Making a Difference for Dairy

P: 202.220.3537 F: 202.331.7820 1250 H Street NW, Suite 900 | 50002 CD ,notgnihsaW www.idfa.org

Received March 30, 2023

Via U.S. Mail and Email 

March 28, 2023 

Ms. Dana Coale, Deputy Administrator 

USDA - AMS - Dairy Programs 

1400 Independence Avenue, SW 

Washington, D.C. 20250-0225 

Dana.Coale@usda.gov 

Re: Petition of the International Dairy Foods Association (“IDFA”) For a Hearing to 

Amend Federal Milk Marketing Orders 

Dear Deputy Administrator Coale: 

The International Dairy Foods Association (“IDFA”) hereby petitions the Secretary of Agriculture 

to institute a proceeding to amend all current Federal Milk Market Orders (FMMOs), 7 C.F.R. Parts 

1000–1135. This Petition supports a Petition filed by the Wisconsin Cheese Makers Association 

(“WCMA”). The petitions seek to relieve the economic hardships on cheese, nonfat dry milk, butter 

and whey manufacturers due to dramatically higher costs of manufacturing these products since 

USDA last established manufacturing cost factors (make allowances) based on industry cost data 

from 2005–2006. 

IDFA has been prepared to file a petition for a hearing to update make allowances since early 

February 2023, but IDFA postponed any submission in a good faith effort, engaging in substantive 

and lengthy discussions with National Milk Producers Federation “NMPF” seeking industry 

consensus. Unfortunately, such consensus is not possible, beyond the fact that both IDFA and 

NMPF agree that the make allowances last updated in 2008 need to be updated. 

1. Introduction and Summary 

Ever since the U.S. Department of Agriculture more than twenty years ago began using component 

pricing to set minimum milk prices for manufactured (Class III and IV) products, the Department 

has hewed hard to one straightforward, overriding principle: minimum manufacturing product 

prices must incorporate a “make allowance” consistent with the average cost of manufacturing 

the core Class III and IV products, as determined by the most recently available cost data. As 

USDA explained when it first adopted this approach effective January 1, 2000: 

The make allowances contained in the proposed rule were developed 

primarily from make allowance studies conducted at and published by 

Cornell University and an analysis of manufacturing plant size in 

relationship to the data contained in the Cornell studies. Audited cost 

of production data published by the California Department of Food 
and Agriculture was also used in determining a reasonable level of 

make allowances. 

. . . . 

. . . Both handler and producer interests argued that failure to cover 

processors’ costs of converting milk to finished products results in a 

disincentive to produce finished dairy products. They expressed 

concern that the disincentive would discourage investment in the 

manufacturing sector, leading to reduced manufacturing capacity and 

reduced outlets for producers’ milk. 

Milk in the New England and Other Marketing Areas; Decision on Proposed Amendments to 

Marketing Agreements and to Orders, 64 Fed. Reg. 16,026, 16,096 (Apr. 2, 1999). 

Since that time, USDA has on four separate occasions held hearings to amend make allowances. In 

every instance, USDA has updated (increased) the make allowances to reflect more recent cost of 

production data. As shown by the following excerpts from the Department’s decision-making, the 

Department has without exception continued to apply the same foundational principle: make 

allowances should reflect the weighted average of actual manufacturing costs: 

December 2000: 

As supported by most of the hearing participants, the make allowances 

incorporated in the component price formulas under the Federal milk 

orders should cover the costs of most of the processing plants that 

receive milk pooled under the orders. . . . 

. . . . 

. . . . [M]anufacturing costs used to determine appropriate make 

allowances for cheddar cheese, butter and nonfat dry milk in this 

proceeding are calculated primarily from a weighted average of the 

RBCS [Rural Business Cooperative Service] and CDFA [California 

Department of Food and Agriculture] surveys, with a check against the 

NCI [National Cheese Institute] survey cost of manufacturing cheddar 

cheese. The cost of manufacturing nonfat dry milk continues to be 

used as the cost of making whey powder due to the nature of the 

information in the hearing record about the actual costs of drying 

whey. 

Milk in the Northeast and Other Marketing Areas; Tentative Decision on Proposed Amendments and 

Opportunity To File Written Exceptions to Tentative Marketing Agreements and to Orders, 65 Fed. 

