Today marked the final day to submit comments to USDA's Grain Inspection, Packers and Stockyards Administration (GIPSA) on their controversial proposed rule on livestock marketing practices. And those in support of and against the plan have been very vocal about relating their positions.
The critics have clearly gotten the attention of GIPSA, as the agency has put a lot of effort into defending the plan. On their website, there are two different documents which answer questions about the proposal. One is a simple question and answer format, while the other seeks to address what GIPSA says are "misconceptions" about the plan.
Follow these links to read more:
As another reflection of GIPSA realizing their proposal is controversial, after the original comment period was about half-way through, GIPSA acted to extend the comment period by 90 days -- to today instead of Aug. 23, 2010, as originally proposed.
Meanwhile, a host of groups have offered up economic studies that signal potential costs of the plan far exceed the levels that USDA has suggested.
Those against the rule have produced two different sets of economic analysis of the plan, with both suggesting costs run well above what GIPSA estimated in their proposal -- up to more than $1 billion.
And it's interesting to note that the commentary in favor of the proposal, or at least many of the examples of why the rule is needed, came from the series of competition workshops that USDA and the Dept. of Justice have held around the country this year.
The final such session will be Dec. 8 in Washington, DC, where the subject area is listed as "margins." It will be interesting to see how the agenda for that meeting unfolds. As one looks through the documentation offered by GIPSA in the items linked to above, they relied on anecdotal information, not bona fide economic analysis. Some of the comments they highlight in the documents did come from congressional hearings, but the bulk are from the workshops or a public meeting GIPSA held as well.
And not only have the supporters of the rule made sure their voices were heard at the DOJ/USDA workshops, but they have simply labeled those journalists such as our own Steve Cornett as trying to downplay what was taking place at these workshops.
So now that the comment period draws to a close, it will be up to GIPSA to make the call on how to move forward from here. They certainly have a lot of information to draw from -- ranging from stories about why the proposal is needed to economic analysis of the potential sizable costs of the plan. The ball is in GIPSA's court and it's up to them on which side they're going to listen to. But if the workshops held this year are any indication, stories could win out over projected economic impacts.
Stories are good, but sometimes they are just that. This is a proposal that cries for analysis, not just anecdotes.