#### Waialua Fresh %%[[villa rose policy]]%% Villa Rose LLC's pursuit of favorable policy in Hawaii's egg industry demonstrates how sharetakers leverage regulatory frameworks to consolidate market power and eliminate competition. From 2021 to 2022, the company deployed offensive advocacy to mandate competitor-eliminating standards through cage-free requirements. When community groups introduced measures to regulate concentrated animal feeding operations (CAFOs) and reform Right-to-Farm protections in 2023-2025, Villa Rose shifted to defensive lobbying to block regulations that would constrain its own operations. The company's hiring of former state Department of Agriculture Chair Scott Enright as their lobbyist exemplifies the revolving door between state agencies and corporate interests. Enright had directly facilitated Villa Rose's development while serving as Hawaii Department of Agriculture Chair, then represented the company in blocking regulations that would apply the same scrutiny to their operations that they had sought to impose on competitors. This case reveals how contemporary agribusiness firms strategically deploy seemingly progressive causes like animal welfare, food security, and environmental sustainability to create insurmountable barriers for competitors while protecting themselves from regulatory scrutiny. Unlike historical plantation interests that relied on political dominance and labor coercion, sharetakers deploy capital investment as both promise and threat, co-opt advocacy organizations to provide grassroots legitimacy, and exploit regulatory ambiguity to claim compliance with undefined standards while blocking protections for others. ##### Hen Pecking at Cage Free and CAFOs Animal welfare bills generally hatch from the likes of PETA, inflaming the green blood cells of industrial and corporate animal agricultures to crow in opposition. In 2021 however, Hawaii's Senate Bill 346 Relating to Farm Animals (SB346) found the Humane Society of the United States (HSUS) and Villa Rose LLC sharing a coop. These unlikely allies in the pursuit of animal rights were joined by a legion of island organizations and residents to pursue mandatory welfare standards for egg-laying hens. The measure would set a date after which cage-free hen housing would be mandatory. This was not the first engagement between HSUS and eponymous Villa Rose LLC partner Rose Acre Farms. In 2010, an HSUS undercover investigation of a Rose Acre facility in Iowa [@piper_2020] led to a Federal Trade Commission (FTC) complaint against the firm for deceptive marketing around animal welfare. HSUS argued Rose Acre's adherence to United Egg Producers (UEP) guidelines was insufficient to warrant their claims. Similar efforts by HSUS and partners led to changes in animal confinement laws in multiple US states [@shields.etal_2017] while battling the tide of ag-gag laws that endeavored to foreclose on such investigations and animal rights protections. Battled that is until 2011, when UEP and HSUS announced a surprising detente. HSUS would suspend their Washington and Oregon ballot initiatives and undercover initiatives while the duo would collectively pursue federal legislation to phase out battery cage production [@neuman_2011; @greene.cowan_2012]. Additional amendments to the Egg Products Inspection Act would nationally mandate egg carton labeling with production type and establish minimum space per hen. After years of enmity, the agreement stunned the agricultural community [@greene.cowan_2012], however the maneuver was far from universally lauded. Egg Farmers of America, representing many smaller egg producers, vehemently opposed the legislation [@okeefe_2012]. Cost was a key factor, with one Minnesota farmer estimating upgrades to new "enriched cages" potentially saddling his 300,000-hen operation with $8 to 9 million in conversion costs [@greene.cowan_2012]. Beyond finances, the partnership also effectively created another moat for UEP members. HSUS agreed to forestall backing litigation or investigations of UEP or its members while the agreement was in place. No similar protections was afforded to the remainder of the industry, adding potential legal costs to the already out of reach conversion costs for smaller operations. The HSUS-UEP partnership pursued a legal environmental to restructure the competitive landscape by forcing smaller producers to go big, go under, or undergo investigation. Despite two years of lobbying, the federal measures failed in Congress. Opposed by beef and pork trade associations concerned that animal production practice regulation could spread to their industries [@gonzalez_2014], the partnership ended in 2014 and HSUS pivoted