I suppose OT will disagree

[Sandhusker]

Why would any R-Calf member sell on video auction for fall delivery? Isn't that the same as forward contracts?

Is the purchase price based on cattle prices at a later date or is the price agreed upon when the deal is made?

 

[Big Muddy rancher]

Why would any R-Calf member sell on video auction for fall delivery? Isn't that the same as forward contracts?

Is the purchase price based on cattle prices at a later date or is the price agreed upon when the deal is made?

Well they are contributing to Captive supply aren't they. Come fall the buyers don't need to be aggressive in purchasing all their supply as they have some already purchased. As well do these R calf members stipulate that packers can't buy them?

 

[Anonymous]

Sand: "Is the purchase price based on cattle prices at a later date or is the price agreed upon when the deal is made?"

What makes you think that you need to save the feeding segment of our industry from their own marketing practices?? Talk about arrogance!

I don't care whether the price is based on last years price, the bottom line is this, you have a willing seller and a willing buyer who both know the terms of the agreement so who the heck are you and your fellow R-CALFers to save these feeders from themselves???

Do you honestly think that feeders who sell fat cattle need fat cattle marketing advice from cow/calf men that sell calves???

When anyone sells on the grid, they know the base price will be based on the weekly weighted average the week prior WHICH MAY BE HIGHER OR LOWER THAN THE CASH MARKET ON THE WEEK OF DELIVERY. You know that risk when you make the agreement. If you don't like that risk, you have the cash market as an option. Nobody has a gun to anyone's head forcing them to sell on the grid.

The reason for grid pricing was for feeders to be paid on carcass merit. In order to do that, you have to establish a base price which is a weekly weighted average of the week you are generally making the agreement. You should have a good idea what the cash market is for that week so your weekly weighted average will be the average of the cash price for the week you make the agreement. The following week you make delivery and your base price becomes the weekly weighted average of the cash price from the week prior WHICH WAS THE WEEK YOU MADE THE AGREEMENT!!

You know the risks!

I hope NCBA sticks to their guns of not allowing the packer blamers in the cow calf segment of the industry (R-CALF) dictate to the feeding industry how the feeding industry will market cattle. NCBA is right on this issue.

Those who don't sell fat cattle have no right to tell those who do how they can market their animals.

Let the sabor rattling begin!



~SH~

 

[Sandhusker]

Why would any R-Calf member sell on video auction for fall delivery? Isn't that the same as forward contracts?

Is the purchase price based on cattle prices at a later date or is the price agreed upon when the deal is made?

Well they are contributing to Captive supply aren't they. Come fall the buyers don't need to be aggressive in purchasing all their supply as they have some already purchased. As well do these R calf members stipulate that packers can't buy them?

What the price is based off of makes all the difference.

 

[Big Muddy rancher]

Is the purchase price based on cattle prices at a later date or is the price agreed upon when the deal is made?

Well they are contributing to Captive supply aren't they. Come fall the buyers don't need to be aggressive in purchasing all their supply as they have some already purchased. As well do these R calf members stipulate that packers can't buy them?

What the price is based off of makes all the difference.

They are "Captive supply" so in the fall if the price is going up they can back out of the market and draw in captive supply. That;s what R calf accuses the packers of doing.

 

[Sandhusker]

One feeder "calling in" his contracted calves and not buying calves for a couple of weeks doesn't make the difference in the national markets that a fart in a thunderstorm does. Compare that to the effect on the markets if Tyson does the same. THAT is the real problem here.

 

[Big Muddy rancher]

One feeder "calling in" his contracted calves and not buying calves for a couple of weeks doesn't make the difference in the national markets that a fart in a thunderstorm does. Compare that to the effect on the markets if Tyson does the same. THAT is the real problem here.

It can make a big difference at one market if it's the day your calves sell.

What's good for the goose is good for the gander. What do you make laws for different sized operations. :roll:

 

[Anonymous]

One feeder "calling in" his contracted calves and not buying calves for a couple of weeks doesn't make the difference in the national markets that a fart in a thunderstorm does. Compare that to the effect on the markets if Tyson does the same. THAT is the real problem here.

It can make a big difference at one market if it's the day your calves sell.

What's good for the goose is good for the gander. What do you make laws for different sized operations. :roll:

Yep- and so does Canada.. In the US they are called anti-trust laws- I think Canada's are called competition laws...Most US federal ones go back over 100 years, altho many states had them long before that...
History of fair competition laws goes back to the Roman Empire...

