit of approximately 18 to 19 million hens compared to the 2022 flock of 326 million at the onset of HPAI.
• This past week, chains apparently narrowed the spread between delivered cost and shelf price. The reoccurrence of HPAI has probably created concern among chain buyers resulting in orders to ensure adequate stock levels to meet demand. Inventory levels will depend on constant re-ordering to fill the pipeline into early November. Discounters are raising prices on generics influencing mainstream retail stores. Eggs are now less competitive in price against the comparable costs for other protein foods, and have recently been highlighted as a contributor to the prevailing perception among consumers of ongoing food inflation.
• Total industry inventory was up by 0.7 percent overall this past week at 1.59 million cases with a concurrent 4.4 percent decrease in breaking stock, following a 4.2 percent fall during the preceding week attributed to diversion to the shell-egg market.
• It is apparent that the inventory held by chains and other significant distributors may be more important on a weekly basis in establishing wholesale price compared to the USDA regional inventory figures. Changes in stock held by DCs and in the pipeline as determined by weekly orders are probably responsible for up to three percent cyclic fluctuation in weekly industry stock, especially into and after a holiday weekend.
• The U.S. poultry industry has moved from a quiescent period regarding HPAI over the past two weeks with incident cases in northern Utah, southern Washington State and Oregon. Two weeks ago Tulare County California recorded an outbreak on a broiler-growing farm with 900,000 birds followed by an additional case on a small farm. Canada has diagnosed cases in The Fraser Valley of British Columbia and an outbreak in Saskatchewan. Over 388 confirmed cases of bovine influenza-H5N1 have been diagnosed in dairy herds in fourteen states with more than 186 herds California. This is a cause for concern since spill-over to laying flocks have occurred in Michigan, Colorado and Utah. More surveillance information should be released by USDA-APHIS as it becomes available, concerning the prevalence rate of avian carriers of H5N1 among resident domestic and migratory free-living birds. This data should be correlated with a review of molecular and field epidemiology for the past spring outbreaks in order to respond appropriately to the fall wave of HPAI that appears to be in progress. The USDA has yet to identify and release specific modes of transmission for the 2022-2024 epornitic including likely airborne spread from wild birds and their excreta over short distances as suggested by current research.
• The established relationship between producers and chain buyers based on a single commercial price discovery system constitutes an impediment to a free market. The benchmark price appears to amplify both downward and upward swings as evidenced over the past three years. 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.
• On October 30^th the stated total flock of 314.0 million, was up by 0.6 million from last week, including about one million molted hens that will resume lay during coming weeks plus 4.5 to 5.0 million pullets scheduled to attain production before the pre-Christmas surge in demand. Given the latest figures for depopulation in Utah, Washington State and Oregon it is estimated that the total flock is approximately 17 to 19 million hens lower than the 326 million before the onset of HPAI in 2022.
• The ex-farm price for breaking stock (rounded to one cent) was up a substantial 26.6 percent to $2.57 per dozen.Checks delivered to Midwest plants were up a noteworthy 30.3 percent to $2.41 per dozen this past week. Prices for breaking stock generally follow the wholesale price for shell eggs but with a lag of one to two weeks that may be shorter as in the present situation with an upward trend in price.

The Week in Review

Prices

According to the USDA Egg Market News Reports, released on October 28^th 2024, the Midwest wholesale price (rounded to one cent) for Extra-large was up 35.9 percent from last week to $4.02 per dozen. Large size was up 36.1 percent to $4.00 per dozen. Mediums were up 26.8 percent to $3.41 per dozen delivered to DCs.

The stock of Medium size was down 5.0 percent and the inventory of Small size was 2.9 percent lower over the past week suggesting pullet flocks placed for the November-December surge in demand have matured but with fewer younger pullets entering production. This has implications for prices during early November.

Prices should be compared to the USDA benchmark average 4-Region blended nest-run cost of 74.6 cents per dozen as determined by the Egg Industry Center based on USDA data for September 2024. This value excludes provisions for packing, packaging materials and transport, amounting to 57 cents per dozen as determined in mid-2023 from an EIC survey (with a low response) and now realistically 60 cents per dozen.