towards corporate social responsibility campaigns [@shields.etal_2017]. ##### Birds of a Feather: [[SB346 2021 farm animals |SB 346 (2021)]] By 2021, the egg production of UEP members Hidden Villa Ranch and Rose Acre Farms own collaboration Villa Rose LLC was ramping up in the islands [@heaton_2021]. Hawaii's Senate Bill 346 Relating to Farm Animals (SB346) proposed to prohibit businesses from selling eggs produced by hens "confined in a cruel manner", defined as confinement in enclosures providing less than one to one and a half square feet per hen (depending on "unfettered access to vertical space"). Akin to the federal amendments, the measure would set a date after which this "cage-free" hen housing would be required. The rule would apply to operations with flocks of ten thousand or more hens, and non-compliance would yield $500 to $1,000 fines. Hawaii has no existing egg-laying hen confinement standards. While each state prohibits animal cruelty, most have some form of exemptions for common animal husbandry practices [@animalwelfareinstitute_2022]. Hawaii's animal cruelty statutes do not explicitly provide such exemptions. The laws focus on pets and equine animals [@hrs_711-1108.5], even when addressing confinement [@hrs_711-1109]. The hen confinement standards in SB346 were strongly supported by HSUS, whose testimony affirmed not just their support of measure, but of Villa Rose, and curiously on behalf of Villa Rose as well: > Due to an emergency, Villa Rose’s representative was unable to provide testimony for this hearing. But the company has stated if SB 346 passes, it will be able to move forward with fulfilling their $100M investment and the construction of 24 additional cage-free barns in Hawaii. [@balk_2021] HSUS's testimony continued with Villa Rose talking points from bolstering food supply to achieving Hawaii's sustainability goals, including job creation projections and infrastructure benefits. HSUS framed the bill as ensuring Hawaii produced eggs "meet the egg industry's own cage-free guidelines," asserting that Villa Rose and Hawaii's other egg producers needed the assurance of "regulatory certainty" to justify their investments [@balk_2021]. Though uncommon, testimony on behalf of other organizations does occur. While HSUS testimony largely focuses on the efforts and (potential) impacts of a single firms activities, it also stated that "\[a]ll of Hawaii’s main egg producers ... support the bill because it adopts the egg industry’s own guidelines for cage-free standards and bolsters the reputation of agribusiness" [@balk_2021]. Not all of Hawaii's main egg producers agreed. Recognizing the competitive threat these standards posed, both Hawaiian Egg Company and Peterson's Upland Farm LLC opposed the measure during its first committee during. Originally introduced with a 12/31/25 effective date, a later draft set 6/30/27 as date when businesses would be prohibited from "selling shell eggs or egg products that are produced by egg-laying hens that were confined in a cruel manner" [@sb346sd2_2021]. This deadline amendment, requested by Hawaiian Egg Company, passed during the second Senate committee hearing. However, after crossing to the House of Representatives, the measure failed to receive a hearing by the House Committee on Agriculture. ##### Return to the Roost: [[SB2977 2022 Egg-laying Hens|SB2977 (2022)]] Unthwarted, the nearly identical Senate Bill 2977 Relating Egg-laying Hens was introduced in the 2022 legislative session [@sb2977_2022]. Villa Rose's testimony, this time provided by their own representative echoed their proxy delivered sentiments from SB346. The firm's written testimony placed the balance of their $100 million investment, scaling to 24 additional barns, and 700% increase in their production in the balance, adding that the company needed the certainty of a "business-friendly regulatory framework" [@kato_2022, p. 1]. Along with a troop of animal rights groups, HSUS again testified in support, though this time without single mention of Villa Rose [@balk_2022]. Villa Rose was the only testifier who explicitly invoked Hawaii's food security in their argument. The most salient opposition testimony came from Marcia Peterson of Peterson's Upland Farms. In her written submittal, she outlined how the cost of cage modifications would be economically devastating to island egg farms, noting the possible timeline of "25-30 years for a farmer to recoup such a massive investment" [@peterson_2022]. Peterson's testimony revealed the strategic asymmetry Villa Rose sought to create—mandated capital expenditures that only well-capitalized operations could absorb. Additional opposition came from the HDOA, Hawaiian Egg