1

 U.S. DEPARTMENT OF AGRICULTURE

 + + + + +

 GRAIN INSPECTION ADVISORY COMMITTEE MEETING

 + + + + +

 WEDNESDAY

 MAY 12, 2021

 + + + + +

 The Committee Meeting met via

Video/teleconference at 11:00 a.m. EDT, Matthew

Kerrigan, GIAC Vice-Chair, presiding. 

PRESENT: 

DAVID AYERS, Champaign Danville Grain Inspection,

Inc. 

JANICE COOPER, Wheat Marketing Center

CURTIS ENGEL, The Scoular Company

NICHOLAS FRIANT, Cargill Inc.

MATTHEW KERRIGAN, EGT, LLC

RYAN KUHL, Northern Plains Grain Inspection

Service 

JOHN LINDGREN, United Grain Corporation

ROBERT SINNER, SB&B Foods, Inc.

ERROL BRENT TURNIPSEED, South Dakota State

University Seed Testing Lab

JIMMY WILLIAMS, Grain Inspection Services

 Administrator 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
2 

ALSO PRESENT: 

LEE CAPPER, FGIS Chief Innovation Officer 

ANTHONY GOODEMAN, Director, FGIS Field Management

 Division 

EDWARD JHEE, Director, FGIS Technology and

 Science Division 

KENDRA KLINE, FGIS Chief of Staff and the 

Advisory Committee Specialist 

JESS MCCLUER, NGFA Vice President of Safety and 

Regulatory Affairs 

ARTHUR NEAL, FGIS Deputy Administrator, DFO 

DENISE RUGGLES, FGIS Executive Program Analyst 

BRUCE SUMMERS, AMS Administrator 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
3

 CONTENTS 

Call to Order and Welcome. . . . . . . . . . . . . 4 

Greetings. . . . . . . . . . . . . . . . . . . . . 5 

FGIS Updates . . . . . . . . . . . . . . . . . . .20 

Financial Overview . . . . . . . . . . . . . . . .28 

Recommendations Update . . . . . . . . . . . . . .45 

Discuss Industry Issues - Corn Borer . . . . . . .78 

Discuss Industry Issues -

Average Inspection Flexibilities . . . . . . . . 109 

Discuss Industry Issues - Falling Number . . . . 144 

Public Comments. . . . . . . . . . . . . . . . . 173 

Adjourn. . . . . . . . . . . . . . . . . . . . . 177 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
4 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

P R O C E E D I N G S

 (11:00 a.m.)

 MR. KERRIGAN: All right. Well, good 

morning, everybody. Appreciate everybody joining 

on the Zoom call here this morning. I know 

everybody. Hopefully this is all pat for 

everybody at this point. I'm sure that we will 

all have some technical difficulties going along 

the way. But just a simple reminder to everybody 

to try and keep muted if you're not speaking, it 

does help with the echo and everything else. I 

assume that as we get through this, Kendra has 

already set up the agenda, it was attached to the 

meeting invite. If you need it, let us know and 

we can get that out to you again.

 We've got several, or a few items 

here, a lot of updates. I'm hoping that Arthur 

is going to be giving everybody, given it's been 

such a long time since we've all met, we've got a 

lot of new members. You know, we've got the 

officer elections. We've got a lot of good stuff 

here, you know. So again, just want to thank 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
5 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

everybody before I turn it back over. And just 

one housekeeping item, I did not get any 

volunteers to as acting secretary for this 

meeting. So depending on what the rules of order 

are, Arthur, we may need to take care of that.

 MR. NEAL: Yes, sir. And we will take 

care of that after we get through the initial 

components of the agenda. And we'll stop and 

take a break and we'll find out if we could 

revisit that particular situation. So thanks, 

Matt. So without any further ado I'd like to, I 

think I saw him earlier, we've got, there he is, 

Bruce Summers our Administrator. He's going to 

bring some greetings to us on behalf of AMS. 

Bruce, I turn it over to you, thank you, sir.

 MR. SUMMERS: Thank you, Arthur. And, 

good morning, everybody. It's good to see youall today, virtually. I hope that you have all 

done well through this period of unique 

challenges caused by the pandemic. I think at 

AMS, we understand that you-all had to modify 

your operations to ensure the health and safety 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
6 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

of you workforce. And that you might be seeing 

some increased demand right now, there have also 

been a lot of challenges with respect to 

transportation and staffing and all sorts of 

hurdles that we've all had to navigate during 

this time period.

 Certainly, at AMS, we've had some of 

the same hurdles that you-all probably have. I'm 

happier, relieved, not sure which word is best to 

use there to say, I think the leadership of our 

Federal Grain Inspection Service, Arthur and his 

team, have really done an admirable job of, you 

know, steering the Committee to make sure our 

employees were safe and healthy and at the same 

time balance that out with continuing to provide 

the services to all of our customers and help 

keep grain moving through the supply chain.

 So I want to give a little shout-out 

to the AMS team for work they've done and also 

acknowledge all that you-all have done to work 

with us during this is difficult time period. 

You know, hopefully, hopefully, hopefully, the 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
7 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

positive developments that we're seeing around 

vaccines and declining case numbers. Our numbers 

across the Agency have gone down to close to zero 

which is a tremendous improvement from what we 

were seeing, certainly last fall and even in 

January. So hopefully this means the next time 

we meet with this Committee, maybe we can do it 

in-person.

 But, you know, really, the virtual 

meetings have been pretty successful. I've been 

in hundreds of virtual meetings and maybe 

thousands by now over the last year. And you 

know, there is that advantage of not requiring 

people to travel and, you know, foregoing the 

expenses of traveling to participate in in-person 

meetings. And so one of the things I've kind of 

noticed, I think in some of these virtual 

meetings, you know, we have more people 

participating probably because that flexibility 

and sometimes reduced costs.

 And so I would expect when we meet or 

we may be in-person, we may have a virtual 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
8 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

component too just to maintain that flexibility 

for our folks and we can kind of keep everybody 

who wants to be able to participate one way or 

the other. So I feel like, you know, as we move 

forward, and how we reopen, and how we staff our 

offices, I think we're probably going to see a 

lot of flexibility and I think kind of a hybrid 

cross between in-person and virtual. But I am 

looking forward to getting back out on the road 

and seeing the real world again. I'm here in 

Washington DC, which few people would call the 

real world. I look forward to getting out on the 

road soon, hopefully see some of you-all.

 At AMS, you know, kind of give you a 

little update on what's going on around here. 

We're continuing to welcome new leadership. USDA 

is, as the new administration continues to ramp 

up, I mean January may feel like a long time ago. 

But really it's still kind of infancy of a new 

administration. You may be aware that Jenny 

Lester Moffitt has been nominated to serve as the 

Under Secretary of the Marketing Regulatory 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
9 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Program missionary. Which is the missionary that 

houses both AMS and APHIS. At this point she's 

waiting for a vote in the senate to confirm her 

to the position. I would expect and hope that as 

soon as she's confirmed that we can maybe start 

talking about having her attend, you know, maybe 

the next next Advisory Committee Meeting for this 

group. So kind of look forward to that.

 Right now, and, you know, in addition 

to working and maintaining the delivery of our 

inspection programs like FGIS, the issue 

marketing in these reports, and all that kind of 

normal operations we work on every day at AMS, we 

are also working really hard. Tremendous effort 

across the Agency to implement a variety of 

pandemic assistance related programs that have 

been authorized by both the Consolidated 

Appropriations Act, which you may recall, asked 

right at the end of December last year, and the 

American Rescue Plan which was put in place in 

March.

 So between those two programs, a lot 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
10 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

of pandemic assistance and a lot of Federal 

dollars. You've heard about it in the news, 

right? A lot of money being pumped into the 

economy. And those were the two Acts, two new 

laws that are really impacting agriculture. Much 

of the work around that pandemic response space 

for AMS is related to grant programs. Both 

beefing up of existing grant programs and new 

programs. New grant programs that all intended to 

provide relief to ag businesses, ag producers or 

hit hard by the pandemic.

 So you may have seen, if you were 

watching the trade press announcements recently 

on things like transfer, especially crop sector 

and local food sector. Those are existing 

programs that are being added onto, and sometimes 

more than doubling in size. And we have a series 

of new grant programs that will be coming out in 

the next few weeks. We continue to meet with the 

Secretary and the new leadership on all of those 

as we ramp up. There is one, it's not a grant 

program, but there's one particular issue I 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
11 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

really would like to raise for this group. And 

then we'll talk about that a little bit and then 

maybe open it up for some conversation.

 But I would like to put to this 

Committee the possibility that you-all would 

consider responding to a Federal Register Notice 

that we put out a few weeks ago. It's related to 

an Executive Order that was issued by President 

Biden in February. And that Executive Order 

directs federal agencies to secure and strengthen 

America's supply chains. So to do that, AMS has 

taken the lead for the entire Department on this. 

And to do that, we're asking for public comments 

from all across agriculture to provide us 

feedback on what do you think the stimulus relief 

programs should look like. How you think 

spending related to food supply chain resilience 

can help increase the variability within the US 

food supply.

 You know, we're asking for comments 

that talk about how stimulus relief programs and 

spending related to the food supply chain can 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
12 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

help with new market opportunities, facilitating 

fair and competitive markets, advancing efforts 

to transform the food system. If that's what 

folks think needs to happen. Meeting the needs 

of the agricultural workforce, supporting 

nutrition security for consumers. So it's really 

a wide open, broad discussion and we really do 

need public comments as we work on this over the 

course of the next year. We have actually one 

year to provide a report to the White House on a 

pretty big topic, right, the entire US 

agriculture supply chain.

 And so I'd like to kind of put it to 

the Committee to consider whether the Committee 

would want to provide comments. And even to youall individually, in your private sector role, to 

provide comments on and your perspectives about 

challenges to the US food supply chain we've seen 

during the pandemic, but even broader than that, 

just in general. So kind of put that charge in 

front of you. Happy to talk about it some more 

if you have any questions, but I'd kind of like 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
13 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

to stop there. Arthur only gave me ten minutes. 

So I've got to be fast and I certainly want to 

leave time for any questions, any feedback, 

anything like that you have from me. So let me 

pause there and, Arthur, let's take any questions 

if there are some.

 MR. NEAL: Are there any questions for 

Bruce? Points of clarification.

 MR. SUMMERS: I'm going to keep youall on track. I'm not going to go long. 

Questions, comments, or feedback, if not, I would 

just say, and I always say this either at the 

beginning or at the end, you know, we know youall could be doing other things, right. We're 

pulling away from your businesses, we're pulling 

you away from your farms, to come serve on these 

committees. You-all are representing grain 

sector at large. We couldn't do this without 

you. We really value the input that you-all give 

to us in these meetings. And the next two days, 

we now you're going to talk about a lot of 

important stuff. You're going to make some 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
14 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

recommendations for us to consider.

 We really appreciate, and respect to 

the fact that you-all have taken this chore on 

and we're glad you're here. We need you. So 

thank you very much for being willing to help us 

out. And if there's no questions, comments, 

Arthur, I'll kick it back to you guys to stay on 

track.

 MR. NEAL: Thank you, Bruce. Are 

there questions?

 MR. FRIANT: Arthur, real quick, Nick 

Friant with Cargill. And, Bruce, thanks for the 

comments, appreciate you taking the time to, you 

know, welcome us and share the update. And your 

comments around the Federal Register Notice, I 

guess just to comment back to you, just raise the 

awareness. I do know that NGFA and NAEGA are 

both drafting comments around the whole supply 

chain issue. So just for your feedback to know 

that some of the trade associations are aware of 

it and are working on some comments back on that 

Federal Register Notice. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
15 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MR. SUMMERS: Yes, I would certainly 

hope that those major organizations would be 

participating and I would be disappointed if they 

weren't. So I'm glad you got the inside 

knowledge on that. But again, you may have some 

things specifically that you want to put forward 

and we would love to hear your perspectives. 

You-all have been in the forefront, front lines, 

whatever you want to call it here for last year. 

And from keeping workers healthy to finding a way 

to ship product, right, and all kinds of 

challenges this year, and we'd like to hear about 

those. So thank you, Nick, I appreciate that 

comment.

 MR. NEAL: Any other comments or 

questions?

 MR. SUMMERS: I hope you guys have a 

great meeting.

 MR. NEAL: Thanks, Bruce, take care. 

So I guess, Matt, I'll go from here. So I want 

to say, good morning, everybody. It's good to 

see your faces. And for those who are hiding 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
16 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

behind names and black boxes, you know, hopefully 

we'll get a chance to see your face too today. 

Ideally it would be great for us to be together. 

The AAGIWA group met down in Nashville a couple 

of weeks ago, I think. And, you know, they they 

were bold and, you know, they had about 90 plus 

people together. And I think they may have been 

some of the first to get back to some normalcy. 

And I was really hoping that I'd be able to get 

down there, but, you know, we haven't gotten a 

green light to travel yet.

 But our goal is for hopefully our next 

Grain Inspection Advisory Committee Meeting that 

that will be in-person. Able to sit around the 

table, you know, whatever protocols we need to 

put in place we'll make every effort to do that. 

But I want us to get together again so that we 

can conduct business and feel like we're doing 

things in a way that allows us to interact and 

develop and enhance the relationships we already 

have. So just good morning.

 I do want to take a moment to 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
17 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

acknowledge and welcome some new members to the 

Grain Inspection Advisory Committee. And because 

we do have a little bit of time, I'm going to 

share some of my time, not a lot though. So 

everybody take about maybe 20 seconds to 

introduce yourselves as I call your name. We've 

got Mr. Curt Engel, who's a new members of the 

Grain Inspection Advisory Committee. Curt, could 

you introduce yourself to those may not have an 

opportunity to have met you.

 MR. ENGEL: Good morning. My name is 

Curt Engel, I work for The Scoular Company in 

Salina, Kansas. And, excuse me, my job 

responsibilities all of the asset businesses that 

are in the Grain Division of The Scoular Company.

 MR. NEAL: Thank you, sir. I'd also 

like welcome Mr. Nick Friant.

 MR. FRIANT: Nick Friant with Cargill. 

Sorry, my video feed is not working well this 

morning, so you're going to see me in bits and 

pieces, I think. Sorry about that, I don't know 

what's going on. But as I mentioned, I'm with 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
18 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Cargill. I'm now part of our North American 

Regulatory Affairs Team. I also chair the NGFA 

Grades and Weights Committee, as well as the 

NAEGA Grades and Inspections Committee.

 MR. NEAL: Thank you, Nick, Ms. Janice 

Cooper.

 MS. COOPER: Good morning. Janice 

Cooper, I'm Managing Director of the Wheat 

Marketing Center. We're a research and technical 

training center and non-profit located Portland, 

Oregon, upstairs from the FGIS office and across 

the river from export loading facilities. So I 

keep an eye on all the wheat that's moving out 

through the Columbia River System. So happy to 

be back on the Committee.

 MR. NEAL: Morning. Thank you. Mr. 

Robert Sinner.

 MR. SINNER: Morning, everyone. I'm 

President of a company called SB&B Foods in 

eastern North Dakota. We are both a producer and 

an exporter of IP Food Grade, especially soil 

beans and specialty grains. I'm also current 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
19 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Chair of the Specialty Soy and Grains Alliance, a 

national organization of IP, food grade 

commodities. Thanks, enjoying participating.

 MR. NEAL: Thank you, sir. We've got 

Mr. Jimmy Williams.

 MR. WILLIAMS: Good morning. Can 

everyone hear me okay? Awesome, all right. So 

again, my name is Jimmy Williams. I work with the 

Missouri Department of Agriculture. I served as 

the Program Manager for the Grain Inspection 

Program for approximately 11 years. I have also 

been very active in AAGIWA. My role with the 

Department recently changed back in January. I'm 

now serving as the Division Director for Weights 

and Measures, but I still am working closely with 

a my peers in the Grain Inspection Program. So 

look forward to meeting some of the new members, 

getting acquainted.

 MR. NEAL: Thank you, Jimmy. Thank 

you-all. We want to, you know, really express my 

gratitude for you-all expressing interest in 

being nominated, and also being selected to serve 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
20 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

on this prestigious committee. We're looking 

forward to leveraging the knowledge and skills 

and all of your experiences. And I also want to 

say good morning to our existing members that 

have been on with us for a couple of years now. 

We look forward to engaging in this over the next 

couple of days. We've talked to some people over 

the past few weeks, but not all of you and I just 

want to give you a few updates.

 You know, since the last time we got 

together, and it's been a while, there's been a 

lot going on in the world. We've all been 

experiencing some highs and some lows, some 

anxieties, and some joys in the midst of it all. 

But I believe that when this COVID pandemic 

initially hit, none of us knew what to expect. 

Most of us were concerned about our health, the 

health of our families, the health of our 

employees and a lot of other things, the health 

of our businesses. But I'm thankful to say that, 

you know, we've made it thus far. We're still 

here. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
21 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

The industry's thriving. Grain is 

moving at a rapid pace. We're moving 60 percent 

more grain this year than we did last year. 

We're moving more grain this year that we did our 

record year back in 2016. And folks have been 

working extremely hard to make that happen on all 

ends. You know, I just want to say thank you to 

all of those who are participating in this 

meeting as a Grain Inspection Advisory Committee 

member, as well as any industry participant. 

Just want to say thank you for what you've been 

doing to contribute to the successful marketing. 

Not just successful marketing, but also the 

marketing grain with integrity. Because of the 

integrity of the official system and the quality 

of US grain we have buyers, we have interest. 

And we want to say thank you for the role that 

you play in making that happen.

 For FGIS, part of the challenge of 

keeping pace with the demand for grain is keeping 

a healthy trained, kind of competent workforce, 

and committed workforce. And I can say that 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
22 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

through this COVID pandemic, our staff has been 

extremely committed to servicing our customers. 

We did not have many instances at all where our 

employees said, you know, they didn't want to go 

to work. Yes, at the initial stages, folks were 

afraid what would happen in this COVID 

environment. But no-one gave us any push-back to 

meeting the charge to our fulfilling the 

expectations of providing service. And they 

worked extremely hard in doing so.

 So I want to publicly thank our staff 

for the work that they've done. And that staff 

that, you know, whether they're on the quality 

side, inspection, the weighing side, the 

management side, I want to say thank you, to all 

of you. Because they've given us the best that 

they've had. And I want to say thank you for our 

customers that they've serviced that have helped 

our staff stay safe because some of our 

customers, when they would clean their 

facilities, they would also take time to clean 

the lab space in which our staff was working. So 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
23 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

I want to publicly thank the industry for 

supporting us that way so that we can keep our 

staff safe.

 Right now, from a staffing standpoint, 

FGIS has roughly about 500 staff. We have a goal 

to hire some more people because there's an 

expectation that grain is still going to move at 

record rates. So particularly in our Gulf area 

where the grain is moving very rapidly, we need 

to hire more people. But in part of hiring more 

people, we also have to make sure we can train 

them. We've had a lot of turnover and change 

over the past few months, particularly in our New 

Orleans Office and our League City Office. In 

New Orleans, the Field Office Manager, Ken 

DeWert, he has transitioned to a new job and he's 

working for the Department of Navy. So we'll be 

soon looking for a Field Office Manager our New 

Orleans Field Office.

 Right now though, we are very grateful 

and thankful Mr. Ron Bundy, who is the Field 

Office Manager for our Domestic Inspection 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
24 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Office, he's now acting down in New Orleans. And 

so we're thankful for that. We've got a strong 

team there, they're holding it together very 

well. But we will be advertising for a Field 

Office Manager in New Orleans. We also had a 

retirement League City. The Field Office Manager 

there, Mr. Alan Wadyko, who served FGIS I believe 

43 years, he retired. I talked to him this 

morning and he's golfing. He's enjoining 

himself. But, you know, one of the things he 

said when I talked to him, he said, you know, I 

loved my work. And I feel that way about most 

folks who work for FGIS and that they loved their 

work.

 But we advertised for that Field 

Office position and that closed, I guess a couple 

of weeks ago. And so we're waiting to hear back 

on who are the candidates we can interview and 

consider. So we're looking to fill that position 

real soon. But with that type of transition, we 

also want to make sure that we have the capacity 

in all other areas to train folks accordingly. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
25 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

And we've got new quality assurance specialists 

in those Field Offices. And so we're we're 

setting up engagements with them and the Board of 

Appeals and Review. So we're just try to make 

sure we can get all of our training components 

tightened up before we start bringing on a whole 

lot of new people as technicians and as graders. 

But that's a small update here on some our Field 

Officers.

 We are expecting some additional 

transitions later on this year. In Portland, we 

may be seeing a transition from one of our Field 

Office Managers. And, you know, hopefully we can 

convince him to stay a little longer, but we'll 

see. But there's talk that RA may be retiring. 

So there's some potential change there. So 

there's a lot of movement going on in the system, 

but we will voice to take advantage of it. Not 

only that, there's opportunity for those were 

listening to become a part of FGIS with the right 

experience.

 And so additional change that we've 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
26 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

experience here at FGIS, as many of you know, 

Karen Guagliardo, who was our Director for 

Quality Assurance and Compliance, she retired 

back in January. And Karen has spent close to 30 

years with FGIS. We hired her replacement a 

couple of weeks ago. A young lady by the name of 

Ms. Karla Whalen. Karla, she's coming to us from 

AMS's Transportation and Marketing Programs. 

She's got about 28 years of experience in the 

Federal Government. Over 20 of those being in 

Compliance and Enforcement in the specialty crops 

world and with US Commerce. So we hope to see 

Karla soon. She'll be starting with us on the 

24th of May. So that's an additional change here 

of our staff.

 We've also hired some new quality 

assurance, not quality assurance. Yes, some 

Compliance Officers in QACD. So for those who 

are going through designations and delegation 

reviews, you may have interactions with some new 

Compliance Officers there. Cathy Brenner, is 

another name that some of you may be familiar 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
27 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

with. Cathy ran our Inspection Branch in the 

National Grain Center, our Instrumentation 

Inspection Branch in the National Grain Center. 

She retired last year as well. And Mr. Jeff 

Vanfossan has taken her role there. And I think 

that's it for some of our more senior positions 

in FGIS where we've experienced some change.

 We've got a lot of questions about 

when are we going to open up for business. And 

when can folks get back into the National Grain 

Center, meet with some of the staff. I want to 

get you the National Grain Center and meeting 

some of the staff. But we haven't opened it back 

up yet because things are still a little tenuous 

and we still have cases here and there. So until 

we get guidance from the White House that Federal 

Buildings can be opened up for re-engagement with 

public, we're just kind of holding tight. Our 

staff they're reporting to work in the National 

Grain Center. A lot of them are rotating in on 

schedules so just be mindful there.

 And it looks like I'm talking too 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
28 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

much. I'm overtime already. There are other 

things that we can talk about. What I'll try to 

do is cover some of those things in our updates 

on recommendations. So I will pause there and I 

will turn it back over to Matt.

 MR. KERRIGAN: Thanks Arthur. Does 

anybody have any, I guess, quick questions for 

Arthur? I'd hate to move on if there's something 

that's on the top of somebody's mind here. And 

he got off it easy that time. All right, well, 

we will keep pressing on here. Denise, if you'd 

like to talk about the financials.

 MS. RUGGLES: Let me see if I can 

figure out how to share my screen here. Can 

everybody see my screen?

 MR. KERRIGAN: Yes.

 MS. RUGGLES: Great, thank you. Okay. 

So I'm going to go over the financials for FGIS 

and talk about our rules that we have out and 

also what we've published on our finances 

publicly on our website. So we have posted on 

the website, the public website, the financial 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
29 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

data up through second quarter for FY21. I'm 

also going to go over the user fee review and 

obligations by each account with the April 

numbers that we have from our status of funds 

plans. And then the fee reviews and the 

financial registers that we've had so far.

 So for second quarter for fiscal year 

2021, you can see that the Inspection Weighing 

Program has about $22.6 million of obligations so 

far and revenue of 20.2. Our operating reserve 

is around about 7.6 million. And then our 

official Agency Program, the obligations are at 

889,0000 and then the revenues only at 474. So 

to bring up about that is because the fee was 

suspended through December 31st, of 2020. So it 

was just reinstated in January. And I'm going to 

go on and talk about the proposed rule that was 

out and the final rule where it's at.

 And then the Rice Program just 

touching briefly, I know this is the Grain 

Committee, but the Rice Program for AMA where we 

are, it's about 2.9 of obligations and we brought 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
30 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

in about 1.4 in revenue. And the Commodity 

Program is about half a million and then we've 

brought in about 1.1 million in revenue. And I'm 

going to talk about the little notes about the 

CARES Act funding briefly when I get to those 

individual programs.

 For a second quarter for the 

Inspection and Weighing Program, we break down 

how we're bringing our expenses or how we're 

accumulating our expenses by the different fees 

and the revenue that's brought in for those. So 

like the national costs is our overhead costs, 

and the revenues brought in from that national 

tonnage fee, the portion of the fee that we 

collect. And then the local tonnage fees for the 

Field Offices, and then their operating expenses 

for those local tonnage fees.

 And then down below you'll see the 

section about our export hourly and Inspection 

Unit fees, and the costs and revenue for that, as 

well as the non-export hourly and inspection 

fees. And that covers such as the Domestic Field 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
31 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Office, Appeals, Scale Testing Program, the 

Expert Registration Program, and the Technology 

and Science Division, the work they do on grain. 

Board Appeals primarily is one of the items.

 So historically, here's a picture of 

the Inspection and Weighing Account. The purple 

line is our export tonnage, metric tons. With 

the right-hand side with the tonnage figures. 

We're estimating that the tonnage this year will 

be at about 140 million. And then what the costs 

as of April are about 42.1 million with revenue 

only bringing in about 3.4 million. So to give 

you an -- to talk about that FY20 our four-and-ahalf months of operating reserve this program was 

to have, was 13.4 million. When we closed the 

FY20, the operating reserve was only 10 million. 

So this did trigger a 5 percent fee increase, 

which is the limitation we have in the rule for 

increasing fees, it's like at a 5 percent maximum 

increase or decrease.

 The goal for 2021, end-of-year fourand-a-half months is $15.8 million due to the 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
32 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

increased costs for the busier season we're 

having this year. The reserve balance is 

estimated at the end of this fiscal year at $7.3 

million. So it's only going to have about two 

months of reserve. We have used some CARES Act 

funding to offset some costs that were caused due 

to the pandemic. Items such as travel costs that 

have been incurred to keep coverage and supplies 

for masks and hand sanitizers and things like 

that.

 The Supervision Account, the tonnage 

fee is estimated to be about the same. Some of 

the tonnage is being shifted from the domestic 

market, of course, to the export market. And 

it's a little trickier to estimate those tons at 

this time. The reserve goal for '20 for the 

Supervision Account was $903,000 for six months 

of reserve. This year, the estimated amount 

needed is $824,000 with the estimated balance of 

the reserve going to be around $2 million or 14 

months of reserve.

 There is a rule, proposed rule that 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
33 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

was put out in clearance and we are working on --

in clearance is the final rule for that 

formulation to make adjustments annually to bring 

the reserve down to mirror the costs. So we are 

working on the getting that rule out so we can 

adjust those fees.

 And then briefly on the Rice Account, 

six months of reserve for the Rice Account was 

2.9 million, at the end of FY20 was the goal. 

And the goal for this year is up again, $2.9 

million of operating reserve. And the estimated 

balance of the reserve is going to be 4.6 million 

or approximately nine months of reserve. We have 

done our fee analysis and it's already been 

published and I'll talk about that, it's coming 

up in another slide. But the new fees have 

already been projected, are already announced for 

starting in October 1, of 2021. And that does 

take into consideration adjusting those fees to 

reduce the operating reserve.

 And then the Commodity Account. 

Here's the Inspection and Commodity Account and 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
34 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

he's about $1.2 million for a six months reserve 

and that's what it was for '20 and '21. At this 

time, based on information we have I and the 

CARES Act funding that we have used for this 

account, we are estimating we're going to have 

about 169,000 or only one month of operating 

reserve at the end of this year.

 On the fee reviews, so the Grain 

Inspection Fees were announced. Annually they're 

announced with the effective date of January 1st 

of each year. January 8th, we made the 

announcement in the Federal Register 86, Federal 

Register 1475, and we did publish a 5 percent fee 

increase. If you can remember back to that 

graph, I know it was really quick, as you can 

see, we're not going to maintain our reserve that 

we need for this program.

 So we will have to have a conversation 

about what we call rightsizing the fees where we 

need to periodically review the fees that have 

adjusted and determine what the correct fee for 

those type of services. To give an example, 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
35 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

would be maybe Aflatoxin Services where the fees 

maybe are not even covering the cost of the 

service as well as, like, the test kit for 

performing that service.

 The Grain Inspection fees, the 

proposed rule was announced in March 2nd, in 

Federal Register 86, Federal Register 12119. And 

that had the proposed rule to implement a 

standard formula to announce the fees each year 

with a January 1st, effective date. That final 

rule is in clearance at this time. We were 

hoping to have it published this month that we 

could have it effective this summer.

 The Rice Fees, of course, as I just 

noted, we had our last Federal Register that had 

the fees that are currently published for this 

year. We had two consecutive 20 percent 

reductions for each year for the portion of FY20 

and then all of '21, we had a reduction. We have 

announced in the Federal Register for the '22 

fees was in Federal Register 86, Federal Register 

20476. That does have the new fees that will go 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
36 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

into effect October 1st. And that uses the new 

formula for determining what the reserve is at, 

adjusting the fees based on that reserve need, 

and also the hourly rates. Now we have a regular 

rate, an overtime rate, and a holiday rate to 

mirror the other AMS programs, as well as 

contract and non-contract.

 And then a Commodity Program, we are 

drafting a new work-plan to adjust that commodity 

fees to cover the costs. And we are continuing 

to implement cost-saving measures where possible. 

We're also going to review the Co-operator 

Agreements that we have in place to assure that 

oversight fee we collect from the co-operators is 

appropriate for those services.

 That was a lot to go over. But is 

there any questions for me about the 

presentation?

 MR. AYERS: Denise, David Ayers, 

Champaign. Is it possible to get a file copy 

sent to the the Committee so we can print it off 

and have it? 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
37 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MS. RUGGLES: Yes, I believe Kendra --

Kendra, you are sharing that, correct, after the 

meeting?

 MS. KLINE: Yes, and it gets made 

public. So it'll be on the public website.

 MS. RUGGLES: Yes.

 MR. AYERS: Thank you.

 MS. RUGGLES: You're welcome. Is 

there any other questions for me?

 MR. KERRIGAN: Have there been any 

initial discussions when you talk about the right 

sizing, I mean, obviously we all see the numbers. 

Costs is always a very touchy subject when it 

comes to be it costs of services as it trickled 

down and such. You know, on a percentage basis, 

has there been anything floated, I guess, as to 

what you guys would like to see knowing that 5 

percent increase just went into maintain your 

guys comfort cushion and the reserves?

 MS. RUGGLES: We have not done a 

detailed breakdown yet of the fees and what fees 

would need to be adjusted yet, we have not done 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
38 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

that, no.

 MR. KERRIGAN: Okay.

 MR. NEAL: I think that was Matt, I'm 

not sure.

 MR. KERRIGAN: Yes.

 MR. NEAL: Yes. But one of the things 

people will have to keep in mind is that over the 

past, I guess four, five years, there have been 

constant, you know, continuous discounts to fees. 

So the fees have been discounted so low now, we 

got to re-adjust to account for just regular 

costs period. Because the whole intent was to 

use the reserves up. So it's not so much that 

FGIS's costs are increasing, They are increasing 

that's because we're moving a heck of a lot more 

product. But the revenue isn't where it should 

be because we've been discounting fees year over 

year over year. And so a five percent discount 

for, you know, to account for, I can't recall the 

total for sending discounts that we'd given the 

five percent discount. It doesn't bring fees 

nearly as close to what they need to be to 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
39 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

account for current operations.

 MR. KERRIGAN: And then a little bit 

different, I guess for, like, out here in the PW, 

Portland Field Office, how much oversight does 

FGIS have in, like, for instance all in all in 

WSDA fees and how those are are rippled through 

the industry. Because, you know, obviously on 

our certificates there is a dual fee for the WSDA 

services, but then also for the FGIS certificates 

and such. Is that just part of the general 

program overview or is it very interactive, I 

guess, between FGIS and WSDA, for example?

 MS. RUGGLES: Well, Compliance 

Division does review their fee schedule that they 

publish. It is reviewed by Compliance Division. 

And, Arthur, I'm not sure if Compliance could 

talk on how they do that analysis of those fees, 

but it does include our fees and their fees.

 MR. KERRIGAN: Okay. And my question, 

just for clarity, does stem from, there's a lot 

of the same discussions going on with WSDA 

regarding fee structure because of the previous 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
40 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

couple of years of, you know, extremely low 

volumes due to, you know, multiple factors and 

things of that nature, and just trying to get 

those operating reserves back up.

 MR. NEAL: Yes, and I think part of 

the requirements that in the review of the fees 

we have to ensure that those fees are reasonable. 

And I understand the position that WSDA's 

probably in since like we are as we've been 

trying to extend down reserves. We want to be in 

a position where, you know, if we have a 

situation where we're shutdown or we've got a 

significant pandemic like we've had this year. 

But we didn't have to tap into reserves per se to 

stay in operation, but if we needed to, we would 

be able to sustain service long enough for that 

pandemic, whatever, to pass through.

 We also want to make sure that we're 

covering our costs such that we have the size of 

workforce that we need to respond, nimbly to 

demand. As, you know, sometimes the demand isn't 

planned. It just it comes and it comes swiftly 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
41 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

and the request for service it comes swiftly. 

And we want to make sure that, you know, we've 

got the resources in place to ensure we've got 

the staff ready to go. So I understand where 

WSDA is with the low demand seasons and then you 

have a high demand season where you didn't 

necessarily predict, particularly through a 

pandemic.

 A lot of other industries, they're not 

necessarily Ag, but in some cases, their demand 

went down, particularly for food, the demand 

increased. You know, so that's a good thing for 

us. And I'm sure everybody who was in a serviceoriented business will be re-evaluating and 

looking at, you know, the cost for things. Look 

at what we're doing with gasoline now, that's 

unfortunate. But just the cost for services, we 

want to make sure that we are recovering the cost 

to provide the service that we're offering. So 

that's that.

 MS. RUGGLES: And on that, it will 

take a Federal Register proposal to be able to 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
--

42 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

implement those rightsizing of fees. That's not

 MR. NEAL: And --

MS. RUGGLES: -- announcement.