Currently producers of generic shell eggs should be operating with strong positive margins irrespective of region and customer-supply agreements. The progression of prices for loose eggs during 2023 and 2024 to date is depicted in the USDA chart reflecting three years of data, updated weekly.

The October 25^th edition of the USDA Egg Markets Overview confirmed that the USDA Combined Region value in cartons (rounded to the nearest cent), was up 78 cents per dozen (+34.6 percent) to $3.03 per dozen delivered to warehouses one week ago. The USDA Combined range for Large in the Midwest was $2.94 per dozen. At the high end of the range, the price in the South Central region attained $3.10 per dozen.

Flock Size 

The loss of 17.3 million hens from April through July 2024 should now be reflected in the most recent weekly data. The loss of approximately 2.8 million laying hens in Utah, Washington State and Oregon during mid-to late October may not be reflected in released USDA estimates of flock size. Any delay in posting accurate and updated data, during fall outbreaks, should be avoided given the importance of weekly flock numbers in pricing. Accurate and current values for both the producing and total flock are required by farmers, packers, breakers and buyers.

According to the USDA the number of producing hens reflecting October 30^th 2024 (rounded to 0.1 million) was up 0.5 million to 307.4 million suggesting that the rate of routine flock depletion and losses from HPAI is lower than the replenishment of flocks through molting and transfer of started pullets. The total U.S. flock includes about one million molted hens due to return to production Approximately 4.5 to 5.0 million pullets on average reach maturity each week, based on USDA monthly chick-hatch data for 20-weeks previously. The increase is offset by routine flock depletion and an additional loss of approximately 18 million hens due to HPAI through July and 2.8 million in October. Many flocks have been replaced on a rotational basis and routine flock depletion is delayed subject to availability of housing. Based on inventory level and prices, the population of hens producing table eggs and breaking stock should now be less than late October demand by consumers. Industrial and food service off-take is stable, attaining pre-COVID levels. Prices for shell eggs declined in August establishing a plateau in late September followed by a progressive rise through October to high seasonal levels before the anticipated post-Halloween increase.

According to the USDA the total U.S. egg-flock on October 30^th 2024 was 0.5 million higher at 314.0 million hens including a higher than normal proportion of second-cycle birds and started pullets. The difference between total and producing flocks was 6.6 million (rounded). Data for the past three weeks presumes that molted hens are resuming production. Given the season and the trajectory in benchmark wholesale prices, producers are retaining as many hens as allowed by capacity. At present it is estimated that there are approximately 17 to 19 million fewer hens in the total flock that now include cases of HPAI emerging in October. The apparent difference is equivalent to about 5.5 percent of the pre-HPAI 2022 national flock of 326 million hens.

INVENTORY LEVELS

Cold storage stock of frozen products in selected centers on October 28^th 2024 was 2.338 million lbs. (1,062 metric tons), up 1.0 percent from last week and 1.1 percent up from the 2.313 million lbs. on October 1^st 2024. The monthly USDA Cold Storage Report below quantified an increase in the actual total stock level at the end of August.

The most recent monthly USDA Cold Storage Report released on September 26^th 2024 documented a total stock of 29.3 million pounds (13,313 metric tons) of frozen egg products on August 31^st 2024. This quantity was down 9.1 percent from the August 31^st 2023 value of 32.2 million pounds. The August 31^st 2024 frozen egg inventory was up 1.3 percent from the previous month ending July 31^st 2024 attributed to presumably lower domestic demand, decreased exports or their combination. Compared to August 31^st 2023, the inventory of whites was down 19.2 percent to 2.18 million lbs. on August 31^st 2024. Compared to August 31^st 2023 yolk inventory was down 19.8 percent to 748,000 lbs. on August 31^st 2024.