Reg. 76,831, 76,839–40 (Dec. 7. 2000). 

November 2002: 

As supported by most of the hearing participants, the make allowances 

incorporated in the component price formulas under the Federal milk 

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orders should cover the costs of most of the processing plants that 

receive milk pooled under the orders. In part, this approach is 

necessary because pooled handlers must be able to compete with 

processors whose milk receipts are not priced in regulated markets. 

The principal reason for this approach, however, is to assure that the 

market is cleared of reserve milk supplies. 

. . . . 

This final decision finds that continuing to use an average make 

allowance of dairy manufacturing plants’ costs is appropriate. 

Reliance on product-price formulas necessitates the need to reflect and 

to offset the manufacturing costs incurred and is supported by the 

record even though there is disagreement on exactly how to 

accomplish this. Using an average make allowance provides a 

reasonable measure to reflect and offset manufacturing costs and is the 

only reasonable measure that can be supported by the record evidence. 

Milk in the Northeast and Other Marketing Areas; Decision on Proposed Amendments to Tentative 

Marketing Agreement and To Orders, 67 Fed. Reg. 67905, 67915 (Nov. 7, 2002). 

November 2006: 

This tentative final decision proposes to adopt, on an interim final and 

emergency basis, changes to the manufacturing allowances contained 

in the Class III and Class IV product price formulas applicable to all 

Federal milk marketing orders. . . . 

. . . . 

The price formulas used to compute Class III and Class IV prices 

contain a factor called a manufacturing (make) allowance. The make 

allowance factor represents the cost manufacturers incur in making 

raw milk into one pound of product. . . . The[ current] make 

allowances were last amended in 2003 and were determined on the 

basis of a California Department of Food and Agriculture (CDFA) and 

a USDA Rural Business Cooperative Service (RBCS) survey of 1998 

manufacturing costs. The current make allowances were computed by 

taking a weighted average of the CDFA and RBCS surveys and 

adjusting for return on investment, general and administrative costs 

and marketing costs. 

. . . . 

This tentative final decision finds that combining the weighted average 

manufacturing costs of the [most recent] CDFA survey and CPDMP 

study for cheese, nonfat dry milk and butter into a single weighted 

average is appropriate for updating make allowances for those three 

products. The CPDMP study weighted average manufacturing cost of 

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dry whey (without California) should be used for the dry whey make 

allowance. 

Milk in the Northeast and Other Marketing Areas; Tentative Final Decision on Proposed 

Amendments and Opportunity To File Written Exceptions to Tentative Marketing Agreements and 

Orders, 71 Federal Register 67,467, 67,469–70, 67,487 (Nov. 22, 2006). 

June 2008: 

This tentative final decision adopts on an interim basis, a proposal 

published in the hearing notice as Proposal 1 which seeks to amend 

the manufacturing allowances for butter, cheese, nonfat dry milk 

(NFDM) and dry whey using the most currently available data . . . . 

. . . . 

The make allowances adopted represent national manufacturing cost 

averages for cheese, butter, NFDM and dry whey. As found and 

determined in previous rulemakings on this issue, an estimation of 

manufacturing costs for national application requires that national 

production volumes of these commodities be considered in 

determining the level of make allowances to be relied upon and used 

in the Class III and Class IV product-pricing formulas. 

Milk in the Northeast and Other Marketing Areas; Tentative Partial Final Decision on Proposed 

Amendments and Opportunity To File Written Exceptions to Tentative Marketing Agreements and 

Orders, 73 Federal Register 35,305, 35,308, 35,325 (June 20, 2008). 

Nearly 15 years have passed since make allowances were last updated. Accurate and up to date make 

allowances are critical to a properly functioning FMMO program. For Class III (cheese) and Class 

IV (butter and nonfat dry milk) products, a manufacturer is legally required by the FMMO to pay the 

farmers supplying it milk the money the manufacturer receives from selling its finished products to 

customers (as determined by monthly audited surveys of actual finished product prices for the core 

Class III and IV products), minus the cost incurred in making those products, as set forth in the 

FMMO regulations (the “make allowance”). As AMS stated when it last revised make allowances 

in 2008: 

The ability of a manufacturer to offset cost increases are limited by the 

level of make allowances in the Class III and Class IV price formulas. 

Manufacturing processors are charged the FMMO minimum price for 

producer milk used to produce Class III and Class IV products. 