 MR. NEAL: -- nothing's going to be 

done rapidly, it'll be done in collaboration, and 

transparency with the industry. Any other 

questions for Denise? Okay. So I apologize, I 

got crossed up looking at the agenda and time. I 

wrapped up my comments sooner than I had to. So 

Denise leaves me with a little bit more time and 

I will share some more what's going on in the 

life of FGIS. We were talking about Field 

Offices. At one point, there was some 

significant work being done by Tony and his team 

in the Field Management Division particularly. 

Well, also PPMAB, Pat McCluskey and his team as 

well in partnership with the Ag Research Service.

 The wheat industry had been looking at 

trying to ship more wheat out of the Gulf and 

that's to China. And one of the tests that's 

required, the TCK test, those tests typically 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
43 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

take place out of the Pacific Northwest by the 

Wheat Marketing Center. I'm pleased to say that 

we have staff now trained out of our League City 

Field Office to perform that test for the wheat 

industry. So that if wheat does need to move out 

of the Gulf, we can take some of that burden out 

of the Pacific Northwest and allow it to move so 

through the Gulf. So we're thankful for that. 

That was a huge team effort between FGIS, the 

wheat industry and Agricultural Research Service. 

So tanks, Tony, for your leadership in that.

 I also want to say regarding 

information technology and modernization, I know 

before I came on board, there was a lot of 

emphasis on, what's it called, Epic. And FGIS 

modernizing its ability to facilitate grading and 

inspection in a more streamline way using 

technology. A lot of things have changed, I 

think, since that time period. Particularly here 

at USDA, there's been a huge shift in its 

information technology staff and its structure 

where a lot of its now consolidated and 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
44 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

centralized. And it also impacts our ability to 

do some of the things that we need to do to 

continue with that type of project, that type of 

effort. Not only that, we want to make sure that 

where we are, we don't invest in areas that won't 

yield significant returns.

 We want to make sure that whatever is 

invested, the industry, the staff, the program, 

the Agency, everyone can experience an impact or 

a return on that investment. And so right now we 

made a decision to ensure that what we have in 

place currently, we spend time maintaining it so 

that it operates well. And we'll be having more 

conversations internally and externally with you, 

our partners, around how we proceed moving 

forward. And there are a number of conversations 

that we know we need to have around forms and 

data collection and things like that. And so 

we'll be planning conversations with industry in 

the days of head around how we proceed 

collectively.

 We did have an informal conversation 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
45 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

with the Grain Inspection Advisory Committee 

around technology. Not just FGIS Technology from 

the standpoint of its enterprise system, but also 

the type of grading and inspection equipment 

that's out in the world today. And having 

conversations amongst industry members about what 

they've seen, what they need. So we're making 

sure that we're in touch with those type of 

needs. And we're also taken them into 

consideration when we're having conversations 

with the Grain Inspection Advisory Committee as 

well our staff. And Dr. Jhee will have some 

updates around equipment.

 A couple of the other updates I have 

will come later, but one update I do want to 

share with you is that there's some standards 

development work that's been going on out of our 

Field Management Division around we've opened up 

the standards for wheat. And so for those 

individuals who had interest in the wheat 

standards, make sure that you have an opportunity 

to review that call for input. We have some 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
46 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

other standards development work going on. Some 

of it's related to some of the GIAC 

recommendations, as a matter of fact, I might as 

well just go into those now.

 One of the recommendations from the 

Grain Inspection Advisory Committee, oh, Kendra, 

can you pull up the recommendations for us, so 

everybody can follow along.

 MS. KLINE: Just give me a second.

 MR. NEAL: Yes, take a minute.

 MS. KLINE: You guys see it okay?

 MR. NEAL: It'll come in a second 

probably. Not yet. Here it comes. So one of 

the recommendations, the GIAC made was that it 

wanted FGIS to take steps to reconcile and 

consolidate instructions to ensure clear, easy to 

access guidance that would be basically helpful 

to the official system and provide more accurate, 

consistent autonomy service. We took this 

recommendation and we worked very closely with 

Pat McCluskey and his team, Tony, to update a 

number of the Grain Inspection Handbooks. So in 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
47 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

fiscal year 2020, we updated the Rice Handbook, 

Fumigation Handbook, Grain Inspection Book 1, 

Grain Inspection Book 2, Grain Inspection Book 3, 

and the Sanitation Handbook.

 Those were three Inspection handbooks 

that we updated in 2020. They've been posted on 

the website and are available for use. We're 

continuing that process in 2021. We're going to 

be, I think they're working on some of the 

certification handbooks and a number of other 

items. And so Tony, if there's anything about 

that, in other words just an update process for 

2021, you can feel free to jump in a to add any 

more information there.

 MR. GOODEMAN: I think you covered, I 

think we've got, I think seven handbooks and 

directives last year, some or a number coming up 

this year. It's a continuing effort and 

recognize the interest in getting updated 

guidance out there that's easy to access. 

Continues to be a major priority for us. I think 

Arthur mentioned, the Certification Handbook. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
48 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

We've got the Pea and Lentil Handbook, the Bean 

Handbook coming out. We've got the NRT handbook 

in the works. Certification being a major one, 

I've said that bout three times now. But, yes, 

still a major focus and we're receptive to 

feedback. We try and plan these out a couple of 

years in advance to try and get them on a 

schedule. So if there's anything that you'd like 

us to focus on or look at most closely we would 

receive that feedback.

 MR. NEAL: Okay. Thanks, Tony. Part 

of that whole process to updating handbooks we're 

also taking a look at the website to see how we 

can cut down on some of the redundancy, organize 

it a little bit better. And it's tough because 

we're operating in a structure that was given to 

us from the last administration. All of the 

Agencies had to put their information into a 

certain structure and it was done corporately. 

So they just took the information from the old 

websites and they put it into an existing kind of 

container. And so we're trying to sort through 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
49 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

it to reorganize it to make it more useful to our 

users and our stakeholders. So we're working on 

it too and Kendra, and Shane, and Ruth, and 

others are kind of leading that team up along 

with Lee and and some of the folks in Policy 

Branch with Pat. So I thank them for that 

effort. Hopefully you'll be able to see some 

improvements soon. 

The next recommendation talks about 

budget. The Advisory Committee recommended that 

Office of Management in budget eliminate the 

limitation on Inspection and Weighing Service 

expenses. And if it's not possible, the 

Committee recommended that $55 million limitation 

only apply to grain export activities under the 

provisions of the USGSA. This is ongoing 

activity for us. We did have a number of 

meetings internal to USDA with our Office of 

Budget and Program Analysis to begin educating 

our leadership regarding the $55 million cap.

 And for those who are not aware of 

what that means, through the appropriations 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
50 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

process, there's a $55 million cap that's being 

applied to FGIS across all of its user-fee 

activities. And what that means is that we 

cannot spend more than $55 million on all grain 

inspection and weighing services. The reality 

that we believe is that the $55 million cap, the 

intent was for that $55 million cap to be placed 

on grain inspection and weighing activities. But 

it's also capturing our activities under Rice and 

Pulses. Which sometimes puts, you know, it 

causes to be very, very -- we should always be 

very careful, deliberate, and targeted in our 

spending.

 But sometimes it can create an 

unnecessary ceiling for us when we're trying to 

do more for Grain Inspection. So what we're 

trying to do is educate our leaders internally to 

see whether or not if we can only have that cap 

apply to our grain inspection and weighing 

activities, not are Rice and our Commodities 

activities under our 580 accounts. That process 

is ongoing. We did have some conversation with 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
51 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

the Hill about it. But the process by which, you 

know, they'd have to go to probably change this 

would be extremely involved. So we're trying to 

see if we can handle it administratively inside 

of USDA versus opening up Pandora's box. So 

we'll continue to provide updates on that.

 The next recommendation is regarding 

a systems approach or the Committee recommended 

that FGIS execution of support for the USDA 

soybeans systems approach should not compel a 

change in US Grading Standards nor require FGIS 

financial resources. To date, APHIS has 

basically paid for FGIS's involvement in this 

systems approach. They've been reimbursing FGIS 

through a reimbursable agreement for any of our 

staff time to work on this project. I think they 

work until it's carried out for a third year. 

And if there any other updates on that, I'll kind 

of kick it to Tony because he will have the 

latest on.

 MR. GOODEMAN: This was a three-year 

project along with it's the overall systems 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
52 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

approach. One component of that was a study of 

weed seeds a farm-gate survey that was 

implemented by APHIS at the state level. And 

FGIS had been assisting in that project by 

evaluating that and also by sending samples to 

the AMS Seed Lab in Gastonia, North Carolina. We 

are entering the third year of that study, the 

third and final year. And the actual analysis 

has not started yet, but the samples are all in 

waiting. We are not using any FGIS money for 

that project that is funded exclusively from 

APHIS. And we do have an inter-agency agreement 

with them to fund our portion of that study. So 

that's, I think that's the big update there, 

Arthur.

 MR. NEAL: Thanks, Tony. Another 

recommendation from the Committee dealt with 

lengthening the terms of service for GIAC 

members. The recommendation stated that the GIAC 

recommends at the 2020, Reauthorization US Grain 

Standards Act establishes a five-year term of 

service for GIAC members with the utilization of 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
53 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

shorter terms and standard appointments. This 

process of appointing members serves to 

strengthen commitments, service established 

continuity, forms a collaboration, and encourage 

cohesiveness on the Committee. Members are 

eligible to serve multiple but not successive 

terms of the reauthorization of the 2020 USGSA 

extended terms service for GIAC members, the 

Committee recommends that the Secretary extend 

current GIAC members terms according to this 

policy.

 So unfortunately, the USGSA did not 

get reauthorized until December 2020. By that 

time, we had already lost, when I say lost, some 

members their terms had already expired from the 

GIAC. However, the reauthorization did include 

an authorization for members to serve consecutive 

terms. Now, those consecutive terms are not 

automatic. Those members would still have to go 

through the nomination process for that second 

term. But the reauthorization does not prevent 

that member from serving a consecutive term 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
54 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

should the Secretary re-appointment them.

 So their recommendation was made known 

to Congress as they were considering the 

reauthorization of USGSA, and they did accept it. 

So you should feel good about that. Another 

recommendation dealt with the review of 

geographic boundaries. And it's stated that the 

GIAC Committee recommends a comprehensive survey 

of the market and scope of service fees in its 

boundary for Official Grain Inspection Services 

and the number of the official agencies.

 Since FGIS was created in 1976, there 

have been significant changes in the number and 

operations of grain handling facilities and 

official designated inspection agencies the 

amount of grain and oil seeds handled and 

processed within each geographic boundary and the 

number of quality attributes and other quality 

tests conducted by these agencies. The Advisory 

Committee believes these changes in the domestic 

marketplace necessitated that FGIS 

comprehensively update information and data upon 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
55 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

which the geographic boundaries are placed.

 The Reauthorization of the Grain 

Standards Act took this issue into account as 

well. And it does contain a requirement that 

after 18 months of the authorization, the 

approval of the USGSA, that we have to complete a 

geographic boundaries review. We've begun that 

review and hope that or we plan to have that 

review completed by, you know, early spring or 

mid-spring 2022. That's our goal and so we have 

started that process.

 The next recommendation dealt with 

vessel storage exams and the Advisory Committee 

commended FGIS on its efforts to incorporate 

innovative technology by delivering services to 

her stakeholders while protecting the safety of 

personnel. The Committee strongly encouraged the 

approval and implementation of the pilot program 

for Barge Stowage Examinations via camera system. 

The Committee also recommends FGIS continuous 

studying its technological innovative programs 

for cost-saving, efficiency and operational 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
56 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

safety concerns as it relates to vessel storage 

examinations. That is UAV with our technology 

and/or camera when applicable. And I'm going to 

kick this with Tony for an update on that.

 MR. GOODEMAN: Yes, so on that first 

about the Barge Stowage Exam with cameras, we did 

implement this. This was put in place via a 

program notice in the fall, I guess it would have 

been August of 2019, so that's available now. 

Implementation has been fairly slow, but we did 

also start the pandemic shortly after that. This 

involves a camera system. It's a it's a site-bysite approval. There's an approval process and 

anybody's welcome to use this. We are definitely 

encouraging this for Barge Stowage Exams.

 If you are a person on top of barges, 

could also result in lower rates long-term 

because it may reduce the insurance premiums paid 

by some of the official agencies for having more 

people working on barges. It is expensive. The 

cameras are very sophisticated. They're high-end 

security cameras that are needed for seeing this 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
57 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

far into the Barge and several thousand dollars, 

but not tens of thousands of dollars. So that's 

existing now and we're looking to continue to 

promote that program.

 Secondly, we've got an FMD Field 

Management Division Project this year to look at 

just more of an exploratory project for Vessel 

Stowage Exams using cameras. And we're in the 

early stages of that, but we're really trying to 

benchmark and see what other efforts have already 

been conducted. What kind of regulatory 

restrictions there are for using drones or other 

cameras in the environments where we have vessel 

exams. We're also looking at our own workplace 

injuries and the cost to justify and to examine 

that expense, just from a safety standpoint.

 So it's really early on and I would 

say that if anybody's got any good points to 

contact on this front, or anybody that really has 

tried this in earnest, drones or otherwise, we'd 

be interested in speaking with them to, again, 

try and get as much information as possible as we 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
58 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

evaluate what might be out there.

 MR. NEAL: Thanks, Tony. Before we 

move onto the next set of updates, I want to 

pause here and ask the Committee if you have any 

questions on what we shared thus far?

 MS. COOPER: I have a quick question 

to Tony on that last report. Did you say how 

long the pilot program for the Barge Stowage Exam 

is going to go on, and then, you know, what --

MR. GOODEMAN: Oh, yes.

 MS. COOPER: -- evaluation process be?

 MR. GOODEMAN: Great question. We ran 

the pilot program for, I think it was about 18 or 

24 months, had great experience with it. And so 

we ended the pilot and implemented it full-scale. 

So the pilot is concluded and that procedure is 

now available to anyone that's on river barges we 

do allow cameras and there's an approval process. 

And that has been posted on our site and is 

publicly available.

 MR. KERRIGAN: Is that both river 

systems, Tony, or is it only been tested on the 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
59 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Ohio and Mississippi River?

 MR. GOODEMAN: Just just on those 

river barges that are the flat bottom. We 

haven't looked at it for the self-unloaders out 

west . It's feasible. It's feasible.

 MR. AYERS: Tony, David Ayers. How 

many cameras are in use currently?

 MR. GOODEMAN: It's only a handful. 

I don't have the exact number, but it's a small 

number. I think it's less than ten still. We 

did start out with rail-car cameras that same way 

and now we have hundreds. So I mean, almost 

every rail-car loader is probably slow to start 

and then it gets momentum. And so I'm hoping 

that this one is similar.

 MR. FRIANT: This is this is Nick 

Friant. I'm not sure if this is a question for 

you, Arthur, or Tony, or someone else on the 

team. But on the systems approach, does FGIS 

have any sort of insight into who's got access to 

those, all the results of the analysis that's 

being performed? My understanding is a lot of 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
60 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

those samples are coming from port facilities. 

So are any of those sample results being shared 

back to the elevators that they come from or, you 

know, any information on how those sample results 

are being shared or not.

 MR. GOODEMAN: That's a good question 

on sharing back. I know APHIS is the point of 

contact for that whole study.

 MR. NEAL: Yes, Nick, I think APHIS 

is, they're keeping that data on house. So it's 

definitely not being shared wildly. So there 

they have a PLC for the study. So probably have 

to get in touch with him for that.

 MR. FRIANT: Okay. Thanks.

 MR. TURNIPSEED: This is Brent. I 

have a question from the educational side of the 

things with the website you're redoing that. 

When they redo the e-learning part and maybe 

they've already somehow have it where you can 

download those grading tutorials where you don't 

have to have an internet connection to go through 

them. Could they make sure that that's possible 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
61 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

again? Years ago you could do that and you 

actually gave out the CD-ROMs of them.

 MR. NEAL: Yes, Brent, I can't tell 

you the last time I saw a CD, man.

 MR. TURNIPSEED: I don't want the CD, 

but I want to be able to download the tutorials.

 MR. NEAL: Yes, I think the only 

challenge, we'll look into it. I think the 

challenge is I think it's almost impossible to 

download anything without having to have a 

internet connection.

 MR. TURNIPSEED: Well, you have to 

have an internet connection to download it, but 

then to be able to use it without the internet 

connection.

 MR. NEAL: Okay.

 MR. TURNIPSEED: Maybe they've got 

that solved but --

MR. NEAL: I see what you're saying 

now. 

MR. TURNIPSEED: Our classrooms have 

always had a good, strong internet connection. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
62 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MR. NEAL: Okay, We'll see, we'll take 

that into consideration.

 MR. TURNIPSEED: So I always download 

other things all the time.

 MR. NEAL: Got you. Any other 

questions or comments based on what we shared 

thus far? All right. Thank you for those that 

you did ask and we're going to move onto the next 

set of recommendation updates and we'll turn it 

to Dr. Ed. Jhee.

 DR. JHEE: Good morning, good 

afternoon, folks. I appreciate this opportunity 

to provide some updates. This one, as far as 

HVAC, the Advisory Committee commends FGIS for 

researching an improved method for HVAC 

classification in durum wheat. The Committee 

recommends FGIS continues to research and develop 

a bleaching method to quantifying separate HVAC 

kernels from soft kernels of durum wheat to 

facilitate sub-class determinations. The 

Committee encourages FGIS to further investigate 

whether the same or similar methods can be used 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
63 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

to determine DHV kernels versus non-vitreous 

kernels in the hard red spring wheat class. 

The update to this, the bar 

investigated the viability of the bleach DHV HVAC 

project for about two years. During this time, 

it was determined that a consensus among 

inspectors could not be made on kernels that 

contain high amounts of fissures or cracks. 

These fissures can create an appearance in a 

kernel that make it appear soft when it's 

actually hard. And they're formed on hard and 

semi-hard kernels due to handling. After several 

attempts to gain consensus among the inspectors, 

the bar decided to suspend the project and focus 

its resources on the possibility of supporting 

imaging technology for DHV HVAC. Kendra, you 

want to go to the next one.

 Mycotoxin test kits. The Advisory 

Committee urges FGIS to continue to identify 

causes of variation in mycotoxin testing and to 

develop a comprehensive plan to address these 

causes. The Committee requests FGIS to 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
64 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

investigate, certifying and reporting at lower 

levels than the current limit of quantitation and 

report back to the Committee. What I'll provide 

an update on is the mycotoxin test kit Federal 

Register Notice. We published this Federal 

Register Notice on some proposed changes to the 

test kit criteria back in December of 2020 with a 

30-day comment period. We did extend the comment 

period in February of this year, which concluded 

around the end of March.

 We're currently analyzing the comments 

and we'll begin formulating responses this month. 

Our next steps will include internal deliberation 

of the responses to the comments, as well as 

internal discussions on what our plans will be to 

move forward. With regards to improving accuracy 

among test kit users, the Technology and Science 

Division, we will have discussions with Field 

Management Division on enhancement, enhancements, 

excuse me, to internal quality control and 

training and licensing improvements. 

Next topic, new devices. The Advisory 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
65 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Committee appreciates FGIS's recognition of the 

importance of encouraging competition in the 

official device system. The Committee urges FGIS 

to develop a comprehensive and proactive approach 

to identifying new technology priorities that may 

bring improved test results, greater efficiency, 

and/or lower costs. The Committee recognizes 

that any new devices must add value to the 

testing system and compliant with current 

guidelines. We, FGIS is in the process of 

developing a comprehensive process for evaluating 

new inspection technology.

 The process will include approvals for 

technology for the official grain inspection 

system. As of now, this evaluation process does 

not apply towards research and development 

efforts that are necessary before the technology 

is deemed fit for posts. Here are some of our 

initial thoughts. That the process includes an 

initial evaluation to determine if the 

manufacturer's proposal meets requirements, 

demonstrating clear benefits for official grain 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
66 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

inspection. Furthermore, we have several 

unanswered questions so far, and we would like to 

engage the GIAC on input on this process. We 

anticipate having a draft of the documented 

process for GIAC input and discussion towards the 

end of this summer.

 Next LED. The Advisory Committee 

recommends FGIS continue research in the most 

appropriate LED lighting solution that may 

include overhead or task lights. TSD and FGIS 

collaborated with official agencies, they have 

Field Management divisions, DIO, Domestic 

Inspection Office, as well as the bar, to develop 

a test plan for the possible use of LED bulbs in 

the inspection system. We established MOUs with 

ten different official agencies who volunteered 

to participate in the study. We had 16 grain 

inspectors at these different official agencies 

provide services for us.

 The selected grain samples were sent 

to each participating location, as well as LED 

lamps. There were circulated to each location as 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
67 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

well. The inspectors graded samples under the 

LED lamps as well as the currently approved 

fluorescent bulbs. Once the official agencies 

completed grading of the samples, all of the 

samples were sent back to the bar for final 

evaluation. They've all recently completed their 

evaluation. And some of our next steps include 

statistical analysis of the data and then a 

decision based on the results of the data 

analysis on whether LED bulbs produce equivalent 

results to the currently approved fluorescent 

bulbs.

 Okay. Next one, Kendra, mycotoxin 

test kits.

 MS. KLINE: That's all of them.

 DR. JHEE: Okay. Got you. With that, 

I'd be happy to answer any questions.

 MR. KERRIGAN: Dr. Jhee, regarding the 

LED lighting and technology and the assessment, 

you know, one of the big issues with the 

fluorescent bulbs has been acquiring them. 

Especially looking to the future, I'm assuming 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
68 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

that that is a discussion point because if I 

remember right, during our last in-person 

meeting, there was a lot of discussions regarding 

the lights that were being evaluated. We still 

had very, very limited supply, suppliers, and 

with some of the different supply chain issues 

we're seeing just around the globe. Has there, 

I'm assuming that the bulbs that were analyzed 

were still the ones that were kind of presented 

to us at the last meeting or has there been the 

addition of potentially some other bulbs that 

that could have a better supply, I guess 

availability

 DR. JHEE: My understanding is that 

the bulbs that we considered to use in this pilot 

study or this project were actually custom-made 

based off the specifications that we needed in 

order to align both colored temperature and then 

the same type of -- in order to produce the same 

type of range as the fluorescent bulbs. So I do 

understand that that may end up becoming an 

additional cost, especially for unique production 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
69 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

of these bulbs. But I think right now we have 

one producer in California that supplied these 

bulbs for us that were of reasonable cost. I do 

know that our preference is to probably purchased 

from US manufacturers. We do know that there's 

some oversee bulbs as well. But that'll be, I 

think, part of the decision-making process as 

well.

 MR. KERRIGAN: Thank you.

 DR. JHEE: Sure.

 MS. COOPER: Ed, I have a question. 

Good morning. Back to the HVAC report that you 

gave, and the decision not to move forward with 

the bleaching project. Could you give us a 

little bit more information about the timeline of 

the imaging technology and how that will rollout, what that will encompass?

 DR. JHEE: Sure. So imaging 

technology, we are actually currently exploring a 

pilot project to determine the feasibility of 

imaging technology for both rice brokens as well 

as DHV, HVAC in wheat. Right now, internally, 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
70 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

we're considering what the scope of work would be 

for this type of pilot project. And our current 

thought process is to solicit participation in 

the pilot via the Federal Register. All of this 

is preliminary if you consider the scope of these 

types of projects. And our current thoughts are 

to consider what would be the performance 

criteria for evaluating imaging technology.

 We need to kind of really have a good 

idea of what we we're looking for. Lastly, we 

have been engaged with USDA's Agricultural 

Research Service, who has been working on a 

project to determine vitreousness in wheat using 

imaging technology. However, it's our 

understanding of this project it's still in its 

infancy. So there's additional discussions that 

we hope to have with ARS. Anything else, if not, 

Arthur, back to you.

 MR. NEAL: Thanks Ed. A number months 

ago, last year actually, we published in the 

Federal Register a proposed rules. I mean, 

Advanced Notice of proposed rule-making for 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
71 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

criteria around granting the exceptions to 

geographic boundaries. Can you-all hear me okay, 

or is it pretty light? I see my microphone bar 

is moving small, I'm trying to figure it all out. 

But we appreciate those who commented. An update 

on that rule-making is that we have a proposed 

rule but we got feedback from our Office of 

General Counsel to make some adjustments to it.

 You know, part of the recommendation 

you-all made to us regarding geographic 

boundaries and the review of it, that ended up 

getting to include it in the Reauthorization of 

the Grain Standards Act. You know, we really 

started asking the questions, you know, what is 

this, you know, what's the impetus behind it, you 

know, what are we really trying to achieve. And 

I really believe that we may be getting at the 

root of geographic boundary situation in the 

proposed rule on exceptions to geographic 

boundaries. A lot of it dealt with customer 

service issues and how to get those resolved if 

one does not believe they're getting timely 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
72 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

serviced.

 And so we're looking at those issues 

and we'll be addressing that in the proposed 

rule. That proposed rule has been put back into 

the USDA currents process. And so we hope to see 

it move swiftly through that process. We'll keep 

you updated on its whereabouts. But we hope to 

see it come out sometime this summer so that we 

can make continued progress on exceptions to 

geographic boundaries issue. So that that is an 

update that I think I failed to mention earlier. 

That is still related to the recommendation for 

FGIS to conduct this assessment or review on 

geographic boundaries.

 So I think team, if I have forgotten 

to mention anything else, you know, we've got a 

little bit more time left. Yes, we've got a lot 

more time left. I will open it up for anything 

that you-all have to share that you think I've 

forgotten and for additional questions from the 

Committee.

 MR. KERRIGAN: Anybody have any 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
73 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

questions for Arthur? Or any other member of the 

FGIS staff that may be present? Arthur, either 

everybody's forgotten to take themselves off mute 

or I think you guys have a clearance pass here.

 MR. NEAL: Well, we'll keep pressing 

ahead, that's for certain. And, you know, if 

questions arise, please let us know. But since 

we do have time, Matt, I would like to pause and 

address that initial question that you asked 

regarding the Secretary. And so I want to make 

sure that the Committee knows when we get into 

the discussion component of the agenda, we really 

need to have someone responsible for capturing 

those critical areas of discussion and also 

helping to summarize the recommendations that 

will flow from the Committee.

 Getting those recommendation crafted 

properly is critical. From the last meeting, 

there were two recommendations. I think one was 

the exceptions recommendation, and the other was 

the consecutive term recommendation for the 

Committee. Getting that language right, took a 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
74 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

while. And without having that Secretary to help 

us think through that process and get it all 

documented right so that we can share it with the 

Secretary, was significant.

 So ask that, you know, as we have a 

few moments that we reconsider that. And, Matt 

will have to pose that question again and ask for 

volunteers without a Secretary volunteering, you 

know, I guess we can take it, but if we do it, 

it's really not, you know, and it's not right, 

kind of not our fault either because we're not 

the Committee, you know.

 MR. KERRIGAN: Yes, you know, you 

know, the biggest thing here, especially for the 

large amount of new members on here, is that 

really the Secretary is just trying to document 

it. And especially on the Zoom, you know, it 

would likely be a sharing of screen of what's 

been typed up within comments to revise it from 

the whole group. It's not not solely relying on 

on the Secretary to craft it by themselves, for 

instance. So, you know, I don't want anybody 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
75 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

scared off by that. You know, what we're looking 

for is somebody kind of volunteer here for the 

next 24-hour period, I guess. And then you can 

kind of, I guess, decided if you'd like to put 

your name in the hat for the next round. 

You know, we do have a lot of examples 

from the last meeting of the previous 

recommendations to go off of. I will say that, 

you know, those are a big help to see how that 

wording is because again, these are 

recommendations to the Secretary. These are not 

recommendations or telling Arthur what to do, you 

know, for instance. You know, but because these 

are our topics, and this is really how this 

group, I guess, creates value for FGIS, you know, 

it's through these formal recommendations.

 So given that we're kind of at that 

mark in the agenda, Arthur, I guess maybe even 

though we're about 45 minutes from lunch, what do 

you think about maybe taking, like, a 15-minute 

break here. We want everybody kind of think 

about if they'd like to assist here. And we'll 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
76 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

come back, because we really, it's going to be 

hard to move forward if we don't have one and 

we'll start off with that in about 15-minutes.

 MR. NEAL: Sounds like a plan.

 MR. KERRIGAN: Okay. So me back here, 

I guess it would be 9:45 my time, which is about 

what, 12:45 Eastern Time.

 MR. NEAL: Yes.

 MR. KERRIGAN: We will come back and 

try and resolve that.

 MR. NEAL: All right.

 MR. KERRIGAN: Thank you.

 (Whereupon, the above-entitled matter 

went off the record at 12:30 p.m. and resumed at 

12:49 p.m.)

 MR. KERRIGAN: Okay. So kind of just 

getting us started back off here to the GIAC 

members, would anybody like to raise their hand 

as Acting Secretary here for the discussion here 

for the rest of this time and then for tomorrow?

 MR. TURNIPSEED: There's nobody else.

 MR. KERRIGAN: Okay. Brent sent me a 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
77 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

note that he would attempt to assist as Acting 

Secretary. So if that's okay with the group, I 

don't know, Arthur, Kendra, do we need to 

actually take a vote for an Acting Secretary or 

can we take it as self-nomination?

 MR. NEAL: You can take a selfnomination.

 MR. KERRIGAN: Okay. Brent, thank you 

very, very much. We're all here to kind of help. 

Like I said, you know, you were a part of the 

last one. So we'll -- hopefully the intent here 

with the rest of our time, we can get through the 

majority of our discussion today. So that way we 

can definitely take the time offline and such to 

review the wording from the previous one so we 

can come in tomorrow's meeting with hopefully a 

draft to start off with so okay. Arthur, do you 

have anything you want to start off with, or do 

you want to just get right into some of these 

topics?

 MR. NEAL: So it's up to you. You 

might as well go ahead and get right into it. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
78 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MR. KERRIGAN: Okay. Nick, do you 

have good enough internet connection to talk 

about the corn borer items since that now has 

your name on it?

 MR. FRIANT: Yes, I think so. I 

understand from Kendra that my voice is coming 

through fine. I don't know why my video isn't. 

It's probably this Zoom gov connection giving me 

fits, probably should pay more taxes or 

something. But yes, for sure. And if my voice 

does not come through very well, somebody please 

just stop me. So I guess Matt, just a question 

from a process perspective, how do we want to 

handle this, just an overview of the topic and --

MR. KERRIGAN: Yes, Kendra, do you 

have the summary write-up that you could 

potentially share the screen on and put up for 

everybody. And then maybe we'll have Nick give a 

brief overview to the entire group. And then 

with kind of, I guess if, you know, kind of where 

where the group is at and maybe if there's any 

FGIS feedback, you know, on concerns with this, I 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
79 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

guess.

 MS. KLINE: Sure, just give me one 

second and I'll get it pulled up.

 MR. FRIANT: I think, Matt, if it's 

okay with you, while Kendra's pulling that up I 

can start in on the overview. So the issue at 

hand here is hearings on Corn Borer 

Certification. And if folks aren't familiar with 

it for grain that originates east of the Rocky 

Mountains, corn, I should say specifically hey, 

that originates east of the Rocky Mountains 

heading west of the Rocky Mountains, particularly 

Arizona, California, Idaho, Nevada, New Mexico, 

Oregon, Texas, Utah, Washington, the grain has to 

be screened or scalped to over a certain size 

mesh to remove any cob, cobs or stalk joints that 

could harbor European Corn Borer. Because 

there's allegedly no corn borer west of the 

Rockies.

 And what happened, and now this is 

getting to be a little bit of an older issue, 

back in 2018, as you can see here on the screen, 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
80 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

in about the second or third paragraph down 

there. Minnesota Department of Agriculture, had 

identified some grain elevators in Minnesota that 

we're shipping those receiving States. And the 

screening wasn't occurring as required. Either 

it wasn't being done or not through the 

appropriate screen sizes. And so it raised a 

bunch of questions around what, well, in short, 

what can be done to address it and were there 

some different options to help manage it and for 

the facilities, right.

 So part of the part of the question at 

hand is, look, if I'm operating facility and I 

need to put in a screen or a scalper, to manage 

this, it could be a fairly expensive costs, 

right. And you can see down there in the, I 

think that's not the fourth paragraph right 

before the next steps. It talks about, you know, 

just the equipment itself could be upwards of 

$200,000 and this was, that $175,000 number was 

about three years ago. So could be even more 

than that today plus any of the, that's just the 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
81 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

cleaner, scalper equipment that doesn't include 

any of the additional belting or drags or 

facility modifications that would be needed to 

actually run that piece of equipment. So you can 

be talking several millions of dollars 

potentially.

 And so the point of this was to say, 

well, what are some options that could happen 

here and what role could FGIS play in supporting 

this. And you can see in the short-term options, 

there was some discussion initially around, you 

know, was there some sort of possibility for FGIS 

to provide some sort of official certification 

where if the grain was officially sampled and 

inspected, now FGIS or, you know, potentially the 

official agencies could issue a certificate 

saying that no live European Corn Borers. No, 

pieces of cob or stalk joints that could harbor 

European Corn Borer were found in the sample, 

something along those lines. 

And then another piece, and this is 

probably a little bit more specific to 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
82 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

facilities. Maybe not necessarily an FGIS 

opportunity, but allowing facilities instead of 

purchasing a brand new scalper or screener for 

their facility, could appropriately assign mesh 

screens put over the dump pit to screen the 

incoming loads while it was happening. So again 

that shorter term option probably not as 

applicable to this group. The question really at 

hand here was because of some option to work with 

FGIS at some sort of certification procedure or 

process for a short-term solution.

 And then longer-term, which I think 

some questions in my mind, what role FGIS and the 

Advisory Committee has to play in this longer 

term option. But eliminating the quarantine 

program for those States west of the Rockies. 

Again, not sure how the Agency might be part of 

those discussions, but that is one of the longer 

term solutions from a grain handler's 

perspective, there's interest in exploring. So 

that's the Overview. You can read the full 

details there and I think it's also posted on the 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
83 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Advisory Committee website, if I remember 

correctly, too.

 The one other piece I wanted to share 

with the group on this particular issue is this, 

as I mentioned earlier, this topic got a whole 

lot of attention in 2018 when Minnesota 

Department of Ag found these facilities that 

didn't have the proper equipment or weren't 

properly scalping the corn. I would add just 

from an industry perspective, since that time, 

and since somebody's initial discussions occurred 

a couple of years ago, the issue has not been a 

major topic for the grain industry. We haven't 

heard a lot of concerns either from handlers in 

Minnesota, North South Dakota, Iowa, Nebraska, 

any states that are are heading with corn west of 

the Rockies.

