Agriculture Workshop Comment Number: AGW-13049

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Comment Number: AGW-13049

From: Sheridan Burgess
Sent: Saturday, December 26, 2009 9:46 AM
To: ATR-Agricultural Workshops
Subject: Comment

As a third generation cow-calf producer from Wyoming I would like the Justice Department to give consideration to the petitions presented to you from R-CALF USA regarding Captive Supplies, Market Competition, COOL and the Restoration of Weakened Disease Standards, Reformaing Trade and Halting Captive Supplies for the following reasons;
1. The practice of using Captive Supplies to manipulate cash prices exists now and has existed, in my experience, for more than the last thirty-five years.  It is a direct violation of our anti-trust laws.
2.  The implementation of COOL, as it was written and signed into law by Congress is not optional, it IS law and DOES provide criteria regarding standards for beef imports.  It should be enforced as it was written. 
3.  The USDA continues, after refusing to accept overwhelmingly negative public commentary, to pursue NAIS.  That plan is flawed, inappropriate, and unnecessary.  It would create a large federal burocracy intent on amassing the personal and private information of individuals into a massive databank.  Such an approach to tracing animal disease source is repugnant to producers for the following reasons;
     a.  By any criteria and the history of past performance the ability to trace to it's source the location of infectious diseases in animals has been proven to exist.  It has been proven to be available in a timely manner.
     b.  The states already have in their possession the capability to accomplish findings and responses to disease outbreaks through their state vet labs and departments of agriculture.
     c.  In spite of these facts the USDA, a large federal burocracy, remains intent on creating another federal burocracy which will further insulate it's parent from reality and accountability.  Accountability is the issue here.  By refusing to accept the facts it solicited and without providing substantive reasons to ignore them the USDA has made the strongest case yet for the exclusion of it's proposed experiments with animal health.
4.  If the Justice Department won't actively pursue these issues I expect the following will happen.  The business of agriculture in this country will be conducted between a handful of very large vertically integrated, multi-national conglomerates firmly in control of supply and price answering only to the USDA on behalf of it's political motivations of the day.
Sheridan Burgess
Updated April 7, 2016

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