Company, Hawai‘i Farm Bureau, and Hawaii Food Industry Association [@aen2601_2022]. Despite these government and industry concerns the bill passed its first committee. In the second senate committee's hearing Villa Rose repeated their testimony. [@ccpjud2982_2022]. Again, despite continued government and industry concern, the measure passed in the senate crossed over to the house. SB2977 ended with the same fate as the prior years efforts and did not receive a hearing by the House Committee on Agriculture. Similar to the two-year federal effort of HSUS-UEP, no similar bill was introduced in 2023. As Villa Rose's production scaled up, their operations drew attention beyond the egg industry. Community and environmental advocates focused on the implications of industrial-scale animal agriculture itself. ##### Turning the Tables: [[SB1585 2023 animal agriculture|SB1585 (2023)]] In 2023, Senate Bill 1585 (SB1585) Relating to Animal Agriculture proposed both a prohibiting new and a phasing out existing concentrated animal feeding operations (CAFOs) by 2028. The bill cited risks to public and environmental health from CAFOs, including a Hawaii Island dairy that despite litigation released millions of gallons of wastewater into streams and the ocean [@sb1585_2023]. The Center for Food Safety and Good Food Movement, national and local organizations, respectively, rallied support behind the measure. [@goodfoodmovement_2023a]. Unlike the animal welfare measures that targeted competitors while exempting Villa Rose, SB1585 threatened their own operations. The company's response elevated past HSUS or their own staff for advocacy needs. Villa Rose LLC hired Scott Enright [@ethicsenrightvl_2023], who had been Chair of the Hawaii Department of Agriculture (HDOA) from 2014-2018. While serving as HDOA Chair, Enright worked with the Villa Rose partners developing the then fledgling Oahu egg farm project [@shimogawa_2015]. In 2015, Hidden Villa Ranch executive Michael Sencer explained that "while the size of the project has not yet been determined, we believe a project that increases employment and produces fresher food to the marketplace helps advance the goals of the Department of Agriculture" and that "with the guidance of the Department of Agriculture, we continue to believe this project has a high probability of success" [as quoted in @shimogawa_2015]. Enright's testimony argued that "not all CAFOs are created equal" emphasizing Villa Rose as a "state of the art solar powered egg farm" [@enright_2023]. The $100 million investment figure included in every prior Villa Rose testimony wasn't part of Enright's remarks. Instead, Enright's written testimony framed operation as a substantial local investment, warning that phasing out existing CAFOs "would potentially constitute a regulatory taking necessitating due compensation" [@enright_2023]. This rhetorical shift reframed the company's capital from a promised economic benefit to an implicit threat of legal liability should the state dare to regulate. During the Senate Agriculture and Environment Committee hearing, Enright elaborated on this position, contrasting Villa Rose's "21st century technology" CAFO with "smaller operations that don't become CAFOs that are worse offenders in terms of pollution and noise and nuisance because they don't have the capital" [@aen02-15_2023]. He argued the bill removed "the protections of Right-to-Farm from animal agriculture that gets done at scale, which is CAFOs" and would hinder Villa Rose's expansion plans "at a time when we can't find eggs on the shelf" [@aen02-15_2023]. Committee Chair Senator Mike Gabbard shared that 89 testimonies were submitted in support, with 11 in opposition [@aen02-15_2023]. Of those many in support, HSUS was not among them. Of the animal rights organizations who had testified in support of the 2021 and 2022 cage free measures, only Hawaiian Humane Society and Animal Rights Hawai'i weighed in on SB1585. During committee questions, HDOA was unable to answer how many CAFOs operate within the state. In this context of regulatory ambiguity, Vice Chair Senator Richards raised concerns about the bill's broad approach, drawing comparisons between CAFOs and range management practices like high-density rotational grazing. He stated "we're striving for food security in this state ... so I'm bothered by this because I think it sends us down a slippery slope" [@aen02-15_2023]. The measure failed in the Senate Agriculture and Environment Committee with a 3-2 vote against [@sb1585_2023]. Enright's testimony had positioned Right-to-Farm laws as essential for industrial operations, raising questions about the scope and application of these agricultural liability