 

[Sandhusker]

One feeder "calling in" his contracted calves and not buying calves for a couple of weeks doesn't make the difference in the national markets that a fart in a thunderstorm does. Compare that to the effect on the markets if Tyson does the same. THAT is the real problem here.

It can make a big difference at one market if it's the day your calves sell.

What's good for the goose is good for the gander. What do you make laws for different sized operations. :roll:

You make laws that accomodate and make possible the desired outcome; In this case, a fair and functioning marketplace free as possible from manipulation and abuse.

 

[Anonymous]

Sand: "You make laws that accomodate and make possible the desired outcome; In this case, a fair and functioning marketplace free as possible from manipulation and abuse."

No Sandhusker, YOU will make laws, founded on baseless conspiracy theories of market manipulation and abuse, that will socialize the fat cattle marketing structure to the point where there is no differenciation in price between cattle regardless of quality. This in turn creates a disincentive to raise better cattle. The word is called "socialism".

Doesn't matter how badly you want to believe market manipulation and abuse are occuring. Doesn't matter how many times you repeat the rhetoric. At some point you have to prove it. If history is any indication I have NEVER seen you support your views with supporting facts. NOT ONCE! Your views are based on WHAT YOU WANT TO BELIEVE rather than what you can prove. Same-O you! That is precisely why R-CALF has such a miserable track record in our court system.


~SH~

 

[RobertMac]

Sand: "You make laws that accomodate and make possible the desired outcome; In this case, a fair and functioning marketplace free as possible from manipulation and abuse."

No Sandhusker, YOU will make laws, founded on baseless conspiracy theories of market manipulation and abuse, that will socialize the fat cattle marketing structure to the point where there is no differenciation in price between cattle regardless of quality. This in turn creates a disincentive to raise better cattle. The word is called "socialism".

Doesn't matter how badly you want to believe market manipulation and abuse are occuring. Doesn't matter how many times you repeat the rhetoric. At some point you have to prove it. If history is any indication I have NEVER seen you support your views with supporting facts. NOT ONCE! Your views are based on WHAT YOU WANT TO BELIEVE rather than what you can prove. Same-O you! That is precisely why R-CALF has such a miserable track record in our court system.


~SH~

Why do we have anti-trust laws and the PSA? Obviously, someone saw a potential problem...like corporations and government collusion to control the marketplace and limit competition.

 

[Anonymous]

This article sure shows who amongst organizations represent the producers- and who has crawled into bed with the Conglomerate multinational Packers/Feeders..

Support for the proposed rule came from R-CALF, The National Farmers Union (NFU), and the American Farm Bureau Federation (AFBF), among others.



NFU vice president of government relations Chandler Goule said, “NFU thanks USDA for standing up for independent family farmers and working toward leveling the playing field by providing the framework for a more competitive marketplace.”



Bob Stallman, AFBF president, said, “For too long producers have had to bear the financial hardship of being at the whim of production contractors, resulting in inequality in production practices, increasing losses and decreasing profitability.” Stallman also says he expects the propose rule would level the playing field.



Opposition to the proposed GIPSA changes come from the National Cattlemen’s Beef Association (NCBA), the American Meat Institute (AMI), the National Pork Producers Council (NPPC) and the National Meat Association (NMA).

GIPSA proposal will spawn multiple lawsuits



Commentary by Greg Henderson - Drovers - Wednesday, July 14, 2010



Agriculture Secretary Tom Vilsack poured gasoline on a smoldering controversy last month when he announced that the Grain Inspection, Packers and Stockyards Administration (GIPSA) will publish a proposed rule that would provide significant new protections for producers against unfair, fraudulent or retaliatory practices.



In announcing the proposed rule, Vilsack said, “Concerns about a lack of fairness and commonsense treatment for livestock and poultry producers have gone unaddressed far too long. This proposed rule will help ensure a level playing field for producers by providing additional protections against unfair practices and addressing new market conditions not covered by existing rules.”



Vilsack’s announcement was quickly followed by a chorus of position statements issued by livestock groups who were either for or against the proposed new rules. As with most issues regarding livestock marketing, there is little grey area.



Most of the proposed changes are not new. Some within the livestock industries have complained about non-competitive markets for many years. Others, however, believe more government intrusion into the market place will have many unintended consequences.



