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How the checkoff program works

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Liberty Belle

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I found this in the Rapid City Journal this morning and thought you might like to see it. I know and greatly respect Myron Williams and have never known him to spread misinformation:

How the checkoff program works
By Myron Williams, a Wall beef producer and chairman of the Federation of State Beef Councils Division, National Cattlemen's Beef Association.

WALL - There's a lot to be learned from talking with U.S. cattle producers. As chairman of the National Cattlemen's Beef Association Federation of State Beef Councils Division, I've found visiting with producers is always enjoyable. And sometimes frustrating.

Most frustration comes from confusion that still exists about who does what in the Beef Checkoff program. Although the checkoff has operated the same way since its inception in 1986, rumors and half-truths spread about the program have kept many producers in the dark about how it really works.

Here are the facts:

The Cattlemen's Beef Promotion and Research Board administers the Beef Checkoff program. Not NCBA. Not the U.S. Department of Agriculture. The Beef Board is made up of 107 checkoff-paying beef producers who sign off on every dollar spent through the Beef Board-administered program.

The producers who serve on the Beef Board are appointed by the U.S. Secretary of Agriculture. These individuals are dedicated to seeing that checkoff funds are used wisely.

The USDA oversees the actions of the Beef Board. All programs administered and budgets set by the Beef Board must first go through USDA scrutiny and receive USDA approval. This assures that the Checkoff Act and Order are followed, that programs are based on facts and that the Board is representing all beef producers paying into the program. Furthermore, by law checkoff dollars cannot be used for lobbying or in any other way influence government policy or action.

State Beef Councils are crucial to the success of the Beef Checkoff program. This seems to be overlooked in discussions about the checkoff. Forty-five qualified state beef councils that make up the Federation of State Beef Councils collect the $1-per-head checkoff assessment in their states and keep 50 cents to do promotion, information and research programs. The other 50 cents is sent to the Cattlemen's Beef Board.

Checkoff programs are implemented through a partnership between national industry organizations and state beef councils for a wide reach and impact. None of the participating organizations may profit from the checkoff. Instead, contractors provide the services at their cost, and are reimbursed for those costs only.

In-state checkoff programs are certainly an important element of the state's 50 cents. Some cattle-producing states, however, recognize the fact that the dollars are more effectively spent where there are more consumers. The Federation of State Beef Councils allows each state council board to combine some of the state "keep home" checkoff funds with dollars from Cattlemen's Beef Board contracts, creating cost-effective, expanded programs nationally and internationally.

Representatives from the federation, a division of the NCBA made up of state beef councils, participate in joint committees with Beef Board members to make recommendations to the Beef Board on spending of checkoff dollars in research, promotion and information.

States share national checkoff budget-establishing and decision-making power with the Cattlemen's Beef Board and USDA. The Beef Promotion Operating Committee, by law, recommends the budget for the national Beef Checkoff program and - makes recommendations to USDA as to which programs and projects that budget will fund. Ten of the committee's 20 members are elected by the Federation of State Beef Councils and 10 are elected by the Cattlemen's Beef Board.

When the Operating Committee deliberates on advisory committee recommendations, it requires acceptance by two-thirds of the Operating Committee members to approve a program or project. These are then sent on to the USDA for final review and approval.

This is the way the mandatory checkoff - approved by 79 percent of producers in 1988 - has always worked. And while we'll never please 100 percent of producers, the level of producer support for the checkoff has always been higher than 60 percent. That's based on independent research conducted twice a year every year the checkoff has been in existence.

Those facts can be verified. Now that the Supreme Court has confirmed the constitutionality of this effort, it's important that we get them out to producers throughout the country.

It has been my goal as chairman of the Federation of State Beef Councils Division to better communicate the important distinctions between the participating organizations and the separation of roles that help keep the checkoff program accountable. When producers know how the process operates, they more fully appreciate the overall power of the checkoff to benefit their operations.
November 26, 2005

http://rapidcityjournal.com/articles/2005/11/26/news/opinion/opin933.txt
 

mrj

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Liberty Belle, thanks for posting that. EVERY cattle producer needs to read and even to study that informative and factual piece about the Beef Checkoff. I hoped to find time to post it soon, and am glad you got it on sooner than I could have done.