protections, and whose interests they serve. ##### Whose Right-to-Farm? [[SB240 2025 Right to Farm|SB240 (2025)]] Right-to-Farm laws, enacted across all 50 states beginning in the 1970s, were originally designed to protect agricultural operations from nuisance lawsuits as suburban development encroached on farmland. In a nationwide analysis, @ashwood.etal_2023 examined Right-to-Farm laws and associated litigation involving disputes between agricultural operations and neighboring property owners, community groups, or government entities over odor, pollution, noise, and health concerns. Their findings revealed significant disparities: large-scale agricultural operations and agribusiness corporations prevailed in nearly 70% of cases, while sole proprietor farmers won only 41%, the lowest success rate among all party types. Homeowners and residents fared similarly, winning 42% and 54% of cases respectively. Local governments seeking to regulate agricultural operations won 65% of cases, though governmental wins often occurred where operations failed to meet existing regulatory standards rather than where communities successfully imposed new restrictions on industrial agriculture [@ashwood.etal_2023]. Hawaii's Right to Farm Act became law in 1982, joining 31 other states with similar legislation [@ashwood.etal_2023; @kato_1982]. The Hawaii Farm Bureau Federation championed the measure to address what one senator described as farms being driven "from one end of the Island to another" due to conflicts with new neighbors [as quoted in @altonn_1982]. The bill passed in its first year. The act's stated purpose addresses conflicts arising when urban or non-agricultural development expands into agricultural regions, exposing farming operations to nuisance lawsuits [@hrs_165]. Citing that such lawsuits could discourage future agricultural investments and force farms off the land, the law significantly curtails the circumstances under which a farming operation could be deemed a nuisance Under the act, if a farm operation is conducted consistent with "generally accepted agricultural and management practices," there is "a rebuttable presumption that a farming operation does not constitute a nuisance" [@hrs_165]. This places the burden of proof onto the plaintiff, not the farm to defend itself.   More directly, farming activities are *de jure* lawful under the Right-to-Farm statute unless proven abusive, and *de facto* insulated from legal challenge harmful practices considered standard industry practice. Ashwood et al. found Hawaii's Right-to-Farm law "provided no explicit protection for farmland," functioning instead as a liability shield that protects agricultural operations from nuisance claims even as "the number of acres in farmland has dropped" substantially since enactment [[email protected]_2023, p. 81]. Their work outlines two cases where Hawaii courts found the statute shielded a multinational agribusiness engaged in chemical-intensive and genetically modified seed production from nuisance claims. In both cases, neighboring residents and landowners alleged that chemical exposure and fugitive dust from industrial seed operations negatively impacted their quality of life. While the courts found these claims credible enough to proceed, decisions ultimately favored the corporate defendant. In an earlier study, Ashwood et al. [[email protected]_2019] demonstrate how the statute's use of terms like "generally accepted" for agricultural and management practices vests definitional power in the industrial agriculture sector itself. The court in _Aana v. Pioneer Hi-Bred International Inc._ (2014) exemplified this circularity by dismissing nuisance claims on grounds that pesticide use was "consistent with generally accepted agricultural or management practices", a standard determined by the very industry being challenged. The use of the term "generally accepted" as a measure, paired with the rebuttable presumption, thus shifts risk away from producers toward neighboring communities while limiting local regulatory authority. **In 2025**, Senate Bill 240 Relating to the Right to Farm (SB240) sought to reconsider the scope of these protections [^sb240disclosure]. [^sb240disclosure]: As Advocacy Director for the Hawaii Farmers Union, I drafted and secured introduction of this bill, inspired by the research findings of @ashwood.etal_2023 [@sb240_2025]. The measure would redefine which farming operations qualified for protection, explicitly adding protection for customary and traditional production practices while explicitly excluding operations with non-transparent ownership structures as well as CAFOs from protection by default. During the first and only hearing