Comments: 83% say keep border closed
May 17, 2004
By Jennifer Womack, Managing Editor
Wyoming Livestock Roundup (WYLR)

P.O. Box 850

Casper, Wyoming 82602

307-234-2700 or 800-967-1647
To submit a Letter to the Editor:
Casper, Wyoming - Livestock producers, agribusiness people and interested parties from across North America, numbering over 3,400, submitted comments on the recently-closed comment period regarding the definition of "minimal risk region" as it relates to BSE.

According to a USDA spokesperson, the response is nearly three times that normally received on USDA's higher profile issues. She said in some ways it was more like a "petition" than a comment process. If USDA changes the definition of minimal risk Canada would become eligible to import bone-in beef and live cattle to the U.S.
Some of those submitting comments cited health reasons, other economic reasons and some cited both.

The Wyoming Livestock Roundup spent early May sorting through the 1,633 "unique" comments posted on the U.S. Department of Agriculture's website.
Those comments were combined with what USDA considers identical comments, in some cases form letters, to arrive at numeric analysis of what the comments had to say.

"We're not statisticians," said Wyoming Livestock Roundup publisher Del Tinsley, "but the comments submitted to USDA easily fell into one of three categories -- for a change in the minimal risk definition and normalized trade with Canada, against a change, or neutral. We sorted the comments into those three categories and based our percentages on those numbers. Overwhelmingly, those commenting opposed a change in the rules and normalized trade with Canada."

Of the 3,378 total comments received by USDA, 83% were opposed to a change in the definition or a change that could result in normalized trade with Canada. Eight percent were in favor of normalized trade, while the remaining 9% either didn't state a position or commented on other species impacted by the current trade restrictions, such as alpaca, bison and sheep.

USDA spokesperson Andrea McNally, during a May 11 interview, said the process isn't a voting process, but a search for substantial comments. She confirmed that if even 90% of those commenting were opposed to the change in definition or normalized trade with Canada, it wouldn't necessarily mean postponement of the decision or a withdrawal of the proposal. McNally also said that USDA is still reviewing the comments and doesn't yet have a timeline for when that process will be complete.

Mid-April the Roundup broke the news that USDA was accepting comments from Canada on the proposed rule. Of all comments received, at least 4% were from Canada. Of the unique comments received, at least 7% stemmed from Canada. Some comments did not include an address and therefore their source could not be determined.

Of the 1,633 unique comments submitted, and subsequently posted on USDA's website, 64% were in opposition to a change in the definition or anything that would result in normalized trade with Canada. Twenty-two percent were in favor of normalized trade with Canada. Over 60% of the comments in favor of normalized trade stemmed from Canada.

Of the 1,633 comments, 676 were submitted during the first comment period, which ended January 5, 2004. Considering the discovery of a BSE-infected cow from Canada in Washington State and announced December 23, USDA reopened that comment period for a month beginning on March 8 and ending on April 8. During that second round of the comment period the remaining 957 unique comments were received. The majority of those comments considered form letters or identical comments by the agency were received during the second half of the comment period.