I, too, have known, liked, and respected Myron as a person and as a dedicated volunteer improving the cattle/beef industry for more years than seems possible.......guess that old adage about time flying when we are having fun means I have had a LOTS of fun!

Myron is right on in his concise and clear explanation of the checkoff program.

MRJ
 

jigs

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any time you take money from the masses, and control it by a few, you are setting the stage for corruption and greed.

now that the people being screwed have raised to question of checkoff necessity, the might USDA steps in and gets the high court to claim it just and fair due to "beef...it's whats for dinner " constitutes govt. speech.

what part of the checkoff is paid by the packer, who REALLY reaps the reward for the beef in the supper market shelves??
 

mrj

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jigs said:
any time you take money from the masses, and control it by a few, you are setting the stage for corruption and greed.

now that the people being screwed have raised to question of checkoff necessity, the might USDA steps in and gets the high court to claim it just and fair due to "beef...it's whats for dinner " constitutes govt. speech.

what part of the checkoff is paid by the packer, who REALLY reaps the reward for the beef in the supper market shelves??

jigs, I happen to believe you are way out of your tree with some of your statements.

First, those so called "masses" VOTED to implement that Beef Checkoff, passing it by a margin of 79+%.

Second, those "masses" are fully represented with all ranchers having the opportunity to be involved in the governance of the Beef Checkoff. The projects originate with ranchers. Ranchers fill the seats on the various governing and operating boards. Ranchers decide which projects will be funded. There are term limits to prevent "empire building" in the governing and operating bodies.

Where has there EVER been any "corruption and greed" in the Beef Checkoff? FACT: those working on behalf of the Beef Checkoff are VOLUNTEERING their time at considerable cost to their own business. The ONLY thing, other than satisfaction of working for the good of the cattle/beef industry, they get is travel expenses. And my guess is that those expenses are not totally covered, either.

Actually, the facts of the court case against the Beef Checkoff are that LMA convinced some ranchers to help them end the checkoff by filing a lawsuit against it. The judge pointed out to them that a constitutionallity complaint would stand a better chance of success, and they jumped at that opportunity. USDA, the Nebraska Cattlemens' Assoc., and individual ranchers defended the Beef Checkoff in court AFTER IT WAS ATTACKED BY LMA AND FRIENDS. Your scenario is ludicrous! It was the attorneys for USDA and NE Cattlemen who presented the case that won the day in the Supreme Court. I was pretty certain that the Beef Checkoff was safe when Mr. Tribe, attorney for the plaintiffs stated that they raise cattle, not beef, and that they do not even like to think about the cattle they care so much about being slaughtered and eaten!

Packers and everyone else selling CATTLE pay the checkoff, with the exception of those who buy and sell, as in order buyers, auction markets, and others who are trading cattle and own them ten days or less. Importers pay too, on both live cattle and boxed beef.

Think about it, jigs, if you raise cattle, is it better for you if beef is selling well in the stores and restaurants, or is it worse? The work of the beef checkoff is much more than just advertising. Maybe you could learn something interesting and constructive if you would check out the information at www.beefboard.org . Surely studying that site would enable you to at least ask more sensible questions and refrain from making such silly statements and baseless accusations as in your post here.

MRJ
 

Econ101

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Jigs, Higher beef demand from consumers may just mean higher prices at the supermarket and not in producer's pockets. There are a lot of hands to go through before it gets to the producer. Why not just put a penny a lb. at the store for a checkoff? We keep hearing about the trickle down. It only makes sense to take the money where it shows up instead of producer pockets and then see if trickle down works. The beef checkoff is just captive advertising. Good idea, but bad execution.
 

mrj

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Econ101 said:
Jigs, Higher beef demand from consumers may just mean higher prices at the supermarket and not in producer's pockets. There are a lot of hands to go through before it gets to the producer. Why not just put a penny a lb. at the store for a checkoff? We keep hearing about the trickle down. It only makes sense to take the money where it shows up instead of producer pockets and then see if trickle down works. The beef checkoff is just captive advertising. Good idea, but bad execution.

Econ, if your idea were how the checkoff was funded, there would, and should, be no control of the checkoff by cattle producers. Producers pay the money, so we decide the programs and projects under the current system.

You sure are throwing lots of bricks at the Beef Checkoff. But you offer no examples of "bad execution". You offer no solutions, only criticism. How are YOU helping the cattle beef industry?