 There hasn't been a lot of attention 

this particular subject, so not sure, you know, 

how that might or might not play into any of our 

Advisory Committee discussions. But I did want 

to make sure that this group could hear that 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
84 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

update from grain handlers/industry perspective. 

I think with that, Matt, I think I can open it up 

to any questions that folks have about it or, or 

comments.

 MR. KERRIGAN: So I will say as an 

exporter I should probably know this question, 

but since it actually predates my time in the 

industry and I've always known it to be an item. 

This quarantine program is this a state-by-state, 

is this something that was rolled out from one of 

the Government Certifying Agencies? Was this due 

to export on the west coast? Does anybody, I 

guess, anybody shed some light, I guess, into how 

this, I guess, originally started as far as, you 

know, for us to kind of look at it from the, you 

know, from how we get past it if it's not an 

issue anymore?

 MR. FRIANT: So I can certainly give 

some of that answer, Matt, and absolutely welcome 

others to jump in as well. Part of, you know, 

part of it is, yes, it is a state-by-state 

requirement. And so I know I've spent some time 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
85 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

along with Jess McCluer at NGFA, having some 

conversations with some of the various State 

Grain Feed Associations and looking at the actual 

regulations. And, yes, basically, each state has 

their own European Corn Borer quarantine 

requirements. And so it is a very, you know, 

state-by-state specific how they may or may not 

change their rules.

 The other piece that you, I kind of 

thought you were going to include as well based 

on your questioning, was this balance between 

domestic and export. And I don't know how every 

state specifically manages it. I have some 

experience with Washington, Oregon, and 

California, where generally speaking, and I don't 

mean all the time, but consignments destined for 

export don't necessarily have to have this what's 

referred to as a Corn Borer Cert.

 So movements that are just in transit 

and are going from the train through the facility 

to the vessel, oftentimes, it's not required 

and/or facilities are not getting the Corn Borer 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
86 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Cert for those shipments. So that's I guess my 

high-level understanding of it. If anybody else 

wants to jumping in that conversation?

 MR. SINNER: Nick, this is Bob Sinner. 

That was a question that I had as well is if 

you're bridging these states for export, it 

wouldn't apply. But the question I have is on 

the certification program. Who's doing the 

certification? I'm assuming that FGIS is not 

involved in that. Is that all through the 

Department of Ag of each state. And then, 

because it would seem to me that if the group 

wanted to endorse the idea that FGIS be 

responsible for some sort of a certification on 

that particular shipment that one or the other 

could apply.

 MR. FRIANT: Yes, so your first 

question is a really good one. And based on my 

understanding of it, it's usually the State 

Department of Ag, yes. There's various, my 

experience is there's kind of some various 

different ways, right. So the Minnesota 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
87 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Department of Ag example, they had the particular 

branch and I don't remember the particular branch 

off the top of my mind. But they had some stuff 

changed in their Department where they started 

sending a number of people, inspectors out, to 

check these scalpers or screening systems that 

locations had.

 I know some other states like 

Nebraska, it's more of a, it's almost like a 

survey that they send out. And then the 

facilities have to have someone inspect their 

screens. So it is a little bit of a patchwork in 

the origin states on how it's managed and who 

certifies it, and who issues the Corn Borer 

Certificates. I know, I think if my memory 

serves correctly, in some states it might be and 

I don't know, Matt can, if or Arthur, can we 

leverage some members of the public that are on 

the call and in my case, particularly if if 

possible, I'd like to leverage Jess McCluer with 

NGFA since he's helped with this, if he's back 

on. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
88 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Or I think some of the States, it 

might be the official agencies that provide some 

sort of a certificate that they know the grain 

was scalped during loading. So I guess I say all 

that to say the origin states is as much of a 

patchwork of regulations and process as the 

destination states are.

 MR. WILLIAMS: Hey, Nick, this is 

Jimmy Williams. You know, I can only speak for 

Missouri, but I know working for the Missouri 

Department of Ag that our State Entomologist is 

the key person who is responsible for making sure 

facilities in the State of Missouri are 

certified. And that certification process, I 

mean, from what I understand, they will send an 

inspector to that facility once a year and 

they'll look at the screens and, you know, I 

don't know, do whatever they do. And one time a 

year and then they get a piece of paper saying 

that, you know, that they're certified.

 So, you know, that's how it's done in 

the state of Missouri. But it seems to me that 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
89 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

the folks that definitely ought to be involved in 

this conversation would be the folks at APHIS. 

Because if you've got a patchwork of rules and 

regulations, you know, with the western states, 

you know, it seems to me that the entity that can 

bring all of them together would be APHIS. You 

know, if this is no longer a problem, I would 

think APHIS could play a huge role in helping 

make this go away.

 MR. KERRIGAN: I don't know. Tony 

Goodeman, are you able to comment at all on on 

what the Field Ops in those various states are 

doing or not doing, I guess, from the FGIS 

perspective.

 MR. GOODEMAN: Yes, I remember when 

this first came up back in 2018, it was 

summertime and I was in Ohio, on leave, great 

State of Ohio. And a message came in, and I said 

corn borer, like, of all the things, like, you 

know, we don't deal really with corn borer, 

hadn't heard about it, maybe except in passing. 

And I guess I had some extended family around 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
90 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

that were corn farmers, I said, do you guys deal 

with the corn borer still. And they said, no, I 

thought that was gone years ago with Bt Corn, 

that was a thing of the past.

 And so yes, looked into it more and it 

is a state-specific program. This is the western 

states that require, that have the quarantine 

unless there's that certification. So we aren't 

really involved in it, no. It is definitely a 

fiber sanitary type issue. There is, I do want 

to offer and be upfront, that there is, like, we 

can measure things pretty easily. We can look 

for, you know, insects pretty easily if they're 

identifiable, you know, if we don't need to send 

them off to to an expert.

 So if somebody needed to know if there 

was pieces of corn cobs or stalk that were of a 

certain measurement, it's feasible that we could 

set up something like that, you know, with the 

statement to either put on a letterhead or or 

something to talk about any findings of cobs or 

stalks, but we don't want to go down that road. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
91 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

And one of the reasons that we're looking for the 

Committee is feedback. If it doesn't mean 

anything to the receiving state, you know, it 

might be all well and good to have this.

 But if it's not going to be acceptable 

by those western states, then it's kind of all 

for -- or if it's not used or acceptable by the 

the origin states for those programs to issue 

that certificate. So I do want to throw that out 

there. We can measure things as long as it's 

pretty prescriptive and easy to do. We could 

look for live insects if they were easily 

identifiable. But that's as far as her 

involvement, right now.

 MR. KERRIGAN: And --

MR. ENGEL: This --

MR. KERRIGAN: I'm sorry.

 MR. ENGEL: This is Curt.

 MR. KERRIGAN: Okay. Go ahead. Go 

ahead, Curt.

 MR. ENGEL: Well, this is Curt. As 

someone who's been doing this for a really, 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
92 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

really long time, you know, this is a quarantine 

issue, not an inspection issue. And I believe 

the background to all of this quarantine activity 

over time is this goes back to when corn was 

shelled by shellers. And the cobs were broken up 

in very large chunks and the stalks and that kind 

of thing. And all of that ended up being 

shipped. Quite frankly, I believe in boxcars. 

And there was active corn borer. There were corn 

borer activity that did end up making it to the 

feeders and consumers of corn on the west coast 

and the mountain states.

 You know, the physicality of scalping 

all of this product particularly is very large 

train loading installations. I mean these 

scalpers are enormous, and they're incredibly 

expensive. And to be able to go at speed, you 

know, if you're loading a train at 50, 60, 70,000 

bushels an hour, this equipment is incredibly 

large and it's hard to get it in the grain 

mainstream without, you know, doubling, well Nick 

was trying to refer to earlier, double and triple 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
93 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

elevating all of the product. You know, there 

was some comments about putting screen over the 

dump pits that would be sufficient to do the 

scalping exercise.

 Well, as I understand it, its halfinch square screen is the standard for knocking 

out the cobs and stalks that would be harborages 

for European Corn Borer. You know, I've never 

seen one and I've been in and around loading a 

lot of corn trains. So I think the quarantine 

piece could be, I don't know how to say this 

correctly, but I think this Advisory group could 

recommend some kind of action to end this 

quarantine corn situation in the states where 

this corn's being shipped.

 But I couldn't begin to think of how 

FGIS could influence whether or not the corn 

scalping activity was being done or not being 

done, and have a validity to a statement of that 

mixture without being included in the 

accountability for that. And one other comment, 

everywhere I've ever been involved in this, it 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
94 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

was the State Boards of Agriculture, in one 

manner or another, who were the certifying agents 

for all of this scalping capacity. And I'll be 

quiet now.

 MR. MCCLUER: Chairman Kerrigan, this 

is Jess McCluer. I just was going to, I mean, I 

know there may be others that may have comments, 

but I'd be happy to, you know, add to what Nick 

was saying earlier if no one else has anything 

else to add.

 MR. KERRIGAN: Any other GIAC members 

have any comments or current questions before let 

other members speak from the public?

 MS. COOPER: Yes, this is Janice. 

Just a couple of thoughts. It sounds like if the 

issue is not related to exports, then that might 

indicate maybe it's not a primary role or 

inappropriate role for FGIS. And someone 

mentioned that APHIS would be a more appropriate 

entity to get involved. It also sounds like this 

is a state issue. So I would hesitate to put the 

Committee on record on this particular issue 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
95 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

unless somebody showed that there was an 

appropriate role.

 I know that our Charter is to advise 

the Secretary. But I think it's really focused 

on FGIS activities. So that would just, that's 

based, I don't know a lot about it, but it's 

based on the discussions so far, that would be my 

reaction. But Jess, you may be able to educate 

us as to why it is a concern for this Committee. 

So I'll drop off.

 MR. FRIANT: Well, and this is Nick. 

I'll add part of the reason because I was 

involved in this when it came up originally in 

2018. Outside the Advisory Committee, part of 

the reasoning behind potential thoughts for FGIS 

was an alternative to get a certificate rather 

than having to install the equipment and some of 

the stuff that we heard from handlers was, you 

know, if we can have some sort of official 

certificate that would be accepted that might 

eliminate this need for the equipment. But Tony, 

you raised a phenomenal point that no guarantee 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
96 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

that the destination states would even be 

accepting of an FGIS certificate certifying, you 

know, no live insect and no FM above a certain 

size. So that's where I think there could be 

some potential FGIS involvement. But I think 

you're raising a good point, Janice, that is this 

really the right forum or not. And I think 

that's why we should be having -- that's the 

exact discussion we should be having here because 

it may not be the right forum anymore.

 MR. MCCLUER: And Nick, is there 

anyone else, Matt, that, or --

MR. KERRIGAN: Go ahead, Jess.

 MR. MCCLUER: Okay. So for those 

don't know me, my name is Jess McCluer, I'm with 

the National Grain and Feed Association. I know 

many of you that are on the call. But Nick had 

referenced me and the Association. We had 

obviously been very involved in this with the 

Minnesota Grain and Feed Association. And just a 

little background on this, I can tell you that it 

has primarily been the State of Minnesota and the 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
97 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Minnesota Department of Ag that has been very 

involved and really pushing this issue. And when 

we had discussions with our other NGFA State 

affiliates in California, Texas, Washington 

State, Nick, correct me if I'm wrong, but it was 

difficult finding staff at those levels within 

those Department of Ags that were very familiar 

with this. It was not a priority issue.

 Okay. And I think from the Minnesota 

Department of Ag standpoint, there was some other 

issues, I think, leading to them pushing this. 

And some of you may remember there was an issue 

of several years ago that came up in Minnesota 

with a general manager of a co-op that had been 

embezzling some funds. And it was a very 

controversial issue and I think that led to a lot 

of the increased inspection and enforcement of 

this based on what happened there.

 So as Nick was saying, this issue 

initially came up, we had discussions with FGIS 

about this. We had a joint NGFA NAEGA Committee 

Meeting and Austin right before the lockdown when 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
98 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

this issue came up and these proposals that Nick 

was mentioning. And then of course, with the 

lockdown, everything was tabled. And thought 

this would be an opportunity to raise it with the 

Advisory Committee. But in the meantime, since 

this discussion began, it has been very quiet. 

There has been really no activity. No, I would 

say this issue is not been raised by a member or 

by the Minnesota Department of Ag.

 And so in that sense, along what 

Janice said, you know, it might be, you know, 

obviously it's the Advisory Committee's decision, 

but, you know, something to consider would be 

maybe this might want to table this for now until 

there is any further development that may need 

input or advice by the Committee on this. And 

obviously, if there is any new development that's 

something that Nick, or other members might 

provide input. The only other thing I would just 

add to that, it's something that might be very 

helpful in line was what I believe Curt had said, 

is that, you know, something to consider as far 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
99 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

as this, you know, obviously this corn borer 

issue is still out there.

 I mean, these rules are still 

required, but maybe something to help, I would 

say that would strengthen the case in repealing 

these requirements might be a study to show that 

the corn borer issue, and a study by a 

university, or a study by an agency having the 

data to show that this is no longer the issue 

that it was 20 years ago. And I think having 

that type of data available might further 

strengthen the push to maybe eliminate the 

requirements. So that's just further background 

information on the issue. So Nick, I don't know 

if there's any anything else to add to that or 

hopefully I was on track.

 MR. FRIANT: Yes, no, nothing else 

from my perspective.

 MR. KERRIGAN: Okay. Just a quick 

question for you just because you mentioned 

obviously, that NGFA, they get involved back in 

2018, to a certain degree and obviously has, I 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
100 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

don't want to say a loose or affiliation but a 

ability to work with the various State agencies 

and such, you know, where we're in this 

discussion about FGIS. Is it NGFA's current 

position that it's kind of let sleeping dogs lie 

since it hasn't come up again or are you guys 

actively thinking about pursuing that, I guess 

from the Trade Association standpoint?

 MR. MCCLUER: From the Trade 

Association standpoint, this is, I would say, we 

are on the let sleeping dogs lie standpoint. We 

have reached out to our State affiliate, the 

Minnesota Grain and Feed Association, and we 

haven't really heard anything back from them 

about this. They were the ones that initially 

raised the issue. They made a presentation to 

our Grain Grades and Weights Committee about this 

issue. We started working with them on putting 

together this material, reaching out to FGIS. 

And it has been very quiet since. And so since 

it's been quiet, in light of everything else that 

we're dealing with, this does not seem to be a 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
101 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

priority. So we would just let it -- from an 

Association standpoint, we're going to let it sit 

until there's any further development.

 MR. KERRIGAN: Okay.

 MR. MCCLUER: Okay. Is that correct 

Nick, you're the Chairman of the Committee, I 

want to make sure.

 MR. FRIANT: Yes. No, I would agree 

with that position from the Association. So I 

guess Matt, my question back to the Committee is, 

what is do we have a procedural steps that we say 

that we're just going to table it or we just --

how do we handle it from this current 

perspective?

 MR. KERRIGAN: Well, so from a 

procedural standpoint, I mean, it's a discussion 

item, you know. And out of that discussion and 

we can put it back on the agenda for future 

meeting. We can try and come to a an agreement 

to make a recommendation to the Secretary. Or, 

we can have the discussion and we can move on is 

kind of the three options. You know, there's 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
102 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

nothing that says that we have to have a 

recommendation. You know, this was a requested 

topic to discuss. You know, we don't have to, if 

the entire Committee, you know, feels that the 

correct approach is to let it be, then that's the 

the Committee's decision.

 I did want to follow up here, I guess 

one of the benefits of Zoom, while there's not 

that many of them, is I was able to reach out to 

one of our head traders and he has confirmed that 

the co bo certificates are only needed for 

domestic markets from their perspective. While 

we get all of them from an export standpoint, 

because we don't always differentiate or IP 

what's going to domestic or export, it's not 

currently a requirement for export in general. 

So just to confirm that I realized that, you 

know, that's one exporting company on the west 

coast and not trying to speak for everybody by 

any means, but that has been our experience so 

far.

 So I guess for the Committee, my only 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
103 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

kind of question is, you know, it could be an 

APHIS, it could be a Department of Ag, for the 

individual states, you know, what does the 

Committee think about, you know, while -- all 

right, Arthur, you have your hand up. I just 

happen to see your hand, Arthur, do you have 

something to add to this?

 Maybe, maybe not. Okay. You know, as 

far as the Committee's concerned, you know, while 

there are obviously, you know, a lot of various 

government agencies that, you know, if we wanted 

to, I guess make a recommendation that the 

recommendation for FGIS is likely not to take 

direct action, but it could always be to interact 

with the other agencies. Again, it is also with 

the Secretary to potentially reach out, you know, 

again for that APHIS group as well. Or if it's 

the individual states, again, I agree with the 

group that from my standpoint, I don't know that 

that's a whole lot of, you know, of action from 

recommendation. It looks like we have a couple 

of questions out there. I apologize how I've got 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
104 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

my screen, I'm not seeing all of them. Brent, do 

you have a question?

 MR. TURNIPSEED: Well, one thing I 

just want to mention, I work at a university and 

I hear the talk about the corn borers and 

everything from our entomologist. The issue will 

go away for a while, but it's going to come back 

probably because I hear from farmers, they don't 

want to buy the Bt Corn now, pay that extra 

because it's so expensive. Because they don't 

have any problems with the borers. So some of 

them are going back to planting non Bt corn until 

the problem increases again. And then they'll 

swap back. So this is not going to go away. So 

I don't think, I hate to see us, I think it's 

more of an APHIS issue as well, as along with 

Janice there. That's just my two cents on it. 

MR. KERRIGAN: No, that's a great 

feedback there, Brent, on that, from a different 

perspective. Any other comments or questions or 

discussion on this?

 MR. NEAL: Hey, Matt, this is Arthur. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
105 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Sorry, I faked you-all out with the raised hand, 

my connection dropped. I just want to provide 

some clarity to on today's agenda talking about 

discussing these issues. You-all don't have to 

take them up for recommendation today because 

that's on the agenda for tomorrow. And so you 

can decide tomorrow whether or not you want to 

table them.

 MR. KERRIGAN: Okay. Arthur, can you 

maybe shed a little bit of light, I guess for 

discussion purposes regarding, and really kind of 

thinking about the intent of the group, you know, 

to the Secretary while obviously our primary 

liaison, you know, it's with yourself and the 

FGIS, you know, group and such. And it actually, 

it looks like Jimmy Williams actually just kind 

of posted up everybody regarding your guys 

interaction with APHIS. Can you describe kind of 

how that is or if there was to be a question to 

reach out to APHIS. So what that could look like 

or how that interaction could happen?

 MR. NEAL: Yes, I mean, jimmy Williams 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
106 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

hit it. You-all could make that recommendation 

that, you know, FGIS reach out to APHIS to help 

facilitate conversation with industry around this 

issue to see, you know, what steps would be taken 

to address the patchwork effect that could work. 

I mean it's going to the Secretary and so we can 

definitely convey that message Aphis and FGIS or 

AMS, we're under the same umbrella Marketing 

Regulatory Programs. We have the same Under 

Secretary, Deputy Under Secretary. And so we can 

definitely convey that recommendation to the 

Secretary and to our Under Secretary. So it's 

not in vein.

 MR. KERRIGAN: Understood. Thank you.

 MR. NEAL: Yes.

 MR. KERRIGAN: Any other discussion 

from the group while we're actually in the middle 

of discussions here. Okay. I just happened to 

notice, looking at the time here, and I apologize 

because I am on a three-hour different time zone 

than everybody else. It looks like it appears to 

be 1:25 Eastern Time and we have scheduled lunch 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
107 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

for 1:15. If there's no other discussion on corn 

borer, it could be my recommendation here that we 

would take a break for lunch and then come back 

to hit the other topics. Again, that's assuming 

that that are current corn borer discussion has 

been exhausted. Is there anybody else from the 

GIAC that has anything that they'd like to share 

or add to this discussion? Okay. Arthur, I'm 

not hearing anything so I'm going to recommend 

that we take a one-hour, we're a little bit ahead 

given that the corn borer is discussion appears 

to be at through. So let's come back at, you 

want to say 2:25. Okay. We'll see everybody in 

an hour. Thank you.

 (Whereupon, the above-entitled matter 

went off the record at 1:26 p.m. and resumed at 

2:26 p.m.) 

MR. KERRIGAN: All right, I'm seeing 

58 people. We definitely had some some that have 

dropped off that joined back again. Given that 

I'm not seen a lot of videos. A few more people 

popping in. It is 12:25 Eastern Time or 12:27 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
108 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Eastern Time. And I feel like my grandma right 

now, I'm trying to figure out what time it is for 

everybody, but I don't know. Does anybody have 

any comments on anything that we've discussed 

this morning, whether it be any of the FGIS, you 

know, item or updates, the previous GIAC topics 

that had been talked about, you know, 

recommendations in the past that we've got an 

update on or the corn borer topic?

 MR. NEAL: Hey, Matt, this is Arthur. 

I did seek some clarity on the corn borer topic 

and I'm corrected in that the GIAC should not 

take a formal action on it as it does not pertain 

to issues that fall under the scope of the USGSA. 

However, you know, a letter can be submitted to 

FGIS asking us to help facilitate a meeting, you 

know, by the industry, you know, with APHIS.

 MR. KERRIGAN: Okay. That is very 

good information to know, I appreciate that 

Arthur.

 MS. COOPER: I have a question about 

some of the recommendations from the last meeting 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
109 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

in 2019. I see there was a hemp rule-making 

item. Were you going to report on that?

 MR. NEAL: Was not taken up as a 

formal, it was a recommendation, but we're not, 

because it does not fall under USGSA, we don't 

have anything to report out on it. It was us 

bringing AMS to the table to update the GIAC on 

AMS's rule-making activities pertaining to hemp.

 MS. COOPER: Thank you.

 MR. KERRIGAN: Anything else from the 

group? Okay. Hearing nothing, if we can, let's 

keep moving on, on the agenda items for the 

discussion. Next one I see there is, Average 

Inspection Flexibilities. If Kendra is able to 

put that write-up up on screen, that'd be great. 

If not, everybody should have received a copy of 

it already. I'm going to take the lead on this 

one as it was submitted by me. I've had 

discussions with with a couple of the GIAC 

members and hopefully everybody has had a time to 

take a look at this.

 But essentially we'd run into a 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
110 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

situation where our export customers, usually and 

most typically on the wheat, are asking for very 

specific tolerances and grade factors that not 

all of them are, I guess, are being governed, 

governs not the proper word there, but not being 

watched by FGIS. And so in the example, the 

second one there is a customer will ask for a 

protein average of 14.0 or more. But there will 

also be a requirement that each sublot has to be 

a minimum of 13.8. Again, every, you know, 

different grade factor here has different reasons 

why the FGIS is only looking at one factor or the 

other.

 But that 13.8 minimum per sublot is in 

the elevator, the loading facility's 

responsibility under a, quote unquote, elevator 

instruction on the load order. Which then, you 

know, requires the shipper to provide that 

documentation, as well as self-manage, you know, 

should we still fall within the actual 14.0 

average at the end of the lot, with a sublot fall 

below 13.7, the actual grade certificate issued 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
111 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

by FGIS, you know, will show that it met all the 

requirements. You know, however, if there was 

one that fell below 13.8, the loading elevator 

would have to EER it. There's no ability for reinspections or anything of that nature.

 Again, this is giving the example, 

just asking for, as this kind of request, because 

these are all factors that are currently being 

graded by FGIS. And it's more in the application 

of how that grade is issued. And so, you know, 

my I guess, request and proposal is kind of a 

discussion regarding the utilization of the of 

the elevator instruction piece, you know, versus 

if those can be incorporated to the actual FGIS 

certificate and graded. John, I believed you had 

her hand up?

 MR. LINDGREN: Yes, Matt, my 

understanding was the 13.8 for each sublot is 

required by WSDA to follow. So you couldn't put 

a 13.7 on board, it would be a material portion. 

The average is what we show as what is the 

responsibility of the loading elevator. Anything 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
112 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

the average is our responsibility, but that 

minimum, 13.8 per sublot, we've been instructed 

that WSDA will lower that.

 MR. KERRIGAN: So they will do it 

either way. You can either state on the load 

order that you want an average of 14.0, and then 

the elevator instruction is the minimum of 13.8, 

or they will look at the 13.8 and then it's our 

responsibility to do the 14.0 at the end. The 

key piece here is that there's no meshing of a 

min-max in an average on the same load order 

peaks.

 MR. LINDGREN: Okay.

 MR. KERRIGAN: So yes, and so that 

seed damage, that's protein. Those were the two 

examples that come up, I feel like, quite a bit 

for us. There's also the typical one on Western 

and club pits because of how some of those 

requests one a specific level of club which is 

either above or below but before the opposing 

into a different classification. So kind of the 

question is, is really from the FGIS a handbook 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
113 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

side, I guess, you know, is there or what are the 

limitations regarding mixing some of these to 

kind of help us watch and market this, you know, 

these load orders and grain that we're selling 

for our customers. What does that mean from that 

application standpoint, from the FGIS standpoint. 

And, you know, one of the thoughts are, as far 

as, you know, could we get some mixture of it to 

help manage that. John, do you have something 

else there too?

 MR. LINDGREN: No, I just think I just 

haven't put my hand down.

 MR. KERRIGAN: Okay. So I don't know 

if Tony or even on the standards standpoint, I 

believe it was that Pat, Arthur, from your side 

that may be able to speak? I don't know if you 

guys have have taken a chance to kind of consider 

this, think about it, or maybe educate me a 

little bit.

 MR. GOODEMAN: I'm happy to speak to 

it. This is average quality right after lunch, 

get your popcorn ready. This is inspection 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
114 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

plans, this is tolerances. So this is exciting 

stuff here.

 MR. KERRIGAN: Hey man, it's day in, 

day out, for us.

 MR. GOODEMAN: Right, oh, I know. I 

said it halfway in jest, but really, it is really 

the bread and butter of exporters trying to meet 

requirements. Okay. So just for an overview. 

Generally, we have a couple of inspection options 

when you're loading a vessel. In one hand I'll 

certify it as one lot, you can do CUSUM which is 

the traditional loading plan and that's intended 

to achieve a set minimum, at a minimum quality 

throughout that lot. And there's a lot of 

restrictions on that. You can go a little bit 

over on certain factors, but in general, there's 

not much leeway there. We have average quality, 

which is become more and more popular, especially 

in corn and soybeans. I don't know if we put out 

exactly what percentage of lots go to, I don't 

think that's sort of public, but its popular. 

And then we've also got no sublot to exceed. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
115 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Now, what we typically will come 

across is applicants that want the best of both 

worlds. They want to say average quality, so 

they've got full leeway to load almost anything. 

And as long as the average works out at the end, 

they're in good shape. I know Arthur's 

entertained, and I'm glad I'm entertaining 

Arthur, get the hand motions going. So average 

quality is very, generally speaking, very 

shipper-friendly. Now I guess the buyer might 

get a better price on that, so maybe it's, it's 

friendly for everybody. But generally, if you 

want, if you get a loader for US number 2, about 

our yellow soybeans, you can have FM anywhere 

from zero up to several percent, as long as the 

average works out in the end, lot of flexibility.

 Now what shippers will sometimes ask 

for and try to get the best of both worlds, they 

want the ability to blend wherever they want, but 

they also want a re-inspection on the stuff that 

goes over, from things that are -- and we have, 

as our policy, if it's average quality, if it 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
116 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

meets, if it's good according to the inspection 

plan which for average quality, almost everything 

is, then it's not eligible for a re-inspection. 

And so that's one angle that we work in our 

instructions to try and address. That's why we 

say, that if you've got average quality, if it's 

accepted by the plan, you're not eligible for reinspection. If you want to have some kind of a 

self-imposed limit, that's fine. But the 

elevator responsible for maintaining that.

 We're happy to maintain it as like a 

no sublot to exceed or some type of a set value 

with use intolerances. But if you want the 

benefit of the average you can have those peaks 

and valleys, then you can maintain any of the 

self-imposed limits. Now, the items on this 

sheet here are actually more restrictive than 

some of these sort of things. It's actually not, 

I think when his first came across, we're 

expecting, you know, something that we see, you 

know, a lot of times. This is actually more 

restrictive --

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
117 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MR. KERRIGAN: Correct.

 MR. GOODEMAN: -- so I do think there 

might be some options here for the heat damage. 

You know, the heat damage is more complicated one 

because I think that I think the grade limit for 

number, we just went over this yesterday in 

preparation and the bullets are escaping me, I 

don't want to misquote the standard, the grade 

chart. But you could ask for a maximum per 

sublot, you know, no sublot to exceed and then 

it's on you to maintain that average. Kind of 

like what John was saying one or the other.

 The protein average is interesting. 

I'm wondering if there's something we couldn't do 

within the CUSUM to tighten the tolerance of what 

would, you know, exceed a break point. Because 

again, if you asked for you, if you just asked 

for a 14.0 on CUSUM, I think you'd have, or 

looking yesterday, about five tens to play with. 

You can have a sublot that was 13.5 as long as 

you brought it back and the average worked out at 

the end, you could potentially have that. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
118 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

I'm trying to think if there might be 

some options to reduce our CUSUM tolerances if 

the applicant requested something like that. And 

then with the white club, that's an interesting 

going to it is correct that we do not allow kind 

of grain or class or subclass except where it's a 

specific reading factor to be averaged. The 

reason being we didn't want to have corn going 

into soybeans in the last, you know, sublot or 

having all the, you know, the white club, you 

know, being put or or subtracted in various 

points. We do have some parameters in place 

trying to, you know, maintain the integrity of 

the shipments to a degree. But the --

MR. KERRIGAN: So for clarity on this, 

these are specific trade terms that our customers 

have versus from us. So yes, I 100 percent agree 

that these are more restrictive. And so from a 

shipper standpoint, we're not trying to get 

additional flexibility. We're just trying to get 

the assistance --

MR. GOODEMAN: Right. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
119 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MR. KERRIGAN: -- in keeping with what 

we sold, I guess.

 MR. GOODEMAN: Yes, and one thing I 

think is maybe stated here, maybe we had it in 

conversations previously, was just some 

assistance in flagging sublots that don't meet 

these criteria. From our standpoint, our primary 

concern is if its eligible for a re-inspection or 

not. If it's not eligible for re-inspection, you 

just want us to have it show up red on the log so 

that somebody hasn't loaded aboard by mistake. 

There might be some options there, might require 

some development work. I don't know. Our expert 

on that, Lee Capper might be able to share how 

cumbersome that would be. But in general, like 

for us to have it wide, you know, more as a 

safeguard might be possible. Again, so long as 

it's not eligible for a re-inspection because 

that make sure --

MR. KERRIGAN: So how this initially 

started, was about 18 months ago, I guess, when 

we first started talking about this. You know, 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
120 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

it was really I thought this was going to be a 

technology piece in the flagging. Yes, but my 

request is not so much focused on the reinspection piece. It's more about having 

assistance because of how most exporters, you 

know, have a duplicate screen available, you 

know, with each sublot coming up with the grades 

and everything's green or gray or red, right. 

And if, you know, as we're doing various lots and 

and again, moving the tonnage per hour we are, if 

we're, you know, those operators they're seeing 

green --

MR. GOODEMAN: Green means go.

 MR. KERRIGAN: Green means go, but 

then also from, you know, from, in our case WSDA 

standpoint, it releases the interlocks to allow 

us to load it.

 MR. GOODEMAN: Okay.

 MR. KERRIGAN: And so then if there's 

a mistake made and everything's loaded and we 

show it to the buyer and he says, hey, you missed 

this, then there's usually one or two options. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
121 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

One of them, which is, is a monetary compensation 

to the buyer.

 MR. GOODEMAN: Right.

 MR. KERRIGAN: But depending on the 

buyer, it could mean unloading that entire lot of 

that vessel and starting over again. So that's 

really our concern is, at least, you know, from 

my perspective, is the flagging portion of it to 

help watch it because we've gotten caught or some 

of us had been caught or very close to being 

caught of not watching it because we're seeing 

all those greens and we're so used to the system 

and how it works.

 MR. GOODEMAN: Right.

 MR. KERRIGAN: And that when we put it 

in the elevator instruction, it's you know, it is 

solely on us. And we understand that. I think 

what I'm asking for is just can we get some 

assistance because we're relying on your guys 

grade and program to help moderate this?

 MR. GOODEMAN: Yes, that's a great 

question. And then with the white club, the not 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
122 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

less than 25 percent average. There are some 

options there, but probably would likely include 

putting that on the CUSUM for 25 percent then it 

kind of limits the flexibility you'd have to go 

really low. Like you wouldn't be able to put on 

I think you'd have several percent to work with, 

but probably couldn't put on, you know, even 

something that met western white, you'd need to 

put on a sublot of 10 percent probably be so far 

below that 25 percent on the CUSUM, that would 

probably kick it out.

 MR. KERRIGAN: And so with at grading 

of obviously CUSUM to average, you know, I 

understand it's about trying to find that piece 

in there, but it's really it's those trigger 

points that are customers are looking for in a 

phrasing. Well, yes, it would be nice to if, you 

know, if everything handled like corn and beans, 

let's face at right. But they do tend to get 

very, very specific. And especially again, I use 

wheat as an example because there are just so 

many grade factors that are traded on, you know, 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
123 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

instead of just a number one, two, or three, 

right?

 MR. GOODEMAN: Right.

 MR. KERRIGAN: Does anybody else from 

the GIAC, I guess, have any comments on this? 

Either from, John, if you have any more comments 

that maybe I have misrepresented or maybe 

haven't. Any examples that you're aware of that 

this could be beneficial, that we want to get out 

there?

 MR. LINDGREN: Well, I think in the 

end, what this average comes down to versus the 

things that are allowed in the CUSUM plan or the 

no sublot to exceed or below, it does come down 

to, like, Tony's mentioning, whether it's an 

ability to do a re-inspection or not. Because 

the example you just used with club, you only get 

5 percent on club. So you were to put a minimum, 

you know, if you'd use a CUSUM plan on a 25 

percent, you can put anything but 20 on board.

 MR. KERRIGAN: Right.