However, plant manufacturing cost increases may not be recovered 

because Class III and Class IV product-price formulas use make 

allowances that are fixed regardless of market conditions and change 

only by regulatory action. 

Id. at 35,323. 

The current make allowances were established by USDA based on evidence presented at FMMO 

hearings held in 2006 and 2007. The evidence presented was based on industry cost data from the 

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periods 2005–2006, the most recent data available at that time. Actual cheese, butter, whey and 

nonfat dry milk plant manufacturing and related costs have risen significantly in the sixteen years 

since. However, FMMO regulations strictly prevent these dairy product manufacturers from in any 

way recovering any portion of those higher costs through higher sales prices or other means. 

When USDA implemented the 1996 Farm Bill's directive to reform FMMOs, it fundamentally 

altered the formulas for establishing the minimum prices which regulated dairy processing plants 

must pay dairy producers and milk marketing cooperatives for milk used in all dairy products. In 

doing so, USDA established a fixed relationship between the wholesale price of dairy products used 

in those formulas and the minimum class prices, with that fixed relationship based on the cost of 

producing cheese and other manufactured products (the "make allowances"). However, USDA 

provided no mechanism to adjust that fixed relationship short of conducting a formal rule-making 

process. 

Neither Congress nor USDA intended to threaten the economic viability of the U.S. cheese, butter, 

nonfat dry milk or whey industries by forcing manufacturers to lose money on every pound of dairy 

products produced, or potentially injure dairy producers by eliminating these important outlets for 

farm milk. However, the current system of FMMO regulated price formulas, unlike its predecessor, 

fixes the difference between the value cheese, butter, whey and nonfat dry milk manufacturers obtain 

in the marketplace for their products and the minimum price they must pay for the milk used to make 

those products based on the industry costs as they existed at or before a May 2000 hearing at which 

the make allowances were established and then modified after a January 2006 hearing and a hearing 

convened over several month from February through July 2007. Without any mechanism to adjust 

the make allowances in response to changes in industry costs, manufacturers are trapped into either 

losing money on every pound of product produced or stopping production entirely. 

The method employed following the May 2000 hearing used to establish make allowances used a 

weighted average (by volume of dairy product production) of two sources of industry cost data. The 

first was the annual published summary of the industry cost audit conducted by the California 

Department of Food and Agriculture (“CDFA”). The second was based on the results of a survey of 

dairy cooperative manufacturing plant costs conducted by the Rural Business Cooperative Service 

of USDA (“RBCS”). At the 2006 and 2007 hearings, proponents presented updated data from CDFA 

and RBCS. In addition, proponents introduced evidence provided by Dr. Mark Stephenson from 

Cornell University who presented a research study conducted by the Cornell Program on Dairy 

Markets and Policy (“CPDMP”). CPDMP assessed the cost of cheddar cheese, dry whey, butter, 

and nonfat dry milk. 

AMS concluded after the 2006 proceeding that CPDMP presented a more comprehensive set of 

FMMO costs than RBCS, and AMS declined to further use RCBS. AMS also concluded that 

combining the CPDMP data with the CDFA data for California plants generally established a 

superior set of data on which to determine revised make allowances. AMS thus decided to use a 

single weighted average of milk volumes studied by CDFA and CPDMP for three of the products -

cheese, butter and nonfat dry milk plus a fixed marketing cost of $0.0015. As to dry whey, AMS 

concluded that it would be best to use the CPDMP manufacturing costs plus the same marketing cost 

of $0.0015. AMS chose not to rely on CDFA study for whey costs due to plant “outliers.” 71 Federal 

Register 67,467, 67,486 (November 22, 2006). 

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The cheese, butter, whey and nonfat dry milk manufacturing industries urgently need immediate 

relief from the highly injurious fixed relationship between output prices and minimum regulated milk 

prices that do not reflect current industry costs. In the intervening years, RBCS data (that AMS 

declined to use) has not been collected and disseminated. The California State Order was replaced 

by the California Federal Order effective November 1, 2018. Nonetheless, CDFA study data of the 

precise kind relied on in the 2006 and 2007 formal rulemaking proceedings is available through 2016. 

In addition, AMS requested Dr. Mark Stephenson (formerly at Cornell and then at the University of 

Wisconsin) to perform a new study using the techniques and methodologies employed by CPDMP. 