Advertising sells more beef. How would selling less beef help cattle producers? Why do you ignore the fact that the Beef Checkoff is much more than just advertising?

MRJ
 

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There are two flaws in MRJ's and Mr. Williams' explanation of how the checkoff works.

1. There is an omission of any explanation as to how it is decided who gets what contracts. I have worked in government procurement. In government procurement 3 competing bids are required for each contracted item. If the bid does not go to the lowest bid, then a detailed justification must be filed. I don't see that kind of process going on with the checkoff. I worked for a private industry carrying out government contracts. We had to follow government procurement requirements. If the checkoff promotes government speech, where are the government procurement requirements?


2. MRJ said "Second, those "masses" are fully represented with all ranchers having the opportunity to be involved in the governance of the Beef Checkoff."

This is misleading. In order to have a part in the governance of the checkoff I must be a member of certain organizations. Granted, additional organizations can have their name added to the "approved" list on the state level. But there is no way I as an individual not associated with any organization can be a part of the governance of the checkoff.

This was the problem Scalia alluded to when he spoke of the freedom of association issue with the checkoff. Many consider the Supreme Court decision a "win" for the checkoff. Scalia sowed the seeds of the checkoffs demise by raising the issue of freedom of association. The government speech argument proved that this is a government program, but the governance process requires specific association that is not permissible under the US Constitution. It is only a matter of time.

These two issues have not been addressed in the article and the following discussion.
 

mrj

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ocm said:
There are two flaws in MRJ's and Mr. Williams' explanation of how the checkoff works.

1. There is an omission of any explanation as to how it is decided who gets what contracts. I have worked in government procurement. In government procurement 3 competing bids are required for each contracted item. If the bid does not go to the lowest bid, then a detailed justification must be filed. I don't see that kind of process going on with the checkoff. I worked for a private industry carrying out government contracts. We had to follow government procurement requirements. If the checkoff promotes government speech, where are the government procurement requirements?


2. MRJ said "Second, those "masses" are fully represented with all ranchers having the opportunity to be involved in the governance of the Beef Checkoff."

This is misleading. In order to have a part in the governance of the checkoff I must be a member of certain organizations. Granted, additional organizations can have their name added to the "approved" list on the state level. But there is no way I as an individual not associated with any organization can be a part of the governance of the checkoff.

This was the problem Scalia alluded to when he spoke of the freedom of association issue with the checkoff. Many consider the Supreme Court decision a "win" for the checkoff. Scalia sowed the seeds of the checkoffs demise by raising the issue of freedom of association. The government speech argument proved that this is a government program, but the governance process requires specific association that is not permissible under the US Constitution. It is only a matter of time.

These two issues have not been addressed in the article and the following discussion.

ocm, surely you do realize Myron Williams' description of operation of the Beef Checkoff was a very brief overview and did not include all the detail.

Wouldn't it be reasonable to believe there is considerable difference in a contract allowing NO profit to the contractor, and one where the contractor will make a profit?

Obviously, R-CALF members and their compadres in the OCM, LMA, Resource Councils, et al intend the Beef Checkoff to be short lived as demonstrated by the MCA recommendations. It will be detrimental to the cattle producer should you succeed. However, it may well be the inspiration for a new system whereby ONLY those who participate will prodit from that system. So, there could be a silver lining for NCBA if the checkoff does end. Maybe we members can come up with one that actually DOES fund our organization, as opposed to the current one that costs us money.

Re. you supposed exclusion from governance of the Beef Checkoff........your buddies in LMA have claimed to represent you "ranchers who do not join organizations". You certainly can attend the state Beef Council meetings and state your views. I dare say, you could run for a seat on the state board, if your are in a state that elects the directors. But it is so much easier, and maybe even more satisfying for some people, to just criticize than to work to make a difference, that I understand your point.

I haven't seen much from Scalia that impressed me, and hopefully, so long as the Beef Checkoff is supported by such a large percentage of cattle producers, it will continue to well serve the cattle industry.

MRJ
 

Murgen

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Jigs, Higher beef demand from consumers may just mean higher prices at the supermarket and not in producer's pockets. There are a lot of hands to go through before it gets to the producer. Why not just put a penny a lb. at the store for a checkoff? We keep hearing about the trickle down. It only makes sense to take the money where it shows up instead of producer pockets and then see if trickle down works. The beef checkoff is just captive advertising. Good idea, but bad execution.

