Beef Marketing Group Beef Marketing Group
Wednesday, April 5 2017 10:22 AM
By Anne Burkholder

BMG's CEO John Butler Comments on the Proposed GIPSA Rule.



March 24, 2017

M. Irene Omade
1400 Independence Ave., NW
Room 2542A-S
Washington, DC 20250-3613

Re: Scope of Sections 202(a) and (b) of the Packers and Stockyards Act; Interim
Final Rule; RIN 0580-AB25; 81 Fed. Reg. 92566 (Dec. 20, 2016): and Unfair Practices
and Undue Preferences in Violation of the Packers and Stockyards Act; Proposed
Rule; RIN 0580-AB27; 81 Fed. Reg. 92703 (Dec. 20, 2016).

Dear Ms. Omade:

I appreciate the opportunity to comment on the proposed GIPSA Rule. The Beef
Marketing Group is a Cooperative focused on creating value with the cattle produced by our
family owned member feed yards. We consist of eighteen growing and feeding operations
located in the states of Kansas and Nebraska. In 2016 we produced approximately 600,000
head targeted to meet the needs of our customer and driven by meeting the needs of the
consumer. To achieve this we have implemented an aligned model based on a systems
approach to beef production. We have successfully broken down many traditional barriers
that have proven to be restrictive to our industry which allows us to be competitive in the
protein marketplace.

The implementation of the proposed rule would essentially destroy the progress we
have made and force us to dismantle the value based system we now have in place.
We would oppose the interim final rule and the unfair practices and undue
preferences proposed rules. We oppose both rules because they will make it easier to sue
under the Packers and Stockyards Act, which encourage needless lawsuits and those
lawsuits, or even just the threat of those lawsuits, will harm the longstanding business
relationships we have with our customer.

We have worked hard and invested considerably to distinguish our cattle and create
the opportunity for enhanced value. The new GIPSA rules are going to harm us because
they will result in our partner eliminating our marketing agreement and eliminating the
opportunity for the packer and our organization to enter into future agreements that are
unique to us. The Packers and Stockyards Act is supposed to help livestock producers but
these new rules will accomplish the opposite result and we oppose them for that reason.
Not only will the rules harm our company, they are a bad idea generally. Any rule
that encourages more lawsuits cannot be a good rule and the federal government should not
be supporting regulations that promote more litigation.

Respectfully submitted,

John Butler


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