On July 30, 2015, the Administrative Law Judge denied the motion for intervention. (AR 126-127) Animal Legal appealed that decision to the Judicial Officer pursuant to 7 C.F.R. § 1.145, arguing that (a) the APA requires that agencies provide interested third parties with an opportunity to participate, (b) Animal Legal has an interest in the proceeding that requires participation under the AP A, ( c) the USDA' s Rules of Practice do not foreclose intervention, and ( d) there was no valid reason to deny intervention. (AR 131-158) USDA opposed that appeal (AR 182-211) and, by order dated March 2016, the Judicial Officer denied the appeal.