Food Aid: Food Aid Dockage Levels: Comments offered to FAS
April 5, 2002
Ms. Ellen Terpstra, Administrator
US Department of Agriculture
Foreign Agricultural Service - Stop 1001
1400 Independence Ave., SW
Washington, DC 20250
Dear Ms. Terpstra:
We are writing in response to the Department of Agriculture's March 7, 2002 Federal Register Notice asking for comments on the Department's Clean Wheat Initiative which was originally launched in June 2000.
During the time the Clean Wheat Initiative has been in force, the dockage levels on U.S. food aid shipments have been reduced under the first step from 1.0 percent to 0.8 percent, a further reduction to 0.7 percent was made in FY 2001, and on February 5, 2002 the level was reduced to 0.6 percent. The Department is now considering whether to continue the reductions to the 0.5 percent level as originally planned.
Our producers see the trend toward customer demand for cleaner wheat as a continuing process, and they indicated their strong support for this further step during a recent meeting of the U.S. Wheat Quality Committee.
The Department held a hearing and sought comments in the Federal Register before launching this initiative. The initiative was in response to repeated complaints, voiced over the years, about the high levels of dockage present in U.S. wheat shipments, and particularly in food aid shipments. While FAS Administrator Tim Galvin had considered several options for lowering dockage, this was the only option accepted by USDA. It is now the only tool that USDA has to help deal this problem.
Not only is dockage an impediment to efficient milling, especially when the mills are not of the most modern design, but there are also increasing environmental concerns in many wheat importing countries over dust emissions from vessels being unloaded. Commercial buyers are also concerned over paying freight and import duties on dockage which has little residual economic value. Thus, we are receiving more -- not fewer -- calls for lower dockage.
While some might see this as a modest or incremental step, it does signal the direction toward providing cleaner US wheat exports. The competition is already offering wheat with dockage levels (0.2 - 0.3 percent), well below the 0.5 percent target of the initiative. We cannot envision the United States reverting back to the earlier 1.0 percent dockage level on food aid.
We strongly urge the Department of Agriculture to proceed to set the dockage standard at 0.5 percent on its food aid programs for the new fiscal year (FY 2003) beginning on October 1, 2002.
Alan T. Tracy
US Wheat Associates
National Association of Wheat Growers
Wheat Export Trade Education Committee
cc: Bob Riemenschneider