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From:
Brian Merrill <[log in to unmask]>
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Date:
Fri, 26 Dec 1997 11:36:51 -0800
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I have just received the following information from Joe Rowland, a
beekeeping colleague from upstate New York and he has asked me to 
forward it to the list.  I beg the indulgence of all
the non-US beekeepers but this is in regards to a current debate within
the US beekeeping industry.  The information is in 3 parts; a cover
letter to the overall text, an editorial analysis of the legislation
proposed by ABF and lastly a form letter to be sent to Congressional
representatives.
 
Brian Merrill
Ellie Bee Apiaries
61 Calumet St., Depew, NY  14043
 
part 1 starts here;
 
December 18th, 1997
 
re: Proposed Honey Board Expansion
 
Dear Mr./Mrs. Beekeeper,
 
I’d like to ask you to take a few minutes of your valuable time to read
an editorial analysis of the legislation presently pending in Congress
that would expand and change the structure and powers of the National
Honey Board.  It was written by Joe Rowland, who after graduating from
Cornell University College of Agriculture in 1973, worked for beekeepers
across the United States (Dave Powell - CA, Charlie Zollinger - UT, Dave
Howland - NY).  For the past 20 years he has operated his own 300 colony
apiary in upstate New York.
 
After a recent hard look at the legislation, Joe wrote this editorial
with the hope of galvanizing beekeeper opposition to it.  This bill, if
passed in Congress and approved in a referendum will:
 
        1) Cost you a bundle;
        2) Tip control of the National Honey Board over to the big honey
           packer’s & importer’s interests, possibly permanently;
        3) Benefit large honey packers & importers hugely while
           benefiting American beekeepers only slightly, if at all;
        4) Add more cumbersome rules & regulations to your life.
 
If after reading it, you disagree, please circular file immediately.
Conversely, if you generally think it darn close to the mark, I ask that
you please do the following:
 
        1) Make 10 copies of this cover letter and the article.
 
        2) Send these copies to 10 beekeepers that you know or know of
           that might be interested in a different view from what we’ve
           been seeing in the beekeeping publications.  Out of state 
           contacts are especially good.
 
        3) Immediately contact your Congressional representatives and
           ask that this legislation not be inserted into the
           Agricultural Research Bill (S1150 in the Senate; 
           HB2534 in the House) and briefly tell them why you think 
           it is a bad bill for beekeepers.  To reach your 
           Congressman’s office, call 202-225-3121 for the capital
           switchboard.  To reach your Senator’s office, call
           202-224-3121.
 
If we all pull together on this right away the majority of American
beekeepers could see this take action in a few weeks.  This legislation
has major implications for us all.  Let’s grab this bull by the horns
and advocate for our own interests at this critical point.  Your future
is in your hands.
 
part 2 start here;
 
                            The 2 CENT BOARD
 
                         A Beekeeper’s Assessment
 
If enacted, the proposed revisions to the Honey Research, Promotion, and
Consumer Information Act will double the assessment on honey from 1 to 2
cents per pound, dramatically alter the Industry representation on the
National Honey Board, and expand the mandate of the Honey Board beyond
generic honey promotion to encompass quality control issues, and
research funding.  Contrary to misinformation being distributed by the
American Beekeeping Federation on behalf of the National Honey Packers
and Dealers Association and Sioux Honey Association, the proposed
legislation is not in the best interests of American beekeepers and in
fact would work against their interests.  The main beneficiaries would
be large honey packers, importers, and some large producers.  These
groups are vigorously promoting the proposed legislation at beekeeper
meetings and through paid advertising in the apicultural trade
magazines.
 
                          The Assessment (Section 7.9)
 
Many beekeepers don’t believe that the additional assessment on their
production will be paid for by the packer who purchases their honey.  In
fact, the additional assessment will be paid for by the beekeeper in the
form of a lower offering price from the packer.  In the present weak
wholesale honey market, this is a very likely scenario.  Combine this
situation with the advertising credit provisions of the proposed
legislation (Sec 9j), where 50% of the so-called packer assessment may
be used to offset 50% of their advertising expense, and the American
beekeeper will, in effect, be subsidizing large honey packer advertising
budgets!
 
