AMI Requests 120-Day Extension of Comment Period on GIPSA Livestock Procurement Proposed RuleFriday, July 2, 2010
(American Meat Institute)
AMI submitted a request for a 120-day extension of the comment period regarding the proposed rule titled Implementation of Regulations Required Under Title XI of the Food, Conservation and Energy Act of 2008; Conduct in Violation of the Act; Proposed Rule; RIN 0580-AB07; 75 Fed. Reg. 35338. If promulgated as proposed, the rule would result in significant changes in how livestock are marketed and procured by meat packers.
AMI’s request was made in a letter sent to J. Dudley Butler, administrator of the Grain Inspection, Packers and Stockyards Administration (GIPSA).
Although the genesis of the rule is the 2008
Farm Bill, the proposed rule goes well beyond
the parameters articulated by that law
“The agency has taken almost two years to
develop and publish this proposed rule, which
would have a highly restrictive impact on how
livestock is procured in the United States,”
the letter states. “Because of the
breadth of the proposal and the impact it
almost certainly would have on how packers and
producers interact, the proposed rules warrant
careful scrutiny, analysis, and the submission
of comprehensive comments. To that end,
it is appropriate, and equity dictates, that
additional time is allotted to the affected
producers, processors, and packers so that they
may provide the most substantive comments
In addition, the letter states that the economic analysis conducted by the agency and identified in the proposal is somewhat limited. An initial review suggests that the analysis understates the direct and indirect costs to producers, processors, and packers. In addition, the economic analysis does not appear to consider the direct and indirect economic impact the proposal could have on consumers. Because it will take considerably more than 60 days to develop a comprehensive economic analysis, an extension is warranted for that reason as well.
To view the letter go to http://www.meatinstitute.org/ht/a/GetDocumentAction/i/60688.