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Docket No. 03-080-2

Regulatory Analysis and Development

PPD APHIS, Station 3C71

4700 River Road Unit 18

Riverdale, MD 20737-1238

RE: Proposed Rule to open US-Canadian border to allow live cattle from Canada

Docket No. 03-080-2

April 7, 2004

 

Dear APHIS,

The South Dakota Stockgrowers Association is a group of 1470+ dues-paying members, primarily independent cattle producers operating family ranches. As an organization, we focus on regaining profitability for independent cattle producers in South Dakota and the entire United States.

The South Dakota Stockgrowers Association opposes the proposal to open the Canadian border to live cattle. In addition, we urge USDA to ban the importation of any beef from Canada at this time, including the boxed beef that is currently allowed into this country.

Canada does not meet the internationally recognized standard for classification as a "Minimal BSE-Risk Country or Zone" under OIE standards. Canada’s ban on feeding ruminant by-products to ruminants has only been in place for six years, not the eight years required by the OIE for a country to obtain a "minimal risk" status.

Currently, the United States is classified as a BSE Provinsially Free Country or Zone, under OIE standards, and for the USDA to facilitate the movement of Canadian live cattle into the United States will put the United States cattle herd at high risk of losing that status.

The suggestion that the United States should invite Canadian live

cattle is irresponsible and illogical. Currently, the U.S. beef export market is effectively stalled. Opening the border to Canadian cattle at this time will flood our market with unneeded beef and cattle and will create an oversupply of beef. Canadians are likely prepared to sell live cattle at less than the cost of production, in an effort to move cattle, which are a perishable product. This potential dumping will likely cause the cattle market to crash, putting an undue and unnecessary burden on the U.S. taxpayer. The benefits from the economic input of the U.S. cattle industry will be severely reduced if U.S. cattle producers are no longer profitable. The U.S. cattle industry greatly impacts the economy. The cattle industry is vital to the economic well-being of South Dakota, and the United States. When the cattle industry struggles, so do many other segments of the economy. We’ve witnessed firsthand the taxpayer burden that BSE caused in Canada. Do we want the same for U.S. taxpayers?

Allowing the importation of beef and live cattle from Canada will jeopardize the economy by unnecessarily risking the health and stability of the U.S. cattle herd and forcing U.S. producers to compete with de-valued and packer-owned Canadian cattle.

Allowing Canadian cattle into the U.S. is like playing a game of high stakes poker. We can see our opponent’s winning hand, the deck is clearly stacked against us - how can we bet all of our chips, knowing that we will lose? The only winners in this game would be the international processing conglomerates who are desperate to ship underpriced Canadian cattle into the U.S. and sell them as "U.S. Beef" on our relatively high market. But, if more cases of BSE are discovered to have been shipped in the U.S. from Canada, even they will lose.

The South Dakota Stockgrowers Association supports and endorses those comments submitted by our national organization, R-CALF USA.

Sincerely,

Ken Knuppe

President

South Dakota Stockgrowers Association