One stated purpose of the proposed legislation (Sec 2.4b 2A) is, “to
maintain and expand the markets for all honey and honey products in a
manner that is not designed to maintain or expand any individual
producer’s, importer’s or handler’s share of the market”.  The
additional assessment coupled with the advertising credit contradicts
this purpose by favoring those large packers who will have advertising
costs dramatically reduced while smaller producer/packers who cannot
afford an advertising budget will pay the full assessment (passed on, of
course, in either case to the beekeeper).  A few large packers will
thereby gain a competitive advantage over the vast majority of small
producer/packers who pack and market a portion of their production.
 
              National Honey Board Reconstitution (Section 7)
 
The proposed legislation significantly re-aligns the Honey Board by
adding two (2) packer representatives and eliminating the public member
seat.  The new set-up would be 7 producers, 4 packers, 2 importers, and
1 seat representing a major inter-regional cooperative, i.e. Sioux
Honey.  All of the non-producers (packers, importers, coop, etc.) will
tend to have priorities that will favor large packer interests.  Most
imported honey flows through the large packers and the inter-regional
cooperative which is functionally a large packer.  At least one of the
producer-reps would be likely to tilt toward the packer viewpoint as
some are closely associated with packers.  What we will then have is a
packer-controlled Honey Board which is absolutely not in the best
interests of the vast majority of small to medium sized producers and
producer/packers.  Most beekeepers I’ve discussed this with are in
agreement on this.
 
                     Re-Reconstitution?  (Section 7)
 
Even more alarming is the likelihood that large packer-importer
interests would have outright control after 5 years.  This is possible
because the proposed legislation (Sec 7b4) provides for a reconstitution
of the representation based on, “the geographic distribution of the
quantities of domestically produced honey assessed..., and changes in
the annual average percentage of assessments owed by importers...,
relative to assessments owed by producers and handlers of domestic
honey...”.  If these proportions are found to vary by more than 6% from,
“the base period proportions,... (1996 fiscal year of the Honey Board)”,
then the make-up of the Honey Board will again be re-aligned to reflect
the more recent proportions.  I believe import assessments were
relatively low in fiscal 96 relative to producer assessments.  The world
honey market was very tight then and the Chinese had cut back
dramatically on exports to the US.  Imports have surged upward in 97 and
domestic production is down significantly this year.  Also, as domestic
consumption continues to increase, those increases will be provided for
not by domestic production, but by increased importation.  When
“reconstitution” time arrives, producer representation will decrease and
large packer interests will unequivocally come to control the Honey
Board.
 
                      Quality Control (Section 8)
 
Another provision of the proposed legislation (Sec 8e9) concerns the
creation of a, “Voluntary Quality Program”.  There will be, “the
establishment of an official Honey Board ‘Seal of Approval’ to be
display on honey and honey products of producers, handlers, and
importers participating in the voluntary program found to meet such
standards of purity as may be established”.  This would entail, “actions
to encourage producers, handlers, and importers to participate in the
program; actions to encourage consumers to purchase honey and honey
products bearing the official seal of approval; periodic inspections by
the Secretary, or other parties approved by the Secretary, of honey and
honey products of producers, handlers, and importers participating,
etc...”.    Again this is in conflict with the stated intent and
purposes of the proposed legislation (Sec 2, 4b2A) in that it will
effectively favor those who comply with the, as yet unestablished,
standards of purity.  What might those standards be?  Will those
standards promote ultra-filtration, pasteurization, or other processing
techniques available only to the largest packers?  Would these standards
pander to large packers who could then brandish their ‘official seal of
approval’ in efforts to increase their market share?  A lot of smaller
packers and beekeepers think the answer to that question is yes.  Our
customers know us and know that we sell a “quality” product already.  We
don’t want to pay an assessment to support a promotional vehicle which
will likely be beyond our reach and that raises big packer sales and
profits at our expense.
 
                          Adulteration (Section 8)
 
The Honey Board would be authorized to develop, “recommendations for
programs and rules and regulations... regarding purity standards for
honey and honey products...  Any program, rule, or regulation issued...
may provide for the inspection... of honey and honey products”.  At a
glance this seems quite reasonable since virtually all beekeepers are
opposed to the adulteration of honey.  This is a much bigger problem for
large packers and importers who obtain their honey from the world
marketplace than it is for a smaller packer or producer who generally is
familiar with the source of his/her honey and is confident of its
purity.  Not surprisingly, twice (2X) as much of our assessment funding
($1,000,000.00) is earmarked for adulteration research/quality control
than is budgeted for beekeeping research ($500,000.00) which will help
keep domestic producers viable.  Should American beekeepers pay for
this?  The responsibility to protect the purity and quality of the
nation’s food supply is expressly the duty of the FDA.  I think they
should do that job through public funding for the public good.  More
testing of imported honey is needed and the FDA is well suited to do
that in the public interest.
 
