“From this point, we will begin the comment-sorting process,” said Jim Brownlee, a USDA spokesperson. “As soon as the similar comments are grouped, a team will begin analyzing each comment and identifying the substantive issues to be considered in the regulatory development process.”
As of Dec. 3, the counter on the Web site, www.regulations.gov, had totaled more than 64,000 comments and more are being posted to the Web site every day. The site is not “real time,” and the docket will continue to grow until all comments filed before the deadline on Nov. 22 are posted. Most comments carry two numbers, with attached files carrying a “.1” extension, so the number of individual comments is somewhat more than half of the total number reflected on the website. Those filing comments ranged from individual meat and poultry producers and associations of producers to large companies and trade associations.
“GIPSA has created a regulatory quagmire that will stifle beef trade, placing beef producers at a competitive disadvantage to other protein suppliers,” wrote the National Cattlemen’s Beef Association.
“The Proposed Rules are a disservice to US pork producers because they fail to recognize that all livestock are produced and marketed very differently,” the National Pork Producers Council said.
“The free-market system that has existed for the nearly 80 years of the Packers & Stockyards Act has worked well and the draconian changes proposed by the rule are not warranted as a national standard,” stated a position statement adopted by the Growout Committee of the Delmarva Poultry Industry (DPI), a regional group representing farmers and chicken companies in Delaware, Maryland, and the eastern shore of Virginia. The Growout Committee represents more than 1,000 farmers in the area.
“The overall effect of the provisions regarding capital improvements will be to hinder technological advances and improvements in the poultry production system,” said Georgia Poultry Federation. “Over time, this will harm the industry’s competitive position compared to producers in other countries, and the result will be economic harm to poultry growers and poultry companies.”
Many individual producers also wrote in to comment on the proposed restrictions on grower compensation.
“I have been a poultry grower for 27 years and truly believe the present pay system is very fair,” wrote Marvin Cole of Carnesville, Georgia. “In my honest opinion, I believe this new proposed regulation will have a very negative impact on the integrators, the contract growers and the poultry industry.”
Others pointed to the challenging national economy and argue that the proposed rule will not help the farmers or the chicken companies. “I employ two people full time and three to five on a part time basis,” wrote Floyd and Ann Lee McPhail of Seneca, SC. “If my profits are cut, these employees are the first to go. This causes a ripple effect that does not contribute to a national financial recovery.”
Many other comments resulted from mass mailing campaigns conducted by organizations on both sides of the issue. More than 7,000 e-mails were generated by Food & Water Watch, an interest group strongly supporting the rule. The Rural Advancement Fund International (RAFI) accounted for more than 1,000 supportive comments, focusing on the poultry sector.
Thousands of postcards, e-mails and form letters were filed by poultry, cattle and hog producers and industry members in opposition to the rule.