Among the proposed changes, packers would be banned from selling livestock to other packers, producers would not have to prove competitive harm to make anticompetitive allegations and private contracts would be made public on GIPSA’s website as soon as 10 days after the terms had been settled.



Support for the proposed rule came from R-CALF, The National Farmers Union (NFU), and the American Farm Bureau Federation (AFBF), among others.



NFU vice president of government relations Chandler Goule said, “NFU thanks USDA for standing up for independent family farmers and working toward leveling the playing field by providing the framework for a more competitive marketplace.”



Bob Stallman, AFBF president, said, “For too long producers have had to bear the financial hardship of being at the whim of production contractors, resulting in inequality in production practices, increasing losses and decreasing profitability.” Stallman also says he expects the propose rule would level the playing field.



Opposition to the proposed GIPSA changes come from the National Cattlemen’s Beef Association (NCBA), the American Meat Institute (AMI), the National Pork Producers Council (NPPC) and the National Meat Association (NMA).



“Many of the proposed changes appear to be in response to unsubstantiated concerns while ignoring the results of industry and congressionally mandated studies,” according to NMA CEO Barry Carpenter. “Under the guise of balance and transparency, it will cause upheaval and confusion while increasing the costs to the entire market chain. It’s going to have the opposite impact of what is intended. NMA has already called upon GIPSA to provide proof that the complaints the agency referenced in the proposal as the basis for change have any validity.”



NCBA president Steve Foglesong said, “we have serious concerns with any efforts to increase government intrusion in the marketplace. Cattle producers support free-market principles and we deserve the right to enter into private negotiations between willing buyers and sellers — just like other sectors of American business. NCBA will fight to protect the use of contract and alternative marketing arrangements in the cattle industry to satisfy the demands of our consumers.”



In an interview with the Associated Press shortly after the announcement, Secretary Vilsack acknowledged the proposed rule changes could be contentious. “I think it’s fair to say that what we’re proposing is aggressive. The reality is, the Packers and Stockyards Act has not kept pace with the marketplace ... Our job is to make sure the playing field is level for producers.”



But many do not agree that the playing field will be leveled. Indeed, many believe that these actions by GIPSA is an attempt to set the livestock industries back 30 or 40 years, to a time when marketing cattle and hogs was less complicated. Many observers also note that USDA under Vilsack and the Obama Administration have promoted programs, such as “Know Your Farmer, Know Your Food,” that are unrealistic.



Perhaps the most troubling aspect of the new rules is the provision that makes it easier for farmers to file suits under the Packers and Stockyards Act. Peter Carstensen, a law professor at the University of Wisconsin who has studied agriculture competition law for decades, says farmers who now sue under the act must show a company has not only harmed them but that it has hurt competition in the overall meat industry.



The new law would change that, making it clear that the law only requires a farmer to show a company has engaged in “unfair” or “discriminatory” acts against the farmer. That sole provision could unleash a wave of litigation, and prompt courts to overturn earlier rulings, Carstensen said.



So, get ready for a whole new series of lawsuits. Whatever USDA does after the comment period, expect one side or the other to file multiple lawsuits. But possibly more frightening is the bevy of lawsuits producers could file if USDA’s proposed rules become law.



Is this really how we want to run the livestock industry, suing each other and the companies who buy our product?



drovers.com

 

[mrj]

STILL at it.......R-CALF calls for government to regulate everyone out of business excepting themeslves!!!!

There remain quite a few of us in various segments of the cattle business who want to think for ourselves and make our own decisions, and R-CALF apparently can't stand that.

mrj

 

[Anonymous]

STILL at it.......R-CALF calls for government to regulate everyone out of business excepting themeslves!!!!

There remain quite a few of us in various segments of the cattle business who want to think for ourselves and make our own decisions, and R-CALF apparently can't stand that.

mrj

Maxine-- Did you notice that it isn't just R-CALF calling for GIPSA reforms and enforcement to support producers- that its also The National Farmers Union (NFU), and the American Farm Bureau Federation (AFBF)... I believe the USCA did too...

But in true form-- NCBA again crawled into bed and supported Big Industry- and the Packer conglomerates over producers...

But finally the country is awakening to the fact that NCBA only represents 1 out of every 33 tax paying cattle producers-- and many cow/calf producer members even disagree with the NCBA leadership and want some teeth in the PSA.....

