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Cattlemen's Capitol Concerns Archive
Contact:
Bethany Shively,
The Cattlemen's Capitol Concerns (CCC) is a weekly report from Washington, D.C., giving an up-to-date summary of top policy initiatives concerning the cattle industry; direct from the National Cattlemen's Beef Association (NCBA). Please feel free to reprint in full or in part. If you would like to include NCBA's logo, contact us at 303-694-0305. | |
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FDA to Implement Feed Ban Despite Public Objections
The National Cattlemen's Beef Association (NCBA) criticized a decision by the Food and Drug Administration (FDA) to proceed with implementation of a new feed ban on April 27, 2009, despite numerous objections from farmers, ranchers, states, and members of Congress.
"This decision is extremely disappointing," says Dr. Elizabeth Parker, Chief Veterinarian for NCBA. "By going ahead with implementation of this unnecessary ban, the FDA is ignoring the substantial costs and environmental burdens it imposes on America's cattle producers."
For years, the livestock industry has made it clear to FDA and the Administration that this rule would exacerbate the problems producers are already facing regarding carcass disposal.
In fact, as early as December 2008, NCBA and producers across the country began voicing concerns about increased costs and disposal issues as many renderers discontinued their services in anticipation of this ban. "Unless FDA provides solutions for these problems, delaying the compliance date is an empty gesture," says Parker.
FDA is establishing a compliance date of October 26, 2009 to give renderers additional time to comply with the new regulations and allow producers more time to identify appropriate methods of disposal. However, they have not provided any means to resolve the disposal issues created by the rule.
"This amounts to an unfunded mandate," Parker continues. "FDA has acknowledged that this rule creates tremendous disposal issues for producers, yet they have not identified any viable solutions to that problem. Moving forward with implementation without addressing these concerns is irresponsible."
In a pre-publication of the final rule, FDA said that, "the underlying bases for these new measures were fully considered through the notice and rulemaking process." Yet the FDA never completed a risk assessment to determine the costs and benefits of the new feed ban.
"The rule creates significant costs and environmental problems, and has no demonstrable benefit," Parker explains. "Our existing feed ban has proven highly successful in limiting bovine spongiform encephalopathy (BSE) in the U.S. herd."
Since 1997, the U.S. has prohibited ruminant feed from including parts of other ruminants. This proactive "ruminant to ruminant" feed ban, combined with other government and industry safeguards, is responsible for the extremely low level risk of BSE in the U.S. This was confirmed by years of robust USDA surveillance and reaffirmed by the U.S. "BSE Controlled Risk" designation by the OIE, the international animal health standard setting body.
For more information, see NCBA's April 7, 2009 press release:
www.beefusa.org/NEWSFDAIgnoringEnvironmentalandEconomic
ImpactsofFeedBan38212.aspx
To see FDA's pre-publication of the confirmation of the effective date of the final rule, visit:
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Progress Being Made in EU Beef Hormone Dispute
On Wednesday, USTR announced it will delay the scheduled "carousel" retaliation of additional duties on a modified list of EU products in connection with World Trade Organization (WTO) dispute settlement rulings in the EU - Beef Hormones dispute. According to United States Trade Representative Ron Kirk, the additional duties-which were set to go into effect on April 23- will be delayed until May 9 in order to provide more time to negotiate a settlement with the EU.
NCBA has been working closely with industry and USTR on this issue for several years, and is encouraged by the recent signs of progress.
"Increasing export market access is a high priority for NCBA, and we're encouraged by the strong leadership that Ambassador Kirk has shown on this issue," said Gregg Doud, NCBA chief economist. "We appreciate USTR's persistence in achieving an agreement that would provide increased market access. America's cattle producers have unfairly suffered as a result of this trade barrier for more than 20 years."
Negotiation talks are expected to continue on Monday in Geneva.
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Regulation of Greenhouse Gas Emissions Under Clean Air Act Could be Devastating for U.S. Agriculture
The National Cattlemen's Beef Association (NCBA) is deeply concerned about the potential impacts that a recent Environmental Protection Agency (EPA) finding could have on livestock operations. EPA's finding-which proposes that greenhouse gas (GHG) emissions are an endangerment to public health and welfare-is the first step in a process that could require GHG regulation under the Clean Air Act (CAA).
The CAA is fundamentally ill-suited for GHG regulation and NCBA is opposed to any attempts to use it for this purpose.