Jigs, Higher beef demand from consumers may just mean higher demand at the supermarket for producer's product. There are a lot of hands to go through before it gets to the consumer. Why not just put a penny a lb. at the store for a checkoff? Volume of pennys adds up! We keep hearing about the trickle up. It only makes sense to take the money where it shows up instead of producer pockets and then see if trickle up works. The beef checkoff is just captive advertising, for the producer's benefit. Good idea, but bad execution of blame.

Wher is the greatest margin?
 

jigs

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I sure see more chicken and pork ads than beef. if this great program is so benifcial, why is it so hidden in the market place? or are them funding the "subliminal message" where I don't see it, but I want to eat beef anyway?

if you truely believe the checkoff is in YOUR best interest, then I suppose you enjoy paying taxes, because you trust the government more with your money than you trust yourself.
 

ocm

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MRJ said:
ocm said:
There are two flaws in MRJ's and Mr. Williams' explanation of how the checkoff works.

1. There is an omission of any explanation as to how it is decided who gets what contracts. I have worked in government procurement. In government procurement 3 competing bids are required for each contracted item. If the bid does not go to the lowest bid, then a detailed justification must be filed. I don't see that kind of process going on with the checkoff. I worked for a private industry carrying out government contracts. We had to follow government procurement requirements. If the checkoff promotes government speech, where are the government procurement requirements?


2. MRJ said "Second, those "masses" are fully represented with all ranchers having the opportunity to be involved in the governance of the Beef Checkoff."

This is misleading. In order to have a part in the governance of the checkoff I must be a member of certain organizations. Granted, additional organizations can have their name added to the "approved" list on the state level. But there is no way I as an individual not associated with any organization can be a part of the governance of the checkoff.

This was the problem Scalia alluded to when he spoke of the freedom of association issue with the checkoff. Many consider the Supreme Court decision a "win" for the checkoff. Scalia sowed the seeds of the checkoffs demise by raising the issue of freedom of association. The government speech argument proved that this is a government program, but the governance process requires specific association that is not permissible under the US Constitution. It is only a matter of time.

These two issues have not been addressed in the article and the following discussion.

ocm, surely you do realize Myron Williams' description of operation of the Beef Checkoff was a very brief overview and did not include all the detail.

Wouldn't it be reasonable to believe there is considerable difference in a contract allowing NO profit to the contractor, and one where the contractor will make a profit?

Obviously, R-CALF members and their compadres in the OCM, LMA, Resource Councils, et al intend the Beef Checkoff to be short lived as demonstrated by the MCA recommendations. It will be detrimental to the cattle producer should you succeed. However, it may well be the inspiration for a new system whereby ONLY those who participate will prodit from that system. So, there could be a silver lining for NCBA if the checkoff does end. Maybe we members can come up with one that actually DOES fund our organization, as opposed to the current one that costs us money.

Re. you supposed exclusion from governance of the Beef Checkoff........your buddies in LMA have claimed to represent you "ranchers who do not join organizations". You certainly can attend the state Beef Council meetings and state your views. I dare say, you could run for a seat on the state board, if your are in a state that elects the directors. But it is so much easier, and maybe even more satisfying for some people, to just criticize than to work to make a difference, that I understand your point.

I haven't seen much from Scalia that impressed me, and hopefully, so long as the Beef Checkoff is supported by such a large percentage of cattle producers, it will continue to well serve the cattle industry.

MRJ

MRJ said:
ocm, surely you do realize Myron Williams' description of operation of the Beef Checkoff was a very brief overview and did not include all the detail.

That was partly my point. Those two issues are significant and need to be addressed.

MRJ said:
Wouldn't it be reasonable to believe there is considerable difference in a contract allowing NO profit to the contractor, and one where the contractor will make a profit?

Absolutley not! It is unconscionable not to have a competitive process consistent with government procedures. Remember the government itself is "non-profit." Surely you realize there is a difference between "non-profit" and "efficient". It is the competitive process that promotes efficiency according to Adam Smith. Shouldn't we want our "non-profit" organizations to be efficient? If they are non-competitive monopolies they will not be.