 

[Sandhusker]

STILL at it.......R-CALF calls for government to regulate everyone out of business excepting themeslves!!!!

There remain quite a few of us in various segments of the cattle business who want to think for ourselves and make our own decisions, and R-CALF apparently can't stand that.

mrj

Like making the decision to test all of your beef for BSE?

 

[Anonymous]

RM: "Why do we have anti-trust laws and the PSA? Obviously, someone saw a potential problem...like corporations and government collusion to control the marketplace and limit competition."

We have anti trust laws to prevent LEGITIMATE abuses of the cattle markets through such acts as COLLUSION and PRICE FIXING and GENUINE MANIPULATION OF THE MARKETS as opposed to "PERCEIVED" abuses of market manipulation coming from the R-CALF conspiracy theorists in our industry.

I haven't heard anyone say we need to repeal the PSA. What we don't need is additional regulations that affect how feeders can sell their cattle which are based on nothing more than conspiracy theories (ie "TAYLORS UNTESTED THEORIES").

That is where the debate needs to occur. What constitutes legimate abuses of the markets and what is nothing more than packer blamers trying to save the feeding industry from their marketing options. I hope NCBA sticks to their guns rather than allowing the packer blamers to socialize cattle marketing.

In regards to the Packers and STOCKYARDS act, I'd like to see the statistics on PSA investigations that have led to legitimate abuses. I'll bet there has been, percentage wise, more abuse in the STOCKYARD'S side than the PACKER'S side. Any bets? That's kinda funny in light of who is always calling for enforcement of the PSA.

Again, it doesn't matter what you WANT TO BELIEVE. All that matters is WHAT YOU CAN PROVE. Wanting to believe there is market manipulation does not justify changing our laws.

~SH~

 

[Anonymous]

OT: "But in true form-- NCBA again crawled into bed and supported Big Industry- and the Packer conglomerates over producers..."

Wrong again OT! NCBA is supporting the feeding sector of the industry THAT ACTUALLY SELL FAT CATTLE from the socialized fat cattle marketing agenda of the R-CALF conspiracy theorists.

Go NCBA! Don't let the packer blamers end fat cattle marketing options as we know them based on their arrogant and ignorant belief that the feeders need R-CALF & CO. to save them from themselves and their ability to market fat cattle as they see fit based on empty conspiracy theories of market manipulation.


~SH~

 

[Beefman]

Maxine-- Did you notice that it isn't just R-CALF calling for GIPSA reforms and enforcement to support producers- that its also The National Farmers Union (NFU), and the American Farm Bureau Federation (AFBF)... I believe the USCA did too...

But in true form-- NCBA again crawled into bed and supported Big Industry- and the Packer conglomerates over producers...

But finally the country is awakening to the fact that NCBA only represents 1 out of every 33 tax paying cattle producers-- and many cow/calf producer members even disagree with the NCBA leadership and want some teeth in the PSA.....

Yes OT, the predictable list of associations lined up to bang the drum in support of the proposed GIPSA rules…..no front page news there. If you’re in favor of increased government regulation in the marketplace, you’ll have no problem finding something you like.
NCBA has voiced concern about the impact these rules will have on value based marketing, grids, etc. They have also recently released a blog at www.beltwaybeef.com. Sam Johnson, of Summitcrest Farms in Ohio wrote a blog on his thoughts on the proposed rules. You can find his blog at http://www.beltwaybeef.com/2010/07/ranchers-perspective-new-gipsa-rule.html. I have copied it here.
---------------------------------------------------------------

I am very concerned about the new proposed GIPSA (USDA's Grain Inspection, Packers and Stockyards Administration) rule on livestock marketing and how it might set back the beef industry 30 to 50 years, and even unwind all of the good things we have done in the past 30 years and even kill any innovation for the future.
Twenty years ago, my dad made a trip to Russia as a paid consultant by the Eaton group. The purpose of his trip was to help devise a plan to supply quality beef to a tourist hotel being built in St. Petersburg. What he found there was a system that was extremely fair, but an absolute economic, production and quality disaster!
Producers were all paid the exact same. The exact same! There was no difference paid for pounds, quality, yield, type, breed etc. This was done in the name of fairness and equality. But nobody won. The price paid for every head was the minimum. Quality was nonexistent. Availability was minimal. A consumer after standing hours in line would get whatever was passed througha window and had no choice of cut or price. As a result, Russia couldn't supply a single hotel in St. Petersburg with any product that would satisfy a foreign tourist.
Dad's recommendation was that they import Certified Angus Beef from the United States because there was nothing to work with in Russia and would take billions of dollars and years to build any system that would deliver quality. That is what they were reluctantly resigned to do. Today Russia is still trying to recover from this central planing economic disaster and are now importing into Russia some of the very best of American genetics that they can find. So that they may jump start the building of an economically viable system. This was also my father's recommendation 20 years ago.
Currently, I have a Russian order for 1,000 bred registered Angus heifers that I am trying to fill. What I am afraid of with these GIPSA rules is that 20 years from now we may need to go back to Russia and buy back our own genetics to recover from our own central planing mistakes. (end of Johnson's comments).