"While the Clean Air Act has done a good job of cleaning up pollutants, it is not adequately equipped to address global climate change," explains NCBA Chief Environmental Counsel Tamara Thies. "Congress never intended to regulate greenhouse gas emissions under the Clean Air Act, and any attempts to use it for this purpose would be devastating for the U.S. economy."
If the Administration and Congress decide to regulate GHGs, a cap-and-trade program would be more appropriate, rather than the CAA's command-and-control regulatory program.
"If the EPA moves forward with this finding, the agency would have unprecedented control over every sector of the U.S. economy," says Thies. "Regulation of greenhouse gases should be thoughtfully considered and voted on by Congress. Allowing the EPA to regulate greenhouse gas emissions under the Clean Air Act would impose untenable burdens, expenses and restrictions on industry, families, and our Nation as a whole."
While agricultural sources are currently generally not required to obtain permits for greenhouse gas emissions, regulation of GHGs under the CAA may for the first time trigger such regulation. According to the advanced notice of proposed rulemaking for regulating greenhouse gases under the Clean Air Act, released last year by the Bush Administration, the U.S. Department of Agriculture estimated that "even very small operations would meet the 100 tons per year emissions threshold to require regulation. For example, dairy facilities with over 25 cows, beef cattle operations of over 50 cattle, swine operations with over 200 hogs, and farms with over 500 acres of corn may need to get a Title V permit."
"Given the fact that America currently has over 2,000,000 farms, it would be virtually impossible to permit a majority of them," says Thies. "The amount of paperwork, time delays, and new technology needs would be insurmountable. In addition, most of America's agricultural producers simply would not be able to afford the regulatory compliance costs that would be imposed on them under such a program, and they would be forced out of business."
According to the EPA, in 2006, GHG emissions from the entire agriculture sector represented only 6.4% of total U.S. GHG emissions in Tg CO2 Eq. (Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006, U.S. Environmental Protection Agency, April 15, 2008). At the same time, land use, land use change, and forestry activities resulted in a net carbon soil sequestration of approximately 14.8% of total U.S. CO2 emissions, or 12.5% of total U.S. greenhouse gas emissions. This means that agriculture provides a significant net benefit to the climate change equation.
"Rather than being subject to overly-burdensome regulations, agriculture should be considered part of the solution to the climate change issue," says Thies. "Agricultural operations can serve as an important source of carbon offsets to enable regulated industries to comply with any cap set by climate change legislation."
NCBA plans to submit comments to EPA during the upcoming 60-day public comment period.
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NCBA Continues to Push for U.S. Beef Trade with China
NCBA continues to urge members of Congress to strip a provision that effectively bans imports of some Chinese chicken products from the 2010 agriculture appropriations. The provision (Section 727), which was included in the recently passed 2009 Omnibus Appropriations Act, has prompted China to request a World Trade Organization (WTO) consultation.
China is currently closed to U.S. beef exports, and NCBA is concerned that the chicken dispute will impede our ongoing efforts to open up China to U.S. beef. China represents one of the largest potential growth markets for U.S. beef-worth in excess of $100 billion.
With its 1.3 billion consumers, rising income levels, and rapid urbanization, growth in China's per capita beef consumption outpaced all major beef-consuming countries during the last decade. (USITC Publication 4033, September 2008). In addition, China demonstrates a niche demand for certain beef cuts, such as offal, that are underutilized in the U.S., and can be marketed in China as premium products.
China officially banned U.S. beef and offal after the discovery of a single case of BSE in the U.S. cattle herd in December 2003. Prior to the ban, the U.S. was China's leading foreign beef supplier by value (excluding transshipments through Hong Kong), and China was the 10th largest U.S. beef export market in 2003.
NCBA and allied industries will continue outreach to the Administration and Congress to ensure future appropriations legislation does not damage global commerce and promotes a favorable, fair international trading environment.
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NCBA Highlights Industry's Successful Beef Safety Efforts
National Cattlemen's Beef Association (NCBA) Senior Vice President of Research, Education and Innovation Bo Reagan testified today during the House Subcommittee on Livestock, Dairy and Poultry hearing to review Federal food safety systems at the United States Department of Agriculture (USDA). Reagan, an NCBA member and chairman of the Beef Industry Food Safety Council (BIFSCo), highlighted the role of the U.S. beef industry in producing the most affordable, nutritious, and safest food supply in the world. Since 1993 cattle producers have invested more than $27 million in beef safety research, and the beef industry as a whole spends approximately $350 million every year in beef safety.