the bill received, testimony was scant. While all reviewed testimony that spoke to customary practice inclusion were in support of the idea, perspectives on the remaining provisions fell along predictable lines. Community and animal rights advocacy organizations and individuals testified in support of reducing corporate protections. Industry and trade organizations, namely the Hawaii Crop Improvement Association, Biotechnology Innovation Organization, Hawaii Farm Bureau, and Hawaii Cattlemen's Council, testified in opposition, deploying food security rhetoric to defend existing protections [@aenhwnsb240_2025]. The testimony invoked challenges facing commercial agriculture, an aging farmer population and declining interest among younger generations, to assert the state needs "all types and sizes of farms" to expand production. Hawaii Farm Bureau framed the bill as a threat to the state's food supply, arguing that "while Hawaii is struggling to meet its local food production for self-sufficiency," the bill "seems very inappropriate at this time." Hawaii Cattlemen's Council similarly argued that "keeping these options open but ensuring the regulations are enforced can be a good way for us to help reach local food production goals." Villa Rose again retained Enright as their lobbyist [@ethics8885_2025]. His written testimony again made the case that "not all CAFO's are created equal, ours at Villa Rose is a credit to the state of Hawaii" and that expansion plans could be jeopardized by the measure if passed [@enright_2025]. His oral testimony repeated the now-familiar refrain that "not all CAFOs are created equal" and positioned Villa Rose's facility as having "21st century technology" that does things "the right way" [@aenhwn01-24_2025]. Contrasting his client with "smaller operations that don't become CAFOs that are worse offenders in terms of pollution and noise and nuisance because they don't have the capital," Enright invoked immediate food scarcity: "at a time when we can't find eggs on the shelf, we're gonna tell them we're gonna remove protections from them." He argued the bill would hinder Villa Rose's expansion plans and noted that his other client, Meadow Gold Dairy, "would like that capability going forward" to potentially expand into CAFO status [@aenhwn01-24_2025]. The hearing also surfaced a constitutional tension and significant regulatory gap in Hawaii's Right-to-Farm framework. Senator Keohokalole questioned whether the bill's protecting Native Hawaiian customary farming was even necessary, noting these rights are already established in the state Constitution [@aenhwn01-24_2025]. He expressed concern that the bill could create "a framework where the Department of Ag would be required to sit in judgment of who is a Hawaiian farmer or not, when, if a Hawaiian farmer can already go to any court and assert their constitutional right" [@aenhwn01-24_2025]. Department Chair Sharon Hurd's response outlined a bureaucratic process such statutory protection could require. She stated the department would need to determine how customary practices comply with the Hawaii Right to Farm Act, and proposed conducting a study to determine "what those practices are and how they would be protected by Chapter 165" [@aen01-24_2025d] This was particularly significant given HDOA's written testimony that no GAAMPs (generally accepted agricultural and management practices) currently exist in Hawaii; not for customary farming, not for CAFOs, not for any agricultural operation. As Hurd testified, "there's no definition for the state, and presumably the definitions will be part of the discussion" [@aenhwn01-24_2025]. The department wrote they "may be receptive" to protecting customary farming only if proven "equivalent to a commercial agricultural, silvicultural, or aquacultural facility or pursuit", yet offered no timeline for establishing the baseline standards against which such equivalence would be measured [@hdoa-sb240_2025]. Meanwhile, operations like Villa Rose continued claiming adherence to unspecified "best practices" and "21st century technology" without any defined GAAMPs to substantiate such claims. HDOA's written testimony stated they "would support a study to investigate what would be the appropriate content of GAAMPs for application throughout Hawaii" but expressed "strong concerns" about the bill's approach, preferring instead a "uniform statewide application" modeled on Michigan's system. Under that model, GAAMPs are developed by "advisory committees comprised of subject area specialists from universities, USDA-Natural Resources Conservation Service, State environmental programs, farm organizations, and farm operations" with "little, if