Agricultural News
Deadline is Tonight for Public Comments on mCOOL Revised Rule
Thu, 11 Apr 2013 05:33:47 CDT
Today is the final day the USDA will accept public comments from interested parties for the Obama Adminstration's revised Mandatory Country of Origin rule. Passions are high on both sides of this issue- supporters of COOL praise the administration for wanting to provide consumers with even more information than the original rule offered- opponents say that it's a further punishment of US livestock producers as well as two of our biggest trading partners- Canada and Mexico.
If you would like to offer comments to USDA on the proposed rule- you may do so electronically. Click here for the link that will allow you to comment, see comments already submitted and see the proposed rule. The deadline is 11 PM central time April 11, 2013.
Steve Dittmer is a former agricultural journalist and currently is the Executive Vice President of the Agribusiness Freedom Foundation. He is strongly opposed to the proposed mCOOL rule- and has written extensively about it in a series of emails he has sent out. His most recent email was released early Thursday morning and offers his final thoughts on the rule- and why he views it as a disaster for the US livestock industry. Here are his comments:
As you finish your comments on the proposed mCOOL rule and compose or polish your pitch to members of Congress, here are some key points to consider:
The summary: the U.S. Congress succumbed to pressure from populists, activists and protectionists in 2008 and passed a law that already -- and is now proposed to accelerate -- requirements that:
significantly restrict free trade (42% drop for beef, 25% for pork)
costs huge amounts of money to packers and retailers, therefore, reduces the amount of money available to pay American livestock producers for their livestock.
reduce the efficiency and viability of certain packing plants, raising costs and pushing certain plants toward closure, meaning lost market access for feeders and lost jobs
put extra pressure on smaller, border packers who have the least size and scale to absorb it
devalue livestock from Canada and Mexico below true market value absent regulatory interference
provide information that consumers have demonstrated they don't use, don't notice and will not want to pay for
pile on more recordkeeping and verification requirements for all meat -- domestic and imported -- to satisfy populists who do not believe in trade, who do not like anyone having more livestock or feeding more livestock than themselves, who believe only small families with small operations should be able to farm and ranch in America. In other words, this administration's political animus against businessmen in general, bigger businesses in particular and its promotion of backyard gardens and local farmers markets as the only preferred methods of food production and distribution will be further codified into law.
treat shabbily our two best trading partners, Mexico and Canada -- both major suppliers and customers for our products -- worth hundreds of billions of dollars annually.
pile another insult onto Canada beyond the refusal to approve the Keystone XL pipeline, cutting off our own nose to spite our face. Don't forget Mexico's justified anger when the U.S. refused to honor NAFTA rules and banned Mexican trucks and retaliation affected our meat trade with Mexico.
The stated reason for this law and proposed intensification is based upon false premises. The only supposed benefit proponents of the law and further tightening can come up with is that the consumer deserves more information. Everyone says they want more information but in the real world -- not the one inhabited by disconnected bureaucrats, overweening politicians or overwrought activists -- that information has to be valuable enough to the customer for them to pay for it. We are not talking here about assurances consumers deserve and have a right to expect from government and the meat chain -- safe, wholesome meat. This labeling has nothing to do with that. Consumer activists make continually escalating demands for more information, just as they want to save every species and subspecies on earth, no matter the cost. Taken to extreme, the government could require each piece of meat bear the name of the sire and the dam and a DNA certificate verifying that parentage as well as county, state/province and country for each stage of life. It's possible technically but not cost effective.
We could assign a Meat Cut Security Agent (MCSA) to follow each cut of meat (one MCSA to each piece of meat) from carcass removal, into the cooler, down all the production lines, into the box, back into the cooler, into the truck to the retailers dock through to the meat case. That doesn't mean any but a very small group of consumers would pay what that would cost. The value of that information would be extremely small in comparison to the cost. But it would be more information for the consumer.
The beef industry has spent good money over the years, tracking consumer needs and wants, building up decades of data. Such research has been the guiding light of the entire beef industry's demand building efforts. The industry relies upon those facts to achieve industry progress -- satisfying consumer wants. Never has country of origin ranked anywhere near the top of the list of consumer wants.
To verify, we looked at the most recent research funded by the national beef check off. The top four attributes important to consumers were: #1 "great tasting," #2 "good value for the money," #3 "extremely safe to eat" and #4 "good results consistently," according to John Lundeen, executive director, market research, National Cattlemen's Beef Assn.
This research confirms consumer surveys we've been observing for over 35 years.
What's more, taking the flip side, the top three limiters of beef consumption as revealed by the research were all cost related (cost of a steak meal, cost of steak/lb. and cost of ground beef/lb.). That is why consumers have been very ill served by this law. Intensifying it like is being proposed, requiring either substantial additional compliance costs or supply cuts and operating inefficiencies, means upward pressure on consumer prices for information virtually useless to consumers -- a gross abuse of government power.
Something else needs to be said. Populist farm groups claim to be concerned about getting full consumer information for customers but that is a smokes screen for their real purpose -- keeping imported meat and feeder animals out of the country to drive the value of domestic livestock above world market value. They believe the sky is the limit, that they can drive consumer prices up and up without losing market share, with no impact on customers and without destroying their own industry. They do not understand economics and markets.
Violating WTO trade rules and refusing to fix the law or the regulations can mean either punishing fines that U.S. taxpayers will have to pay to Canada or tariffs put on products or services exported to Canada. That will mean artificially increased prices and reduced volume on those products, reduced sales revenue, fewer profits and possible loss of jobs in American industries, some of them not even involved in the dispute.
Either way, the livestock industries involved continued to get punished, consumers ill-served and the economy is further damaged. This proposed rule needs to be withdrawn, the original misconceived law repealed and the business of trade with Canada and Mexico returned to market forces.
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