Dr. Stephenson and AMS published the results of that study based mostly on 2018 data on February 

14, 2022. See Federal Milk Marketing Orders, Agricultural Marketing Service, 2021 Cost of 

Processing Study, https://www.ams.usda.gov/rules-regulations/moa/dairy (last visited Mar. 27, 

2023); Mark Stephenson, Cost of Processing in Cheese, Whey, Butter and Nonfat Dry Milk Plants 

(Dec. 2021), https://dairymarkets.org/cop/Report/2021_COP_Report.pdf. But costs have continued 

to spiral upwards since 2018. 

In 2022, IDFA retained Dr. William Schiek, CEO of the Dairy Institute of California, to analyze and 

update, the CDFA data from 2006–2016, first by corroborating Dr. Stephenson’s AMS 

commissioned study relying on data through 2018 and then to further updating the CDFA studies 

through 2022. IDFA and the WCMA have also jointly retained Dr. Stephenson to update his 2018 

study data through the most current time period available to him. 

This updated data supports and justifies IDFA’s Petition here to bring the FMMOs in line with the 

modern cost data. Specifically, IDFA seeks immediate consideration of the following proposed 

change in FMMO regulations: 

Update the make allowances used in all FMMO minimum class price formulas 

using the most recently available industry cost data. 

IDFA requests that USDA promptly issue a Notice of Hearing on the requested changes in the 

FMMO class price formulas. 

2. Explanation of the Problem 

As discussed above, the make allowances currently used throughout the FMMO system for cheese, 

dry whey, butter and nonfat dry milk were updated, as discussed above, after two hearings held in 

2006 and 2007. At that time, industry cost data was available for the years 2005–2006, and this 

formed the basis of testimony of a number of industry participants. In a decision based on those 

hearings, USDA fixed the make allowances for cheese, butter and nonfat dry milk by using data 

from two sources presented at the hearing. The first source was based on actual plant cost audits 

conducted by the California Department of Food and Agriculture (CDFA). The second source 

relied on the studies conducted by CPDMP. In both cases, the data came from actual industry costs 

during the period 2005–2006. The method adopted by USDA was to weight these two data sources 

by the volume of cheese, butter and nonfat dry milk represented by each data source and add a 

fixed marketing cost of $0.0015. The method adopted by USDA for dry whey was to rely solely 

on the CPDMP studies plus the same fixed marketing cost of $0.0015. 71 Fed. Reg. at 67,486. 

At the same time, USDA's National Agricultural Statistics Service (NASS) conducts weekly 

surveys of dairy product transaction prices (cheddar cheese, dry whey, butter and nonfat dry milk) 

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from manufacturing plants across the entire United States. These weekly averages are used to 

calculate monthly, weighted average prices for these four products. The Department then uses 

those monthly average prices to determine the minimum component and class prices. In this 

manner, the FMMO minimum price of farm milk changes in conformity with changes in the 

wholesale prices of the manufactured dairy products in the market. While those prices thus adjust 

constantly, cheese, butter, whey and nonfat dry milk manufacturers on the cost side are trapped in 

a 16-year-old cost structure that fails to account for the significant cost increases. 

As noted above, the manufacturing cost allowances presently in place throughout the FMMO system 

for these products are based upon cost data from surveys and data dating to 2005 and 2006. 

Manufacturing costs for all dairy products have soared significantly in the intervening 16 years. Even 

a layperson is abundantly aware of the unprecedented increase in costs for business operations during 

the recent years. It would be incorrect, and in fact unreasonable, to assume that somehow technology 

or other efficiency improvements at plants have somehow offset these escalating costs. 

As correctly recounted by Agri-Mark in its 2005 submission to AMS: 

Dairy product manufacturers under Federal Milk Orders are trapped 

into a fixed make allowance with no opportunity to cover their higher 

costs no matter what the price of their dairy products are. If 

manufacturers raise their product prices to cover higher costs, those 

higher prices automatically lead to higher milk prices, leaving no 

additional net income to apply to the higher costs. 

Letter from Robert D. Wellington, Sr. Vice President for Econ., Commc’ns & Legis. Affairs, AgriMark Dairy Coop., to Dana Coale, Deputy Adm’r, Dairy Programs, USDA Agric. Marketing Serv. 