any, county/local government input and very limited participation by non-agricultural/non-governmental organizations" [@hdoa-sb240_2025]. The bill was indefinitely deferred by the Committee on Hawaiian Affairs. Chair Richards cited the constitutional concerns raised by Senator Keohokalole regarding Native Hawaiian farming protections, testimony from "bonafide agricultural experts" on agricultural development, and agreement with some concerns in the bill while disagreeing that SB240 was the appropriate vehicle to address them. ##### Coming Home to Roost: Policy as Market Consolidation Villa Rose's policy campaign demonstrates how contemporary agribusiness firms employ regulatory strategy as a market power mechanism, strategically weaponizing progressive policy causes to restructure competitive landscapes in their favor. The company's approach divided into clear offensive and defensive phases: first weaponizing animal welfare advocacy to impose capital-intensive requirements on competitors (2021-2022), then deploying professional lobbying and legal threats to shield their own operations from regulation (2023-2025). Throughout both phases, Villa Rose consistently framed their operations as advancing state goals—invoking food security during egg shortages, sustainability through solar-powered facilities, and local production through employment promises. This rhetorical strategy positioned their private profit-seeking as public benefit, making opposition appear against animal welfare or food security. Peterson's Upland Farm testimony quantifying the 25-30 year cost recovery timeline exposed cage-free mandates as intentional barriers to entry rather than genuine welfare improvements—compliance requirements that only well-capitalized operations could absorb. Villa Rose's 2021 and 2022 testimony framed policy certainty as a precondition for their investment—but this reverses the actual logic at work. Traditional agricultural development sees operations expand based on market conditions, with policy following to regulate existing activity. Villa Rose sought the opposite: policy that would manufacture favorable market conditions before they committed capital. Their $100 million investment promise wasn't contingent on regulatory stability but on regulations that would eliminate competitors. The cage-free mandate wasn't a request for clear rules; it was a demand that the state clear the competitive field. When Villa Rose entered the Hawaii egg market, they intended to enter a market they had already captured through policy—not one they would have to compete in. Villa Rose's rhetorical flexibility—from promising $100 million investments contingent on favorable regulation to threatening regulatory takings claims when facing restrictions—demonstrates how financial scale itself becomes a policy tool. This represents a scalar shift in governance: decision-making power flows not from democratic participation or local accountability, but from the capacity to deploy capital as both carrot (promised investment) and stick (litigation threat). The alliance with HSUS illustrates how corporate actors co-opt social movement organizations to provide grassroots legitimacy while pursuing fundamentally anti-competitive objectives. HSUS's willingness to testify on Villa Rose's behalf during cage-free advocacy, combined with their silence on comprehensive CAFO regulation, exposed these advocacy partnerships as transactional arrangements that advance corporate consolidation under the banner of animal welfare. The failure of HSUS and UEP to enact federal measures left a patchwork of state-level regulatory environments, making state-by-state advocacy viable for well-resourced parties. Villa Rose could later exploit this fragmented regulatory landscape, and Hawaii's lack of any applicable confinement laws, to fill the regulatory vacuum with definitions that suited their aims. %%ambiguity theme%% With SB346 (2021) and SB2977 (2022) Villa Rose wasn't seeking compliance with UEP guidelines but authorship of the only rules that would exist—standards they already met and competitors could not afford to adopt. Enright's revolving-door lobbying exemplifies regulatory capture mechanisms spanning the entire project timeline. As HDOA Chair, Enright provided "guidance" for Villa Rose's development, with Hidden Villa Ranch executives citing departmental support as key to their project's viability. Years later, as Villa Rose's hired lobbyist, Enright leveraged that insider knowledge and relationships to shield his former collaborators from regulatory oversight. His testimony positioning Villa Rose's industrial-scale CAFO as superior to smaller operations because of capital access