 

[mrj]

Sure did, OT! and not surprise, especially when considering NFU is first and foremost a UNION of (some) farmers.....and members who join for other reasons. Around here, people who bought their water softener salt at their stores were considered 'members'. Wonder how many actually pay dues these days???

No surprise about USCA either, just R-CALF lite, in spite of what was done to them by the take over.

AFBA, is truly disapointing to me. They KNOW better than to believe the unsubstantiated claims of wrongdoing by NCBA, and KNOW that beef checkoff funds CANNOT be used for anything that the CBB and Federation members of the Operating Committee does not approve. AND those contracts are on a COST RECOVERY ONLY basis with total oversight by USDA. Therefore, USDA knows full well that there is no legitimacy to claims NCBA "uses your money against you", IF they check the audits.

Truth to tell, NCBA Policy Div. was poised to give up too much control over MEMBERS' business in the attempt to make it easier for people to understand the structure and for more people to have more control.

Further, the Federation is truly the Federation of state beef councils, with directors named by STATE beef councils which are comprised of members representing ALL cattle organizations within a state, and answering only to their state and the CBB, also named first by the state BIC's, then by USDA. The Federation is under control of their STATE BIC, and uses a portion of the STATE share (50cents) of the beef checkoff to enhance projects the CBB originates.

For the record, you have never shown any proof that "packers" in any way, shape, or form have, or exert any control over NCBA.

It is probably a foreign concept to you, but many cattle producers and feeders do benefit from the free and open markets that this so called 'reform' will destroy and THEY are the NCBA members driving the stand of the organization.

 

[Anonymous]

New game, new rules



ALAN GUEBERT / Columnist - Journal Star (NE) - July 17, 2010



Watching Big Pork and Big Beef respond to proposed U.S. Department of Agriculture rules to "clarify conduct that violates the P&S (Packers and Stockyards) Act" is like watching Wall Street bankers: They find it impossible to pull their hands out of your pockets long enough to pull themselves out of the mess they've made.



That's a good explanation of recent calls by the National Pork Producers Council and the National Cattlemen's Beef Association for the Grain Inspection, Packers and Stockyards Administration, or GIPSA, to triple the customary 60-day comment period on new rules that give producers more power in today's increasingly opaque, packer-dominated poultry and red meat markets.



What's up with that?



Simple, say industry watchers. Both NPPC and NCBA made formal calls for the rules to be lost in the bureaucracy because the American Meat Institute, the packers' powerful lobby, wants time to strangle ‘em in their crib, undermine GIPSA's new administrator, J. Dudley Butler, and, hopefully, elect a more packer-friendly Congress.



If so, NPPC and NCBA's actions leave little doubt as to who wears the leather in either group. Each echo the packers' July 2 letter to Butler that requested the 120-day extension by moaning "the rules will result in significant changes in how livestock are marketed and procured by meat packers."



Well, duh.



When the rules were announced June 22, GIPSA fulfilled a 2008 Farm Bill mandate that "instructed the Secretary to promulgate regulations" to oversee the new game of fast-growing production contracts between producers and packers.



Specifically, explained USDA in the Federal Register that day, the new regs "would clarify when certain conduct in the livestock and poultry industries represents the making or giving of an undue or unreasonable preference or advantage" in livestock markets.



Also, the rules would give producers more rights in packer-linked production contracts when binding arbitration was the packer crowbar to solve problems.



As important as these new rules are to open markets, NPPC and NCBA defended the status quo. The rules, explained NPPC July 7, "could limit pork producers' options in selling pigs to processors."



