TCFA GIPSA rule comment 11 22 10-pg1

November 22, 2010 Ms. Tess Butler GIPSA United States Department of Agriculture 1400 Independence Avenue, S.W. Room 1643-S Washington, DC 20250-3604 RE: Comments of the Texas Cattle Feeders Association on Farm Bill Comments, TEXAS 1Proposed Regulations, 75 Fed. Reg. 35338-35354 (June 22, 2010) CATTLE Dear Ms. Butler: FEEDERS ASSOCIATION Texas Cattle Feeders Association (TCFA) opposes the Proposed Rules contained in “Implementation of Regulations Required Under Title XI of the Food, Conservation 5501 I-40 W. and Energy Act of 2008; Conduct in Violation of the Act (the “Proposed Rules”).” The Amarillo, TX 79106-4617 Proposed Rules have been issued by the Grain Inspection, Packers and Stockyards (806) 358-3681 FAX (806) 352-6026 Administration (“GIPSA”) pursuant to the provisions of the Packers and Stockyards info@tcfa.org Act, 1921 (the “PSA”), 7 U.S.C. § 181 et seq., and Title XIwww.tcfa.org and Energy Act of 2008 (the “Farm Bill”) (P.L. 110-246). TCFA also strongly supports and associates itself with comments filed by the National Cattlemen’s Beef Association. Bo Kizziar Chairman GIPSA, among other things, failed to perform an adequate economic impact analysis James M. Peters as required by administrative law; failed to consider several decades of legal Chairman-Elect precedent requiring proof of injury to competition; failed to recognize Congressional Walt Olson intent and rejection of similar proposals during ...