A total of 88.7 percent (26.37 million lbs.) of combined inventory comprised the categories of “Whole and Mixed” (42.6 percent) and “Unclassified” (46.1 percent). The lack of specificity in classification requires a more diligent approach to enumerating and reporting inventory by the USDA as it appears that they have the makings of a giant omelet!

Shell Inventory

The USDA reported that the national stock of generic shell eggs effective October 28^th 2024 was down 0.7 percent over the previous week. Inventory over the past week followed a rise of 3.8 percent the previous week confirming increased demand by consumers through mid to late October. Combined with breaking stock, the total inventory of shell eggs in industry cold rooms is now at a rounded level of 1.59 million cases rounded (1.58 million last week; Up 10,300 cases). The U.S. population of laying hens at this time is influenced by:-

• Losses following outbreaks of HPAI with the depopulation of over 22.0 million hens since April 1^st. Losses are offset by approximately 22 million pullets transferred each month year-to-date
• The population unaffected by HPAI or fires.
• Flocks retained after molting with an anticipated increase in this category as influenced by prevailing wholesale egg prices, and indirectly responding to flock depopulation from HPAI.
• Started pullets from chick placements during May 2024. Going forward, younger hens will assume a larger proportion of the national flock as more flocks are placed compensating for the flocks depleted due to HPAI.

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

• The Midwest Region was down 1.5 percent from the previous week to 469,700 cases
• The Southeast Region was up 3.8 percent to 259,000 cases
• The South Central Region down 0.2 percent to 225,400 cases
• The Northeast Region was up 6.1 percent to 167,100 cases
• The Southwest Region was up 0.3 percent to 113,500 cases.
• The Northwest Region was up a substantial 25.4 percent but over a small base to 58,400 cases

The total USDA six-area stock of commodity eggs comprised 1,585,400 cases (1,575,100 cases last week), up 0.7 percent, of which 81.6 percent were shell eggs (80.6 percent last week). The inventory of breaking stock was down 4.4 percent to 292,400 cases. Shell-egg inventory was up 1.9 percent attaining 1,293,000 cases. These changes are a function of regional shell-egg demand. Reoccurrence of HPAI affecting egg-production complexes in three states and a large broiler farm in California may influence buyers who were previously unconcerned over short-term supply.

The average price for Midwest breaking stock was up 26.6 percent last week and checks were up 30.3 percent. The average price for breaking stock and checks combined was equivalent to 62.1 percent of the average value of Midwest Extra-large and Large shell eggs, (65.9 percent last week) consistent with the differential in prices for shell eggs (up 36.1 percent) compared to a disproportionately lower price rise of 22.0 percent for breaking stock and checks combined this past week. The differential of 65.9 percent can be compared to 80.0 percent in April 2022 reflecting the initial period of high demand for both shell eggs and products following losses due to HPAI at the onset of the epornitic. The sharp increase in price demonstrates the respective demands for shell eggs and egg products (inventory down 4.4 percent this past week) confirming the interconnectivity of the packing and breaking segments of the egg industry under circumstances of extreme disturbances in either supply (lower due to HPAI in 2022) or demand (higher during early COVID in 2020). The relative prices for breaking stock and checks are influenced by the actual demand for generic shell eggs and contract obligations with breakers.

On October 28^th 2024 the inventory of other than generic eggs amounting to 425,800 cases (up 0.9 percent from last week at 429,600 cases) among three categories (with the previous week in parentheses) comprised: -

• Specialty category, down a substantial 14.3 percent to 33,800 cases. (was up 17.9 % to 39,400 cases) due to heavy promotion and a rise in the price of generics
• Certified Organic, up 3.4 percent to 68,400 cases. (was up 2.5% to 66,700 cases)
• Cage-Free category, down 0.1 percent to 323,400 cases. (was up 8.3% to 324,000 cases)

Existing and proposed individual state legislation mandating sale of only cage-free eggs will support most of the completed and in-progress transition from cages but significant additional re-housing will not be completed by the beginning of 2025, now three months away and obviously never, as projected previously by most industry observers. The constitutional status of Proposition #12 was confirmed by SCOTUS in a May 11^th 2023 decision with specific reference to the Dormant Commerce Clause relating to interstate trade. Legislation rolling back California Proposition #12 (‘EATS Act”) will probably not be incorporated into the delayed 2023 Farm Bill. Many retail chains are ‘renEGGing’ on or extending their time commitments to achieve an acceptable transition to cage-free eggs despite coercion by animal welfare groups.