 MR. LINDGREN: And then it's some of 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
124 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

those that are so subjective, that's where the 

challenge lies. And getting DHV picks or club 

picks, which are the ones that we're talking 

about on class where you can't average, you know, 

below a class and things like that that are the 

challenge. But I don't know, there seems to be a 

lot of discrepancy on how the load orders need to 

be written to meet what our customers are asking 

for and what FGIS can issue load orders as. The 

difference between the average and minimum or 

maximum, you know, soon as they see the word 

average, you throw out anything with min-max and 

it becomes the elevators responsibility.

 To your point, we, as well, you have 

been right on that cusp of whether or not you put 

something aboard that's not in a, like grade, you 

know, when we're trying to track it. And the 

responsibility is solely on the elevator. So if 

there is a system that can flag instead of the 

green to go, or allowing it to go, make sure that 

the communication is there of where you're at 

with your average, that's self-imposed. CUSUM, I 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
125 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

think is pretty straightforward or the no min or 

max, you know, per sublot. But it's when you get 

into these averages that the challenge is there.

 Even as Tony, I'm sure you're aware, 

and Matt, you can even have the CUSUM plan. And 

with some of these lots that we do, you're within 

the CUSUM plan, but it's not a material portion. 

And it doesn't make grade and there's no reports 

for the elevator to even do a re-inspection 

because it's not a material portion. I think one 

thing somehow to, and I know this was clear back 

to long time ago when I first started, material 

portions used to be anything that was in that 

CUSUM plan you you could re-inspect the sublot. 

Didn't necessarily have to be the one that kicked 

it over. It could've been anything that's 

involved in that sublot or in that material 

portion range.

 That's being said, I think from the 

export standpoint, I know they would like to have 

more flexibility on possibly re-inspecting things 

that are subjective, the club picks, when it's an 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
126 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

average and you get below a certain point. I 

don't know. I don't know that we can get there 

because that's basically it's the plan that FGIS 

has. And just that it's becoming more and more 

difficult to meet the customers' needs on what 

they want and to try to line it up with what FGIS 

load orders need to read. So all this being 

said, I don't know that there's a great solution 

because what's currently there. I think we 

understand but we were just looking for some help 

to avoid a disaster. But I know it's our 

responsibility to do so.

 And I don't know if we can only ask 

for, in our case, you know, Matt and mine, WSDA 

and other locations that have FGIS, their aid in 

making sure that we know where we're at, ten 

minutes accurate. We at United Grain actually 

don't have a slave monitor that has that green to 

go. We are relying on communication in a 

different fashion from that. I don't know, Tony, 

whatever, you know, we're just looking for a 

little more guidance on what we can do to help 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
127 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

facilitate the loading of these crazy load orders 

that we get all the time and they, they're 

becoming more and more challenging.

 MR. GOODEMAN: Right.

 MR. LINDGREN: I mean, a customer 

that's going, well, I need this, this, this, 

this, and we can't even meet some of that so --

MR. GOODEMAN: I'd be curious what 

options we have internally with our own software 

that we use, the Inspection Testing and Weighing 

Application in FGIS for any kind of flags and 

what that might look like for us, I don't know if 

that's easy or hard. From a policy standpoint, 

we talk about, you know, some of the subjective 

factors, or even some of the other tests. I 

imagine from the shipper's standpoint, you'd want 

to re-check the ones that you thought might be 

too high or too low but without those set 

criteria.

 You know, like for example, what would 

the buyer want to be re-checking again, you know, 

ones that might have been really high or really 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
128 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

low, you know, and their viewpoint. So if you've 

got to average, you're cherry picking the ones 

that you want to have checked again and then 

including those all on the average and not reinspecting everything else. A little bit 

debatable there without, you know, the confines 

of a set loading claim like the CUSUM plan.

 I would also add that, you know, 

certificates don't look any different. We do 

CUSUM, we do average quality. The certificate is 

the same and I think that's something, you know, 

whenever we're looking at, whenever a policy 

group whenever we look with the Field Office, we 

want to make sure that certificate tells an 

accurate story. And if we further water down 

what that average quality could be, and then 

allow further options for re-inspections of ones 

that are selected by the shipper only, I think it 

would dilute, I've concerns about diluting, you 

know, what, that certificate says, just in 

general with an average quality.

 MR. KERRIGAN: I know that the grade 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
129 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

log gets sent on many, if not all of the 

shipments to our customers --

MR. GOODEMAN: Sure.

 MR. KERRIGAN: -- and that they're 

probably looking at that more from their 

standpoint where the certificate is more for the 

financial side, frankly, of who's getting paid 

and banking and such.

 MR. GOODEMAN: Yes, that's noted.

 MR. KERRIGAN: So, you know, without 

trying to make this, you know, overly 

complicated, given that the original intent was 

some sort of flag in the system --

MR. GOODEMAN: Yes.

 MR. KERRIGAN: -- what, in your eyes, 

you know, what can we ask you to do. Obviously, 

you've got some background work, you know, what 

do you think is even feasible, I guess, from the 

flagging side or maybe because, you know, what I 

don't want to do is, is say that we need to open 

up every handbook.

 MR. GOODEMAN: Right. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
130 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MR. KERRIGAN: And change this because 

the the items in red, I believe were sent back to 

me from WSDA when I passed this along to them and 

that was their response and reasoning for why 

they weren't. And so that's my concern, is is it 

a handbook issue or do we think that it's a 

technology issue in that program, or possibly 

both, I guess.

 MR. GOODEMAN: Yes, I would say I 

would say just, you know, my initial response 

will be both. That because typically when we 

flag something, it's either in-process, it's 

green, which means that it met the loading plan 

or its red like is rejected and you have some 

options to either re-inspect it or reject it. 

You know, it's pretty confined. So it's, I'm not 

committing or promising anything, but it is 

feasible. I mean, it sounds, you know 

reasonable. This request sounds reasonable to 

look at.

 Policy options just for some kind of 

a flag just so everybody, you know, so it doesn't 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
131 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

get loaded. But not allowing the re-inspection 

necessarily. But then of course, that would 

require some type of an update. And that is the 

part that I'm not sure if that's really easy to 

do or really complex. You know, if some people 

spend a couple of days working on it or this is 

like a big, big, big overhaul.

 MR. KERRIGAN: Well, nothing simple 

and in the systems, right. You know, but that's 

kind of the point of it to, John's comment is 

these requests aren't getting fewer and fewer. 

And we all know this. But they all seem to be 

around trying to tighten these windows around 

average, you know, the CUSUM and things of that 

nature. I think everybody understands it's kind 

of that combination of them being able to tighten 

up the actual average. Not that that helps or 

hurts, you know, and this is getting into the 

weeds a little bit but, you know, we have a green 

and red and maybe there just needs to be a 

yellow, right.

 You know, like I say, to your comment, 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
132 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

you know, we understand that that if it's not 

allowed to have a re-inspect without some major 

changes. And there's obviously a lot of rulemaking that goes into that to make sure that the 

integrity isn't compromised. And we fully 

understand that, you know, but but just, you 

know, to flag either for WC, FGIS side for 

communication, would that be from the monitor or 

just, you know, how are the communications done 

today?

 MR. GOODEMAN: I would say if you're 

looking for it, like what would be the most 

easily digestible for us to receive some 

information like that, I would say consideration 

of an option to flag those self-imposed limits. 

Not necessarily with a re-inspection option, but 

just to flag them in some manner. I would also 

consider like if these criteria, this load order 

criteria, contract criteria are tighter and even 

what are CUSUM would allow. Maybe ask us to 

explore options there to set up a loader with 

tighter specs than what the CUSUM would give you. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
133 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Like for the protein example, there is a good 

example.

 MR. KERRIGAN: You're killing me.

 MR. GOODEMAN: I'm sorry, I'm trying 

to give you what you want here. Just say, yes.

 MR. KERRIGAN: Yes, I mean, I think 

everybody understands CUSUM. It's very tough on 

a mathematical side to get it honed in, right. 

And it's all about the homogeneous product. And 

so CUSUM could be an option. I don't know that 

I'd like to raise my hand and say that sounds 

like a great option because CUSUM tends to be a 

little bit of a bad word on the exporter side. 

Because of, you know, how restrictive it is, how 

confusing it is for everybody as far as what that 

next, you know, item, you know, or sublot needs 

to be.

 Especially, and that typically comes 

frankly on the commercial side with a premium, 

you know, because of how the blending is, because 

of how the high-speed is, you know, as we're 

actually doing this loading. So, you know, it 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
134 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

absolutely could be an option, but, yes, 

definitely --

MR. GOODEMAN: I understand.

 MR. KERRIGAN: I would rather see a 

flagging system than --

MR. GOODEMAN: I got you.

 MR. KERRIGAN: -- you know, these 

average with min and max to a CUSUM.

 MR. GOODEMAN: Because you're right, 

I mean, even if you put, even if we tightened up 

the CUSUM tolerance on the protein to be, you 

know, in specific situation on the applicant's 

request to be 13.8 instead of a 13.5, you still 

couldn't have a bunch of 13.8s in a row. You'd 

probably only be allowed to have one 13.8 and you 

have to make sure the next one is 14 or 14.1, you 

know, bring it back so --

MR. KERRIGAN: And all year that 

protein is high and there's not a lot of value 

to, I mean, some if these vessels do go out over 

a broad for instance.

 MR. GOODEMAN: Yes. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
135 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MR. KERRIGAN: You know, to where you 

would be able to put, you know, 15s on. I mean, 

most of the time the customer would love it, 

right. You know, but if you have that tolerance 

because you still have that upper range as well.

 MR. GOODEMAN: Got you.

 MR. KERRIGAN: Does anybody else from 

the GIAC have any comments or questions? I know 

this is tends to be very specific on the exporter 

load order standpoint. Like I say, I have spoken 

to a few of you, you know, but as far as 

questions on, kind of what we're looking at here, 

or maybe if there's any concerns or applicability 

or similarities, I guess elsewhere throughout the 

system?

 MR. FRIANT: This is Nick Friant. Oh, 

go ahead, Janice.

 MS. COOPER: Oh, thank you. Just 

really a comment, Matt, this is, I mean, wheat is 

so complicated from the time you're growing it to 

the time you're selling it and and loading it on 

the ship. So I just wondered if you had checked 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
136 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

with US Wheat Associates on these issues because 

they're the ones that deal with the customers and 

try and educate them on how to contract more 

effectively for what they're looking to buy. 

Just wondered if you had had a chance to consult 

with with any of the US Wheat folks?

 MR. KERRIGAN: I actually have not. 

That's not a bad idea. You know, from my -- it's 

probably a good discussion to have, but, you 

know, what I will say is that, you know, the 

commercial side and all the buyers and the 

countries, that tends to get to be a bit of a can 

of worms when we start talking about changing 

grades. Because then it seems like we don't want 

to supply what they feel is in their head. But I 

can definitely, because obviously, you know, here 

in Portland such would be open to kind of 

discussing this to see if maybe some of the 

culprits or primary culprits, you know, would 

look for some of these other options. That's a 

great idea. Nick, did you have something as 

well? 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
137 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MR. FRIANT: Yes, actually, I have two 

things now. Thanks, Janice, for bringing up the 

the US perspective. I would tag on too, Matt, 

that this might be an opportunity to bring this 

to the NAEGA Grades and Inspections Committee, 

because I think it'd be something, you know, 

we've heard comments from John as well. I think 

it'd be something that a number of NAEGA 

membership would be interested in having some 

chance to talk about and maybe provide additional 

input and support. Just I think that's commented 

like to make from that direction.

 And the other one is when I was 

reading through the one-page summary and thinking 

about it, and it's kind of been brought up here 

in a couple of different comments, kind of this 

question about when it says average grades or 

average not to exceed or not less than a certain 

number depending on the factor. I know that one 

also creates a lot of confusion in this space. 

And I think, you know, to your point, that some 

of these customers, the requests that they're 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
138 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

making and the industry interpretation of it 

versus the FGIS rules.

 Around like John alluded to, you know, 

if it says average, and then a max or a min, you 

know, the way FGIS automatically looks at that 

and disregards or includes it, you know, it 

depends on the situation. I think that might be 

part of this discussion as well, that, you know, 

whether it's clarity in rules or a change in 

rules of this direction, that we would happen to 

go. I think that's another piece that to me fits 

in this discussion, and, you know, folks can 

disagree with that for sure, but I think that 

would be a part of this one as well. 

MR. CAPPER: This is Lee Capper with 

FGIS. And Nick, if I can add to that, I think 

part of what's here is we don't currently have a 

specific Load Order Form that is common across 

the all the shippers. And so some of these 

questions could be more clearly answered by 

having, you know, specific options that are 

available in, you know, a great deal of 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
139 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

description about what that option means. So 

there would be clarity around what's being 

requested for grading versus, you know, 

potentially these other flagging scenarios.

 So we may want to consider a 

recommendation around it. You know, more fully 

exploring what does flagging means as well. You 

know, is it sublot based, is it overall load 

basis, you know, and just understanding more 

nuances that will be requested there as well.

 MR. KERRIGAN: Those are all very good 

comments.

 MR. NEAL: Let me, this is Arthur, 

asking a point of clarification as well. If 

customers can submit load order requests or make 

all different types of request with no parameters 

around it, that will make it pretty difficult for 

us to kind of standardize things across the 

system, right. So piggybacking a little bit off 

of Lee's comment, would it make sense for us it 

think about standardizing, as best we can, load 

order requests? I don't know so that we got a 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
140 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

little bit more certainty and control over how 

these requests come in, such so that we're not 

doing acrobatics every time we get one. That's 

just a thought.

 MR. KERRIGAN: Well, we kind of have 

that now with probably more informal unofficial 

what we're told we can put on a load order and 

what we can't. You know, which is, you know, 

then how we either self-impose it or to be 

honest, we bring in an independent 

surveyor/grading agency to provide their 

certificate to do that. And, you know, 

unfortunately, you know, that's a little bit 

counter to the mission, you know, of facilitating 

trade. Because if, you know, which I understand 

that this could get really broad, you know, but 

there are some very specific items here that are 

already being graded by FGIS, which is, like, if 

we're already looking at them versus maybe items 

that aren't being looked at on a regular basis. 

You know, if there is a way to monitor that as 

well is is where I was going with that. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
141 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MR. CAPPER: This is Lee again. Yes, 

I mean, I think certainly everything's within the 

realm of possibility from a technology 

perspective. But again, given how nuanced we all 

know, ship loading is, especially in wheat, we 

would want to be, you know, very, very clear 

about what it is we want to have offered and not 

offered.

 MR. KERRIGAN: So and this is a little 

bit in to tomorrow's, I guess, session, but kind 

of with that, given that I just gave a couple of 

examples here. And this a little bit of the 

policy or the kind of meat and potatoes of how 

the GIAC works, Arthur. But would this group be 

able to almost like with what's going to come up 

with the FDA MOU, kind of maybe take a step back 

to kind of, you know, try and gather these 

specific items while maybe FGIS is taking a look 

at the system and handbook kind of concurrently 

without necessarily a recommendation to the 

Secretary. Is that a potential for this group as 

an end result, I guess, as I think about this? 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
142 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MR. NEAL: Yes, I mean, it's still may 

be open for, you know, as a business item, agenda 

item. Homework can still be conducted on it on 

both ends. And you revisit it to see what kind 

of progress we make and whatnot a recommendation 

needs to be made down the road. Or, we may come 

to some kind of resolution in the meantime, and 

then you can close it off, close the agenda item 

out at the next meeting or the meeting.

 MR. KERRIGAN: Okay. Yes, because the 

last thing that I would not want to do is we get 

very specific on two or three items. But then as 

soon as that's done, right, there's another two 

items that we hadn't seen for a while or forgot 

about or didn't get an accurate poll of the 

industry or something of that nature to where it 

was very limited and, you know, requires extra 

work on everybody, I guess.

 MR. NEAL: Yes, and I mean, it sounds 

like this one's pretty involved, it will require 

some extra digging, and it makes perfect sense 

though. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
143 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MR. KERRIGAN: No further questions or 

comments? This is a great discussion on this, 

appreciate it.

 MR. GOODEMAN: I did get a note, and 

I appreciate Dave in Portland for pointing this 

out too. Sometimes it looks like in our CUSUM 

log for things that are set up as CUSUM factors 

like subclass, then perhaps the running average 

isn't shown in the column next to that result 

like it is for average factors. So that could be 

an enhancement potentially. So I think it just 

shows how far you are into the CUSUM which is 

critically important, but it may not show again 

the running average. So again, just the, I guess 

the awareness everybody knows where they stand, I 

think is really important too, from industry 

standpoint.

 MR. CAPPER: So Tony, to follow-up on 

that, I do believe the running average is shown 

at the bottom on the view side at the bottom. So 

it's not shown to the inspector, but it is 

available to the customer if they're viewing it 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
144 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

or the elevator.

 MR. GOODEMAN: Okay. Thank you.

 MR. KERRIGAN: Any further discussion 

from GIAC, FGIS or members of the public? Okay. 

I'd like to move onto the next agenda topic, 

which is falling number. I believe John 

Lindgren, I believe you are taking the lead on 

that one?

 MR. LINDGREN: Yes. Good afternoon 

again, everybody. Welcome back from lunch, it's 

just about lunchtime out here. I've had some 

conversations over the past 18-months with 

several different people when falling numbers was 

first kind of at our last actual meeting. And 

there's been a lot done, I think to already get 

the recommendation. The biggest concerns that I 

had back in the day was the inconsistencies, at 

least the proceed inconsistencies on how the test 

was run, whether it was everybody was running it 

on that 14 percent moisture basis.

 And I know the shake-o-matic has come 

into play where everybody's doing that. I think 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
145 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

all of this has helped align things, it is 

better, the last year-and-a-half than it was a 

year-and-a-half ago. As far as origin grades, 

meeting what destination expects, there's still 

some inadequacies, I believe. And obviously when 

there's good falling numbers like there has been 

lately, the concern isn't as high, they seem to 

repeat at the higher level. So until we get back 

down into the struggles with white wheat at below 

300 and the spraying winter wheats, not much 

winter wheats, but the spring wheats that get 

down in that 300 range as well. I think we're 

just looking for consistency on how the test is 

run at origin.

 In my recommendation, I think part of 

the biggest problem was not everyone was doing 14 

percent moisture basis. And that will change the 

falling number quickly if you're not running it 

that way. The two tube method, and somebody can 

correct me if I'm wrong as I'm going to here, but 

from an expert standpoint, you have to run the 

two tube method. Domestically I don't think 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
146 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

that's a requirement. And understand that 

running two tubes instead of one, cuts your 

production in-house because everybody likes to 

run two tests at the same time if they can get 

away with it. Which makes complete sense to me.

 If you're doing a 115 car unit train, 

and if you'd have to run 115 tests as opposed to, 

you know, 65, that's a big difference in timing. 

So I don't know what the best solution is on the 

one tube, versus two tube. But in the end it's 

basically tests need to be run the same at origin 

as they are at destination to give yourself a 

chance for repeatability. We all know that 

falling numbers is enough of a challenge without 

tests being run differently. So it's about 

accurate information. Hopefully testing is done 

better.

 I had a conversation with Mr. 

McCluskey and Mr. Easy, I'm not sure if that's 

how Greg pronounces his last name for sure, a 

couple of months ago. And I think FGIS has made 

great headway in helping solving the issues that 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
147 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

were there. So it's open for more discussion. 

MR. KERRIGAN: And to clarify, John, 

the biggest thing here is making sure that there 

are accurate results between origin to 

destination to the actual results that are 

actually there versus getting a grade from origin 

then having it turned around and maybe put that 

product directly on the vessel for destination 

and we get something completely different, 

correct?

 MR. LINDGREN: Yes, it's mostly about 

you have an idea of what you've got coming at 

you, and you're thinking it's going to make grade 

and when it gets here, there's a, you know, a 50 

to 60 point difference which as you know, is 

impossible to make grade at times depending on 

the quality.

 MS. COOPER: I wonder if if someone 

could clarify the requirement for the double tube 

method where it's required and where it's not and 

what the reasons are. Can someone, Tony, maybe 

you can discuss that or someone? 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
148 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MR. GOODEMAN: Yes, so the falling 

number test, let me back up a little bit. In 

general, when official agencies are licensed or 

when they're authorized to perform tests, if 

they're designated for those services, they can 

only do it the official way. If they're going to 

grade corn damage, if they're going to do 

soybean, they can only do it by our instructions. 

So that's one thing. There is, I'm not going to 

call an exception, but that's under anything done 

under the US Grain Standards Act. We say that 

they can only do it officially.

 The falling number test, however, is 

run under the authority of the Agriculture 

Marketing Act because it was originally developed 

for flour. We don't really run on flour anymore, 

but that's how it was developed and we've set up 

all of our instructions and rules under the 

framework of the Ag Marketing Act, which does not 

contain that restriction. So when you doing 

things under the AMA, you can do, if you're an 

official agency or a co-operative, you can do 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
149 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

things officially if you want to and put it on a 

FGIS Certificate. Or you can do it unofficially 

and put it on Tony's grain Inspection 

certificate, whatever that is.

 So if you run it unofficially, you 

can, it's very, very loose, you can do it with 

one tube. You don't have to do the barometric 

pressure correction. And it's very, very much, 

you don't have to use a shake-o-matic, it's very 

loose. And that is something we definitely are 

considering to make sure there is greater clarity 

in lining this under the US Grain Standards Act 

to say that, okay, if you're an official agency, 

a co-op, or wherever you are, if you're North 

Dakota Grain Inspection Champaign, Danville, 

State of Missouri, whatever it is, you've got to 

follow these official procedures if you want to 

run this on this test.

 There's concerns there because it's a 

huge advantage to just do one tube both for the 

producers that are paying for the service and for 

the agency in providing timely service. So we 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
150 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

would maybe consider using official commercial 

inspection services, which we can use some 

modifications under a different certificate, 

under a different protocol to maintain the one 

tube, but require other the other procedural 

conformities. But that's a long answer to a 

short question. So yes, anybody running the 

falling number tests can do so unofficially under 

their own company name, letterhead, whatever. 

But if they do it officially under an FGIS 

certificate, it's got to be run with two tubes 

and with all the barometric pressure correction, 

everything else. All the other exact word-forword procedures, you know, or instruction.

 MR. NEAL: And, Tony, the two tube 

method along with the barometric pressure 

adjustment is to ensure greater accuracy.

 MR. GOODEMAN: Absolutely, yes. If 

the barometric pressure correction was a change 

in what was that early 2019, to a type where 

greater uniformity because we talked about this 

before, but there can be even at 500 foot, 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
151 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

elevation changes, there can be differences in 

the falling number results. And so our previous 

instruction only implemented a correction 

starting at 2000 feet, when in reality you can 

see variation much lower increments than that. 

Kansas City, I think, is at 1000 feet, versus, 

you know, a lot of those locations at sea level 

and the PMW locations and higher country in 

Montana. So I don't know if that answered the 

question, Ms. Cooper?

 MS. COOPER: It answered, but also 

opened the door to many more. It's a complicated 

topic. So is there some consideration being 

given, I wasn't quite sure, and what would the 

process be to move that particular test from the 

AMA to the Grain Standards Act cover?

 MR. GOODEMAN: You know what, this 

topic is really (Audio interference.) got it. 

You know, now that we made that change in 2019, 

we saw and probably what this topic is speaking 

to in the fall of '19, we saw some differences 

that I think are attributable to that moisture 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
152 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

basis. If somebody wants to be really creative 

or if they have the leeway in their contractual 

terms, you can get some bonus points by lowering 

the moisture basis. So just in general, thanks 

to Greg for pulling this up real quick, the 

standard moisture basis for falling number is 14 

percent. And it's talking about pat, it seems 

like the standard for flour testing in general. 

So 14 percent.

 If you were to do, if you had a sample 

that was 292 seconds at 14 moisture basis, if you 

said, hey, I want the certified at dry matter 

basis, so all the way down to zero moisture, the 

falling number is going to be 340 seconds. If 

your moisture was around 10 percent or so and you 

need it as is, so instead of being 14, and be 

reported at the as-is moisture of whatever the 

result was, a 10.2 percent it would be 305 

seconds. So you can have a lot of manipulation 

just in reporting the moisture basis differently. 

And we don't obviously like that in wheat 

protein. That standard moisture basis is 12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
153 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

percent.

 And for any other alternative moisture 

basis, you have to report the 12 percent first. 

And then you can report if somebody wants to know 

what the dry matter or as-is basis is or 

alternative, we can show that as well. So we're 

looking at several policy options to continue 

that greater alignment in the falling number 

test. I think that we made some good strides in 

2019. TSD and ARS did a lot of great work with 

the barometric pressure correction and shake-omatic requirements. But I think there's probably 

more to be done just so the certificate is clear, 

kind of like we talked about earlier, making sure 

the certificate tells the accurate story.

 Not that it's inaccurate because it 

says what the moisture basis is, but if you're 

not going to catch it, if you've got somebody 

involved that, you know, or if it ends up on a 

spreadsheet somewhere, you know, it sort of get 

says, okay, you know, during the 20 that, you 

know, 320, you know, and then it shows up at 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
154 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

export and it, you know, doesn't having trouble 

making grade. So we're looking at policy options 

to clarify that. What would be needed, it's 

definitely going to be public process in some 

manner. But I think this is one of the first 

steps and that is engaging you-all.

 And the report in the moisture 

reporting doesn't necessarily need a move to 

USGSA. We could do that, I think through an 

instruction. I think when we moved the wheat 

protein to be a standard 12 percent and mandating 

that standard moisture basis on the certificate. 

I think that was actually done through the 

Federal Register, but that was decades ago. I 

think it was sometime in the 90s. I'm not sure 

if we have to go through that or not.

 MR. KERRIGAN: So if I'm hearing you 

correctly, Tony, that the ability for agencies to 

report it, I guess unofficially, is because what 

the falling number testing requirements under ANA 

versus is USGSA, right?

 MR. GOODEMAN: That's correct. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
155 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MR. KERRIGAN: So, you know, to try 

and get apples to apples to reflect all of the 

hard work that you guys have done to try and get 

this as accurate as possible, you know, it's 

really that that movement piece because it then 

incorporates all these changes, all these 

updates, all these trials that you're doing 

because it hones that in, right, from your 

perspective of how that reporting is, correct?

 MR. GOODEMAN: It would, yes, but 

perhaps with some other side effects, 

consequences, you know, as far as efficiency, 

price, price to test, if we were require them to 

use the two tubes, that's correct.

 MR. KERRIGAN: John, with you being 

the champion of this, and obviously, we all 

understand the time and money involved with this 

testing, especially on the origin side, what's 

your feeling or thoughts on that movement to 

fully official versus having a flexibility? Is 

it is it a reporting issue of somebody being 

clear or is it just that, you know, that FGIS has 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
156 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

done a lot of work to try and make this better, 

but there's no requirement for the unofficial to 

actually follow-up?

 MR. LINDGREN: Well, I think in the 

end what it is, and that was actually a topic 

that Pat McCluskey and Greg and I spoke about 

too, was the movement over to USGSA. And it 

would require the origin to run at the same way 

as we do on export. So that would help get 

things tighter in my opinion. To Tony's point, I 

don't know how difficult it is to move that over 

to USGSA. The impact that it has, it makes sense 

to be under USGSA. Because that's what we all 

use it as and I think that's what the 

expectations are.

 But as far as, and I don't know, 

running one tube or two tubes, I've looked back 

on several shipments. We get a copy of the 

falling number log that shows how many times when 

you're running the two tube method, if you go 

outside 5 percent, the test has to be re-run. So 

I went back and looked at several shipments on 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
157 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

how many times two tubes actually go outside 5 

percent. And it's probably less than 5 percent 

of the time. So would one tube be as accurate? 

No. Will it be close enough from a speed 

standpoint to allow that? And I don't I don't 

know if you could have the choices of running one 

tube or two tube.

 The one piece in my recommendation 

where I said, where possible run the two tube 

method, we all know that that means, okay, I have 

an out to run just one tube. I think it will 

make it, it's definitely going to be more 

accurate if everybody is, for lack of better 

word, to run two tubes. But that is going to 

impact how quickly you can get results. So from, 

I think, the exporter standpoint, the accuracy is 

important, but I don't know what the cost 

actually ends up being that will be put back on 

them if they need it run on two tubes.

 And another piece that Tony mentioned, 

if it can at least be on a certificate on how it 

was run. I mean, sure, it says 14 percent 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
158 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

moisture basis, but does anybody really look at 

that or do they just see the result? And then 

the same thing, was it run on two tubes or, you 

know, on the certificate can say that it was? 

And I don't even know if that's an option that 

FGIS would think about is giving you the option 

to run one or two. Right now, if it's under the 

official standard, it's two tubes.

 MR. KERRIGAN: Yes, just as far --

MR. LINDGREN: So to play with those 

options, I'm not entirely sure the best route to 

go.

 MR. NEAL: And this is Arthur. And I 

think also to take into consideration is still 

ponder on the challenge, the impact it has on 

exports if customers receive wheat run off of one 

tube, and it doesn't meet that expectations. And 

then we end up dealing with complainants. So we 

have to take that into consideration too that 

we've done everything within our power to try to 

ensure that the official system yielded the type 

of results that customers expect. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
159 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MR. KERRIGAN: Well, it's complaints, 

but then, you know, I'll be honest with you, I 

don't know that I've actually checked our certs 

to know when we've had issues, whether it's been 

an official falling number cer or an unofficial 

you know, cer when all of a sudden it comes in 

because it's complaints, but it's also monetary 

on what was purchased or what was expected, 

right.

 MR. KUHL: This is Ryan Kuhl, from 

Northern Plains Grain Inspection in Grand Forks, 

North Dakota. We run quite a few falling numbers 

with the spring wheat in our area. And we do 

official falling numbers the two tube method, as 

well as the unofficial method with the one tube. 

We do use the barometric pressure calibration or 

the formula. What we see when we're loading the 

shuttle trains is the time. We all know that it 

takes time, but you run into probably eight to 

ten minutes a test by preparing your sample. And 

then letting it come down, or come out.

 I don't see a probably an issue on the 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
160 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

argument side if we can get those results to the 

loader quick enough to know what to put in the 

next car or the next car. So I would say, for us 

to give that information in a timely manner, the 

one tube method is still important. I cannot 

argue, I guess agree, that the two tube method is 

better and more consistent, it's just the time it 

takes.

 MR. NEAL: So this is just me just 

talking again. What I hear, I hear an efficiency 

concern. I also hear an accuracy, concern. 

Trying to meet the expectation of the loader and 

also trying to meet expectation of exporter who's 

trying to meet the expectation of the customer. 

And I think as we think this through, you've got 

to factor all of those in along with the process 

so that we get to a place of reasonability as 

well. That's a lot of expectation.

 MR. CAPPER: This is Lee again. And 

if I just piggyback, you know, one of the things 

as an analysis over the last several years 

describing that method of performing it, the 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
161 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

specific tests as part of the certification, you 

know, I think is something that potentially we do 

need to consider. There are multiple factors. 

What we have is some varying methods where if we 

do it, and the sort of certificate just states 

the actual result without disclosing either on 

the log, inspection log itself, or on the 

certificate, you know, what was the method.

 MR. KERRIGAN: So if I'm hearing 

you're right, Lee, that, you know, as kind of 

balance is it's maybe not so much a change in the 

process, but a sharing of the information to what 

exactly was done, so that way everybody 

understands potentially.

 MR. CAPPER: Correct.

 MR. KERRIGAN: With that residing 

under AMA so if that was a case that the 

unofficial certificate needed to show that 

information would it be an unofficial, is there a 

way to, you know, a way to govern now or is that 

just a requirement that would have to be on the 

buyer to request that or to require that? 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
162 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MR. CAPPER: In the current system?

 MR. KERRIGAN: Correct.

 MR. CAPPER: Yes, whoever's involved 

in that transaction would, if you mandated that 

the test had to be run officially and you want it 

on a, you know, an FGIS certificate and they have 

to follow all the protocols which would right now 

would be two tubes. For mesh pressure 

correction, shake-o-matic, everything like that.

 MR. KERRIGAN: Because the other of 

that, that is the unofficial method, there's 

really no way to govern them requiring to state 

what they're doing if they're doing it on 

unofficially; is that correct?

 MR. CAPPER: Exactly, I mean, if you 

can think of unofficial, it just be like, you 

know, like, an NQI, an SGS, Russell Marine, it's 

companies like that don't have to, aren't 

authorized by us, don't follow our rules. 

Basically an official agency, we allow them to 

wear that hat under the AMA so that they can 

issue something on their own letterhead, their 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
163 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

own company name, their own company certificate. 

It can't be FGIS, but it would be kind of along 

the same line as one of those other unofficial 

companies. And it's just really within their own 

rules or however they design that certificate, if 

they even report a moisture basis if they, you 

know, would do one tube or two or whatever 

procedures they follow.

 MR. KUHL: I have spoke with, this 

Ryan Kuhl, and I have spoke with a number of 

agencies around us, North Dakota, South Dakota. 

And, yes, we all do the official method as well 

as be allowed unofficial method. And I would say 

probably compared to NQI which we don't know, 

official agencies are basically doing the 

personal metric with the shake-o-matic. We have 

all the equipment, so we use the shake-o-matic 

wheat grind, what is it, 250 grams. We're just 

cutting back to the one tube to save time. Now, 

like you mentioned, Tony, NQI, SGS what they're 

doing, we don't know. 

MR. GOODEMAN: Right. 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
164 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MR. KUHL: So maybe, and is this even 

something that we can discuss with it being on 

AMA side, or is it something that would be easier 

to get on the GSA side first and prepare it that 

way?

 MR. GOODEMAN: Yes, I mean, you right 

in reality, the official agencies that currently 

offer this test unofficially are using the same 

people, same equipment, same machines. But they 

don't have to. They don't have to be licensed. 

You don't have to use, you know, the right 

procedures. And I think that there's probably an 

option, you know, in some way to further restrict 

tests provided under the AMA like that. But 

really, I think the most obvious and everything 

else we do really just move under USGSA and 

therefore falls in line with all the other 

structure where you've got to be licensed. 

You've got to use the proper equipment, the 

equipment has to be checked. You've got to 

follow procedures which includes everything we 

talked about today. Is that what you getting at 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
165 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

there, Ryan?

 MR. KUHL: Yes. Yes, I probably could 

consider moving it to the GSA side.

 MR. GOODEMAN: Yes.

 MR. KUHL: And obviously if we didn't 

walk that trail carefully, because I know that if 

the one tube option is not going to be available 

these loaders that can load these 110 cars in 

eight to ten hours, they're going to be waiting a 

long time to know what to put in the next car, or 

the following car.