MRJ said:
your buddies in LMA have claimed to represent you
They don't. This is a legal argument. It still remains unaddressed. Voting for a representative on a beef council requires me to join something somewhere. That was Scalia's argument.
MRJ said:
I haven't seen much from Scalia that impressed me

That would put you somewhere to the left of me politically. And of George Bush. The usual argument is that people like me are raging liberals. I guess not.
 
A

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Conman: "Jigs, Higher beef demand from consumers may just mean higher prices at the supermarket and not in producer's pockets. There are a lot of hands to go through before it gets to the producer. Why not just put a penny a lb. at the store for a checkoff? We keep hearing about the trickle down. It only makes sense to take the money where it shows up instead of producer pockets and then see if trickle down works. The beef checkoff is just captive advertising. Good idea, but bad execution."


Conman 101 calls the checkoff captive advertising yet he cannot explain why boxed beef prices drive live cattle prices. One more example of Conman's enternal ignorance.

Nobody has more incentive to improve beef demand than the producer does. The packer, the retailer, and the feeder are all margin operators AND THE PRODUCER GETS WHAT IS LEFT.

The retailer pays the packer according to what consumers pay for beef.
The packer pays the feeder for his cattle according to what the retailer pays for boxed beef.
The feeder pays the producer according to what the packer is paying for fat cattle.

THE PRODUCER GETS WHAT IS LEFT.

The retailer, packer, and feeder are going to price their raw products according to what they get paid and the producer gets what is left.

WHO HAS THE MOST INCENTIVE TO PROMOTE BEEF CONSUMPTION IN THAT SITUATION????

How ironic that those who are so critical of the packing industry would like the packers to pay for the checkoff so they could pay that much less for our cattle and have control of how those dollars are spent. The ignorance never ends!

Mark my words, these same packer blamers who are bitching about the packers and retailers not paying more into the checkoff would be bitching about the packers having control of the checkoff if they were paying more in to the program.

We got some real wizards out there.


OCM,

Give me an exampe of misappropriation of checkoff funds since you are so concerned about who gets the contract or is this just something else for the industry blamers to bitch about?



~SH~
 

Econ101

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~SH~ said:
Conman: "Jigs, Higher beef demand from consumers may just mean higher prices at the supermarket and not in producer's pockets. There are a lot of hands to go through before it gets to the producer. Why not just put a penny a lb. at the store for a checkoff? We keep hearing about the trickle down. It only makes sense to take the money where it shows up instead of producer pockets and then see if trickle down works. The beef checkoff is just captive advertising. Good idea, but bad execution."


Conman 101 calls the checkoff captive advertising yet he cannot explain why boxed beef prices drive live cattle prices. One more example of Conman's enternal ignorance.

Nobody has more incentive to improve beef demand than the producer does. The packer, the retailer, and the feeder are all margin operators AND THE PRODUCER GETS WHAT IS LEFT.

The retailer pays the packer according to what consumers pay for beef.
The packer pays the feeder for his cattle according to what the retailer pays for boxed beef.
The feeder pays the producer according to what the packer is paying for fat cattle.

THE PRODUCER GETS WHAT IS LEFT.

The retailer, packer, and feeder are going to price their raw products according to what they get paid and the producer gets what is left.

WHO HAS THE MOST INCENTIVE TO PROMOTE BEEF CONSUMPTION IN THAT SITUATION????

How ironic that those who are so critical of the packing industry would like the packers to pay for the checkoff so they could pay that much less for our cattle and have control of how those dollars are spent. The ignorance never ends!

Mark my words, these same packer blamers who are bitching about the packers and retailers not paying more into the checkoff would be bitching about the packers having control of the checkoff if they were paying more in to the program.

We got some real wizards out there.


OCM,

Give me an exampe of misappropriation of checkoff funds since you are so concerned about who gets the contract or is this just something else for the industry blamers to bitch about?



~SH~

SH, tell me why a tax for advertising beef would not work better if it were taken at the retail level. After all, this is your argument in reverse. I would much rather see margins at the retail level go down 1 penny a lb. than to see it taken off the animal before the hide comes off.
 
A

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Conman: "SH, tell me why a tax for advertising beef would not work better if it were taken at the retail level."

I just did!

Nobody has more incentive to promote beef than the producer does because ever other segment of this industry operates on a margin and we get what is left. When we increase the amount that consumers pay for beef, our profit increases.

