ArtWASHINGTON – The American Meat Institute (A.M.I.) has requested a 120-day comment period extension for 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.

The rule would result in significant changes in how livestock are marketed and procured by meat packers, if promulgated as proposed.

A.M.I.’s request was made in a letter sent to J. Dudley Butler, administrator of the Grain Inspection, Packers and Stockyards Administration (G.I.P.S.A.).

Although the genesis of the rule is the 2008 Farm Bill, the proposed rule goes well beyond the parameters articulated by that law, A.M.I. relays.

“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 possible.”

The letter also states the economic analysis conducted by the agency and identified in the proposal is somewhat limited. An initial review suggests the analysis understates the direct and indirect costs to producers, processors, and packers.

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 read the letter, visit