(Sept. 29, 2005) at 3, https://www.ams.usda.gov/sites/default/files/media/DYClassIIIIVMake 

AllowancesAgriMarkReq.pdf. 

Despite the significant cost increases, FMMO provisions have effectively stopped manufacturers 

from covering these higher costs through higher sales prices or other means. The amount of time 

that has elapsed since the last hearing and rulemaking on these pricing formulas is almost twice as 

long as the interval from AMS first establishing formula prices in Federal Order Reform in 2000 and 

the updates adopted in 2007 and late 2008 based upon 2005 and 2006 data. Industry faced an 

emergency then and faces and even greater emergency now. 

AMS retained Dr. Mark Stephenson to conduct an updated survey of Class III and IV plant costs. 

That study was published by AMS last February and is based mostly on 2018 data. This study 

confirms enormous cost increases since the current allowances were set (note that Dr. Stephenson 

allocated energy costs between butter and nonfat dry milk differently than by CDFA or CPDMP; 

IDFA proposes to account and adjust for that at any hearing as it concludes that nonfat dry milk costs 

are overstated while butter costs are understated): 

Current 

 Make Allowances 

 Stephenson Study 

2018 Costs 

Cheese 

Butter 

Whey 

$0.2003 

$0.1717 

$0.1991 

$0.2491 

$0.1426 

$0.2665 

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Nonfat Dry Milk $0.1678 $0.2948 

In the intervening time since 2018, significant additional cost increases have occurred. IDFA 

proposes that in considering the need for a hearing (and at the hearing as submitted evidence) USDA 

take into account, in addition to Dr. Stephenson’s study, an updated cost study by Dr. William 

Schiek, CEO of the Dairy Institute of California, previously presented to USDA in November 2022. 

This hearing request provides in summary Dr. Schiek’s most current projections, based on CDFA 

studies and updated with indices, that encompass 2022: 

Cheese $0.3021 

Whey $0.2968 

Butter $0.2379 

NFDM $0.2668 

At the hearing, IDFA will also ask USDA to consider and take into account an updated version of 

the USDA-commissioned study “Cost of Processing Study for Cheese, Whey, Butter and Nonfat Dry 

Milk Plants” released by Dr. Stephenson in early 2022. The Wisconsin Cheese Maskers Association 

and the International Dairy Foods Association have commissioned Dr. Stephenson to update his 

study with 2022–2023 data. IDFA will also provide testimony and support for accounting for Dr. 

Stephenson’s allocation of costs between butter and nonfat dry milk in order to adjust it to prior 

practice. 

The existing use of fixed out-of-date make allowances is a major problem for all dairy product 

manufacturers producing cheese, butter, whey and nonfat dry milk. These everyday losses are 

impossible to sustain. IDFA members include both farmer owned cooperatives many of whom are 

routinely returning dairy farmer payments with significant deductions from FMMO uniform 

minimum prices because of these losses. Proprietary members of IDFA are also absorbing losses, 

attempting to sell specialty cheeses at prices designed to mitigate losses, and/or otherwise failing to 

invest in plants and facilities. In fact, investments in plants overall are stagnant. This is not 

sustainable for the plants, nor for dairy farmers who depend on these plants as outlets for their raw 

milk. 

In January, 2023, CoBank Cooperative, one of the largest private providers of credit to the rural 

economy, acknowledged the need to update make allowances in in their Knowledge Exchange 

publication, “Updating Make Allowances is Central to the Future of Federal Milk Marketing 

Orders,” which is posted in the Knowledge Exchange section of the CoBank website. 

https://www.cobank.com/knowledge-exchange/dairy/updating-make-allowances-is-central-to-thefuture-of-federal-milk-marketing-orders 

Noting that “make allowances were last updated in 2008 and were based on data from as far back 

as 2006”, the CoBank publication cited several federal statistics on cost increases. “Labor costs in 

dairy product manufacturing climbed 48% per unit of production, according to the U.S. Bureau of 

Labor Statistics. From 2006 to 2022, the industrial rate prices for electricity rose 64%. 

The CoBank publication concluded that “Cost structures among handlers will continue to change 

over time, requiring future adjustments in make allowances. While updating make allowances does 

not guarantee more investment in new processing assets with every handler, not updating them 

may result in lost growth opportunities for the dairy industry over the long term.” 