Why do you want retailers and packers to have more control of the beef checkoff when they will simply turn around and deduct that expense from the price of our cattle? WE PAY EITHER WAY so why not have control of how those dollars are spent like we do now?

How ironic that you, the ultimate packer and retailer critic, wants to give the retailer and packer more control of our checkoff program.


Conman: "I would much rather see margins at the retail level go down 1 penny a lb. than to see it taken off the animal before the hide comes off."

Because you don't know any better.

We pay either way. We either pay for the checkoff and have control or the packer or retailer pays the checkoff, takes control of the program and pays that much less for boxed beef and/or cattle.

Either way, THE PRODUCER GETS WHAT'S LEFT!


Now, with that said, I support your idea IF THE PRODUCER IS THE PACKER AND RETAILER as is the case with Harris Ranches.


~SH~
 

Sandhusker

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SH, "Conman 101 calls the checkoff captive advertising yet he cannot explain why boxed beef prices drive live cattle prices. One more example of Conman's enternal ignorance."

If boxed beef drives cattle prices, why weren't Canadian producers getting the same price for their cattle as US producers? Boxed beef prices were about the same, but there was a huge disaprity in cattle prices of the two countries. Is your ignorance internal or eternal?
 

Econ101

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~SH~ said:
Conman: "SH, tell me why a tax for advertising beef would not work better if it were taken at the retail level."

I just did!

Nobody has more incentive to promote beef than the producer does because ever other segment of this industry operates on a margin and we get what is left. When we increase the amount that consumers pay for beef, our profit increases.

Why do you want retailers and packers to have more control of the beef checkoff when they will simply turn around and deduct that expense from the price of our cattle? WE PAY EITHER WAY so why not have control of how those dollars are spent like we do now?

How ironic that you, the ultimate packer and retailer critic, wants to give the retailer and packer more control of our checkoff program.


Conman: "I would much rather see margins at the retail level go down 1 penny a lb. than to see it taken off the animal before the hide comes off."

Because you don't know any better.

We pay either way. We either pay for the checkoff and have control or the packer or retailer pays the checkoff, takes control of the program and pays that much less for boxed beef and/or cattle.

Either way, THE PRODUCER GETS WHAT'S LEFT!


Now, with that said, I support your idea IF THE PRODUCER IS THE PACKER AND RETAILER as is the case with Harris Ranches.


~SH~

SH, do the spreads between retailer and producer always remain the same? That is your argument for producers to benefit.
 

Jason

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Sandhusker said:
SH, "Conman 101 calls the checkoff captive advertising yet he cannot explain why boxed beef prices drive live cattle prices. One more example of Conman's enternal ignorance."

If boxed beef drives cattle prices, why weren't Canadian producers getting the same price for their cattle as US producers? Boxed beef prices were about the same, but there was a huge disaprity in cattle prices of the two countries. Is your ignorance internal or eternal?

Canadian boxed beef selling into the US market has been at a discount. I am not sure if this is still the case, but it was prior to the opening of the border to live cattle.

We still had the problem of more cattle than slaughter space that had something to do with the price difference.
 
A

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Sandbag: "If boxed beef drives cattle prices, why weren't Canadian producers getting the same price for their cattle as US producers? Boxed beef prices were about the same, but there was a huge disaprity in cattle prices of the two countries."

Canadian packers had the added costs of SRM removal in UTM cattle. This was revealed in the Canadian government's investigation.

Packers in Canada profitted from a situation of more cattle than slaughter capacity. That is not the situation in the U.S.


NEXT!



~SH~
 

Sandhusker

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~SH~ said:
Sandbag: "If boxed beef drives cattle prices, why weren't Canadian producers getting the same price for their cattle as US producers? Boxed beef prices were about the same, but there was a huge disaprity in cattle prices of the two countries."

Canadian packers had the added costs of SRM removal in UTM cattle. This was revealed in the Canadian government's investigation. Packers in Canada profitted from a situation of more cattle than slaughter capacity. That is not the situation in the U.S. NEXT!

They're still removing SRMs and the prices for fats has risen considerably. This tells us your SRM removal expense excuse is a smoke screen. Why doen't your single bias of truth come forward and admit that boxed beef does not always drive cattle prices? Quit spinning and making excuses. Tell the truth.


So now you say packer's profited from a lack of slaughter capacity. Yet, you say fat prices track boxed beef. Which is true?
 

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