August 25, 2011
Submitted by:
Allan Sents
Director, Marketing and Competition Chairman
U.S. Cattlemen’s Association
The U.S. Cattlemen’s Association would like to provide the following comments in regards to the “Looking Ahead: Kansas and the 2012 Farm Bill”. As an active and dedicated member of the Kansas livestock and agricultural community, I would like to provide insight and comments on behalf of myself and the U.S. Cattlemen’s Association on several issues that will be highlighted within the upcoming 2012 Farm Bill.
As a native of Kansas and a livestock owner in McPherson, Kansas, the most contentious issues within the debate so far are those that will affect not only my operation but those of producers across the nation as well. The U.S. Cattlemen’s Association is a national association of cattle ranchers and state associations, whose mission is to present an effective voice for the United States cattle industry. The membership of USCA includes cow-calf operators, backgrounders, and feedlot operators. USCA would like to offer the following comments in regards to the 2012 Farm Bill and this hearing:
GIPSA:
USCA submitted comments to USDA in regards to the proposed GIPSA rule and we maintain the belief that the intent of the proposed rule is sound and sorely needed. We outlined concerns within our comments that we saw as needing additional clarification by the department. Further, we are confident the final rule will incorporate appropriate changes in response to the 60,000 comments received.
The 2008 Farm Bill clearly defined the need to provide clarification and stricter guidelines within the Packers and Stockyards Act. The proposed rule is needed for the following reasons:
1) Present law has been gutted by court actions that defeat the intent of the Act.
a) If individual protection is to be preserved the standard of “competitive injury”
that requires proof of industry wide harm is unreasonable.
b) USDA recognized in the rule summary that unfair practices have occurred that do not have an anticompetitive impact on the entire industry. If packers are engaged in “unfair” practices a jury is likely to identify, the reasonable action is to change the practices. If the practices are not “unfair” they have nothing to fear.
2) The assumption packers will cease “value based” buying under this rule is unfounded.
a) Rule makers were clear these transactions would be allowed, packer claims to
the contrary are blatant attempts to kill the rule by inducing fear into producers.
b) The absence of alternative proposals from rule opponents indicates a total lack of interest in appropriate conduct in the marketplace, anything goes.
3) A seldom mentioned benefit from this rule would be a more informed and transparent marketplace leading to more participants and greater competition.
4) Failure to effectively regulate livestock markets now will lead to an inevitable and painful correction someday, similar to what the banking industry recently experienced.
The U.S. Cattlemen’s Association supports letting the rule-making process take its due course and as such maintaining the current funding for this provision within the upcoming Farm Bill.
COOL:
The U.S. Cattlemen’s Association remains staunchly supportive of mandatory country-of-origin labeling (COOL). USCA has been involved with this issue from its inception and has worked with the Office of the U.S. Trade Representative in developing a strong and effective defense for the rule as it undergoes a ruling within the World Trade Organization. In light of recently leaked preliminary reports, the unofficial ruling has favored the disputing countries, Mexico and Canada, over the United States. As the final rule is released by the WTO this fall, USCA will remain committed to seeing through an appeal process by the United States. COOL allows the nation’s cattle producers to promote their own product. The fundamentals driving any profitable marketplace are based on the ability to promote and market one’s product. COOL allows consumers to have a choice in what product they purchase and assists in the maintenance of a sense of food security across the nation. In a marketplace that is increasingly driven by a consumer who values and demands to know how their product was manufactured and where it originated, COOL maintains meat’s legitimacy within this discussion while also giving the public the opportunity to choose what they purchase. COOL is funded within the 2008 Farm Bill and USCA supports maintaining funding while the case continues to be litigated in the WTO.
Livestock Disaster Programs:
Producers across the nation have benefitted greatly from the Livestock Indemnity Program, the Supplemental Agricultural Disaster Assistance Programs and the Livestock Forage Disaster Program. As regions across the country have been severely hit with a myriad of natural disasters recently these programs are crucial to maintaining viable herds and operations in midst of such unavoidable circumstances.
As of May 18, 2011, there are 32 states with some type of disaster status applied to their agriculture regions. These events have ranged from flooding in the Mississippi River Basin, drought and wildfires in Texas and New Mexico and severe flooding throughout the upper Midwest. The current disaster funding is set to expire in October and it is vital for Congress to include such assistance within the upcoming bill.
The recent extreme weather has prompted lawmakers and some Agriculture groups to support the creation of ad-hoc spending for disaster assistance. In the current political and economic climate, ad-hoc spending bills for disaster relief is a gamble as to whether funding can be secured. Prior to the 2008 Farm Bill, ad-hoc spending on such bills was supported, no one can say with certainty if the same stance will be adopted for the Farm Bill. As such, USCA supports maintaining a permanent disaster assistance title for livestock producers within the 2012 Farm Bill.
Conservation Programs:
Livestock Producers are first and foremost stewards of the land. Multiple titles within the current 2008 Farm Bill support such practices through encouraging and rewarding those who adopt sustainable and environmentally conscious practices on their operations. Specific titles such as the Conservation Reserve Program, the Environmental Quality Incentive Program and the Conservation Stewardship Program currently will be targeted as each program has continued to increase in acres secured since implemented.
EQIP funding must be maintained as it acts as a preemptive measure to several other titles within the farm bill as well as acting as a preventative tool in the ongoing fight against increasing regulations issued by the Environmental Protection Agency. In order to maximize administrative and implementation costs, using EQIP as an umbrella title under which specific and targeted programs may be included will aid in decreasing overhead as is currently facilitated through multiple conservation programs. The Wetland Reserve Program (WRP) and Conservation Stewardship Program (CSP) may be included in this action and subsequently issued funding under EQIP. WSP aims to have ranchers enter into 10 year contracts in order to preserve and restore wetlands; such funding may be consolidated within the EQIP title as the programs share the same objectives of conservation while maintaining the working aspect of the land. CSP adopts the same objective in targeting a certain area which to focus conservation efforts.
As the price of farm and ranch land continues to escalate across the country and the number of acres currently unusable as a result of recent natural disasters, it is necessary to maintain as many acres in a working state as possible. Currently, through the Conservation Reserve Program, these valuable acres are tied in a retired state under their previous agreements. Given the demand for land in both areas struck with natural disasters, and communities where agriculture land is being developed, it is necessary to begin transitioning land once held within the CRP to a more working lands state. The need for a transition of land from a retired-land state to a more usable, productive and working condition for farmers and ranchers is necessary now more than ever given recent events and economic volatility. The phase out of this land would release funds within CRP to be allocated elsewhere. While land could be released from this title and transitioned back to a working state, EQIP and alternate conservation programs may be part of a joint agreement applied to such land as to ensure landowners maintain responsible and sustainable practices. |