 MR. GOODEMAN: Right.

 MR. KUHL: Or not doing it at all, and 

then it gets to the PMW or wherever it's going, 

and going just were its hoping.

 MR. GOODEMAN: Right. And I mean, 

it's definitely we don't want to, we like to 

bring more things into the official system. 

Don't want to drive somebody away from using it. 

That's the whole reason we have what we call 

OCIS, Official Commercial Inspection Service 

setup is to do these quick checks. You know, 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
166 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

ideally, I think it was designed to do like a 

truck inspection really high volume, really fast. 

And you can set up an OCIS agreement with a 

customer and you can frankly, take shortcuts. 

Its authorized shortcuts in different parts of 

the procedure, like for corn damage.

 There was a concern, this is probably 

taking place for a long time. of customers 

wanting to say, hey, you guys take way too long 

to pick 250 grams for damage, you know, I can do 

house grader or I can use some other company and 

they'll only pick a little handful. And so you 

can modify procedures, just do 225 grams for 

example. Because on an OCIS cert, everybody 

knows what that is. And so there are some 

options there that I think we'd look at for some 

types of domestic shipments to look at the one 

tube if there was a lot of interest in that under 

OCIS.

 MR. KUHL: Did visit with Pat 

McCluskey about this, I think it was last week 

and he mentioned the OCIS agreement with me. And 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
167 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

I guess, the only, and that would be up for 

probably a different discussion, but the only 

thing that came about that is here and all North 

Dakota, does all about the same methods is 

sometimes before an elevator will get ready to 

load a train, you know, they'll submit in, you 

know, 100 falling numbers, 20 falling numbers. 

They may also have a bigger producer that will 

bring in very long falling numbers that are going 

to that certain elevator. Well, how many OCIS 

contracts would I need in one day for one train?

 MR. GOODEMAN: The way that our 

current OCIS setup is for the applicant. So that 

does make it more complex perhaps. I do 

recognize that, you know, if you're taking a lot 

of submitted samples and yes, so we do require 

the setup OCIS agreement with the applicant. 

Applicant specific, because they've got to agree 

to it, they've got to know that they're not 

getting the full procedure, they're getting a 

different procure.

 MR. KERRIGAN: Hey, Ryan, I'm sorry, 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
168 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Tony, can you finish please.

 MR. GOODEMAN: Go ahead.

 MR. KERRIGAN: Ryan, a question for 

you, given that you do the kind official 

methodology with the official equipment, but only 

one tube, in your opinion, is there a significant 

time difference between the rest of the 

methodology with the barometric pressure 

adjustment, with the shake-o-matic versus other 

methodologies other than just the one tube versus 

two tubes, in your opinion?

 MR. KUHL: Not really. No, after we 

started doing quite a few more official falling 

number since the 2019, crop year, there's not 

FGIS, as Easy Farm, and actually some of the 

certificate programs will have that in as your 

typing the certificate, it will do the 

calculation for you. So no, there isn't much 

time and that's when we all kind of discussed and 

we all just said well, the shake-o-matic, I think 

that runs for is it even ten seconds. So I guess 

you could save ten seconds skipping that method 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
169 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

but it also does it for you. So no, there's not 

other than you can get two samples done out of 

one run rather than different --

MR. KERRIGAN: Okay. Anybody that 

hasn't been called on that has some commentary 

questions on this topic? There are a lot of 

crickets out there. Definitely spent about five, 

six years out in the PMW, and I'm fairly certain 

that falling number was one of the first topics 

in the PMW Regional and Washington State 

Department of Agriculture meetings and it has not 

disappointed that it's come up and every single 

meeting ever since. So we're going to get 

opportunity tomorrow to kind of, after we've 

thought about this and probably discuss a little 

bit more as far as what the Committee would like 

to do if anything. So yes, just throw it out 

back to the GIAC if there's any other information 

that we want to try and glean here before we move 

on for the day.

 MR. CAPPER: This is Lee again. Just 

one final comment. If we look to try and have 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
170 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

standards and enforce agreement with various 

things, this is the only test that can go on a 

USGSA certificate, that is not a USGSA based 

test. And so it causes a lot of extra hoops to 

jump through from validating. All their tests 

are aligned under USGSA and, you know, are 

validated that way. So it will bring some 

efficiencies to some of our information 

management if we pursue moving it under USGSA.

 MR. KERRIGAN: And then as a follow-up 

kind of summary, Tony, to to one of your original 

points regarding, I apologize, I don't know your 

exact words, but it was something to the effect 

that you were looking from a policy standpoint at 

this item. Is this something that you feel that 

FGIS or, you know, whichever group I guess needs 

to spearhead it, will be looking at, I guess, on 

your own moving forward or where would you say 

that you guys are at I guess with that, given 

that you're looking at or considering it?

 MR. GOODEMAN: I think the point of 

our internal project now is to evaluate, you 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
171 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

know, what's going on in the market. What are 

options are. If we did make a move, what that 

would entail? Is this going to be your followup? But if the Advisory Committee, if a 

recommendation would be helpful and I definitely 

think it would, if that's something that you-all 

wanted to do, it certainly help us, you know, 

knowing what kind of big other groups are, you 

know, where they stand on something like this.

 MR. KUHL: Thank you.

 MR. SINNER: Matt, I got just one 

question and just to help clarify. What is the, 

on the destination side, what is the method most 

commonly used for running falling numbers?

 MR. KERRIGAN: We're all getting 

official certs on the destination side. We're 

not using -- or sorry, we may have some customers 

that request an independent lab cer. But as far 

as the loading goes, from the export standpoint, 

we're using WSDA which is using the official, 

cer. We do have some customers that are are 

requesting a private double-checks. John, do you 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
172 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

know on the double-checks, I'm assuming that's 

using the official method or do you know if 

that's otherwise?

 MR. LINDGREN: What has been told to me 

is that it's the official message, but it's done 

by unofficial. So you have to assume that they're 

telling you the truth when they say that yes, we 

use the shake-o-matic, yes, we use two tubes.

 MR. SINNER: Okay. All right, thanks.

 MR. KERRIGAN: Okay. I believe I'm 

hearing no more commentary on this one. We're a 

little bit past our break time here, a little bit 

off. But we did get through, I believe, all the 

the agenda industry issues. My recommendation 

here was that we'd take a 17-minute break. That 

would take us to 4:00 and then we can open up 

into public comments, any other agenda items at 

that point in time, if that's okay. So be back 

in about 17 minutes. So that's 1:00 Pacific, 

4:00 Eastern Time. Thank you.

 (Whereupon, the above-entitled matter 

went off the record at 3:43 p.m. and resumed at 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
173 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

4:01 p.m.)

 MR. KERRIGAN: Welcome back everybody. 

The next topic on our agenda is actually 

regarding public comments. And I believe, 

Kendra, you said that we have not received any 

public comments; is that correct? Okay. Good 

deal. So I guess the question to the group or 

or, Arthur, is we are currently sitting about an 

hour earlier than scheduled for the day. Do we 

want to forge ahead, just kind of begin 

discussions on the FDA MOU or would you like to 

adjourn early and give that time back to 

everybody?

 MR. NEAL: Yes, because we have the 

agenda published for that topic to be considered 

for tomorrow, we have to wait until tomorrow.

 MR. KERRIGAN: Okay. That's fine. 

Does anybody have any questions or additional 

comments on what we have discussed today up until 

this point?

 MR. FRIANT: Hey, Matt, this is Nick. 

Just a question of order because this is a little 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
174 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

bit different process than the last time I served 

on the Committee. So we brought three industry 

issues for discussion today with a lot of good 

discussion, you know, presentation, good 

discussion of them. Like, from a process 

perspective, what's the intent, are, you know, 

the next steps for that? Are these topics that 

we are aiming to have resolutions on or are they 

just general discussion topics and we'll have 

some time as an Advisory Committee to talk more 

about it tomorrow or just help me a little bit 

from a process perspective.

 MR. KERRIGAN: Yes, so on the agenda 

tomorrow, we've got about another roughly two 

hours set aside tomorrow to come back to those 

items that we discussed today. And, you know, 

basically discussed them to see what our next 

steps are. If there is a next step.

 MR. FRIANT: Okay.

 MR. KERRIGAN: And so that's kind of 

the order of of how it's set aside to make sure 

that there isn't any more information or that 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
175 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

everybody has a time to kind of chew on it a 

little bit. That's why during some of the 

topics, you know, I was trying to kind of lead 

into what those next steps could look like 

depending on where we land tomorrow.

 MR. FRIANT: Okay. Thanks.

 MS. COOPER: So a further question on 

process, again, coming from our prior experience 

we usually put together the recommendations while 

we were in Kansas City as a result of the 

discussion of the first day then we came up with, 

you know, as you know, sometimes 20 or more 

recommendations. So is that no longer allowed 

even if we're there in-person. And so are we 

just basically talking about three things?

 MR. KERRIGAN: The three items that 

were on the agenda are that were published in the 

Federal Register that were recommended given that 

we haven't received any other items previous to 

the meeting to put on there, are the three items 

that we are talking about for moving forward.

 MS. COOPER: Wow. Okay. That is a 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
176 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

shorter discussion then, isn't it?

 MR. KERRIGAN: A little bit, yes. You 

know, my first meeting, and that was kind of one 

of the big things, you know, with Arthur coming 

on board is to really try and get it into a less 

of an ad-hoc committee and more of a, you know, 

very appointed, directed, good conversation, and 

well-thought out versus just blasting the 

Secretary with thoughts and comments, you know. 

And to make sure that especially a lot of the 

items that FGIS, you know, could answer without 

recommendations and things of that nature, and 

have an opportunity to respond to. Arthur, if I 

misstated that, you're more than happy to chime 

in.

 MR. NEAL: No, I think you've done a 

good job summarizing it. We're trying to bring 

the Grain Inspection Advisory Committee in 

alignment with most other committees USDA 

facilitates. Looking at the past, it seemed like 

it was more of a scattered approach is that folks 

would come to the meeting, not necessarily having 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
177 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

a clear agenda, and figure out on the fly, 

whereas most other committees to the meeting with 

an agenda with structured dialogue to bring some 

constructive recommendations that can be 

considered and possibly implemented. And it also 

gave the committee members an opportunity to be 

prepared when they came. That's why we have 

discussion around the topics in advance before we 

move them.

 MR. KERRIGAN: Okay. Any anything 

else after that? Anymore discussion, like I say, 

we still have an hour still slated? If there's 

anything else on those topics or public comment 

we need to talk about, otherwise, we will adjourn 

for the day. A lot of blank stares and silence. 

So we'll adjourn for the day and we will join 

back here again at 11:00 a.m. Eastern Time, 8:00 

a.m. for those of us on the west coast and we'll 

be ready to get started again. So have a good 

evening, everybody. Thank you.

 (Whereupon, above-entitled matter went 

off the record at 4:07 p.m.) 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com