Consumers 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 conditions of supply and demand. Similarly, consumers will traditionally purchase white-shelled generic eggs in preference to white or brown-shelled cage-free with a differential of over $1.20 per dozen.

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 using conjoint analysis. Above all, agricultural economists should evaluate the impact of disruption in supply and demand arising from large-scale depopulation following the 2015 and 2022-2024 HPAI epornitics including the late spring to early summer wave of outbreaks.

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

RELATIVE PRICES OF SHELL-EGG CATEGORIES

USDA-AMS posted the following national shell egg prices as available, on October 25^th 2024 for the preceding week in the Egg Markets Overview report representing dozen cartons with comparable prices in parentheses for the previous week: -

Advertised Retail Prices

Large, in cartons generic white: $2.32 Up 5.5 percent ($2.20)

Large, in cartons cage-free brown: $3.06 Down 7.6 percent ($2.86)

Wholesale

Midwest in cartons $2.94 Up 31.3 percent ($2.17)

Large C-F, California in Cartons: $4.84 Up 67.5 percent ($2.89)

National loose, (FOB dock): $3.66 Up 37.5 percent ($2.66)

NYC in cartons to retailer: $4.30 Up 36.1 percent ($3.28)

Regional in cartons to warehouse reported October 25^thfor the previous week.

Midwest $2.16 Up 36.1percent ($2.16)

Northeast $2.99 Up 35.3 percent ($2.21)

Southeast $3.08 Up 33.9 percent ($2.30)

South Central $3.10 Up 33.6 percent ($2.32)

Combined $3.03 Up 34.7 percent ($2.25)

 USDA has failed to post data on specific categories of eggs since October 16^th.  This section will be restored when data is available.

USDA Cage-Free Data

According to the latest monthly USDA Cage-free Hen Report released on October 1^st 2024, the number of certified organic hens in September was higher by 6.5 percent from August 2024 to 20.8 million, (rounded to 0.1 million) representing the differential between replacements and scheduled flock depletions combined offset by previous flock depopulation due to HPAI.

The USDA reported that the cage-free (non-organic) flock in September 2024 was up 2.9 percent from August 2024 to 106.9 million, (rounded to 0.1 million).

According to the USDA the population of hens producing cage-free and certified organic eggs in September 2024 comprised: -

Total U.S. flock held for USDA Certified Organic production = 20.8 million (20.0 million in Q3 2024).

Total U.S. flock held for cage-free production = 106.9 million (103.9 million in Q3 2024).

Total U.S. non-caged flock = 127.7 million (123.9 million in Q3 2024).

This total flock size represents 39.1 percent (August 37.9 percent) of a nominal 326 million total U.S. flock pre-HPAI in 2022 but 41.3 percent of the national flock after HPAI mortality to a presumed complement of 303 million in production. 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 was previously questioned given a history of either constant numbers or a sharp change in successive months as documented over the past two years. It is presumed that the October release reflects a realistic number of producing hens housed cage-free during August 2024. Precise quarterly reports would be more suitable for the industry in planning expansion and allocation of capital than inaccurate monthly values.

