“I have strong concerns that the Administration’s cost-benefit analysis [C.B.A.] of proposed changes is inadequate,” Mr. Roberts wrote. “Given the potential impacts of the proposed rule on livestock and poultry producers, processors and consumers, I believe it is critical that a robust and comprehensive C.B.A. is conducted to ensure that all affected stakeholders have a firm understanding of the potential consequences of this regulation on their economic welfare and livelihood.”
G.I.P.S.A.’s C.B.A. never referenced costs to consumers, Mr. Roberts noted. He added it overlooks the potential for producers who currently receive a premium for operating efficiently and producing higher-quality livestock and poultry to lose income due to an erosion or elimination of marketing options for their livestock.
Mr. Roberts referenced a 2007 G.I.P.S.A. Livestock and Meat Marketing Study which showed that over 10 years, a 25% reduction in alternative marketing arrangements would cost feeder cattle producers $5.1 billion; fed cattle producers $3.9 billion; and $2.5 billion for consumers. If marketing arrangements were eliminated, the 10-year cumulative losses for producers and consumers would be more than $60 billion.
Feeder cattle producers would lose $29 billion; fed cattle producers would lose $21.8 billion; and consumers would lose $13.7 billion.
“I urge the Administration to look deeper into the proposed rule and provide the public with a better understanding of its potential impact on their daily lives and pocketbooks,” he concluded.