178 

A

a.m 1:8 4:2 177:17,18 

AAGIWA 16:4 19:12 

ability 43:16 44:1 100:2 

111:4 115:19 123:16 

154:18 

able 8:3 16:9,14 40:16 

41:22 49:7 61:6,14 

89:11 92:17 95:8 

102:9 109:14 113:16 

119:14 122:5 131:16 

135:2 141:15 

aboard 119:11 124:16 

above-entitled 76:13 

107:15 172:21 177:21 

absolutely 84:19 134:1 

150:18 

accept 54:4 

acceptable 91:5,7 

accepted 95:20 116:7 

accepting 96:2 

access 46:17 47:20 

59:20 

account 29:3 31:6 

32:11,17 33:7,8,21,22 

34:5 38:11,19 39:1 

55:3 

accountability 93:21 

accounts 50:21 

accumulating 30:10 

accuracy 64:16 150:17 

157:16 160:11 

accurate 46:18 126:17 

128:15 142:15 146:16 

147:4 153:15 155:4 

157:3,13 

achieve 71:16 114:13 

acknowledge 6:20 17:1 

acquainted 19:18 

acquiring 67:21 

acrobatics 140:3 

Act 9:18 30:5 32:5 34:4 

52:21 55:3 71:13 

148:11,15,19 149:12 

151:16 

acting 5:3 24:1 76:19 

77:1,4 

action 93:13 103:14,20 

108:13 

active 19:12 92:9 

actively 100:7 

activities 49:15 50:3,8 

50:9,20,21 95:5 109:8 

activity 49:17 92:3,10 

93:18 98:7 

Acts 10:4 

actual 52:8 85:3 110:20 

110:22 111:14 131:17 

144:14 147:5 161:6 

ad-hoc 176:6 

add 47:13 65:8 83:9 

94:8,10 95:12 98:20 

99:15 103:7 107:8 

128:8 138:16 

added 10:16 

addition 9:9 68:11 

additional 25:10,22 

26:14 68:22 70:16 

72:20 81:2 118:20 

137:10 173:18 

address 63:21 73:9 

80:9 106:5 116:5 

addressing 72:3 

adjourn 3:21 173:12 

177:14,16 

adjust 33:6 36:9 

adjusted 34:21 37:22 

adjusting 33:19 36:3 

adjustment 150:17 

168:9 

adjustments 33:3 71:8 

administration 8:17,20 

48:17 

administratively 51:4 

Administrator 1:18 

2:20,22 5:13 

admirable 6:12 

ado 5:11 

advance 48:7 177:8 

Advanced 70:22 

advancing 12:2 

advantage 7:13 25:18 

149:20 

advertised 24:15 

advertising 24:4 

advice 98:16 

advise 95:3 

Advisory 1:3 2:17 9:7 

16:13 17:2,8 21:9 

45:1,11 46:6 49:10 

54:19 55:13 62:14 

63:18 64:22 66:7 

82:14 83:1,21 93:12 

95:14 98:5,12 171:4 

174:10 176:18 

Affairs 2:19 18:2 

affiliate 100:12 

affiliates 97:4 

affiliation 100:1 

Aflatoxin 35:1 

afraid 22:6 

afternoon 62:12 144:9 

ag 10:10,10 41:10 42:18 

83:7 86:11,20 87:1 

88:11 97:1,10 98:9 

103:2 148:19 

agencies 11:10 48:18 

54:11,15,19 56:19 

66:11,16,18 67:3 

81:16 84:11 88:2 

100:2 103:11,15 

148:3 154:18 163:11 

163:15 164:7 

agency 7:3 9:15 29:12 

44:9 82:17 99:8 

140:11 148:22 149:13 

149:22 162:20 

agenda 4:13 5:8 42:9 

73:12 75:18 101:18 

105:3,6 109:12 142:2 

142:8 144:5 172:14 

172:17 173:3,15 

174:13 175:17 177:1 

177:3 

agents 94:2 

ago 8:18 11:7 16:5 

24:17 26:6 61:1 70:20 

80:21 83:12 90:3 

97:13 99:10 119:21 

125:12 145:3 146:21 

154:14 

agree 101:8 103:18 

118:17 160:6 167:18 

agreement 51:15 52:12 

101:19 166:3,22 

167:17 170:1 

Agreements 36:13 

agricultural 12:5 43:10 

70:11 

agriculture 1:1 10:5 

11:14 12:12 19:9 80:2 

94:1 148:14 169:11 

Ags 97:7 

ahead 73:6 77:22 91:19 

91:20 96:13 107:10 

135:17 168:2 173:10 

aid 126:15 

aiming 174:8 

Alan 24:7 

align 68:18 145:1 

aligned 170:6 

alignment 153:8 176:19 

allegedly 79:18 

Alliance 19:1 

allow 43:7 58:18 118:5 

120:16 128:17 132:20 

157:5 162:20 

allowed 123:13 132:2 

134:15 163:13 175:13 

allowing 82:2 124:20 

131:1 

allows 16:19 

alluded 138:3 

alternative 95:16 153:2 

153:6 

AMA 29:21 148:21 

151:16 161:17 162:21 

164:3,14 

America's 11:11 

American 9:20 18:1 

amount 32:18 54:16 

74:15 

amounts 63:8 

AMS 2:22 5:14,21 6:7 

6:19 8:14 9:2,13 10:7 

11:11 36:6 52:6 106:8 

109:7 

AMS's 26:8 109:8 

ANA 154:20 

analysis 33:14 39:17 

49:19 52:8 59:21 67:8 

67:10 160:21 

Analyst 2:21 

analyzed 68:8 

analyzing 64:11 

and-a-half 31:22 

and/or 56:3 65:7 85:22 

angle 116:4 

announce 35:9 

announced 33:17 34:9 

34:10 35:6,20 

announcement 34:12 

42:4 

announcements 10:13 

annually 33:3 34:9 

answer 67:17 84:19 

150:6 176:11 

answered 138:20 151:9 

151:11 

ANTHONY 2:12 

anticipate 66:4 

anxieties 20:14 

anybody 28:7 57:19 

72:22 74:22 76:18 

84:12,13 86:2 107:6 

108:3 123:4 135:7 

150:7 158:1 169:4 

173:18 

anybody's 56:14 57:18 

anymore 84:17 96:10 

148:16 177:11 

Aphis 9:2 51:12 52:3,12 

60:7,9 89:2,6,8 94:19 

103:2,17 104:16 

105:18,20 106:2,7 

108:17 

apologize 42:8 103:22 

106:19 170:12 

Appeals 25:4 31:1,4 

appear 63:10 

appearance 63:9 

appears 106:21 107:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
179 

apples 155:2,2 

applicability 135:13 

applicable 56:3 82:8 

applicant 118:3 167:13 

167:17,18 

applicant's 134:12 

applicants 115:2 

application 111:9 113:6 

127:11 

applied 50:2 

apply 49:15 50:19 

65:16 86:7,16 

appointed 176:7 

appointing 53:2 

appointments 53:1 

appreciate 4:4 14:2,13 

15:13 62:12 71:5 

108:19 143:3,5 

appreciates 65:1 

approach 51:8,10,14 

52:1 59:19 65:4 102:5 

176:21 

appropriate 36:15 66:9 

80:7 94:19 95:2 

appropriately 82:4 

appropriations 9:18 

49:22 

approval 55:6,18 56:13 

56:13 58:18 

approvals 65:13 

approved 67:2,11 

approximately 19:11 

33:13 

April 29:3 31:11 

area 23:8 159:13 

areas 24:22 44:5 73:14 

argue 160:6 

argument 160:1 

Arizona 79:13 

ARS 70:17 153:10 

Arthur 2:20 4:17 5:5,16 

6:11 13:1,5 14:7,11 

28:6,8 39:16 47:22 

52:15 59:18 70:18 

73:1,2 75:12,18 77:3 

77:17 87:17 103:5,6 

104:22 105:9 107:8 

108:10,20 113:15 

115:8 139:13 141:14 

158:13 173:8 176:4 

176:13 

Arthur's 115:6 

as-is 152:17 153:5 

aside 174:15,21 

asked 9:18 73:9 117:17 

117:17 

asking 11:13,20 71:14 

108:16 110:2 111:7 

121:18 124:8 139:14 

assessment 67:19 

72:13 

asset 17:14 

assign 82:4 

assist 75:22 77:1 

assistance 9:16 10:1 

118:21 119:6 120:5 

121:19 

assisting 52:4 

Associates 136:1 

Association 96:16,18 

96:20 100:8,10,13 

101:2,9 

associations 14:20 

85:3 

assume 4:12 172:6 

assuming 67:22 68:8 

86:9 107:4 172:1 

assurance 25:1 26:3,17 

26:17 

assure 36:13 

attached 4:13 

attempt 77:1 

attempts 63:13 

attend 9:6 

attention 83:6,18 

attributable 151:22 

attributes 54:18 

Audio 151:18 

August 56:9 

Austin 97:22 

authority 148:14 

authorization 53:17 

55:5 

authorized 9:17 148:4 

162:19 166:5 

automatic 53:19 

automatically 138:5 

autonomy 46:19 

availability 68:13 

available 47:7 56:9 

58:17,20 99:11 120:6 

138:22 143:22 165:7 

average 3:15 109:13 

110:8,21 111:21 

112:1,6,11 113:21 

114:17 115:3,5,8,16 

115:22 116:2,6,14 

117:11,13,21 122:1 

122:13 123:12 124:4 

124:10,12,22 126:1 

128:2,4,10,16,21 

131:14,17 134:8 

137:17,18 138:4 

143:8,10,14,19 

averaged 118:7 

averages 125:3 

avoid 126:11 

aware 8:20 14:20 49:21 

123:8 125:4 

awareness 14:17 

143:15 

Awesome 19:7 

Ayers 1:11 36:19,19 

37:7 59:6,6 

B

back 5:1 8:9 14:7,16,21 

16:8 18:15 19:13 21:5 

24:17 26:4 27:10,13 

28:5 34:14 40:4 60:3 

60:7 64:3,7 67:5 

69:12 70:18 72:4 76:1 

76:5,9,17 79:22 87:21 

89:16 92:4 99:21 

100:14 101:10,18 

104:7,12,14 107:3,12 

107:20 117:21 125:11 

130:2 134:17 141:16 

144:10,17 145:8 

148:2 156:17,22 

157:18 163:19 169:18 

172:18 173:2,12 

174:15 177:17 

background 92:3 96:21 

99:13 129:17 

bad 133:13 136:8 

balance 6:15 32:2,19 

33:12 85:11 161:11 

banking 129:8 

bar 63:3,14 66:13 67:5 

71:3 

Barge 55:19 56:6,15 

57:1 58:8 

barges 56:16,20 58:17 

59:3 

barometric 149:7 

150:12,16,19 153:11 

159:16 168:8 

based 34:3 36:3 62:6 

67:9 68:17 85:10 

86:18 95:6,7 97:18 

139:8 170:3 

basically 46:17 51:13 

85:4 126:3 146:11 

162:20 163:15 174:17 

175:15 

basis 37:15 139:9 

140:20 144:20 145:17 

152:1,4,6,11,13,20,22 

153:3,5,17 154:12 

158:1 163:6 

Bean 48:1 

beans 18:22 122:18 

becoming 68:21 126:4 

127:3 

beefing 10:8 

began 98:6 

beginning 13:13 

begun 55:7 

behalf 5:14 

believe 20:15 24:7 37:1 

50:6 71:17,22 92:2,8 

98:21 113:15 130:2 

143:19 144:6,7 145:5 

172:10,13 173:4 

believed 111:15 

believes 54:20 

belting 81:2 

benchmark 57:10 

beneficial 123:9 

benefit 116:14 

benefits 65:22 102:8 

best 6:9 22:16 115:2,18 

139:21 146:9 158:11 

better 48:15 68:12 

115:11 145:2 146:17 

156:1 157:13 160:7 

Biden 11:9 

big 12:11 52:14 67:20 

75:9 131:7,7,7 146:8 

171:8 176:4 

bigger 167:8 

biggest 74:14 144:16 

145:16 147:3 

bit 11:2 17:3 39:2 42:11 

48:15 69:15 72:17 

79:21 81:22 87:12 

105:10 107:10 112:16 

113:19 114:15 128:5 

131:19 133:13 136:12 

139:19 140:1,13 

141:10,12 148:2 

169:16 172:12,12 

174:1,11 175:2 176:2 

bits 17:20 

black 16:1 

blank 177:15 

blasting 176:8 

bleach 63:4 

bleaching 62:18 69:14 

blend 115:19 

blending 133:20 

bo 102:11 

board 25:3 31:4 43:14 

111:20 123:20 176:5 

Boards 94:1 

Bob 86:4 

bold 16:6 

bonus 152:3 

Book 47:2,3,3 

borer 3:12 78:3 79:7,17 

79:18 81:19 85:5,18 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
180 

85:22 87:14 89:19,20 

90:2 92:9,10 93:8 

99:1,7 107:2,5,11 

108:9,11 

borers 81:17 104:5,11 

bottom 59:3 143:20,20 

boundaries 54:7 55:1,7 

71:2,11,20 72:10,14 

boundary 54:10,17 

71:18 

bout 48:4 

box 51:5 

boxcars 92:8 

boxes 16:1 

branch 27:1,3 49:6 87:2 

87:2 

brand 82:3 

bread 114:7 

break 5:9 30:8 75:21 

107:3 117:16 172:12 

172:15 

breakdown 37:21 

Brenner 26:21 

Brent 1:16 60:15 61:3 

76:22 77:8 104:1,19 

bridging 86:6 

brief 78:19 

briefly 29:20 30:5 33:7 

bring 5:14 29:14 33:3 

38:21 65:6 89:6 

134:17 137:4 140:10 

165:18 167:9 170:7 

176:17 177:3 

bringing 25:6 30:9 

31:12 109:7 137:2 

broad 12:7 134:21 

140:16 

broader 12:19 

broken 92:5 

brokens 69:21 

brought 29:22 30:3,11 

30:13 117:21 137:15 

174:2 

Bruce 2:22 5:13,15 13:8 

14:9,12 15:19 

Bt 90:3 104:9,12 

budget 49:10,11,19 

Buildings 27:17 

bulbs 66:14 67:3,10,12 

67:21 68:8,11,15,20 

69:1,3,6 

bullets 117:7 

bunch 80:8 134:14 

Bundy 23:21 

burden 43:6 

bushels 92:19 

busier 32:1 

business 16:18 27:9 

41:14 142:2 

businesses 10:10 

13:15 17:14 20:20 

butter 114:7 

buy 104:9 136:4 

buyer 115:10 120:21 

121:2,5 127:21 

161:22 

buyers 21:16 136:11 

C

C 4:1 

calculation 168:18 

calibration 159:16 

California 69:2 79:13 

85:15 97:4 

call 3:2 4:5 8:11 15:9 

17:6 34:19 45:22 

87:19 96:17 148:10 

165:20 

called 18:19 43:15 

169:5 

camera 55:19 56:3,12 

cameras 56:6,21,22 

57:8,13 58:18 59:7,11 

candidates 24:18 

cap 49:20 50:1,6,7,18 

capacity 24:21 94:3 

Capper 2:11 119:14 

138:15,15 141:1 

143:18 160:19 161:15 

162:1,3,15 169:21 

capturing 50:9 73:13 

car 146:6 160:3,3 

165:10,11 

care 5:5,7 15:19 

careful 50:12 

carefully 165:6 

CARES 30:5 32:5 34:4 

Cargill 1:13 14:12 17:18 

18:1 

Carolina 52:6 

carried 51:17 

cars 165:8 

case 7:2 87:19 99:5 

120:15 126:14 161:17 

cases 27:15 41:10 

catch 153:18 

Cathy 26:21 27:1 

caught 121:9,10,11 

caused 5:20 32:6 

causes 50:11 63:20,22 

170:4 

CD 61:4,5 

CD-ROMs 61:2 

ceiling 50:15 

center 1:12 18:9,10 

27:2,3,11,12,20 43:2 

centralized 44:1 

cents 104:17 

cer 159:5,6 171:18,21 

cert 85:18 86:1 166:14 

certain 48:19 73:6 

79:15 90:18 96:3 

99:22 114:16 126:1 

137:18 167:10 169:8 

certainly 6:7 7:5 13:2 

15:1 84:18 141:2 

171:7 

certainty 140:1 

certificate 81:16 88:3 

91:9 95:16,20 96:2 

110:22 111:15 128:10 

128:14,20 129:6 

140:12 149:2,4 150:3 

150:11 153:13,15 

154:12 157:21 158:4 

161:5,8,18 162:6 

163:1,5 168:16,17 

170:3 

certificates 39:8,9 

87:15 102:11 128:9 

certification 47:10,22 

48:3 79:8 81:13 82:10 

86:8,9,14 88:14 90:8 

161:1 

certified 88:14,20 

152:12 

certifies 87:14 

certify 114:11 

certifying 64:1 84:11 

94:2 96:2 

certs 159:3 171:16 

chain 6:17 11:17,22 

12:12,18 14:19 68:6 

chains 11:11 

chair 18:2 19:1 

Chairman 94:5 101:6 

challenge 21:19 61:8,9 

124:2,6 125:3 146:14 

158:15 

challenges 5:20 6:3 

12:18 15:12 

challenging 127:3 

Champaign 1:11 36:20 

149:15 

champion 155:16 

chance 16:2 113:17 

136:5 137:10 146:13 

change 23:12 25:16,22 

26:14 27:7 51:2,11 

85:8 130:1 138:9 

145:17 150:19 151:19 

161:11 

changed 19:13 43:18 

87:4 

changes 54:13,20 64:6 

132:3 151:1 155:6 

changing 136:13 

charge 12:20 22:8 

chart 117:9 

Charter 95:3 

check 87:6 

checked 128:3 135:22 

159:3 164:20 

checks 165:22 

cherry 128:2 

chew 175:1 

Chief 2:11,16 

chime 176:14 

China 42:21 

choices 157:6 

chore 14:3 

chunks 92:6 

circulated 66:22 

City 23:14 24:6 43:3 

151:6 175:10 

claim 128:7 

clarification 13:8 

139:14 

clarify 147:2,19 154:3 

171:12 

clarity 39:20 105:3 

108:11 118:15 138:9 

139:2 149:11 

class 63:2 118:6 124:4 

124:5 

classification 62:16 

112:21 

classrooms 61:21 

clean 22:20,21 

cleaner 81:1 

clear 46:16 65:22 

125:11 141:6 153:13 

155:22 177:1 

clearance 33:1,2 35:11 

73:4 

clearly 138:20 

close 7:3 26:4 38:22 

121:10 142:8,8 157:4 

closed 24:16 31:15 

closely 19:15 46:20 

48:9 

club 112:18,19 118:4 

118:10 121:22 123:17 

123:18 124:2 125:22 

co-op 97:14 149:14 

co-operative 148:22 

Co-operator 36:12 

co-operators 36:14 

coast 84:12 92:11 

102:19 177:18 

cob 79:16 81:18 

cobs 79:16 90:17,21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
181 

92:5 93:7 

cohesiveness 53:5 

collaborated 66:11 

collaboration 42:6 53:4 

collect 30:15 36:14 

collection 44:18 

collectively 44:21 

colored 68:18 

Columbia 18:14 

column 143:9 

combination 131:16 

come 13:16 45:15 

46:12 60:3 72:8 76:1 

76:9 77:16 78:11 

100:6 101:19 104:7 

107:3,12 112:16 

115:1 123:14 140:2 

141:15 142:6 144:21 

159:21,21 169:12 

174:15 176:22 

comes 37:14 40:22,22 

41:1 46:13 123:12 

133:18 159:6 

comfort 37:19 

coming 10:18 26:7 

33:15 47:17 48:2 60:1 

78:6 120:7 147:12 

175:8 176:4 

commended 55:14 

commends 62:14 

comment 14:16 15:14 

64:8,8 89:11 93:21 

131:10,22 135:19 

139:20 169:22 177:13 

commentary 169:5 

172:11 

commented 71:5 

137:11 

comments 3:19 11:13 

11:20 12:8,15,17 

13:11 14:6,13,15,18 

14:21 15:15 42:10 

62:6 64:11,14 74:19 

84:4 93:2 94:7,12 

104:20 108:4 123:5,6 

135:8 137:7,16 

139:12 143:2 172:17 

173:4,6,19 176:9 

Commerce 26:12 

commercial 133:19 

136:11 150:1 165:21 

commitments 53:3 

committed 21:22 22:2 

committee 1:3,7 2:17 

6:13 7:7 9:7 11:5 

12:14,14 16:13 17:2,8 

18:3,4,15 20:1 21:9 

29:21 36:21 45:1,11 

46:6 49:10,14 51:8 

52:17 53:5,9 54:8,20 

55:13,17,20 58:4 

62:14,16,21 63:19,22 

64:3 65:1,3,7 66:7 

72:21 73:11,16,22 

74:12 82:14 83:1,21 

91:2 94:22 95:9,14 

97:21 98:5,16 100:17 

101:6,10 102:4,22 

103:4 137:5 169:16 

171:4 174:2,10 176:6 

176:18 177:6 

Committee's 98:12 

102:6 103:9 

committees 13:17 

176:19 177:2 

committing 130:17 

commodities 19:3 

50:20 

commodity 30:1 33:21 

33:22 36:8,9 

common 138:18 

commonly 171:14 

communication 124:21 

126:19 132:8 

communications 132:9 

companies 162:18 

163:4 

company 1:12 17:12,15 

18:19 102:18 150:9 

163:1,1 166:11 

compared 163:14 

compel 51:10 

compensation 121:1 

competent 21:21 

competition 65:2 

competitive 12:2 

complainants 158:18 

complaints 159:1,7 

complete 55:6 146:5 

completed 55:9 67:4,6 

completely 147:9 

complex 131:5 167:14 

Compliance 26:3,11,18 

26:21 39:13,15,16 

compliant 65:9 

complicated 117:4 

129:12 135:20 151:12 

component 8:1 52:1 

73:12 

components 5:8 25:5 

comprehensive 54:8 

63:21 65:4,11 

comprehensively

54:22 

compromised 132:5 

concern 95:9 119:8 

121:7 130:5 145:7 

160:11,11 166:7 

concerned 20:17 103:9 

concerns 56:1 78:22 

83:14 128:19 135:13 

144:16 149:19 

concluded 58:16 64:9 

concurrently 141:19 

conduct 16:18 72:13 

conducted 54:19 57:11 

142:3 

confined 130:16 

confines 128:6 

confirm 9:3 102:17 

confirmed 9:5 102:10 

conformities 150:6 

confusing 133:15 

confusion 137:20 

Congress 54:3 

connection 60:21 61:11 

61:13,15,22 78:2,8 

105:2 

consecutive 35:17 

53:17,18,22 73:21 

consensus 63:6,13 

consequences 155:12 

consider 11:6 12:14 

14:1 24:19 70:5,7 

98:13,22 113:17 

132:18 139:5 150:1 

161:3 165:3 

consideration 33:19 

45:10 62:2 132:14 

151:13 158:14,19 

considered 68:15 

173:15 177:5 

considering 54:3 70:1 

149:11 170:20 

consignments 85:16 

consistency 145:13 

consistent 46:19 160:7 

consolidate 46:16 

consolidated 9:17 

43:22 

constant 38:9 

constructive 177:4 

consult 136:5 

consumers 12:6 92:11 

contact 57:19 60:8 

contain 55:4 63:8 

148:20 

container 48:22 

CONTENTS 3:1 

continue 10:19 44:3 

51:6 57:3 63:19 66:8 

153:7 

continued 72:9 

continues 8:17 47:21 

62:17 

continuing 6:15 8:16 

36:10 47:8,18 

continuity 53:4 

continuous 38:9 55:20 

contract 36:7 132:19 

136:3 

contracts 167:11 

contractual 152:2 

contribute 21:12 

control 64:20 140:1 

controversial 97:16 

conversation 11:3 

34:18 44:22 50:22 

86:3 89:2 106:3 

146:18 176:7 

conversations 44:14 

44:16,19 45:6,10 85:2 

119:5 144:12 

convey 106:7,11 

convince 25:14 

Cooper 1:12 18:6,7,8 

58:6,11 69:11 94:14 

108:21 109:9 135:18 

147:18 151:10,11 

175:7,22 

copy 36:20 109:16 

156:18 

corn 3:12 78:3 79:7,10 

79:17,18 81:17,19 

83:9,16 85:5,18,22 

87:14 89:19,20 90:1,2 

90:3,17 92:4,9,9,11 

93:8,10,14,17 99:1,7 

104:5,9,12 107:1,5,11 

108:9,11 114:19 

118:8 122:18 148:7 

166:6 

corn's 93:15 

corporately 48:19 

Corporation 1:15 

correct 34:21 37:2 97:5 

101:5 102:5 117:1 

118:5 145:20 147:10 

154:22 155:9,14 

161:15 162:2,14 

173:6 

corrected 108:12 

correction 149:8 

150:12,19 151:3 

153:11 162:9 

correctly 83:2 87:16 

93:12 154:18 

cost 35:2 41:15,17,18 

57:15 68:22 69:3 

157:17 

cost-saving 36:11 

55:22 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
182 

costs 7:20 30:12,12,20 

31:10 32:1,6,7 33:4 

36:10 37:13,14 38:12 

38:14 40:19 65:7 

80:15 

could've 125:16 

Counsel 71:8 

counter 140:14 

countries 136:12 

country 151:8 

couple 16:4 20:5,7 

24:16 26:6 40:1 45:14 

48:6 83:12 94:15 

103:21 109:19 114:9 

131:6 137:16 141:11 

146:21 

course 12:9 32:14 

35:14 98:2 131:2 

cover 28:3 36:10 

151:16 

coverage 32:8 

covered 47:15 

covering 35:2 40:19 

covers 30:22 

COVID 20:15 22:1,6 

cracks 63:8 

craft 74:21 

crafted 73:17 

crazy 127:1 

create 50:14 63:9 

created 54:12 

creates 75:15 137:20 

creative 152:1 

crickets 169:7 

criteria 64:7 70:8 71:1 

119:7 127:19 132:18 

132:19,19 

critical 73:14,18 

critically 143:13 

crop 10:14 168:14 

crops 26:11 

cross 8:8 

crossed 42:9 

culprits 136:19,19 

cumbersome 119:15 

curious 127:8 

current 18:22 39:1 

53:10 64:2 65:9 70:2 

70:6 94:12 100:4 

101:13 107:5 162:1 

167:13 

currently 35:16 44:12 

59:7 64:11 67:2,11 

69:19 102:16 111:8 

126:9 138:17 164:7 

173:8 

currents 72:5 

Curt 17:7,8,12 91:18,20 

91:21 98:21 

CURTIS 1:12 

cushion 37:19 

cusp 124:15 

custom-made 68:16 

customer 71:20 110:7 

127:5 135:3 143:22 

160:14 166:4 

customers 6:16 22:2,18 

22:20 110:1 113:5 

118:16 122:16 124:8 

129:2 136:2 137:22 

139:15 158:16,22 

166:8 171:17,21 

customers' 126:5 

CUSUM 114:11 117:15 

117:18 118:2 122:3 

122:10,13 123:13,19 

124:22 125:5,7,14 

128:7,10 131:14 

132:20,22 133:7,10 

133:12 134:8,11 

143:6,7,12 

cut 48:14 

cuts 146:2 

cutting 163:19 

D

D 4:1 

Dakota 1:16 18:20 

83:15 149:15 159:12 

163:11,11 167:4 

damage 112:15 117:3,4 

148:7 166:6,10 

Danville 1:11 149:15 

data 29:1 44:18 54:22 

60:10 67:8,9 99:9,11 

date 34:10 35:10 51:12 

Dave 143:5 

David 1:11 36:19 59:6 

day 9:13 114:3,4 144:17 

167:11 169:20 173:9 

175:11 177:15,16 

days 13:20 20:7 44:20 

131:6 

DC 8:11 

deal 89:20 90:1 136:2 

138:22 173:7 

dealing 100:22 158:18 

dealt 52:17 54:6 55:12 

71:20 

debatable 128:6 

decades 154:14 

December 9:19 29:15 

53:13 64:7 

decide 105:7 

decided 63:14 75:4 

decision 44:11 67:9 

69:13 98:12 102:6 

decision-making 69:7 

declining 7:2 

decrease 31:20 

deemed 65:18 

definitely 56:14 60:11 

77:14 89:1 90:9 106:7 

106:11 107:19 134:2 

136:16 149:10 154:4 

157:12 165:17 169:7 

171:5 

degree 99:22 118:14 

delegation 26:19 

deliberate 50:12 

deliberation 64:13 

delivering 55:15 

delivery 9:10 

demand 6:2 21:20 

40:21,21 41:5,6,10,11 

demonstrating 65:22 

Denise 2:21 28:11 

36:19 42:8,11 

Department 1:1 11:12 

19:9,13 23:17 80:2 

83:7 86:11,20 87:1,4 

88:11 97:1,7,10 98:9 

103:2 169:11 

depending 5:4 121:4 

137:19 147:16 175:5 

depends 138:7 

Deputy 2:20 106:10 

describe 105:18 

describing 160:22 

description 139:1 

design 163:5 

designated 54:15 148:5 

designations 26:19 

designed 166:1 

destination 88:7 96:1 

145:4 146:12 147:5,8 

171:13,16 

destined 85:16 

detailed 37:21 

details 82:22 

determinations 62:20 

determine 34:21 63:1 

65:20 69:20 70:13 

determined 63:6 

determining 36:2 

develop 16:20 62:17 

63:21 65:4 66:13 

developed 148:15,17 

developing 65:11 

development 45:17 

46:1 65:16 98:15,17 

101:3 119:13 

developments 7:1 

device 65:3 

devices 64:22 65:8 

DeWert 23:16 

DFO 2:20 

DHV 63:1,4,16 69:22 

124:2 

dialogue 177:3 

difference 124:10 146:8 

147:15 168:7 

differences 151:1,21 

different 30:10 39:3 

66:16,18 68:6 80:10 

86:22 104:19 106:20 

110:11,11 112:21 

126:20 128:9 137:16 

139:16 144:13 147:9 

150:3,4 166:5 167:2 

167:21 169:3 174:1 

differentiate 102:14 

differently 146:15 

152:20 

difficult 6:21 97:6 126:5 

139:17 156:11 

difficulties 4:8 

digestible 132:13 

digging 142:21 

dilute 128:19 

diluting 128:19 

DIO 66:12 

direct 103:14 

directed 176:7 

direction 137:12 138:10 

directives 47:17 

directly 147:8 

Director 2:12,14 18:8 

19:14 26:2 

directs 11:10 

disagree 138:13 

disappointed 15:3 

169:12 

disaster 126:11 

disclosing 161:6 

discount 38:18,21 

discounted 38:10 

discounting 38:17 

discounts 38:9,20 

discrepancy 124:7 

discuss 3:12,14,17 

102:3 147:22 164:2 

169:15 

discussed 108:4 

168:19 173:19 174:16 

174:17 

discussing 105:4 

136:18 

discussion 12:7 66:5 

68:1 73:12,14 76:19 

77:13 81:11 96:9 98:6 

100:4 101:16,17,21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
183 

104:21 105:11 106:16 

107:1,5,8,11 109:13 

111:12 136:9 138:8 

138:12 143:2 144:3 

147:1 167:2 174:3,4,5 

174:9 175:11 176:1 

177:8,11 

discussions 37:11 

39:21 64:15,18 68:3 

70:16 82:18 83:11,21 

95:7 97:3,20 106:18 

109:19 173:11 

disregards 138:6 

Division 2:13,15 17:15 

19:14 31:3 39:14,15 

42:16 45:18 57:6 

64:18,19 

divisions 66:12 

document 74:16 

documentation 110:19 

documented 66:4 74:3 

dogs 100:5,11 

doing 13:14 16:18 

21:12 22:10 41:16 

86:8 89:13,13 91:22 

120:9 133:22 140:3 

144:22 145:16 146:6 

148:20 155:7 162:13 

162:13 163:15,21 

165:13 168:13 

dollars 10:2 57:1,2 81:5 

domestic 23:22 30:22 

32:13 54:20 66:12 

85:12 102:12,15 

166:17 

Domestically 145:22 

door 151:12 

double 92:22 147:19 

double-checks 171:22 

172:1 

doubling 10:17 92:21 

download 60:20 61:6 

61:10,13 62:3 

Dr 45:12 62:10,11 67:16 

67:18 68:14 69:10,18 

draft 66:4 77:17 

drafting 14:18 36:9 

drags 81:2 

drive 165:19 

drones 57:12,20 

drop 95:10 

dropped 105:2 107:20 

dry 152:12 153:5 

dual 39:8 

due 31:22 32:6 40:2 

63:12 84:11 

dump 82:5 93:3 

duplicate 120:6 

durum 62:16,19 

E

E 4:1,1 

e-learning 60:18 

earlier 5:12 72:11 83:5 

92:22 94:9 153:14 

173:9 

early 55:9 57:9,17 

150:20 173:12 

earnest 57:20 

easier 164:3 

easily 90:12,13 91:12 

132:13 

east 79:9,11 

eastern 18:20 76:7 

106:22 107:22 108:1 

172:20 177:17 

easy 28:10 46:16 47:20 

91:11 127:13 131:4 

146:19 168:15 

echo 4:11 

economy 10:4 

Ed 62:10 69:11 70:19 

EDT 1:8 

educate 50:17 95:8 

113:18 136:3 

educating 49:19 

educational 60:16 

EDWARD 2:14 

EER 111:4 

effect 36:1 106:5 

170:13 

effective 34:10 35:10 

35:13 

effectively 136:4 

effects 155:11 

efficiencies 170:8 

efficiency 55:22 65:6 

155:12 160:10 

effort 9:14 16:16 43:9 

44:4 47:18 49:7 

efforts 12:2 55:14 57:10 

65:17 

EGT 1:13 

eight 159:19 165:9 

either 13:12 73:2 74:11 

80:5 83:14 90:20 

112:5,5,20 123:6 

130:12,15 132:7 

140:9 161:6 

elections 4:21 

elevating 93:1 

elevation 151:1 

elevator 110:15,16 

111:3,13,22 112:7 

116:10 121:16 124:18 

125:9 144:1 167:5,10 

elevators 60:3 80:3 

124:13 

eligible 53:6 116:3,7 

119:8,9,18 

eliminate 49:11 95:21 

99:12 

eliminating 82:15 

embezzling 97:15 

emphasis 43:15 

employees 6:14 20:19 

22:4 

encompass 69:17 

encourage 53:4 

encouraged 55:17 

encourages 62:21 

encouraging 56:15 

65:2 

end-of-year 31:21 

ended 58:15 71:11 92:7 

endorse 86:13 

ends 21:7 142:4 153:19 

157:18 

enforce 170:1 

enforcement 26:11 

97:17 

engage 66:3 

engaged 70:11 

engagements 25:3 

engaging 20:6 154:6 

Engel 1:12 17:7,11,12 

91:16,18,21 

enhance 16:20 

enhancement 64:19 

143:11 

enhancements 64:19 

enjoining 24:9 

enjoying 19:3 

enormous 92:16 

ensure 5:22 40:7 41:3 

44:11 46:16 150:17 

158:21 

entail 171:3 

entering 52:7 

enterprise 45:3 

entertained 115:7 

entertaining 115:7 

entire 11:12 12:11 

78:19 102:4 121:5 

entirely 158:11 

entity 89:5 94:20 

entomologist 88:11 

104:6 

environment 22:7 

environments 57:13 

Epic 43:15 

equipment 45:4,13 

80:19 81:1,4 83:8 

92:19 95:17,21 

163:17 164:9,19,20 

168:5 

equivalent 67:10 

ERROL 1:16 

escaping 117:7 

especially 10:14 18:21 

67:22 68:22 74:14,17 

114:18 122:20 133:18 

141:5 155:18 176:10 

essentially 109:22 

established 53:3 66:15 

establishes 52:21 

estimate 32:15 

estimated 32:3,12,18 

32:19 33:11 

estimating 31:9 34:5 

European 79:17 81:17 

81:19 85:5 93:8 

evaluate 58:1 170:22 

evaluated 68:4 

evaluating 52:5 65:11 

70:8 

evaluation 58:11 65:15 

65:20 67:6,7 

evening 177:20 

everybody 4:4,4,6,7,9 

4:18 5:1,17 8:2 15:21 

17:5 28:15 41:13 46:8 

75:21 78:18 102:19 

105:17 106:21 107:13 

108:3 109:16,20 

115:12 130:22 131:15 

133:7,15 142:18 

143:15 144:10,19 

146:3 157:13 161:13 

166:14 173:2,13 

175:1 177:20 

everybody's 73:3 

144:22 

everything's 120:8,20 

141:2 

exact 59:9 96:9 150:13 

170:13 

exactly 114:20 161:13 

162:15 

Exam 56:6 58:8 

examinations 55:19 

56:2 

examine 57:15 

example 34:22 39:12 

87:1 110:6 111:6 

122:21 123:17 127:20 

133:1,2 166:14 

examples 75:6 112:16 

123:8 141:12 

exams 55:13 56:15 57:8 

57:14 

exceed 114:22 116:12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
184 

117:10,16 123:14 

137:18 

exception 148:10 

exceptions 71:1,19 

72:9 73:20 

exciting 114:1 

exclusively 52:11 

excuse 17:13 64:20 

execution 51:9 

Executive 2:21 11:8,9 

exercise 93:4 

exhausted 107:6 

existing 10:8,15 20:4 

48:21 57:3 

expect 7:21 9:4 20:16 

158:22 

expectation 23:7 

160:12,13,14,18 

expectations 22:9 

156:15 158:17 

expected 159:8 

expecting 25:10 116:20 

expects 145:4 

expense 57:16 

expenses 7:15 30:9,10 

30:16 49:13 

expensive 56:20 80:15 

92:17 104:10 

experience 25:21 26:1 

26:9 44:9 58:14 85:14 

86:21 102:20 175:8 

experienced 27:7 

experiences 20:3 

experiencing 20:13 

expert 31:2 90:15 

119:13 145:21 

expired 53:15 

exploratory 57:7 

explore 132:21 

exploring 69:19 82:20 

139:7 

export 18:12 30:19 31:7 

32:14 49:15 84:12 

85:12,17 86:6 102:13 

102:15,16 110:1 

125:20 154:1 156:9 

171:19 

exporter 18:21 84:6 

133:13 135:9 157:16 

160:13 

exporters 114:7 120:5 

exporting 102:18 

exports 94:16 158:16 

express 19:20 

expressing 19:21 

extend 40:10 53:9 64:8 

extended 53:8 89:22 

externally 44:14 

extra 104:9 142:17,21 

170:4 

extremely 21:6 22:2,10 

40:1 51:3 

eye 18:13 

eyes 129:15 

F

face 16:2 122:19 

faces 15:22 

facilitate 43:16 62:20 

106:3 108:16 127:1 

facilitates 176:20 

facilitating 12:1 140:14 

facilities 18:12 22:21 

54:14 60:1 80:11 82:1 

82:2 83:7 85:22 87:11 

88:13 

facility 80:13 81:3 82:4 

85:20 88:16 

facility's 110:15 

fact 14:3 46:3 

factor 110:11,12 118:7 

137:19 160:16 

factors 40:2 110:3 

111:8 114:16 122:22 

127:15 143:7,10 

161:3 

failed 72:11 

fair 12:2 

fairly 56:10 80:15 169:8 

faked 105:1 

fall 7:5 56:8 108:14 

109:5 110:20,21 

151:21 

falling 3:17 144:6,13 

145:6,18 146:14 

148:1,13 150:8 151:2 

152:6,14 153:8 

154:20 156:19 159:5 

159:12,14 167:7,7,9 

168:13 169:9 171:14 

falls 164:17 

familiar 26:22 79:8 97:7 

families 20:18 

family 89:22 

far 20:21 29:6,10 57:1 

58:5 62:7,13 66:2 

84:14 91:13 95:7 

98:22 102:21 103:9 

113:7 122:9 133:15 

135:11 143:12 145:3 

155:12 156:16 158:9 

169:16 171:18 

Farm 168:15 

farm-gate 52:2 

farmers 90:1 104:8 

farms 13:16 

fashion 126:20 

fast 13:2 166:2 

fault 74:11 

FDA 141:16 173:11 

feasibility 69:20 

feasible 59:5,5 90:18 

129:18 130:18 

February 11:9 64:9 

federal 6:11 10:1 11:6 

11:10 14:15,22 26:10 

27:16 34:12,12 35:7,7 

35:15,20,21,21 41:22 

64:4,5 70:4,21 154:14 

175:18 

fee 29:2,5,14 30:14,14 

31:17 32:12 33:14 

34:8,13,21 36:14 39:8 

39:14,22 

feed 17:19 85:3 96:16 

96:20 100:13 

feedback 11:15 13:3,11 

14:19 48:6,10 71:7 

78:22 91:2 104:19 

feeders 92:11 

feel 8:4,18 16:18 24:12 

47:13 54:5 108:1 

112:16 136:15 170:15 

feeling 155:19 

feels 102:4 

fees 30:10,15,17,20,22 

31:19 33:6,16,19 34:9 

34:19,20 35:1,5,9,14 

35:16,21,22 36:3,10 

37:21,21 38:9,10,17 

38:21 39:6,17,18,18 

40:6,7 42:1 54:9 

feet 151:4,6 

fell 111:3 

fewer 131:11,11 

FGIS's 38:14 51:13 65:1 

fiber 90:10 

Field 2:12 23:15,18,19 

23:21 24:4,6,15 25:2 

25:8,12 30:16,22 39:4 

42:13,16 43:4 45:18 

57:5 64:18 66:12 

89:12 128:13 

figure 28:14 71:4 108:2 

177:1 

figures 31:8 

file 36:20 

fill 24:19 