Processed Eggs

For the processing week ending October 26^th 2024 the quantity of eggs processed under FSIS inspection during the week as reported on October 30^th 2024 was down 1.2 percent compared to the previous processing week to a level of 1,404,927 cases, (1,421,287 cases last week). The proportion of eggs broken by in-line complexes was 54.4 percent (52.7 percent processed in-line for the previous week). Diversion to higher-priced shell markets continues by uncommitted producers. The differential in price for shell sales and breaking will determine the movement of uncommitted eggs. This past week 71.6 percent of egg production was directed to the shell market, (71.9 percent for the previous week), responding to the differential in prices paid by breakers and packers. Breaking stock inventory was down 4.4 percent this past week to 292,400 cases. Apparent demand from QSRs and casual dining is at stable to slightly lower levels. There is ongoing demand from baking and eat-at-home despite the weekly fluctuation in the inventory of breaking stock. During the corresponding processing week in 2023 in-line breakers processed 53.3 percent of eggs broken.

For the most recent monthly report reflecting September 2024, yield from 6,098,319 cases (5,551,343 cases in August) denoted a decrease in demand for liquid and more diversion to shell egg sales over the period September 1^st 2024 through September 28^th 2024. Edible yield was 39.1 percent, distributed in the following proportions expressed as percentages: liquid whole, 61.2; white, 23.7; yolk, 11.9; dried, 3.1.

All eggs broken during 2023 attained 69.78 million cases, 8.4 percent less than 2022. Eggs broken in 2024 to date amounted to 61.47 million cases, 5.2 percent less than the corresponding period in 2023. Weekly changes are attributed to fluctuations in demand for egg liquids from retail, food service and QSRs and casual dining restaurants. Consumers are constrained by economic uncertainty following the ending of COVID support, high credit card interest rates, mortgage repayments or rent and a tendency to purchase only essentials.

PRODUCTION AND PRICES

Breaking Stock

The average rounded price for breaking stock was up 26.6 percent this past week to $2.57 per dozen with the most frequent range of $2.54 to $2.60 per dozen delivered to Central States plants on October 28^th. The price of checks was up 30.3 percent this past week at an average of $2.41 per dozen over the most frequent range of $2.40 to $2.42 per dozen. The market for breaking stock this week led prices for shell eggs in both timing and value with a sharp upward swing.

Shell Eggs

The USDA Egg Market News Report dated October 28^th 2024 confirmed that Midwest wholesale prices for Extra-large and Large were up 35.9 and 36.1 percent respectively from last week and Medium size was up 26.8 percent from the previous week. A 1.9 percent higher shell egg inventory, with a rising benchmark price, suggests that the market is operating with increased demand relative to supply. The following table lists the “most frequent” ranges of values as delivered to warehouses:-

The October 28^th 2024 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 up 34.1 percent from last week, (with the previous week in parentheses): -

1. $4.01 ($3.02), (estimated by proportion): L. $3.97 ($2.96): M. $3.36 ($2.64)

The October 28^th 2024 California negotiated 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 up 33.6 percent from last week, partly due to increased demand with supply still limited by depopulation. A third of the laying hens in the state were lost during the 4^th quarter of 2023 but offset by replacement pullets albeit with lower availability of eggs from Midwest and Southwest supplying states. In August the hen population increased to 8.50 million from 8.19 million in July but compared to 10.3 million in July 2023.

1. $4.92 ($3.70); L. $4.85 ($3.63); M. $4.56 ($3.44)

Shell-Egg Demand Indicator

The USDA-AMS Shell Egg Demand Indicator reported on October 30^th 2024 was down 1.5 points from the last weekly report to -0.5 with a 0.7 percent increase in total inventory and a 1.9 percent higher shell inventory from the past week as determined by the USDA-ERS as follows: -

The USDA Monthly Report covering August 2024 production including text, tables, data and prices and the Q1 FY 2025 financial results for Cal-Maine Foods can be accessed under the STATISTICS tab.

Egg Products

Again the USDA did not release complete data for egg products for the past week. 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. This situation is unacceptable given the extent of trading and the resources of the USDA.

Dried Egg

The stated range in prices for dried whole egg and yolk products in $ per lb. was not released for the most recent week ending October 28^th. Values over past months illustrate the trend in prices influenced by HPAI depopulation and subsequent re-population:-

Frozen Egg

On October 25^th the USDA posted the range in prices for frozen whole egg for the previous week. Prices in cents per lb. are shown for products during the previous week:-

1. Extreme range

In the absence of data it is not possible to assess demand for categories of egg products by the manufacturing, food service and export sectors. Since trading is occurring USDA should be able to ascertain and post prices.