The NCBA's line was more circumspect: "(W)e believe that this rule... could have a huge impact on the marketing of cattle in the United States."



Well, double duh.



For proof, look no further than the June 30 announcement by JBS SA to buy the 130,000-head McElhaney Feedyard in Arizona. According to published reports surrounding the deal, the purchase would give the giant Brazilian meatpacker, now on par in the U.S. with meat masters Cargill and Tyson, a yearly cattle-feeding capacity of nearly 2.5 million head.



Or, as DTN livestock analyst John Harrington noted in his online commentary the next day, 47 percent of JBS' annual cattle kill will soon come from its captive supplies.



"While there is significant disagreement over exactly how much such captive sourcing hurts negotiated cash (prices)," the Nebraska market expert explained, "most would agree that the category of packer-owned cattle tends to be the most toxic in poisoning cash market demand."



In short, if new rules are not forthcoming to limit the massive market-moving capabilities of massive meatpackers, open and transparent markets will vanish - as they have in poultry markets - and production, like in poultry, will be by invitation - contract - only.



That's what NPPC and NCBA advocate when each parrots the packers' call to delay the GIPSA rule comment period in hopes of killing it.



USDA should disregard these toads' croaking and enact the new rules-and more to tackle packer captive supplies-to protect what's left of independent markets and independent producers.



It's not only the right thing to do for producers and consumers alike, it's what Congress ordered.



Alan Guebert is a freelance agricultural journalist.



journalstar.com

USDA on right track after nearly nine decades



By Mabel Dobbs**

The Prairie Star (MT) - Friday, July 16, 2010 3:12 PM MDT



It has taken 89 years for U.S. Department of Agriculture (USDA) to put teeth in the Packers and Stockyards Act of 1921 (P&SA). The agency has proposed new rules to level the playing field for livestock producers and restore some fairness to livestock markets.



A tiny handful of giant meatpackers and processors have been underpaying and unfairly treating livestock producers for decades. These packers control the livestock markets and their market power harms independent producers and the prosperity of rural communities.



In 1921, when Congress passed the P&SA, it was the most comprehensive antitrust legislation enacted in this country. Back then, five companies controlled between 75 percent and 80 percent of all interstate livestock slaughter. Today, the livestock packing industry is even more concentrated. Three packing companies control over 80 percent of all livestock slaughter and have taken control of the marketplace in beef and hogs.



These companies manipulate the market and keep the real prices they pay for hogs and cattle a secret. Packers use livestock they own and control under contract to drive down prices to livestock producers. When the cattle prices are high, packers slaughter the cattle they already own or control. When the prices are low, they slaughter my cattle.



This manipulation impedes the ability of ranchers to earn a decent price for their cattle sold on the cash market. A 2006 USDA study found that use of these “captive supplies” cost cattle producers $69 per head and hog producers $32 per head. In total, captive supplies cost family farmers and ranchers nearly $2 billion in 2006 - four years later those losses continue to increase.



The proposed rules prohibit packers from selling livestock to each other and end discrimination against producers based upon volume of cattle sold. The rules restrict livestock buyers from acquiring cattle for more than one packer.



In addition, the rules make it easier for ranchers to sue meat packing companies accused of using deceptive trade practices or offering unfairly low prices.



The rules are a first step toward improving the livelihoods of producers and their families. However, USDA needs to do more to address the market power of the large packers. The next step is to develop an open and competitive market by requiring packers to pay a firm bid price for all livestock they procure and require them to sell in an open public market where all buyers and sellers have access.



Producers and consumers have an opportunity to review the proposed rules and send three clear messages to USDA.



First, the unfair practices and market power of the packers have harmed independent producers and rural communities.



Second, the agency should adopt the proposed rules.



Third, USDA must take another step and address market concentration by requiring packers to pay a firm bid price for all livestock they procure and require packers to sell in an open public market where all buyers and sellers have access.



The public can submit comments by email at [email protected].; fax to (202) 690-2173; mail to Tess Butler, GIPSA, USDA, 1400 Independence Ave. SW, Rm 1643-S, Washington, DC 20250-3604; or on the Federal e-rulemaking portal at http://www.regulations.gov. Comments are due Aug. 23.



** Mabel Dobbs is a rancher from Weiser, Idaho, and Chair of Western Organization of Resource Councils' (WORC) Livestock Committee.



theprairiestar.com