final 29:18 33:2 35:10 

52:8 67:5 169:22 

finances 28:20 

financial 3:8 28:22 29:6 

51:12 129:7 

financials 28:12,18 

find 5:9 122:14 

finding 15:10 97:6 

findings 90:21 

fine 78:7 116:9 173:17 

finish 168:1 

first 16:8 56:5 86:17 

89:16 116:19 119:22 

125:12 144:14 153:3 

154:5 164:4 169:9 

175:11 176:3 

fiscal 29:7 32:3 47:1 

fissures 63:8,9 

fit 65:18 

fits 78:9 138:11 

five 38:8,18,21 117:19 

169:7 

five-year 52:21 

flag 124:19 129:13 

130:12,22 132:7,15 

132:17 

flagging 119:6 120:2 

121:8 129:19 134:5 

139:4,7 

flags 127:11 

flat 59:3 

Flexibilities 3:15 

109:14 

flexibility 7:19 8:1,7 

115:16 118:20 122:4 

125:21 155:20 

floated 37:16 

flour 148:16,16 152:8 

flow 73:16 

fluorescent 67:3,11,21 

68:20 

fly 177:1 

FM 96:3 115:14 

FMD 57:5 

focus 48:5,9 63:14 

focused 95:4 120:3 

folks 8:2 12:4 21:5 22:5 

24:13,22 27:10 49:5 

62:12 79:8 84:3 89:1 

89:2 136:6 138:12 

176:21 

follow 46:8 102:7 

111:19 149:17 162:7 

162:19 163:8 164:21 

follow- 171:3 

follow-up 143:18 156:3 

170:10 

following 165:11 

food 10:15 11:17,19,22 

12:3,18 18:21 19:2 

41:11 

Foods 1:15 18:19 

foot 150:22 

forefront 15:8 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
185 

foregoing 7:14 

forge 173:10 

forgot 142:14 

forgotten 72:15,20 73:3 

Forks 159:11 

Form 138:18 

formal 75:16 108:13 

109:4 

formed 63:11 

forms 44:17 53:4 

formula 35:9 36:2 

159:17 

formulating 64:12 

formulation 33:3 

forum 96:7,10 

forward 8:5,9,12 9:8 

15:6 19:17 20:2,6 

44:16 64:16 69:13 

76:2 170:18 175:21 

found 81:19 83:7 

four 38:8 

four- 31:21 

four-and-a- 31:13 

fourth 80:17 

framework 148:19 

frankly 92:8 129:7 

133:19 166:4 

free 47:13 

Friant 1:13 14:11,12 

17:17,18,18 59:16,17 

60:14 78:5 79:4 84:18 

86:17 95:11 99:17 

101:8 135:16,16 

137:1 173:21 174:19 

175:6 

friendly 115:12 

front 12:21 15:8 57:19 

fulfilling 22:8 

full 82:21 115:4 167:20 

full-scale 58:15 

fully 132:5 139:6 

155:20 

Fumigation 47:2 

fund 52:13 

funded 52:11 

funding 30:5 32:6 34:4 

funds 29:4 97:15 

further 5:11 62:21 

98:15 99:11,13 101:3 

128:15,17 143:1 

144:3 164:13 175:7 

Furthermore 66:1 

future 67:22 101:18 

FY20 31:13,16 33:9 

35:18 

FY21 29:1 

G

G 4:1 

gain 63:13 

gasoline 41:16 

Gastonia 52:6 

gather 141:17 

general 12:20 39:10 

71:8 97:14 102:16 

114:16 119:15 128:21 

148:3 152:4,8 174:9 

generally 85:15 114:9 

115:9,12 

geographic 54:7,17 

55:1,7 71:2,10,18,19 

72:10,14 

getting 8:9,12 19:18 

33:5 47:19 71:12,17 

71:22 73:17,22 76:17 

79:21 85:22 124:2 

129:7 131:11,18 

147:6 164:22 167:20 

167:20 171:15 

GIAC 1:8 46:2,14 52:18 

52:19,22 53:8,10,16 

54:8 66:3,5 76:17 

94:11 107:7 108:6,12 

109:7,19 123:5 135:8 

141:14 144:4 169:18 

give 6:18 8:14 13:19 

20:9 31:12 34:22 46:9 

69:14 78:18 79:2 

84:18 132:22 133:5 

146:12 160:4 173:12 

given 4:18 22:16 38:20 

48:16 75:17 107:11 

107:20 129:12 141:4 

141:11 151:14 168:4 

170:19 175:18 

giving 4:18 78:8 111:6 

158:6 

glad 14:4 15:4 115:7 

glean 169:19 

globe 68:7 

goal 16:12 23:5 31:21 

32:16 33:9,10 55:10 

golfing 24:9 

Goodeman 2:12 47:15 

51:21 56:5 58:10,12 

59:2,8 60:6 89:11,15 

113:20 114:5 117:2 

118:22 119:3 120:13 

120:18 121:3,14,21 

123:3 127:4,8 129:3,9 

129:14,22 130:9 

132:11 133:4 134:3,6 

134:9,22 135:6 143:4 

144:2 148:1 150:18 

151:17 154:22 155:10 

163:22 164:6 165:4 

165:12,16 167:12 

168:2 170:21 

gotten 16:10 121:9 

gov 78:8 

govern 161:20 162:12 

governed 110:4 

government 26:10 

84:11 103:11 

governs 110:5 

grade 18:21 19:2 110:3 

110:11,22 111:10 

117:5,8 121:20 

122:22 124:16 125:8 

128:22 147:6,13,16 

148:7 154:2 

graded 67:1 111:9,15 

140:18 

grader 166:11 

graders 25:7 

grades 18:3,4 100:17 

120:7 136:14 137:5 

137:17 145:3 

grading 43:16 45:4 

51:11 60:20 67:4 

122:12 139:3 

grain 1:3,11,14,15,17 

6:11,17 13:17 16:13 

17:2,8,15 19:10,16 

21:1,3,4,9,14,16,20 

23:7,9 27:2,3,10,12 

27:20 29:20 31:3 34:8 

35:5 45:1,11 46:6,22 

47:2,3,3 49:15 50:4,8 

50:16,19 52:20 54:10 

54:14,16 55:2 65:14 

65:22 66:17,20 71:13 

79:9,14 80:3 81:14 

82:19 83:13 84:1 85:3 

88:3 92:20 96:16,20 

100:13,17 113:4 

118:6 126:17 148:11 

149:3,12,15 151:16 

159:11 176:18 

grains 18:22 19:1 

grams 163:18 166:10 

166:13 

Grand 159:11 

grandma 108:1 

grant 10:7,8,9,18,21 

granting 71:1 

graph 34:15 

grateful 23:20 

gratitude 19:21 

gray 120:8 

greater 65:6 149:11 

150:17,21 153:8 

green 16:11 120:8,12 

120:13,14 124:20 

126:18 130:13 131:19 

greens 121:12 

greetings 3:4 5:14 

Greg 146:20 152:5 

156:6 

grind 163:18 

group 9:8 11:1 16:4 

74:20 75:15 77:2 

78:19,21 82:8 83:4,22 

86:12 93:12 103:17 

103:19 105:12,15 

106:17 109:11 128:13 

141:14,21 170:16 

173:7 

groups 171:8 

growing 135:20 

GSA 164:4 165:3 

Guagliardo 26:2 

guarantee 95:22 

guess 14:16 15:20 

24:16 28:7 37:16 38:8 

39:3,12 56:8 68:12 

74:9 75:3,4,15,18 

76:6 78:12,20 79:1 

84:13,13,14 86:1 88:4 

89:13,22 100:7 

101:10 102:7,22 

103:12 105:10 110:4 

111:11 113:1 115:10 

119:2,21 123:5 

129:18 130:8 135:14 

141:10,22 142:18 

143:14 154:19 160:6 

167:1 168:21 170:16 

170:17,19 173:7 

guidance 27:16 46:17 

47:20 126:22 

guidelines 65:10 

Gulf 23:8 42:20 43:6,8 

H

half 30:2 31:14 

half- 93:5 

halfway 114:6 

hand 32:9 76:18 79:7 

80:13 82:9 103:5,6 

105:1 111:16 113:12 

114:10 115:8 133:11 

handbook 47:1,2,4,22 

48:1,2,2 112:22 

129:21 130:6 141:19 

handbooks 46:22 47:5 

47:10,16 48:12 

handful 59:8 166:12 

handle 51:4 78:14 

101:13 

handled 54:16 122:18 

handler's 82:19 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
186 

handlers 83:14 95:18 

handlers/industry 84:1 

handling 54:14 63:12 

happen 12:4 21:6,18 

22:6 81:8 103:6 

105:21 138:10 

happened 79:20 97:18 

106:18 

happening 82:6 

happier 6:9 

happy 12:21 18:14 

67:17 94:8 113:20 

116:11 176:14 

harbor 79:17 81:18 

harborages 93:7 

hard 9:14 10:11 21:6 

22:10 63:2,11,11 76:2 

92:20 127:13 155:3 

hat 75:5 162:21 

hate 28:8 104:15 

head 44:20 102:10 

136:15 

heading 79:12 83:16 

headway 146:22 

health 5:22 20:17,18,18 

20:19 

healthy 6:14 15:10 

21:21 

hear 15:7,12 19:7 24:17 

71:2 83:22 104:5,8 

160:10,10,11 

heard 10:2 83:14 89:21 

95:18 100:14 137:7 

hearing 107:9 109:11 

154:17 161:9 172:11 

hearings 79:7 

heat 117:3,4 

heck 38:15 

help 4:11 6:16 11:18 

12:1 14:5 74:1 75:9 

77:9 80:10 99:4 106:2 

108:16 113:3,9 121:9 

121:20 126:10,22 

156:9 171:7,12 

174:11 

helped 22:18 87:21 

145:1 

helpful 46:17 98:21 

171:5 

helping 73:15 89:8 

146:22 

helps 131:17 

hemp 109:1,8 

hesitate 94:21 

hey 79:10 88:8 104:22 

108:10 114:3 120:21 

152:12 166:9 167:22 

173:21 

hiding 15:22 

high 41:6 63:8 127:18 

127:22 134:19 145:7 

166:2 

high-end 56:21 

high-level 86:2 

high-speed 133:21 

higher 145:8 151:8 

highs 20:13 

Hill 51:1 

hire 23:6,10 

hired 26:5,16 

hiring 23:10 

historically 31:5 

hit 10:11 20:16 106:1 

107:4 

holding 24:3 27:18 

holiday 36:5 

Homework 142:3 

homogeneous 133:9 

honed 133:8 

hones 155:8 

honest 140:10 159:2 

hoops 170:4 

hope 5:18 9:4 15:2,17 

26:12 55:8 70:17 72:5 

72:7 

hopefully 4:6 6:22,22 

6:22 7:6 8:13 16:1,12 

25:13 49:7 77:11,16 

99:16 109:20 146:16 

hoping 4:17 16:9 35:12 

59:14 165:15 

hour 92:19 107:14 

120:10 173:9 177:12 

hourly 30:19,21 36:4 

hours 165:9 174:15 

house 12:10 27:16 

60:10 166:11 

housekeeping 5:2 

houses 9:2 

huge 43:9,20 89:8 

149:20 

hundreds 7:11 59:12 

hurdles 6:5,8 

hurts 131:18 

HVAC 62:14,15,18 63:4 

63:16 69:12,22 

hybrid 8:7 

I

Idaho 79:13 

idea 70:10 86:13 136:8 

136:21 147:12 

ideally 16:3 166:1 

identifiable 90:14 91:13 

identified 80:3 

identify 63:19 

identifying 65:5 

imagine 127:16 

imaging 63:16 69:16,18 

69:21 70:8,14 

impact 44:9 156:12 

157:15 158:15 

impacting 10:5 

impacts 44:1 

impetus 71:15 

implement 9:15 35:8 

36:11 42:1 56:7 

implementation 55:18 

56:10 

implemented 52:3 

58:15 151:3 177:5 

importance 65:2 

important 13:22 143:13 

143:16 157:17 160:5 

impossible 61:9 147:16 

improved 62:15 65:6 

improvement 7:4 

improvements 49:8 

64:21 

improving 64:16 

in-house 146:3 

in-person 7:8,15,22 8:8 

16:14 68:2 175:14 

in-process 130:12 

inaccurate 153:16 

inadequacies 145:5 

inappropriate 94:18 

inch 93:6 

include 39:18 53:16 

64:13 65:13 66:10 

67:7 71:12 81:1 85:10 

122:2 

included 93:20 

includes 65:19 138:6 

164:21 

including 128:4 

incoming 82:6 

inconsistencies 144:17 

144:18 

incorporate 55:14 

incorporated 111:14 

incorporates 155:6 

increase 11:18 31:17 

31:20 34:14 37:18 

increased 6:2 32:1 

41:12 97:17 

increases 104:13 

increasing 31:19 38:14 

38:14 

incredibly 92:16,19 

increments 151:5 

incurred 32:8 

independent 140:10 

171:18 

indicate 94:17 

individual 30:6 103:3 

103:18 

individually 12:16 

individuals 45:20 

industries 41:9 

industry 3:12,14,17 

21:10 23:1 39:7 42:7 

42:19 43:5,10 44:8,19 

45:6 83:10,13 84:8 

106:3 108:17 138:1 

142:16 143:16 172:14 

174:2 

industry's 21:1 

infancy 8:19 70:16 

influence 93:17 

informal 44:22 140:6 

information 34:3 43:13 

43:21 47:14 48:18,20 

54:22 57:22 60:4 

69:15 99:14 108:19 

132:14 146:16 160:4 

161:12,19 169:18 

170:8 174:22 

initial 5:7 22:5 37:11 

65:19,20 73:9 83:11 

130:10 

initially 20:16 81:11 

97:20 100:15 119:20 

injuries 57:15 

Innovation 2:11 

innovative 55:15,21 

input 13:19 45:22 66:3 

66:5 98:16,19 137:11 

insect 96:3 

insects 90:13 91:12 

inside 15:4 51:4 

insight 59:20 

inspect 87:11 

inspected 81:15 

inspecting 128:5 

inspection 1:3,11,14,17 

3:15 6:11 9:11 16:13 

17:2,8 19:10,16 21:9 

22:14 23:22 27:1,3 

29:8 30:8,19,21 31:6 

33:22 34:9 35:5 43:17 

45:1,4,11 46:6,22 

47:2,3,3,5 49:12 50:5 

50:8,16,19 54:10,15 

65:12,14 66:1,13,15 

92:2 97:17 109:14 

113:22 114:9 116:1,8 

120:4 127:10 149:3 

149:15 150:2 159:11 

161:7 165:21 166:2 

176:18 

inspections 18:4 111:5 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
187 

137:5 

inspector 88:16 143:21 

inspectors 63:7,13 

66:18 67:1 87:5 

install 95:17 

installations 92:15 

instance 39:5 74:22 

75:13 134:21 

instances 22:3 

instructed 112:2 

instruction 110:17 

111:13 112:7 121:16 

150:14 151:3 154:10 

instructions 46:16 

116:5 148:8,18 

Instrumentation 27:2 

insurance 56:18 

integrity 21:14,15 

118:13 132:5 

intended 10:9 114:12 

intent 38:12 50:7 77:11 

105:12 129:12 174:6 

inter-agency 52:12 

interact 16:19 103:14 

interaction 105:18,21 

interactions 26:20 

interactive 39:11 

interest 19:21 21:16 

45:20 47:19 82:20 

166:18 

interested 57:21 137:9 

interesting 117:13 

118:4 

interference 151:18 

interlocks 120:16 

internal 49:18 64:13,15 

64:20 170:22 

internally 44:14 50:17 

69:22 127:9 

internet 60:21 61:11,13 

61:14,22 78:2 

interpretation 138:1 

interview 24:18 

intolerances 116:13 

introduce 17:6,9 

invest 44:5 

invested 44:8 

investigate 62:21 64:1 

investigated 63:4 

investment 44:10 

invite 4:14 

involved 51:3 86:10 

89:1 90:9 93:22 94:20 

95:13 96:19 97:2 

99:21 125:17 142:20 

153:19 155:17 162:3 

involvement 51:13 

91:14 96:5 

involves 56:12 

Iowa 83:15 

IP 18:21 19:2 102:14 

issue 9:11 10:22 14:19 

55:3 72:10 79:6,21 

81:16 83:4,12 84:17 

90:10 91:8 92:2,2 

94:16,21,22 97:2,8,12 

97:16,19 98:1,8 99:2 

99:7,9,14 100:16,18 

104:6,16 106:4 124:9 

130:6,7 155:21 

159:22 162:22 

issued 11:8 110:22 

111:10 

issues 3:12,14,17 67:20 

68:6 71:21 72:2 87:14 

97:11 105:4 108:14 

136:1 146:22 159:4 

172:14 174:3 

it'd 137:6,8 

it'll 37:5 42:6 46:12 

item 5:2 84:8 101:17 

108:6 109:2 133:16 

142:2,3,8 170:15 

items 4:16 31:4 32:7 

47:11 78:3 109:12 

116:16 130:2 140:17 

140:19 141:18 142:12 

142:14 172:17 174:16 

175:16,19,20 176:11 

J

Janice 1:12 18:5,7 

94:14 96:6 98:11 

104:17 135:17 137:2 

January 7:6 8:18 19:13 

26:4 29:16 34:10,11 

35:10 

Jeff 27:4 

Jenny 8:20 

Jess 2:18 85:1 87:20 

94:6 95:8 96:13,15 

jest 114:6 

Jhee 2:14 45:12 62:10 

62:11 67:16,18 68:14 

69:10,18 

jimmy 1:17 19:5,8,19 

88:9 105:16,22 

job 6:12 17:13 23:16 

176:17 

John 1:15 111:15 113:9 

117:12 123:6 137:7 

138:3 144:6 147:2 

155:15 171:22 

John's 131:10 

join 177:16 

joined 107:20 

joining 4:4 

joint 97:21 

joints 79:16 81:18 

joys 20:14 

jump 47:13 84:20 170:5 

jumping 86:3 

justify 57:15 

K

Kansas 17:13 151:6 

175:10 

Karen 26:2,4 

Karla 26:7,7,13 

keep 4:10 6:17 8:2 13:9 

18:13 23:2 28:11 32:8 

38:7 72:6 73:5 109:12 

keeping 15:10 21:20,20 

60:10 119:1 

Ken 23:15 

Kendra 2:16 4:12 37:1 

37:2 46:6 49:3 63:16 

67:13 77:3 78:6,15 

109:14 173:5 

Kendra's 79:5 

kernel 63:10 

kernels 62:19,19 63:1,2 

63:7,12 

Kerrigan 1:8,13 4:3 

28:6,16 37:10 38:2,5 

39:2,19 58:21 67:18 

69:9 72:22 74:13 76:5 

76:9,12,16,22 77:8 

78:1,15 84:5 89:10 

91:15,17,19 94:5,11 

96:13 99:19 101:4,15 

104:18 105:9 106:14 

106:16 107:18 108:18 

109:10 112:4,14 

113:13 114:3 117:1 

118:15 119:1,20 

120:14,19 121:4,15 

122:12 123:4,21 

128:22 129:4,10,15 

130:1 131:8 133:3,6 

134:4,7,18 135:1,7 

136:7 139:11 140:5 

141:9 142:10 143:1 

144:3 147:2 154:17 

155:1,15 158:9 159:1 

161:9,16 162:2,10 

167:22 168:3 169:4 

170:10 171:15 172:10 

173:2,17 174:13,20 

175:16 176:2 177:10 

key 88:12 112:10 

kick 14:7 51:19 56:4 

122:11 

kicked 125:15 

killing 133:3 

kinds 15:11 

kit 35:3 64:4,7,17 

kits 63:18 67:14 

KLINE 2:16 37:4 46:9 

46:11 67:15 79:2 

knew 20:16 

knocking 93:6 

knowing 37:17 171:8 

knowledge 15:5 20:2 

known 54:2 84:8 

knows 73:11 143:15 

166:15 

Kuhl 1:14 159:10,10 

163:9,10 164:1 165:2 

165:5,13 166:20 

168:12 171:10 

L

lab 1:16 22:22 52:6 

171:18 

lack 157:13 

lady 26:6 

lamps 66:22 67:2 

land 175:5 

language 73:22 

large 13:18 74:15 92:6 

92:14,20 

Lastly 70:10 

lately 145:7 

latest 51:20 

laws 10:5 

lead 11:12 109:17 144:7 

175:3 

leaders 50:17 

leadership 6:10 8:16 

10:20 43:11 49:20 

leading 49:4 97:11 

League 23:14 24:6 43:3 

leave 13:3 89:17 

leaves 42:11 

led 66:7,9,14,21 67:2,10 

67:19 97:16 

Lee 2:11 49:5 119:14 

138:15 141:1 160:19 

161:10 169:21 

Lee's 139:20 

leeway 114:17 115:4 

152:2 

left 72:17,18 

lengthening 52:18 

Lentil 48:1 

Lester 8:21 

let's 13:5 107:12 109:11 

122:19 

letter 108:15 

letterhead 90:20 150:9 

162:22 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
188 

letting 159:21 

level 52:3 112:19 145:8 

151:7 

levels 64:2 97:6 

leverage 87:18,20 

leveraging 20:2 

liaison 105:14 

licensed 148:3 164:10 

164:18 

licensing 64:21 

lie 100:5,11 

lies 124:2 

life 42:13 

light 16:11 71:3 84:13 

100:21 105:10 

lighting 66:9 67:19 

lights 66:10 68:4 

likes 146:3 

limit 64:2 116:9 117:5 

limitation 31:18 49:12 

49:14 

limitations 113:2 

limited 68:5 142:17 

limits 116:16 122:4 

132:15 

Lindgren 1:15 111:17 

112:13 113:11 123:11 

123:22 127:5 144:7,9 

147:11 156:4 158:10 

172:4 

line 31:7 98:21 126:6 

163:3 164:17 

lines 15:8 81:20 

lining 149:12 

listening 25:20 

little 6:18 8:15 11:2 

17:3 25:14 27:14 30:4 

32:15 39:2 42:11 

48:15 69:15 72:17 

79:21 81:22 87:12 

96:21 105:10 107:10 

113:19 114:15 126:22 

128:5 131:19 133:13 

139:19 140:1,13 

141:9,12 148:2 

166:12 169:15 172:12 

172:12 173:22 174:11 

175:2 176:2 

live 81:17 91:12 96:3 

LLC 1:13 

load 110:17 112:5,11 

113:4 115:4 120:17 

124:7,9 126:7 127:1 

132:18 135:10 138:18 

139:8,15,21 140:7 

165:8 167:6 

loaded 119:11 120:20 

131:1 

loader 59:13 115:13 

132:21 160:2,12 

loaders 165:8 

loading 18:12 88:4 

92:15,18 93:9 110:15 

111:3,22 114:10,12 

127:1 128:7 130:13 

133:22 135:21 141:5 

159:17 171:19 

loads 82:6 

local 10:15 30:15,17 

located 18:10 

location 66:21,22 

locations 87:7 126:15 

151:7,8 

lockdown 97:22 98:3 

log 119:10 129:1 143:7 

156:19 161:7,7 

long 4:19 8:18 13:10 

40:16 58:8 91:10 92:1 

115:5,15 117:20 

119:17 125:12 150:6 

165:10 166:8,9 167:9 

long-term 56:17 

longer 25:14 82:14,18 

89:7 99:9 175:13 

longer-term 82:12 

look 8:12 9:8 11:16 

19:17 20:6 41:15 48:9 

48:13 57:6 61:8 80:13 

84:15 88:17 90:12 

91:12 105:20 109:21 

112:8 127:12 128:9 

128:13 130:20 136:20 

141:18 158:1 166:16 

166:17 169:22 175:4 

looked 59:4 90:5 

140:20 156:17,22 

looking 8:9 20:1 23:18 

24:19 41:15 42:9,19 

57:3,14 67:22 70:10 

72:2 75:1 85:3 91:1 

106:19 110:12 117:19 

122:16 126:10,21 

128:12 129:5 132:12 

135:12 136:4 140:19 

145:13 153:7 154:2 

170:14,17,20 176:20 

looks 27:22 103:21 

105:16 106:21 138:5 

143:6 

loose 100:1 149:6,10 

lost 53:14,14 

lot 4:17,20,21 6:3 8:7 

9:22 10:1,3 13:21 

17:4 20:12,19 23:12 

25:7,17 27:8,20 36:16 

38:15 39:20 41:9 

43:14,18,22 59:22 

68:3 71:20 72:17 75:6 

83:6,14,18 93:10 95:6 

97:16 103:10,20 

107:21 110:21 114:11 

114:14,14 115:16 

116:21 121:5 124:7 

132:3 134:19 137:20 

144:15 151:7 152:19 

153:10 156:1 160:18 

166:18 167:15 169:6 

170:4 174:3 176:10 

177:15 

lots 114:20 120:9 125:6 

love 15:7 135:3 

loved 24:12,13 

low 38:10 40:1 41:5 

122:5 127:18 128:1 

lower 56:17 64:1 65:7 

112:3 151:5 

lowering 152:3 

lows 20:13 

lunch 75:19 106:22 

107:3 113:21 144:10 

lunchtime 144:11 

M

machines 164:9 

mainstream 92:21 

maintain 8:1 34:16 

37:18 116:11,15 

117:11 118:13 150:4 

maintaining 9:10 44:12 

116:10 

major 15:2 47:21 48:3,5 

83:13 132:2 

majority 77:13 

making 21:18 45:7 

88:12 92:10 126:16 

132:4 138:1 147:3 

153:14 154:2 

man 61:4 114:3 

manage 80:10,14 113:9 

managed 87:13 

management 2:12 

22:15 42:16 45:18 

49:11 57:6 64:19 

66:12 170:9 

manager 19:10 23:15 

23:18,22 24:5,6 97:14 

Managers 25:13 

manages 85:13 

Managing 18:8 

mandated 162:4 

mandating 154:11 

manipulation 152:19 

manner 94:2 132:17 

154:5 160:4 

manufacturer's 65:21 

manufacturers 69:5 

March 9:21 35:6 64:10 

Marine 162:17 

mark 75:18 

market 12:1 32:14,14 

54:9 113:3 171:1 

marketing 1:12 8:22 

9:12 18:9 21:12,13,14 

26:8 43:2 106:8 

148:15,19 

marketplace 54:21 

markets 12:2 102:12 

masks 32:9 

material 100:19 111:20 

125:7,10,12,17 

mathematical 133:8 

matic 153:12 

Matt 5:11 15:20 28:5 

38:3 73:8 74:6 78:12 

79:4 84:2,19 87:17 

96:12 101:10 104:22 

108:10 111:17 125:5 

126:14 135:19 137:3 

171:11 173:21 

matter 46:3 76:13 

107:15 152:12 153:5 

172:21 177:21 

Matthew 1:8,13 

max 125:2 134:8 138:4 

maximum 31:19 117:9 

124:11 

McCluer 2:18 85:1 

87:20 94:5,6 96:11,14 

96:15 100:9 101:5 

McCluskey 42:17 46:21 

146:19 156:6 166:21 

mean 8:18 37:12 59:12 

70:21 85:16 88:15 

91:2 92:15 94:6 99:3 

101:16 105:22 106:6 

113:5 121:5 127:5 

130:18 133:6 134:10 

134:20 135:2,19 

141:2 142:1,19 

157:22 162:15 164:6 

165:16 

means 7:6 49:22 50:3 

102:20 120:13,14 

130:13 139:1,7 

157:10 

measure 90:12 91:10 

measurement 90:18 

measures 19:15 36:11 

meat 141:13 

meet 7:7,21 10:19 

27:11 114:7 119:6 

124:8 126:5 127:7 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
189 

158:17 160:12,13,14 

meeting 1:3,7 4:14 5:4 

9:7 12:4 15:18 16:13 

19:17 21:9 22:8 27:12 

37:3 68:3,10 73:18 

75:7 77:16 97:22 

101:19 108:16,22 

142:9,9 144:14 145:4 

169:13 175:20 176:3 

176:22 177:2 

meetings 7:10,11,16,18 

13:20 49:18 169:11 

meets 65:21 116:1 

member 21:10 53:22 

73:1 98:8 

members 4:20 17:1,7 

19:17 20:4 45:6 52:19 

52:22 53:2,5,8,10,15 

53:17,19 74:15 76:18 

87:18 94:11,13 98:18 

109:20 144:4 177:6 

membership 137:9 

memory 87:15 

mention 72:11,16 104:4 

mentioned 17:22 47:22 

83:5 94:19 99:20 

157:20 163:20 166:22 

mentioning 98:2 

123:15 

mesh 79:16 82:4 162:8 

meshing 112:10 

message 89:18 106:7 

172:5 

met 1:7 4:19 16:4 17:10 

111:1 122:8 130:13 

method 62:15,18 

145:19,22 147:20 

150:16 156:20 157:10 

159:14,15 160:5,6,22 

161:8 162:11 163:12 

163:13 168:22 171:13 

172:2 

methodologies 168:10 

methodology 168:5,8 

methods 62:22 161:4 

167:4 

metric 31:7 163:16 

Mexico 79:13 

microphone 71:3 

mid-spring 55:10 

middle 106:17 

midst 20:14 

million 29:9,11 30:2,3 

31:10,11,12,15,16,22 

32:4,20 33:9,11,12 

34:1 49:14,20 50:1,4 

50:6,7 

millions 81:5 

min 125:1 134:8 138:4 

min-max 112:11 124:12 

mind 28:9 38:7 82:13 

87:3 

mindful 27:21 

mine 126:14 

minimum 110:10,14 

112:2,7 114:13,13 

123:18 124:10 

Minnesota 80:2,3 83:6 

83:15 86:22 96:20,22 

97:1,9,13 98:9 100:13 

minute 46:10 

minutes 13:1 75:19 

126:17 159:20 172:19 

mirror 33:4 36:6 

misquote 117:8 

misrepresented 123:7 

missed 120:21 

mission 140:14 

missionary 9:1,1 

Mississippi 59:1 

Missouri 19:9 88:10,10 

88:13,22 149:16 

misstated 176:14 

mistake 119:11 120:20 

mixing 113:2 

mixture 93:20 113:8 

moderate 121:20 

modernization 43:13 

modernizing 43:16 

modifications 81:3 

150:3 

modify 5:21 166:13 

Moffitt 8:21 

moisture 144:20 145:17 

151:22 152:4,6,11,13 

152:15,17,20,22 

153:2,17 154:7,12 

158:1 163:6 

moment 16:22 

moments 74:6 

momentum 59:14 

monetary 121:1 159:7 

money 10:3 52:10 

155:17 

monitor 126:18 132:8 

140:21 

Montana 151:9 

month 34:6 35:12 64:12 

months 23:13 31:14,22 

32:5,17,21 33:8,13 

34:1 55:5 58:14 70:19 

119:21 146:21 

morning 4:4,5 5:17 

15:21 16:21 17:11,20 

18:7,16,18 19:6 20:4 

24:9 62:11 69:12 

108:5 

motions 115:8 

MOU 141:16 173:11 

mountain 92:12 

Mountains 79:10,11,12 

MOUs 66:15 

move 8:4 23:7 28:8 

43:5,7 58:3 62:8 

64:16 69:13 72:6 76:2 

101:21 144:5 151:15 

154:8 156:11 164:16 

169:19 171:2 177:9 

moved 154:10 

movement 25:17 155:5 

155:19 156:7 

movements 85:19 

moving 6:17 18:13 21:2 

21:2,4 23:9 38:15 

44:15 71:4 109:12 

120:10 165:3 170:9 

170:18 175:21 

multiple 40:2 53:6 

161:3 

mute 73:3 

muted 4:10 

mycotoxin 63:18,20 

64:4 67:13 

N

N 4:1 

NAEGA 14:17 18:4 

97:21 137:5,8 

name 17:6,11 19:8 26:6 

26:22 75:5 78:4 96:15 

146:20 150:9 163:1 

names 16:1 

Nashville 16:4 

national 19:2 27:2,3,10 

27:12,19 30:12,13 

96:16 

nature 40:3 111:5 

131:15 142:16 176:12 

navigate 6:5 

Navy 23:17 

NEAL 2:20 5:6 13:7 

14:9 15:15,19 17:16 

18:5,16 19:4,19 38:3 

38:6 40:5 42:3,5 

46:10,12 48:11 52:16 

58:2 60:9 61:3,7,16 

61:19 62:1,5 70:19 

73:5 76:4,8,11 77:6 

77:21 104:22 105:22 

106:15 108:10 109:3 

139:13 142:1,19 

150:15 158:13 160:9 

173:14 176:16 

nearly 38:22 

Nebraska 83:15 87:9 

necessarily 41:7,10 

82:1 85:17 125:15 

131:2 132:16 141:20 

154:8 176:22 

necessary 65:17 

necessitated 54:21 

need 4:14 5:5 12:8 14:4 

16:15 23:9 34:17,20 

36:3 37:22 38:22 

40:20 43:5 44:2,17 

45:7 70:9 73:13 77:3 

80:14 90:14 95:21 

98:15 122:8 124:7 

126:7 127:6 129:20 

146:11 152:16 154:8 

157:19 161:3 167:11 

177:14 

needed 32:19 40:15 

56:22 68:17 81:3 

90:16 102:11 154:3 

161:18 

needs 12:4,4 45:9 

126:5 131:20 133:16 

142:6 170:16 

Nevada 79:13 

never 93:8 

new 4:20 8:16,17,19 

10:4,8,9,18,20 12:1 

17:1,7 19:17 23:13,15 

23:16,18 24:1,5 25:1 

25:7 26:16,20 33:16 

35:22 36:1,9 64:22 

65:5,8,12 74:15 79:13 

82:3 98:17 

news 10:2 

NGFA 2:18 14:17 18:2 

85:1 87:21 97:3,21 

99:21 

NGFA's 100:4 

nice 122:17 

NICHOLAS 1:13 

Nick 14:11 15:13 17:17 

17:18 18:5 59:16 60:9 

78:1,18 86:4 88:8 

92:21 94:8 95:11 

96:11,17 97:5,19 98:1 

98:18 99:14 101:6 

135:16 136:21 138:16 

173:21 

nimbly 40:20 

nine 33:13 

no-one 22:7 

nominated 8:21 19:22 

nomination 53:20 77:7 

non 104:12 

non-contract 36:7 

non-export 30:21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
190 

non-profit 18:10 

non-vitreous 63:1 

normal 9:13 

normalcy 16:8 

North 18:1,20 52:6 

83:15 149:14 159:12 

163:11 167:3 

Northern 1:14 159:11 

Northwest 43:1,7 

note 77:1 143:4 

noted 35:15 129:9 

notes 30:4 

nothing's 42:5 

notice 11:6 14:15,22 

56:8 64:5,6 70:22 

106:19 

noticed 7:17 

NQI 162:17 163:14,20 

NRT 48:2 

nuanced 141:4 

nuances 139:10 

number 3:17 44:16 

46:22 47:10,17 49:17 

54:11,13,18 59:9,10 

70:19 80:20 87:5 

115:13 117:6 123:1 

137:8,19 144:6 

145:18 148:2,13 

150:8 151:2 152:6,14 

153:8 154:20 156:19 

159:5 163:10 168:14 

169:9 

numbers 7:2,2 29:4 

37:12 144:13 145:6 

146:14 159:12,14 

167:7,7,9 171:14 

nutrition 12:6 

O

O 4:1 

obligations 29:3,9,12 

29:22 

obvious 164:15 

obviously 37:12 39:7 

96:19 98:12,17 99:1 

99:21,22 103:10 

105:13 122:13 129:16 

132:3 136:16 145:5 

152:21 155:16 165:5 

occurred 83:11 

occurring 80:5 

OCIS 165:21 166:3,14 

166:19,22 167:10,13 

167:17 

October 33:18 36:1 

offer 90:11 164:8 

offered 141:7,8 

offering 41:19 

office 18:11 23:14,14 

23:15,18,19,22 24:1,5 

24:6,16 25:13 31:1 

39:4 43:4 49:11,18 

66:13 71:7 128:13 

officer 2:11 4:21 

Officers 25:9 26:18,21 

offices 8:6 25:2 30:16 

42:14 

official 21:15 29:12 

46:18 54:10,11,15 

56:19 65:3,14,22 

66:11,16,18 67:3 

81:13,16 88:2 95:19 

148:3,6,22 149:13,17 

150:1 155:20 158:8 

158:21 159:5,14 

162:20 163:12,15 

164:7 165:18,21 

168:4,5,13 171:16,20 

172:2,5 

officially 81:14 148:12 

149:1 150:10 162:5 

offline 77:14 

offset 32:6 

oftentimes 85:21 

Ohio 59:1 89:17,18 

oil 54:16 

old 48:20 

older 79:21 

once 67:3 88:16 

one's 142:20 

one-hour 107:10 

one-page 137:14 

ones 68:9 100:15 124:3 

127:17,22 128:2,17 

136:2 

ongoing 49:16 50:22 

open 11:3 12:7 27:9 

72:18 84:2 129:20 

136:17 142:2 147:1 

172:16 

opened 27:13,17 45:18 

151:12 

opening 51:5 

operates 44:13 

operating 29:10 30:16 

31:14,16 33:11,20 

34:6 40:4 48:16 80:13 

operation 40:15 

operational 55:22 

operations 5:22 9:13 

39:1 54:14 

operators 120:11 

opinion 156:10 168:6 

168:11 

opportunities 12:1 

opportunity 17:10 

25:19 45:21 62:12 

82:2 98:4 137:4 

169:14 176:13 177:6 

opposed 146:7 

opposing 112:20 

Ops 89:12 

option 82:7,9,15 132:15 

132:16 133:10,12 

134:1 139:1 158:5,6 

164:13 165:7 

options 80:10 81:8,10 

101:22 114:9 117:3 

118:2 119:12 120:22 

122:2 127:9 128:17 

130:15,21 132:21 

136:20 138:21 153:7 

154:2 158:11 166:16 

171:2 

order 3:2 5:4 11:8,9 

68:18,19 110:17 

112:6,11 132:18 

135:10 138:18 139:15 

139:22 140:7 173:22 

174:21 

orders 113:4 124:7,9 

126:7 127:1 

Oregon 18:11 79:14 

85:14 

organization 19:2 

organizations 15:2 

organize 48:14 

oriented 41:14 

origin 87:13 88:5 91:8 

145:3,14 146:11 

147:4,6 155:18 156:8 

original 129:12 170:11 

originally 84:14 95:13 

148:15 

originates 79:9,11 

Orleans 23:14,15,19 

24:1,5 

ought 89:1 

outside 95:14 156:21 

157:1 

overall 51:22 139:8 

overhaul 131:7 

overhead 30:12 66:10 

overly 129:11 

oversee 69:6 

oversight 36:14 39:4 

overtime 28:1 36:5 

overview 3:8 39:11 

78:14,19 79:6 82:21 

114:8 

P

P 4:1 

p.m 76:14,15 107:16,17 

172:22 173:1 177:22 

pace 21:2,20 

Pacific 43:1,7 172:19 

paid 51:13 56:18 129:7 

pandemic 5:20 9:16 

10:1,6,11 12:19 20:15 

22:1 32:7 40:13,17 

41:8 56:11 

Pandora's 51:5 

paper 88:19 

paragraph 80:1,17 

parameters 118:12 

139:16 

part 18:1 21:19 23:10 

25:20 39:10 40:5 

48:11 60:18 69:7 71:9 

77:10 80:12,12 82:17 

84:20,21 95:12,14 

131:4 138:8,14,17 

145:15 161:1 

participant 21:10 

participate 7:15 8:3 

66:17 

participating 7:19 15:3 

19:3 21:8 66:21 

participation 70:3 

particular 5:10 10:22 

83:4,19 86:15 87:1,2 

94:22 151:15 

particularly 23:8,13 

41:7,11 42:16 43:19 

79:12 87:19 92:14 

partners 44:15 

partnership 42:18 

parts 166:5 

pass 40:17 73:4 

passed 130:3 

passing 89:21 

pat 4:6 42:17 46:21 

49:6 113:15 152:7 

156:6 166:20 

patchwork 87:12 88:6 

89:3 106:5 

pause 13:5 28:4 58:4 

73:8 

pay 78:9 104:9 

paying 149:21 

Pea 48:1 

peaks 112:12 116:14 

peers 19:16 

people 7:14,18 8:11 

16:7 20:7 23:6,10,11 

25:7 38:7 56:20 87:5 

107:19,21 131:5 

144:13 164:9 

percent 21:2 31:17,19 

34:13 35:17 37:18 

38:18,21 115:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
191 

118:17 122:1,3,6,9,10 

123:18,20 144:20 

145:17 152:7,9,15,18 

153:1,3 154:11 

156:21 157:2,2,22 

percentage 37:15 

114:20 

perfect 142:21 

perform 43:4 148:4 

performance 70:7 

performed 59:22 

performing 35:4 160:22 

period 5:19 6:6,21 

38:12 43:19 64:8,9 

75:3 

periodically 34:20 

person 56:16 88:12 

personal 163:16 

personnel 55:17 

perspective 78:13 

82:20 83:10 84:1 

89:14 99:18 101:14 

102:12 104:20 121:8 

137:3 141:4 155:9 

174:6,12 

perspectives 12:17 

15:7 

pertain 108:13 

pertaining 109:8 

phenomenal 95:22 

phrasing 122:17 

physicality 92:13 

pick 166:10,12 

picking 128:2 

picks 124:2,3 125:22 

picture 31:5 

piece 81:4,21 83:3 85:9 

88:19 93:11 111:13 

112:10 120:2,4 

122:14 138:11 155:5 

157:8,20 

pieces 17:21 81:18 

90:17 

piggyback 160:20 

piggybacking 139:19 

pilot 55:18 58:8,13,15 

58:16 68:15 69:20 

70:2,4 

pit 82:5 

pits 93:3 112:18 

place 9:20 16:16 36:13 

41:3 43:1 44:12 56:7 

118:12 160:17 166:8 

placed 50:7 55:1 

Plains 1:14 159:11 

plan 9:20 48:6 55:8 

63:21 66:14 76:4 

114:12 116:2,7 

123:13,19 125:5,7,14 

126:3 128:7 130:13 

planned 40:22 

planning 44:19 

plans 29:5 64:15 114:1 

planting 104:12 

play 21:18 81:9 82:14 

83:20 89:8 117:19 

144:22 158:10 

PLC 60:12 

please 73:7 78:11 168:1 

pleased 43:2 

plus 16:6 80:22 

PMW 151:8 165:14 

169:8,10 

point 4:7 9:2 42:14 60:7 

68:1 81:7 95:22 96:6 

117:16 124:14 126:1 

131:10 137:21 139:14 

147:15 156:10 170:21 

172:18 173:20 

pointing 143:5 

points 13:8 57:18 

118:12 122:16 152:3 

170:12 