September averages (August): Whole. $1.87, ($2.27); Whites, $1,35, (N/A); Yolks, $2.64, ($2.55).

Liquid Egg

October 25^th values for Whites and Yolks covering certified truckload quantities have been released at irregular intervals over past months. The release for whole egg was 185 cents per lb. was for the current week compared to the previous week at 138 cents per lb. September values (in parentheses) were: -

Whole, $1.44, ($1.89); Whites, $0.96 ($1.32); Yolks, N/A, ($2.29). (certified product)

COMMENTS

An egg-production complex with 800,000 birds was diagnosed with HPAI in Clackamus County, an area of high poultry density in central Oregon this past week. During mid-October concurrent outbreaks of HPAI H5N1 occurred in commercial flocks under common ownership in Utah (bovine-origin strain) and Washington State (avian-origin strain). Two incident cases were diagnosed in broiler flocks in Kings County and one in Tulare County. Outbreaks among backyard flocks in Oregon, Washington State and Idaho in recent weeks suggest dissemination by waterfowl commencing their southward migration. The frequency of reports however reflects surveillance intensity. The H5N1 strain B3.13 infection in dairy herds now been recognized as bovine influenza-A affecting approximately 388 diagnosed dairy herds in fourteen states with cases rising to 186 in California mainly in the Central Valley. Given the prevailing risks and consequences of infection it will be necessary to intensify structural and operational biosecurity in poultry operations with anticipated exposure from November onwards depending on weather patterns and temperature in all four fly zones. Incident outbreaks might be anticipated from domestic resident birds and spillover from dairy operations coincident with southward migration that is underway.

Approximate losses in commercial flocks confirmed with HPAI and updates during the 2022/3 phases of the current epornitic included:-

• 6,900,000 broilers on 28 farms in 8 states during 2002 - 2023
• 330,000 broiler breeders on 11 farms in 6 states.
• 360,000 upland game birds October through December 2023.
• 14,100,000 turkeys including breeder flocks in 8 states during 2022 and through 2023 year-to-date.
• 52,300,000 egg-production hens in total with 95 percent on 37 large complexes above 0.5 million in addition to 3,500,000 pullets with a total of 54 locations in 12 states. Pullet mortality does not include “at risk” replacements depleted on affected complexes with contiguous pullet rearing. During the fourth quarter of 2023 more than 13.0 million hens were depopulated in 13 outbreaks.

Losses reported in 2024 to date include:-

• 19 million egg-producing hens and 1.5 million replacement pullets
• 4 million commercial meat turkeys
• 7 million broilers
• Various semi-commercial flocks and game-birds

Backyard flocks (non-WOAH) allowed outside access will continue to be at risk of infection in the U.S. These small clusters of birds in both suburban and rural areas are of minimal significance to the epidemiology of avian influenza as it relates to 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 late 2023- 2024 epornitic evidently had a long tail. Recent outbreaks in backyard flocks especially in northern tier states suggest shedding by resident, non-migratory free-living birds that may have become reservoirs. This has implications for seasonality and endemnicity.

It is hoped that APHIS recognizes the need to provide the industry with science-based recommendations to prevent additional incident HPAI outbreaks. This presumes prompt analysis and reporting of whatever field and molecular epidemiology is collected and processed. APHIS is presumed to have planned epidemiologic field studies and allocated personnel and other resources in anticipation of a fall 2024 resurgence in HPAI. Large complexes in six states were infected during November and December 2023 and again in April, May, July and October 2024. Accordingly appropriate guidance from USDA-APHIS is anticipated by the Industry before more incident cases are diagnosed. A release on the investigation of risk factors associated with outbreaks in dairy herds and a comment on the specifics of mutations that have occurred in viruses isolated from infected animals and the serologic status of workers in contact with infected flocks would be informative.