                          Research (Section 7)
 
The proposed legislation recommends that 8% of collected assessments be
designated for, “approved research projects designed to advance the cost
effectiveness, competitiveness, efficiency, pest and disease control,
and other management aspects of beekeeping and honey production.”  That
sounds great, but in fact is a poor value for beekeepers.  The
approximately 1/2 million dollars raised will not go very far and is in
fact a small splash in the national research bucket for apiculture.
Eight (8) cents of the assessment dollar will be spent on research that
beekeepers might support (or not!) and ninety two (92) cents will be
spent to protect and promote packer/importer interest on the newly
restructured Honey Board.  Does this make sense for beekeepers?  More
research funding is desperately needed, especially in the search for and
registration of cost-effective, low-hazard mite controls.  However in
the context of the overwhelmingly packer-friendly legislation, its main
purpose is to provide smoke and mirrors necessary to win beekeeper
support.
 
                    The Referendum and the Bottom Line
 
The proposed revisions to the Honey Research, Promotion, and Consumer
Information Act will benefit large honey packing interests in several
ways while providing a minimum of benefit to the beekeepers who will pay
for it.  Even the referendum process itself will give the large packer
an advantage.  Every eligible assessment-paying voter has only one vote
that is worth one unit and another vote which is weighted by the size of
the assessment paid.  Both types of vote are tallied separately and both
totals must exceed 50% in order to approve the referendum.  A packer who
imports would receive 2 voting units for each pound of honey handled.
The same is true for a packer who is also a producer.  Remember that 15
packers handle 50% of the honey packed in the USA.  If, in effect, the
packers are passing their assessment on to the beekeepers through a
lower offered price, then the beekeepers are paying for part of the
packer’s weighted vote!  Will they (the packers) use that vote (paid for
by you) to their benefit or the beekeepers?  Will your assessment be
spent in a way that benefits your business and justifies what amounts to
an income tax of several percent on your profits?  Remember that the
Honey Board assessment comes right off the top and as your profit margin
per pound narrows due to lower offered prices, your Honey Board “Income
Tax” escalates.  In a weak market can you afford to double this tax when
your tangible return is minimal?
 
                        The Time for Action
 
Beekeepers need to contact their Congressional representatives and tell
them what they think about this legislation immediately.  I think that
bigger is not necessarily better for the Honey Board, that producers
should clearly control the Honey Board, and that the American Beekeeping
Federation is not speaking for a majority of American beekeepers when
they promote these proposed revisions to the Honey Research, Promotion,
and Consumer Information Act.  I also believe that we need to talk to
our beekeeping friends and others with the aim of mounting a grassroots
effort to block this legislation before it becomes law and goes to the
referendum stage.  If it should go to referendum we will have to defeat
it there, and we can expect a long and bitter struggle in the process.
The time to act is now!
 
part 3 starts here;
 
Dear Sir:
 
I’m writing today in regard to proposed legislation, The Honey Research,
Promotion, and Consumer Information Act, that is being considered for
inclusion in S1150 (HB2534), The Agricultural Research Bill.
 
The proposed legislation works against American beekeeper interests in
many ways and promotes the interest of large honey packers and
importers.  Inclusion and approval of the Act will ultimately promote
increased imports of honey effecting balance of trade, and reduce the
viability of domestic producers.  I am strongly opposed to the insertion
of this Act into the Agricultural Research Bill.  Please refer to the
enclosed editorial analysis of the Act for more in-depth information
regarding its contents.
 
American beekeepers provide pollination services, paid and unpaid, to
large sectors of American agriculture.  Their continued economic
vitality is already under siege by bee diseases, pesticide damage, a
weak world honey market, increasing expenses, and creeping urbanization
of former agricultural areas.
 
The value of honey bee pollinated food and fiber runs into billions of
dollars and is therefore of importance to many sectors of agriculture
and the nation’s food supply.  The general public interest is thus
served by a vigorous domestic beekeeping industry.
 
Please help American beekeepers block this damaging proposal from
becoming law.
 
Thanks in advance for your cooperation.
 
Best regard,

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