"Above all, safety is a non-competitive issue for the beef industry," said Reagan. "As an industry, we continue to remain committed to a broad, coordinated effort to solve pathogen issues by developing industry-wide, science- and risk-based strategies to address safety challenges."
The following is an excerpt from Reagan's remarks as prepared:
"Everyone plays an important role in the safety of food. All beef is subject to strict government oversight and everyone who plays a role in the production chain is committed to producing safe beef products. Every meat processing facility undergoes daily, on-going USDA inspections by the Food Safety and Inspection Service - FSIS. Inspectors are in meat processing facilities daily performing their inspection duties as well as reviewing Hazardous Analysis Critical Control Point (HACCP) plans.
"It's important to note that HACCP plans were pro-actively developed by the food industry as a method to identify the potential hazards and then to prevent them. In 1996, FSIS enacted a rule requiring HACCP plans for all beef processing facilities. The HACCP program is successful as it focuses on process controls rather than testing as a means to protecting public health - you cannot test your way to safety, as you must focus on the process and the controls that are in place to reduce potential hazards.
"On the research, promotion and education side of the beef industry - in my role at NCBA I have the privilege to oversee beef safety research, consumer education and the development of new beef products. Throughout the years, there have been several opportunities for the beef industry and USDA to create partnerships on beef safety research. This collaborative effort is vital as USDA and the industry are able to leverage dollars and utilize the scientific expertise of USDA's Agricultural Research Service's (ARS) scientists to ensure safety challenges and knowledge gaps are being addressed proactively. It is imperative that USDA continues and increases ARS funding of food safety research. In order to achieve the goal of food safety, we have to understand the science of the pathogens and the interventions that may be used to control them or their environment.
"As the food safety policy discussions continue, we encourage Congress to work with FSIS to focus on the resources needed to effectively implement the science- and risk-based regulations that are currently in place. Just as important is the need for employee training and the communication of any new regulatory changes to FSIS inspectors in the field so that there is not any confusion or misinterpretation of the law. We realize that communicating regulatory changes to personnel throughout the country is a challenge, but this is an area of concern for the beef industry.
"With regards to small and very-small operations, there is a greater need of information and resources from USDA to be provided for these small businesses to utilize. We encourage USDA to continue and increase their outreach efforts to these small businesses.
"Lastly, consumers will always play an important role to ensure that their food is safe. The beef industry has created numerous resources like www.safeandsavory160.com for consumers to learn more about the proper storage, handling and cooking of beef products. Any assistance the federal government can provide to ensure that consumers learn more about their important role in food safety and the educational resources that are available for their use would be appreciated."
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Economic Outlook: Drop Credit Drag
Economic conditions in the cattle industry have improved during April, with live cattle trade continuing this week at $88/cwt ($0.88 / pound) -- up about $7/cwt from a month ago. Nearly all of this strength can be attributed to improvement in domestic demand and wholesale Choice beef cutout values, which have risen this week to over $150/cwt -- up more than $15/cwt since April began.
Breakeven prices in feedlots have been in decline during the same period and are running in the upper $80s/cwt to lower $90s/cwt, resulting in a considerable improvement in sentiment regarding that part of our industry compared to the first quarter.
But any optimism is muted by the knowledge that the number of market ready cattle will increase significantly in the coming weeks, and that export demand remains soft due to the relatively high value of the dollar and global economic conditions.
Without question, however, the most significant difference in this industry compared to a year ago is the value of the drop credit, which is comprised of non-meat items including the hide, tallow and offals. On a live animal basis, this $5-6/cwt difference in the drop credit versus year-ago levels, mostly based on at least a 50% decline in the value of hides, is unquestionably the reason why all sectors of the beef industry continue to struggle economically. The bottom line is that if we had drop credit values at year ago levels, all sectors of our industry could potentially be in the black.
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Don't Miss NCBA's Cattlemen to Cattlemen!
Don't miss NCBA's Cattlemen to Cattlemen, April 28 - May 2! We'll take a look at how cattlemen are using DNA technology on their operations, and learn more about equipping ATVs to treat brush. Plus, we'll spend a day in the life of a Nebraska cattleman.
NCBA'S Cattlemen to Cattlemen is now an hour long! The show debuts Tuesdays at 8:30 p.m. and airs again Wednesdays at 10:30 a.m. and Saturdays at 9 a.m. (All times are Eastern). Don't forget, you can watch NCBA's Cattlemen to Cattlemen online anytime by visiting www.CattlemenToCattlemen.org | |
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