inverted democratic accountability—arguing that only those with sufficient financial resources should be permitted to farm at scale. The state's regulatory architecture itself enabled Villa Rose's strategic maneuvering through multiple forms of ambiguity. HDOA's inability to identify how many CAFOs operate in Hawaii during SB1585 hearings revealed a fundamental lack of baseline data about industrial agriculture's scope. The complete absence of defined GAAMPs meant no measurable standards existed against which any agricultural operation's practices could be evaluated, yet Right-to-Farm protections applied nonetheless. When community advocates sought to extend those protections to customary farming, HDOA proposed extensive studies and compliance frameworks—bureaucratic gatekeeping never required of existing industrial operations. The department's preference for industry-dominated GAAMP development processes, explicitly limiting participation by non-agricultural organizations and local governments, demonstrated how regulatory ambiguity serves to concentrate power. These overlapping gaps—in data collection, standards definition, enforcement capacity, and participatory processes—created an operational environment where large-capitalized firms could claim adherence to undefined best practices while smaller operations faced regulatory uncertainty. This regulatory vacuum functions not as administrative oversight but as structural advantage for well-capitalized actors capable of navigating ambiguity through professional lobbying and legal resources. The 2025 Right-to-Farm hearing revealed how the absence of defined standards functions as a form of regulatory privilege. While HDOA proposed studies, compliance determinations, and equivalence standards before extending protections to customary farming, existing operations—including CAFOs—already enjoyed Right-to-Farm protections despite the complete absence of GAAMPs. This regulatory vacuum allowed large-scale operations to claim adherence to undefined "best practices" and invoke "21st century technology" without measurable standards, while any expansion of protections to other farming types would require bureaucratic gatekeeping. HDOA's preference for Michigan-style GAAMP development—privileging "subject area specialists" from universities, USDA, state agencies, and farm organizations while limiting "county/local government input" and "participation by non-agricultural/non-governmental organizations"—further illustrates how technical expertise displaces democratic participation in agricultural governance. The proposed framework would concentrate definitional power in the hands of agricultural industry and allied institutions, creating standards that existing large operations helped define while smaller and alternative operations faced compliance with rules they had no role in shaping. Most significantly, Villa Rose's defense of Right-to-Farm protections for themselves while simultaneously pursuing regulations to eliminate competitors reveals the fundamental asymmetry of their policy strategy. They argued their own operations deserved protection from regulatory "taking" while advocating for regulations that would effectively take their competitors' businesses through compliance costs. When community advocates and farmers' organizations sought to either regulate CAFOs existence or curtail their protections, Villa Rose deployed lobbyists to block such measures—all while operating in a regulatory environment with no defined standards governing anyone's practices. This case demonstrates how policy becomes a mechanism for market consolidation in the sharetaker era: enlisting national advocacy partners to provide legitimacy, framing private accumulation as public benefit through food security and sustainability rhetoric, securing state guidance during development then converting that relationship into lobbying access, deploying capital as both promise and threat, creating regulatory frameworks favoring economies of scale, using compliance costs as barriers to entry, strategically applying progressive causes to advance corporate interests, and maintaining regulatory ambiguity as operational advantage. The absence of GAAMPs is not a gap to be filled but a feature to be maintained—it allows large, well-capitalized operations to claim compliance with undefined standards while blocking regulatory protections for competitors. The result is not improved animal welfare, environmental protection, or agricultural sustainability, but rather the systematic elimination of diversified, community-scale production in favor of consolidated corporate control—achieved through policy manipulation rather than market competition.