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| # [Meat Importers Council of America, Inc.]{.smallcaps}               |
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| 1901 NORTH FORT MEYER DRIVE • ARLINGTON, VIRGINIA 22209               |
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| \(703\) 522-1910 • FAX (703) 524-6039 • E-mail: micausa@aol.com       |
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September 24, 2007

Mr. Warren Preston

Chief, Livestock and Grain Market News Branch

Agricultural Marketing Service

U.S. Department of Agriculture

Room 2619-S

1400 Independence Ave. SW,

Washington DC 20250-0252

**Re: Livestock Mandatory Reporting; Proposed Rule - Docket LS-07-01**

This submission is provided on behalf of the Meat Importers Council of
America, Inc. ("MICA") pursuant to the USDA AMS Proposed Rule for
Livestock Mandatory Reporting; Reestablishment and Revision of the
Reporting Regulation for Swine, Cattle, Lamb, and Boxed Beef published
in the Federal Register on August 8, 2007, Federal Register, Volume 72,
Number 152 Pages 44671-44722, Docket Number LS-07-01.

MICA is an incorporated trade association, which represents the U.S.
industry that imports fresh, chilled and frozen beef and lamb into the
United States. MICA's regular members are importers who account for most
of the non-NAFTA imports of these products. MICA's membership also
includes organizations such as port authorities, refrigerated
warehouses, customhouse brokers, etc. who provide services in connection
with this imported product, as well as users of the same.

MICA is opposed to the mandatory disclosure on imported lamb as outlined
in the proposed rule and contends that the price reporting requirements
for imported lamb are burdensome on the small businesses engaged in the
import trade and raise serious confidentiality issues because of the
limited number of companies importing lamb.

The objective of the rule is to provide US producers with information
which can assist in price discovery for their own production. However we
do not believe that this is achieved with reporting of imported lamb
data. There is no identifiable correlation between prices paid for
imported lamb cuts and US domestic slaughter lamb prices. The products
are distinctly different and lags between the time of purchase by the
importer and sale in the market, created by shipping and storage, make
price comparisons potentially misleading in the context of real time
market information which price reporting is supposedly intended to
achieve.

The proposed rule describes processes for the confidential treatment of
price information and outlines the basis on which supplier details
remain confidential to AMS. This confidentiality issue is a serious
concern to lamb importers as there is only a small number of lamb
importers involved in the imported lamb trade. The number of qualifying
importers who import more than 2,500 tonnes is even smaller and the size
distribution of those who do qualify is wide. Consequently some
competitors who know their own market share would be well positioned to
determine the price of the major market shareholder.

The confidentiality concerns are made more of an issue by the reporting
format that was adopted by AMS which also identified the country of
origin. There is no legislative reference to this requirement and no
justification for its reporting. The country of origin is not relevant
to price and by including it creates greater risk of confidentiality
being compromised. The aggregation of imported product from all
supplying countries involved and reporting the prices under a single
'imported' category would be preferable, reducing the risk that
confidentiality would be compromised.

In conclusion it is MICA's view that mandatory price reporting should
not be applied to imported lamb because it fails to achieve the stated
aim to provide US producers with information which can assist in price
discovery and also because of the potential for confidentiality to be
compromised. However, at the very least the country of origin reference
should be removed and consolidated in to a single "imported" lamb
category.

Thank you for the opportunity to provide comments.

Sincerely yours,

Laurie Bryant

Executive Director

Meat Importers Council of America, Inc.