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IDFA understands and appreciates the concerns of our members’ dairy farmer patrons for whom 

increased make allowances mean lower regulated minimum prices. However, the loss of significant 

plant capacity and the resulting loss of competition will mean greater pain for everyone, including 

especially dairy farmers. Such losses of plant capacity would certainly result in disorderly marketing 

conditions that FMMOs are designed to alleviate not exacerbate. IDFA cooperative members and 

other dairy product manufacturers that serve as nearby outlets for local dairy farmer milk and as 

balancers of billions of pounds of FMMO milk cannot come close to covering their costs under 

current FMMO provisions. As AMS itself explained when it last increased make allowances in 2008: 

Opponents of increasing make allowances argue a number of points— 

that they are already set at too high a level, that dairy farmer production 

costs also have increased significantly due to higher energy and feed 

costs, that processors should look beyond asking dairy farmers to 

receive less for their milk by charging more for manufactured 

products, and that make allowance increases should be made only 

when all dairy farmer production costs are captured in their milk pay 

price. These are not valid arguments for opposing how make 

allowances should be determined or what levels make allowances need 

to be in the Class III and Class IV product-pricing formulas. The 

record demonstrates that current make allowance levels are not 

reflective of the costs manufacturers incur in processing raw milk into 

the finished products of cheese, butter, NFDM and dry whey. 

Additionally, the Class III and Class IV product-price formulas 

establish derived classified prices for producer milk that are used 

nationally in all Federal milk orders. When dairy farmer production 

costs exceed the value for which products are sold in the marketplace, 

no source of revenue from the marketplace is available to cover those 

costs. 

In the aggregate, the costs of producing milk are reflected in the supply 

and demand conditions for the dairy products. When the supply of 

milk is insufficient to meet the demand for Class III and Class IV 

products, the prices for these products increase as do regulated 

minimum milk prices paid to dairy farmers because the milk is more 

valuable and this greater milk value is captured in the pricing formulas. 

Dairy farmers face no regulatory minimums in their costs and face no 

regulated minimum payment obligation in the way that regulated 

handlers must pay dairy farmers for milk. 

73 Fed. Reg. at 35,324. 

IDFA is aware and supportive of USDA and industry efforts for USDA itself to have the authority 

and funding to conduct regular, audited dairy product cost studies. A long-term solution would be 

to have such studies efficiently used to update Section 50 make allowances on a regular basis. 

However, this requires Congressional action both to authorize and fund the audits. It will likely then 

take at least another year or two, if not longer, after (not yet introduced, must less passed) legislation 

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________________ 

before such information can be available. Following that approval is the long hearing process before 

a solution can be implemented. The dairy manufacturing industry cannot wait for that data to become 

available, be debated by the industry, and initiate a lengthy hearing and decision process which 

considers all aspects of the Class III and IV FMMO price formulas. These 16 years of dated 

manufacturing allowances must be updated immediately using the best available means. 

CONCLUSION 

Current manufacturing allowances are well below the actual costs involved in manufacturing cheese, 

whey powder, butter, and nonfat dry milk powder. Every day that goes by means losses on the part 

of manufacturers who provide outlets for billions of pounds of Federal Order milk production as well 

as balancing services to their respective Orders. We clearly need this proposal considered on 

promptly to address these serious economic problems. 

IDFA member companies and other dairy product manufacturers regulated by FMMOs are trapped 

by a fixed make allowance in combination with a surveyed commodity price, leaving no opportunity 

to cover their higher costs. If manufacturers raise their product prices to cover higher costs, those 

higher prices automatically lead to higher minimum component and class prices. IDFA’s proposal 

is very straightforward and can be accommodated through a very short hearing. The proposed 

method for determining make allowances is identical to that supported by most dairy producer groups 

during prior hearings, and adopted by the Department. IDFA is not proposing to reconsider or change 

the methodology used to set minimum prices, or the FMMO formulas, or the data sources used in 

those formulas. IDFA only proposes to update the formulas by using the most currently available 

make allowance data from the same sources previously utilized. 

IDFA urges that USDA hold a hearing as soon as possible and move expeditiously to a decision. 

Respectively Submitted, 

Mike Brown 

Chief Economist 

International Dairy Foods Association 

1250 H Street NW, Suite 900 

Washington, DC 20005 

202-737-4332 

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