policy 49:5 53:11 

115:22 127:13 128:12 

130:21 141:13 153:7 

154:2 170:14 

poll 142:15 

ponder 158:15 

popcorn 113:22 

popping 107:22 

popular 114:18,21 

port 60:1 

portion 30:14 35:18 

52:13 111:20 121:8 

125:7,10,18 

portions 125:13 

Portland 18:10 25:11 

39:4 136:17 143:5 

pose 74:7 

position 9:4 24:16,19 

40:8,11 100:5 101:9 

positions 27:6 

positive 7:1 

possibility 11:5 63:15 

81:12 141:3 

possible 36:11,20 

49:13 57:22 60:22 

66:14 87:20 119:17 

155:4 157:9 

possibly 125:21 130:7 

177:5 

posted 28:21 47:6 

58:19 82:22 105:17 

posts 65:18 

potatoes 141:13 

potential 25:16 95:15 

96:5 141:21 

potentially 68:11 78:17 

81:6,15 103:16 

117:22 139:4 143:11 

161:2,14 

power 158:20 

PPMAB 42:17 

predates 84:7 

predict 41:7 

preference 69:4 

preliminary 70:5 

premium 133:19 

premiums 56:18 

preparation 117:7 

prepare 164:4 

prepared 177:7 

preparing 159:20 

prescriptive 91:11 

present 1:10 2:9 73:2 

presentation 36:18 

100:16 174:4 

presented 68:9 

President 2:18 11:8 

18:19 

presiding 1:8 

press 10:13 

pressing 28:11 73:5 

pressure 149:8 150:12 

150:16,19 153:11 

159:16 162:8 168:8 

prestigious 20:1 

pretty 7:10 12:11 71:3 

90:12,13 91:11 125:1 

130:16 139:17 142:20 

prevent 53:21 

previous 39:22 75:7 

77:15 108:6 151:2 

175:19 

previously 119:5 

price 115:11 155:13,13 

primarily 31:4 96:22 

primary 94:17 105:13 

119:7 136:19 

print 36:21 

prior 175:8 

priorities 65:5 

priority 47:21 97:8 

101:1 

private 12:16 171:22 

proactive 65:4 

probably 6:8 7:19 8:6 

40:9 46:13 51:2 59:13 

60:12 69:4 78:8,9 

81:22 82:7 84:6 104:8 

122:2,7,9,11 129:5 

134:15 136:9 140:6 

151:20 153:12 157:2 

159:19,22 163:14 

164:12 165:2 166:7 

167:2 169:15 

problem 89:7 104:13 

145:16 

problems 104:11 

procedural 101:11,16 

150:5 

procedure 58:16 82:10 

166:6 167:20 

procedures 149:17 

150:14 163:8 164:12 

164:21 166:13 

proceed 44:15,20 

144:18 

process 47:8,12 48:12 

50:1,21 51:1 53:2,20 

55:11 56:13 58:11,18 

65:10,11,13,15,19 

66:3,5 69:7 70:3 72:5 

72:6 74:2 78:13 82:11 

88:6,14 151:15 154:4 

160:16 161:12 174:1 

174:5,12 175:8 

processed 54:17 

procure 167:21 

produce 67:10 68:19 

producer 18:20 69:2 

167:8 

producers 10:10 

149:21 

product 15:11 38:16 

92:14 93:1 133:9 

147:8 

production 68:22 146:3 

program 2:21 9:1 10:22 

19:10,11,16 29:9,12 

29:19,21 30:2,8 31:1 

31:2,14 34:17 36:8 

39:11 44:8 49:19 

55:18 56:8 57:4 58:8 

58:13 82:16 84:9 86:8 

90:6 121:20 130:7 

programs 9:11,16,22 

10:7,8,9,9,16,18 

11:16,21 26:8 30:6 

36:6 55:21 91:8 106:9 

168:16 

progress 72:9 142:5 

project 44:3 51:16,22 

52:4,11 57:6,7 63:5 

63:14 68:16 69:14,20 

70:2,13,15 170:22 

projected 33:17 

projects 70:6 

promising 130:17 

promote 57:4 

pronounces 146:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
192 

proper 83:8 110:5 

164:19 

properly 73:18 83:9 

proposal 41:22 65:21 

111:11 

proposals 98:1 

proposed 29:17 32:22 

35:6,8 64:6 70:21,22 

71:6,19 72:3,4 

protecting 55:16 

protein 110:8 112:15 

117:13 133:1 134:11 

134:19 152:22 154:11 

protocol 150:4 

protocols 16:15 162:7 

provide 6:15 10:10 

11:14 12:10,15,17 

41:19 46:18 51:6 

62:13 64:3 66:19 

81:13 88:2 98:19 

105:2 110:18 137:10 

140:11 

provided 164:14 

providing 22:9 149:22 

provisions 49:16 

public 3:19 11:13 12:8 

27:18 28:22 37:5,5 

87:18 94:13 114:21 

144:4 154:4 172:17 

173:4,6 177:13 

publicly 22:11 23:1 

28:21 58:20 

publish 34:13 39:15 

published 28:20 33:15 

35:12,16 64:5 70:20 

173:15 175:17 

pull 46:7 

pulled 79:3 

pulling 13:15,15 79:5 

152:5 

Pulses 50:10 

pumped 10:3 

purchased 69:4 159:8 

purchasing 82:3 

purple 31:6 

purposes 105:11 

pursue 170:9 

pursuing 100:7 

push 99:12 

push-back 22:7 

pushing 97:2,11 

put 9:20 11:4,7 12:13 

12:20 15:6 16:16 33:1 

48:18,21 56:7 72:4 

75:4 78:17 80:14 82:5 

90:20 94:21 101:18 

109:15 111:19 113:12 

114:19 118:11 121:15 

122:5,7,9 123:18,20 

124:15 134:10 135:2 

140:7 147:7 149:1,3 

157:18 160:2 165:10 

175:9,20 

puts 50:10 

putting 93:2 100:18 

122:3 

PW 39:3 

Q

QACD 26:18 

quality 21:15 22:13 

25:1 26:3,16,17 54:18 

54:18 64:20 113:21 

114:13,17 115:3,9,22 

116:2,6 128:10,16,21 

147:17 

quantifying 62:18 

quantitation 64:2 

quarantine 82:15 84:9 

85:5 90:7 92:1,3 

93:10,14 

quarter 29:1,7 30:7 

question 39:19 58:6,12 

59:17 60:6,16 69:11 

73:9 74:7 78:12 80:12 

82:8 84:6 86:5,7,18 

99:20 101:10 103:1 

104:2 105:19 108:21 

112:22 121:22 137:17 

150:7 151:10 168:3 

171:12 173:7,22 

175:7 

questioning 85:11 

questions 12:22 13:3,5 

13:7,11 14:6,10 15:16 

27:8 28:7 36:17 37:9 

42:8 58:5 62:6 66:2 

67:17 71:14 72:20 

73:1,7 80:8 82:13 

84:3 94:12 103:22 

104:20 135:8,12 

138:20 143:1 169:6 

173:18 

quick 14:11 28:7 34:15 

58:6 99:19 152:5 

160:2 165:22 

quickly 145:18 157:15 

quiet 94:4 98:6 100:20 

100:21 

quite 92:8 112:16 

151:14 159:12 168:13 

quote 110:16 

R

R 4:1 

RA 25:15 

rail-car 59:11,13 

raise 11:1 14:16 76:18 

98:4 133:11 

raised 80:7 95:22 98:8 

100:16 105:1 

raising 96:6 

ramp 8:17 10:21 

ran 27:1 58:12 

range 68:20 125:18 

135:5 145:12 

rapid 21:2 

rapidly 23:9 42:6 

rate 36:5,5,5 

rates 23:8 36:4 56:17 

re- 111:4 116:7 120:3 

128:4 

re-adjust 38:11 

re-appointment 54:1 

re-check 127:17 

re-checking 127:21 

re-engagement 27:17 

re-evaluating 41:14 

re-inspect 125:14 

130:15 132:2 

re-inspecting 125:21 

re-inspection 115:20 

116:3 119:8,9,18 

123:16 125:9 131:1 

132:16 

re-inspections 128:17 

re-run 156:21 

reach 102:9 103:16 

105:20 106:2 

reached 100:12 

reaching 100:19 

reaction 95:8 

read 82:21 126:7 

reading 118:7 137:14 

ready 41:4 113:22 

167:5 177:19 

real 8:10,12 14:11 

24:20 152:5 

reality 50:5 151:4 164:7 

realized 102:17 

realm 141:3 

reason 95:12 118:8 

165:20 

reasonability 160:17 

reasonable 40:7 69:3 

130:19,19 

reasoning 95:15 130:4 

reasons 91:1 110:11 

147:21 

reauthorization 52:20 

53:7,16,21 54:4 55:2 

71:12 

reauthorized 53:13 

recall 9:18 38:19 

receive 48:10 132:13 

158:16 

received 109:16 173:5 

175:19 

receiving 80:4 91:3 

receptive 48:5 

recognition 65:1 

recognize 47:19 167:15 

recognizes 65:7 

recommend 93:13 

107:9 

recommendation 46:20 

49:9 51:7 52:17,19 

54:2,6 55:12 62:9 

71:9 72:12 73:17,20 

73:21 101:20 102:2 

103:12,13,21 105:5 

106:1,11 107:2 109:4 

139:6 141:20 142:5 

144:16 145:15 157:8 

171:5 172:14 

recommendations 3:10 

14:1 28:4 46:3,5,7,14 

73:15,19 75:8,11,12 

75:16 108:8,22 175:9 

175:13 176:12 177:4 

recommended 49:10 

49:14 51:8 175:18 

recommends 52:20 

53:9 54:8 55:20 62:17 

66:8 

reconcile 46:15 

reconsider 74:6 

record 21:5 23:8 76:14 

94:22 107:16 172:22 

177:22 

recovering 41:18 

red 63:2 119:10 120:8 

130:2,14 131:20 

redo 60:18 

redoing 60:17 

reduce 33:20 56:18 

118:2 

reduced 7:20 

reduction 35:19 

reductions 35:18 

redundancy 48:14 

refer 92:22 

referenced 96:18 

referred 85:18 

reflect 155:2 

regarding 39:22 43:12 

49:20 51:7 67:18 68:3 

71:10 73:10 105:11 

105:17 111:12 113:2 

170:12 173:4 

regards 64:16 

Regional 169:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
193 

Register 11:6 14:15,22 

34:12,13 35:7,7,15,20 

35:21,21 41:22 64:5,6 

70:4,21 154:14 

175:18 

registers 29:6 

Registration 31:2 

regular 36:4 38:11 

140:20 

regulations 85:4 88:6 

89:4 

regulatory 2:19 8:22 

18:2 57:11 106:9 

reimbursable 51:15 

reimbursing 51:14 

reinstated 29:16 

reject 130:15 

rejected 130:14 

related 9:16 10:7 11:7 

11:17,22 46:2 72:12 

94:16 

relates 56:1 

relationships 16:20 

releases 120:16 

relief 10:10 11:15,21 

relieved 6:9 

relying 74:20 121:19 

126:19 

remember 34:14 68:2 

83:1 87:2 89:15 97:12 

reminder 4:9 

remove 79:16 

reopen 8:5 

reorganize 49:1 

repealing 99:5 

repeat 145:8 

repeatability 146:13 

replacement 26:5 

report 12:10 58:7 64:3 

69:12 109:2,6 153:3,4 

154:7,19 163:6 

reported 152:17 

reporting 27:19 64:1 

152:20 154:8 155:9 

155:21 

reports 9:12 125:8 

representing 13:17 

request 41:1 111:7,11 

120:3 130:19 134:13 

139:16 161:22 171:18 

requested 102:2 118:3 

139:3,10 

requesting 171:22 

requests 63:22 112:19 

131:11 137:22 139:15 

139:22 140:2 

require 51:11 90:7 

119:12 131:3 142:20 

150:5 155:13 156:8 

161:22 167:16 

required 42:22 80:5 

85:21 99:4 111:19 

147:20 

requirement 55:4 84:22 

102:16 110:9 146:1 

147:19 156:2 161:21 

requirements 40:6 

65:21 85:6 99:6,13 

111:2 114:8 153:12 

154:20 

requires 110:18 142:17 

requiring 7:13 162:12 

Rescue 9:20 

research 18:9 42:18 

43:10 62:17 65:16 

66:8 70:12 

researching 62:15 

reserve 29:10 31:14,16 

32:2,5,16,18,20,21 

33:4,8,11,12,13,20 

34:1,7,16 36:2,3 

reserves 37:19 38:13 

40:4,10,14 

residing 161:16 

resilience 11:17 

resolution 142:7 

resolutions 174:8 

resolve 76:10 

resolved 71:21 

resources 41:3 51:12 

63:15 

respect 6:3 14:2 

respond 40:20 176:13 

responding 11:6 

response 10:6 130:4,10 

responses 64:12,14 

responsibilities 17:14 

responsibility 110:16 

111:22 112:1,9 

124:13,18 126:12 

responsible 73:13 

86:14 88:12 116:10 

rest 76:20 77:12 168:7 

restrict 164:13 

restriction 148:20 

restrictions 57:12 

114:15 

restrictive 116:17,22 

118:18 133:14 

result 56:17 141:22 

143:9 152:18 158:2 

161:6 175:10 

results 59:21 60:2,4 

65:6 67:9,11 147:4,5 

151:2 157:15 158:22 

160:1 

resumed 76:14 107:16 

172:22 

retired 24:8 26:3 27:4 

retirement 24:6 

retiring 25:15 

return 44:10 

returns 44:6 

revenue 29:10 30:1,3 

30:11,20 31:11 38:16 

revenues 29:13 30:13 

review 25:4 29:2 34:20 

36:12 39:14 40:6 

45:22 54:6 55:7,8,9 

71:11 72:13 77:15 

reviewed 39:15 

reviews 26:20 29:5 34:8 

revise 74:19 

revisit 5:10 142:4 

rice 29:19,21 33:7,8 

35:14 47:1 50:9,20 

69:21 

right-hand 31:8 

rightsizing 34:19 42:1 

rippled 39:6 

river 18:12,14 58:17,21 

59:1,3 

road 8:9,13 90:22 142:6 

Robert 1:15 18:17 

Rockies 79:19 82:16 

83:17 

Rocky 79:9,11,12 

role 12:16 19:12 21:17 

27:5 81:9 82:13 89:8 

94:17,18 95:2 

roll- 69:16 

rolled 84:10 

Ron 23:21 

root 71:18 

rotating 27:20 

roughly 23:5 174:14 

round 75:5 

route 158:11 

row 134:14 

RUGGLES 2:21 28:13 

28:17 37:1,6,8,20 

39:13 41:21 42:4 

rule 29:17,18 31:18 

32:22,22 33:2,5 35:6 

35:8,11 71:7,19 72:4 

72:4 

rule- 132:3 

rule-making 70:22 71:6 

109:1,8 

rules 5:4 28:19 70:21 

85:8 89:3 99:3 138:2 

138:9,10 148:18 

162:19 163:5 

run 81:4 109:22 144:19 

145:14,21 146:4,7,11 

146:15 148:14,16 

149:5,18 150:11 

156:8 157:9,11,14,19 

157:22 158:3,7,16 

159:12,19 162:5 

169:3 

running 143:8,14,19 

144:19 145:18 146:2 

150:7 156:17,20 

157:6 171:14 

runs 168:21 

Russell 162:17 

Ruth 49:3 

Ryan 1:14 159:10 

163:10 165:1 167:22 

168:3 

S

S 4:1 

safe 6:14 22:19 23:3 

safeguard 119:17 

safety 2:18 5:22 55:16 

56:1 57:16 

Salina 17:13 

sample 60:2,4 81:19 

152:10 159:20 

sampled 81:14 

samples 52:5,9 60:1 

66:20 67:1,4,5 167:16 

169:2 

sanitary 90:10 

Sanitation 47:4 

sanitizers 32:9 

save 163:19 168:22 

saw 5:12 61:4 151:20 

151:21 

saying 61:19 81:17 

88:19 94:9 97:19 

117:12 

says 102:1 120:21 

128:20 137:17 138:4 

153:17,21 157:22 

SB&B 1:15 18:19 

Scale 31:1 

scalped 79:15 88:4 

scalper 80:14 81:1 82:3 

scalpers 87:6 92:16 

scalping 83:9 92:13 

93:4,18 94:3 

scared 75:1 

scattered 176:21 

scenarios 139:4 

schedule 39:14 48:8 

scheduled 106:22 

173:9 

schedules 27:21 

Science 2:15 31:3 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
194 

64:17 

scope 54:9 70:1,5 

108:14 

Scoular 1:12 17:12,15 

screen 28:14,15 74:18 

78:17 79:22 80:7,14 

82:5 93:2,6 104:1 

109:15 120:6 

screened 79:15 

screener 82:3 

screening 80:5 87:6 

screens 82:5 87:12 

88:17 

se 40:14 

sea 151:7 

season 32:1 41:6 

seasons 41:5 

second 29:1,7 30:7 

46:9,12 53:20 79:3 

80:1 110:7 

Secondly 57:5 

seconds 17:5 152:11 

152:14,19 168:21,22 

secretary 5:3 8:22 

10:20 53:9 54:1 73:10 

74:1,4,8,16,21 75:11 

76:19 77:2,4 95:4 

101:20 103:16 105:13 

106:6,10,10,12,12 

141:21 176:9 

section 30:19 

sector 10:14,15 12:16 

13:18 

secure 11:10 

security 12:6 56:22 

seed 1:16 52:6 112:15 

seeds 52:2 54:16 

seeing 6:1 7:1,5 8:10 

25:12 56:22 68:7 

104:1 107:18 120:11 

121:11 

seek 108:11 

seen 10:12 12:18 45:7 

93:9 107:21 142:14 

selected 19:22 66:20 

128:18 

self- 77:6 

self-impose 140:9 

self-imposed 116:9,16 

124:22 132:15 

self-manage 110:19 

self-nomination 77:5 

self-unloaders 59:4 

selling 113:4 135:21 

semi-hard 63:12 

senate 9:3 

send 87:10 88:15 90:14 

sending 38:20 52:5 

87:5 

senior 27:6 

sense 98:10 139:20 

142:21 146:5 156:12 

sent 36:21 66:20 67:5 

76:22 129:1 130:2 

separate 62:18 

series 10:17 

serve 8:21 13:16 19:22 

53:6,17 

served 19:9 24:7 174:1 

serves 53:2 87:16 

service 1:14 6:11 22:9 

35:3,4 40:16 41:1,19 

42:18 43:10 46:19 

49:12 52:18,22 53:3,8 

54:9 70:12 71:21 

149:21,22 165:21 

service- 41:13 

serviced 22:18 72:1 

services 1:17 6:16 

34:22 35:1 36:15 

37:14 39:9 41:17 50:5 

54:10 55:15 66:19 

148:5 150:2 

servicing 22:2 

serving 19:14 53:22 

session 141:10 

set 4:13 58:3 62:9 90:19 

114:13 116:12 127:18 

128:7 132:21 143:7 

148:17 166:3 174:15 

174:21 

setting 25:3 

setup 165:22 167:13,17 

seven 47:16 

SGS 162:17 163:20 

shake-o- 153:11 

shake-o-matic 144:21 

149:9 162:9 163:16 

163:17 168:9,20 

172:8 

Shane 49:3 

shape 115:6 

share 14:14 17:4 28:14 

42:12 45:16 72:19 

74:3 78:17 83:3 107:7 

119:14 

shared 58:5 60:2,5,11 

62:6 

sharing 37:2 60:7 74:18 

161:12 

She'll 26:13 

shed 84:13 105:10 

sheet 116:17 

shelled 92:5 

shellers 92:5 

shift 43:20 

shifted 32:13 

ship 15:11 42:20 

135:22 141:5 

shipment 86:15 

shipments 86:1 118:14 

129:2 156:18,22 

166:17 

shipped 92:8 93:15 

shipper 110:18 118:19 

128:18 

shipper's 127:16 

shipper-friendly 115:10 

shippers 115:17 138:19 

shipping 80:4 

short 80:8 150:7 

short-term 81:10 82:11 

shortcuts 166:4,5 

shorter 53:1 82:7 176:1 

shortly 56:11 

shout-out 6:18 

show 99:6,9 111:1,21 

119:10 120:21 143:13 

153:6 161:18 

showed 95:1 

shown 143:9,19,21 

shows 143:12 153:22 

156:19 

shutdown 40:12 

shuttle 159:18 

side 22:14,14,15 31:8 

60:16 113:1,15 129:7 

129:19 132:7 133:8 

133:13,19 136:11 

143:20 155:11,18 

160:1 164:3,4 165:3 

171:13,16 

significant 40:13 42:15 

44:6 54:13 74:4 168:6 

silence 177:15 

similar 59:15 62:22 

similarities 135:14 

simple 4:9 131:8 

single 169:12 

Sinner 1:15 18:17,18 

86:4,4 171:11 172:9 

sir 5:6,15 17:16 19:4 

sit 16:14 101:2 

site 56:13 58:19 

site-by- 56:12 

sitting 173:8 

situation 5:10 40:12 

71:18 93:14 110:1 

134:12 138:7 

six 32:17 33:8 34:1 

169:8 

size 10:17 40:19 79:15 

96:4 

sizes 80:7 

sizing 37:12 

skills 20:2 

skipping 168:22 

slated 177:12 

slave 126:18 

sleeping 100:5,11 

slide 33:16 

slow 56:10 59:13 

small 25:8 59:9 71:4 

soft 62:19 63:10 

software 127:9 

soil 18:21 

sold 119:2 

solely 74:20 121:17 

124:18 

solicit 70:3 

solution 66:9 82:11 

126:8 146:9 

solutions 82:19 

solved 61:18 

solving 146:22 

somebody 75:2 78:11 

90:16 95:1 119:11 

145:19 152:1 153:4 

153:18 155:21 165:19 

somebody's 28:9 83:11 

soon 8:13 9:5 23:18 

24:20 26:13 49:8 

124:11 142:13 

sooner 42:10 

sophisticated 56:21 

sorry 17:19,21 91:17 

105:1 133:4 167:22 

171:17 

sort 48:22 59:20 81:12 

81:13 82:10 86:14 

88:3 95:19 114:21 

116:18 129:13 153:20 

161:5 

sorts 6:4 

sounds 76:4 94:15,20 

130:18,19 133:11 

142:19 

South 1:16 83:15 

163:11 

Soy 19:1 

soybean 148:8 

soybeans 51:10 114:19 

115:14 118:9 

space 10:6 22:22 

137:20 

speak 88:9 94:13 

102:19 113:16,20 

speaking 4:10 57:21 

85:15 115:9 151:20 

spearhead 170:17 

Specialist 2:17 

specialists 25:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
195 

specialty 18:22 19:1 

26:11 

specific 81:22 85:7 

110:3 112:19 118:7 

118:16 122:20 134:12 

135:9 138:18,21 

140:17 141:18 142:12 

161:1 167:18 

specifically 15:6 79:10 

85:13 

specifications 68:17 

specs 132:22 

speed 92:17 157:4 

spend 44:12 50:4 131:6 

spending 11:17,22 

50:13 

spent 26:4 84:22 169:7 

spoke 156:6 163:9,10 

spoken 135:10 

spraying 145:10 

spreadsheet 153:20 

spring 55:9 63:2 145:11 

159:13 

square 93:6 

staff 2:16 8:5 22:1,11 

22:12,19,22 23:3,5 

26:15 27:11,13,19 

41:4 43:3,21 44:8 

45:12 51:16 73:2 97:6 

staffing 6:4 23:4 

stages 22:5 57:9 

stakeholders 49:2 

55:16 

stalk 79:16 81:18 90:17 

stalks 90:22 92:6 93:7 

stand 143:15 171:9 

standard 35:9 53:1 93:6 

117:8 152:6,8,22 

154:11,12 158:8 

standardize 139:18 

standardizing 139:21 

standards 45:16,19,21 

46:1 51:11 52:21 55:3 

71:13 113:14 148:11 

149:12 151:16 170:1 

standpoint 23:4 45:3 

57:16 97:10 100:8,10 

100:11 101:2,16 

102:13 103:19 113:6 

113:6,14 118:19 

119:7 120:16 125:20 

127:13,16 129:6 

135:10 143:17 145:21 

157:5,16 170:14 

171:19 

stares 177:15 

start 9:5 25:6 56:11 

59:11,13 76:3 77:17 

77:18 79:6 136:13 

started 52:9 55:11 

71:14 76:17 84:14 

87:4 100:18 119:21 

119:22 125:12 168:13 

177:19 

starting 26:13 33:18 

121:6 151:4 

state 1:16 52:3 85:2,4 

85:13 86:11,19 88:11 

88:13,22 89:18 91:3 

94:1,21 96:22 97:3,5 

100:2,12 112:5 

149:16 162:12 169:10 

state-by-state 84:9,21 

85:7 

state-specific 90:6 

stated 52:19 54:7 119:4 

statement 90:20 93:19 

states 80:4 82:16 83:16 

86:6 87:8,13,16 88:1 

88:5,7 89:4,12 90:7 

91:6,8 92:12 93:14 

96:1 103:3,18 161:5 

statistical 67:8 

status 29:4 

stay 14:7 22:19 25:14 

40:15 

steering 6:13 

stem 39:20 

step 141:16 174:18 

steps 46:15 64:13 67:7 

80:18 101:11 106:4 

154:6 174:7,18 175:4 

stimulus 11:15,21 

stop 5:8 13:1 78:12 

storage 55:13 56:1 

story 128:15 153:15 

Stowage 55:19 56:6,15 

57:8 58:8 

straightforward 125:1 

streamline 43:17 

strengthen 11:10 53:3 

99:5,12 

strides 153:9 

strong 24:2 61:22 

strongly 55:17 

structure 39:22 43:21 

48:16,19 164:18 

structured 177:3 

struggles 145:9 

study 52:1,7,13 60:8,12 

66:17 68:16 99:6,7,8 

studying 55:21 

stuff 4:21 13:22 87:3 

95:18 114:2 115:20 

sub-class 62:20 

subclass 118:6 143:8 

subject 37:13 83:19 

subjective 124:1 

125:22 127:14 

sublot 110:9,14,21 

111:18 112:2 114:22 

116:12 117:10,10,20 

118:9 120:7 122:9 

123:14 125:2,14,17 

133:16 139:8 

sublots 119:6 

submit 139:15 167:6 

submitted 108:15 

109:18 167:16 

subtracted 118:11 

successful 7:10 21:12 

21:13 

successive 53:6 

sudden 159:6 

sufficient 93:3 

summarize 73:15 

summarizing 176:17 

summary 78:16 137:14 

170:11 

summer 35:13 66:6 

72:8 

Summers 2:22 5:13,16 

13:9 15:1,17 

summertime 89:17 

Supervision 32:11,17 

supplied 69:2 

suppliers 68:5 

supplies 32:8 

supply 6:17 11:11,17 

11:19,22 12:12,18 

14:18 68:5,6,12 

136:15 

support 51:9 137:11 

supporting 12:5 23:2 

63:15 81:9 

survey 52:2 54:8 87:10 

surveyor/grading

140:11 

suspend 63:14 

suspended 29:15 

sustain 40:16 

swap 104:14 

swiftly 40:22 41:1 72:6 

system 12:3 18:14 

21:15 25:17 45:3 

46:18 55:19 56:12 

65:3,9,15 66:15 

121:12 124:19 129:13 

134:5 135:15 139:19 

141:19 158:21 162:1 

165:18 

systems 51:8,10,14,22 

58:22 59:19 87:6 

131:9 

T

table 16:15 98:14 

101:12 105:8 109:7 

tabled 98:3 

tag 137:3 

taken 11:12 14:3 27:5 

45:9 106:4 109:3 

113:17 

takes 159:19 160:8 

talk 11:2,21 12:21 13:21 

25:15 28:2,12,19 

29:17 30:4 31:13 

33:15 37:11 39:17 

78:2 90:21 104:5 

127:14 137:10 174:10 

177:14 

talked 20:7 24:8,11 

108:7 150:21 153:14 

164:22 

talking 9:6 27:22 42:13 

81:5 105:3 119:22 

124:3 136:13 152:7 

160:10 175:15,21 

talks 49:9 80:18 

tanks 43:11 

tap 40:14 

targeted 50:12 

task 66:10 

taxes 78:9 

TCK 42:22 

team 6:12,19 18:2 24:3 

42:15,17 43:9 46:21 

49:4 59:19 72:15 

technical 4:8 18:9 

technicians 25:7 

technological 55:21 

technology 2:14 31:2 

43:13,18,21 45:2,2 

55:15 56:2 63:16 

64:17 65:5,12,14,17 

67:19 69:16,19,21 

70:8,14 120:2 130:7 

141:3 

tell 61:3 96:21 

telling 75:12 172:7 

tells 128:14 153:15 

temperature 68:18 

ten 13:1 59:10 66:16 

126:16 159:20 165:9 

168:21,22 

tend 122:19 

tends 133:12 135:9 

136:12 

tens 57:2 117:19 

tenuous 27:14 

term 52:21 53:21,22 

73:21 82:7,15,19 

terms 52:18 53:1,7,8,10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
196 

53:15,18,18 118:16 

152:3 

test 35:3 42:22 43:4 

63:18 64:4,7,17 65:6 

66:14 67:14 144:18 

145:13 148:2,13 

149:18 151:15 153:9 

155:13 156:21 159:20 

162:5 164:8 170:2,4 

tested 58:22 

testing 1:16 31:1 63:20 

65:9 127:10 146:16 

152:8 154:20 155:18 

tests 42:21,22 54:19 

127:15 146:4,7,11,15 

148:4 150:8 161:1 

164:14 170:5 

Texas 79:14 97:4 

thank 4:22 5:15,16 14:5 

14:9 15:13 17:16 18:5 

18:16 19:4,19,19 21:7 

21:11,17 22:11,15,17 

23:1 28:17 37:7 49:6 

62:7 69:9 76:12 77:8 

106:14 107:14 109:9 

135:18 144:2 171:10 

172:20 177:20 

thankful 20:20 23:21 

24:2 43:8 

thanks 5:10 14:12 

15:19 19:3 28:6 48:11 

52:16 58:2 60:14 

70:19 137:2 152:4 

172:9 175:6 

that'd 109:15 

they'd 51:2 75:22 107:7 

things 7:16 10:14 13:14 

15:6 16:19 20:19 

24:10 27:14 28:2,3 

32:9 38:6 40:3 41:15 

43:18 44:2,18 60:17 

62:4 89:19 90:12 

91:10 115:21 116:18 

123:13 124:5 125:21 

131:14 137:2 139:18 

143:7 145:1 148:21 

149:1 156:10 160:20 

165:18 170:2 175:15 

176:4,12 

third 51:17 52:7,8 80:1 

thought 70:3 85:10 

90:3 98:3 120:1 

127:17 140:4 169:15 

thoughts 65:19 70:6 

94:15 95:15 113:7 

155:19 176:9 

thousand 57:1 

thousands 7:12 57:2 

three 47:5 48:4 80:21 

101:22 123:1 142:12 

174:2 175:15,16,20 

three-hour 106:20 

three-year 51:21 

thriving 21:1 

throw 91:9 124:12 

169:17 

tight 27:18 

tighten 117:15 131:13 

131:16 

tightened 25:6 134:10 

tighter 132:19,22 

156:10 

timeline 69:15 

timely 71:22 149:22 

160:4 

times 48:4 116:21 

147:16 156:19 157:1 

timing 146:8 

today 5:18 16:2 45:5 

77:13 80:22 105:5 

132:10 164:22 173:19 

174:3,16 

today's 105:3 

told 140:7 172:4 

tolerance 117:15 

134:11 135:4 

tolerances 110:3 114:1 

118:2 

tomorrow 76:20 105:6 

105:7 169:14 173:16 

173:16 174:11,14,15 

175:5 

tomorrow's 77:16 

141:10 

tonnage 30:14,15,17 

31:7,8,9 32:11,13 

120:10 

tons 31:7 32:15 

Tony 42:15 43:11 46:21 

47:11 48:11 51:19 

52:16 56:4 58:2,7,22 

59:6,18 89:10 95:21 

113:14 125:4 126:20 

143:18 147:21 150:15 

154:18 157:20 163:20 

168:1 170:11 

Tony's 123:15 149:3 

156:10 

top 28:9 56:16 87:3 

topic 12:11 64:22 78:14 

83:5,13 102:3 108:9 

108:11 144:5 151:13 

151:18,20 156:5 

169:6 173:3,15 

topics 75:14 77:20 

107:4 108:6 169:9 

174:7,9 175:3 177:8 

177:13 

total 38:20 

touch 45:8 60:13 

touching 29:20 

touchy 37:13 

tough 48:15 133:7 

track 13:10 14:8 99:16 

124:17 

trade 10:13 14:20 100:8 

100:9 118:16 140:15 

traded 122:22 

traders 102:10 

traditional 114:12 

trail 165:6 

train 23:11 24:22 85:20 

92:15,18 146:6 167:6 

167:11 

trained 21:21 43:3 

training 18:10 25:5 

64:21 

trains 93:10 159:18 

transaction 162:4 

transfer 10:14 

transform 12:3 

transit 85:19 

transition 24:20 25:12 

transitioned 23:16 

transitions 25:11 

transparency 42:7 

transportation 6:4 26:8 

travel 7:14 16:11 32:7 

traveling 7:15 

tremendous 7:4 9:14 

trials 155:7 

trickier 32:15 

trickled 37:14 

tried 57:20 

trigger 31:17 122:15 

triple 92:22 

trouble 154:1 

truck 166:2 

truth 172:7 

try 4:10 25:4 28:2 48:6 

48:7 57:22 76:10 

101:19 115:18 116:5 

126:6 136:3 141:17 

155:1,3 156:1 158:20 

169:19,22 176:5 

trying 40:3,10 42:20 

48:22 50:15,17 51:3 

57:9 71:4,16 74:16 

92:22 102:19 108:2 

114:7 118:1,13,19,20 

122:14 124:17 129:11 

131:13 133:4 160:12 

160:13,14 175:3 

176:17 

TSD 66:10 153:10 

tube 145:19,22 146:10 

146:10 147:19 149:7 

149:20 150:5,15 

156:17,20 157:3,7,7,9 

157:11 158:17 159:14 

159:15 160:5,6 163:7 

163:19 165:7 166:18 

168:6,10 

tubes 146:2 150:11 

155:14 156:17 157:1 

157:14,19 158:3,8 

162:8 168:11 172:8 

turn 5:1,15 28:5 62:9 

turned 147:7 

TURNIPSEED 1:16 

60:15 61:5,12,17,21 

62:3 76:21 104:3 

turnover 23:12 

tutorials 60:20 61:6 

two 9:22 10:4,4 13:20 

32:4 35:17 63:5 73:19 

104:17 112:15 120:22 

123:1 137:1 142:12 

142:13 145:19,22 

146:2,4,10 150:11,15 

155:14 156:17,20 

157:1,7,9,14,19 158:3 

158:7,8 159:14 160:6 

162:8 163:7 168:11 

169:2 172:8 174:14 

type 24:20 34:22 44:3,3 

45:4,8 68:19,20 70:2 

90:10 99:11 116:12 

131:3 150:20 158:21 

typed 74:19 

types 70:6 139:16 

166:17 

typical 112:17 

typically 42:22 110:2 

115:1 130:11 133:18 

typing 168:17 

U

U.S 1:1 

UAV 56:2 

umbrella 106:8 

unanswered 66:2 

understand 5:21 40:8 

41:4 68:21 78:6 88:15 

93:5 121:17 122:14 

126:10 132:1,6 134:3 

140:15 146:1 155:17 

understanding 59:22 

68:14 70:15 86:2,19 

111:18 139:9 

understands 131:15 

133:7 161:14 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
197 

Understood 106:14 

unfortunate 41:17 

unfortunately 53:12 

140:13 

uniformity 150:21 

unique 5:19 68:22 

unit 30:20 146:6 

United 1:15 126:17 

university 1:16 99:8 

104:4 

unloading 121:5 

unnecessary 50:15 

unofficial 140:6 156:2 

159:5,15 161:18,19 

162:11,16 163:3,13 

172:6 

unofficially 149:2,5 

150:8 154:19 162:14 

164:8 

unquote 110:16 

update 3:10 8:15 14:14 

25:8 45:15 46:21 

47:12 52:14 54:22 

56:4 63:3 64:4 71:5 

72:11 84:1 108:9 

109:7 131:3 

updated 47:1,6,19 72:7 

updates 3:6 4:17 20:9 

28:3 45:13,14 51:6,18 

58:3 62:9,13 108:6 

155:7 

updating 48:12 

upfront 90:11 

upper 135:5 

upstairs 18:11 

upwards 80:19 

urges 63:19 65:3 

USDA 8:16 43:20 49:18 

51:5,9 72:5 176:19 

USDA's 70:11 

use 6:10 38:13 47:7 

56:14 59:7 61:14 

66:14 68:15 116:13 

122:20 123:19 127:10 

149:9 150:2 155:14 

156:14 159:16 163:17 

164:11,19 166:11 

172:8,8 

useful 49:1 

user 29:2 

user-fee 50:2 

users 49:2 64:17 

uses 36:1 

USGSA 49:16 53:7,12 

54:4 55:6 108:14 

109:5 154:9,21 156:7 

156:12,13 164:16 

170:3,3,6,9 

usually 86:19 110:1 

120:22 175:9 

Utah 79:14 

utilization 52:22 111:12 

V

vaccines 7:2 

validated 170:7 

validating 170:5 

validity 93:19 

valleys 116:15 

value 13:19 65:8 75:15 

116:12 134:19 

Vanfossan 27:5 

variability 11:18 

variation 63:20 151:5 

variety 9:15 

various 85:2 86:20,21 

89:12 100:2 103:10 

118:11 120:9 170:1 

varying 161:4 

vein 106:13 

versus 51:5 63:1 

111:13 118:17 123:12 

138:2 139:3 140:19 

146:10 147:6 151:6 

154:21 155:20 168:9 

168:10 176:8 

vessel 55:13 56:1 57:7 

57:13 85:21 114:10 

121:6 147:8 

vessels 134:20 

viability 63:4 

Vice 2:18 

Vice-Chair 1:8 

video 17:19 78:7 

Video/teleconference

1:8 

videos 107:21 

view 143:20 

viewing 143:22 

viewpoint 128:1 

virtual 7:9,11,17,22 8:8 

virtually 5:18 

visit 166:20 

vitreousness 70:13 

voice 25:18 78:6,10 

volume 166:2 

volumes 40:2 

volunteer 75:2 

volunteered 66:16 

volunteering 74:8 

volunteers 5:3 74:8 

vote 9:3 77:4 

W

Wadyko 24:7 

wait 173:16 

waiting 9:3 24:17 52:10 

165:9 

walk 165:6 

wanted 46:15 83:3 

86:13 103:11 171:7 

wanting 166:9 

wants 8:3 86:3 152:1 

153:4 

Washington 8:11 79:14 

85:14 97:4 169:10 

wasn't 80:5,6 151:14 

watch 113:3 121:9 

watched 110:6 

watching 10:13 121:11 

water 128:15 

way 4:9 8:3 15:10 16:19 

23:2 24:12 43:17 

59:11 77:13 112:5 

138:5 140:21 145:19 

148:6 152:13 156:8 

161:13,20,20 162:12 

164:5,13 166:9 

167:12 170:7 

ways 86:22 

WC 132:7 

wear 162:21 

website 28:21,22,22 

37:5 47:7 48:13 60:17 

83:1 

websites 48:21 

WEDNESDAY 1:5 

weed 52:2 

weeds 131:19 

week 166:21 

weeks 10:19 11:7 16:5 

20:8 24:17 26:6 

weighing 22:14 29:8 

30:8 31:6 49:12 50:5 

50:8,19 127:10 

Weights 18:3 19:14 

100:17 

welcome 3:2 8:16 14:14 

17:1,17 37:8 56:14 

84:19 144:10 173:2 

well-thought 176:8 

went 37:18 41:11 76:14 

107:16 117:6 156:22 

172:22 177:21 

weren't 15:4 83:8 130:5 

west 59:5 79:12,18 

82:16 83:16 84:12 

92:11 102:18 177:18 

western 89:4 90:6 91:6 

112:17 122:8 

Whalen 26:7 

whatnot 142:5 

wheat 1:12 18:8,13 

42:19,20 43:2,4,5,10 

45:19,20 62:16,19 

63:2 69:22 70:13 

110:2 122:21 135:19 

136:1,6 141:5 145:9 

152:21 154:10 158:16 

159:13 163:18 

wheats 145:10,11,11 

whereabouts 72:7 

whichever 170:16 

white 12:10 27:16 118:4 

118:10 121:22 122:8 

145:9 

whoever's 162:3 

wide 12:7 119:16 

wildly 60:11 

Williams 1:17 19:5,6,8 

88:8,9 105:16,22 

willing 14:5 

windows 131:13 

winter 145:10,11 

wonder 147:18 

wondered 135:22 136:5 

wondering 117:14 

word 6:9 110:5 124:11 

133:13 150:14 157:14 

word-for- 150:13 

wording 75:10 77:15 

words 47:12 170:13 

work 6:19,20 9:13 10:6 

12:8 17:12 19:8 22:5 

22:12 24:12,13,14 

27:19 31:3 42:15 

45:17 46:1 51:16,17 

70:1 82:9 100:2 104:4 

106:5 116:4 119:13 

122:6 129:17 142:18 

153:10 155:3 156:1 

work-plan 36:9 

worked 22:10 46:20 

117:21 

workers 15:10 

workforce 6:1 12:5 

21:21,22 40:20 

working 9:10,14 14:21 

17:19 19:15 21:6 

22:22 23:17 33:1,5 

47:9 49:2 56:20 70:12 

88:10 100:18 131:6 

workplace 57:14 

works 48:3 115:5,16 

121:13 141:14 

world 8:10,12 20:12 

26:12 45:5 

worlds 115:3,18 

worms 136:13 

wouldn't 86:7 122:5 

Wow 175:22 

wrapped 42:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
198 

write-up 78:16 109:15 

written 124:8 

wrong 97:5 145:20 

WSDA 39:6,8,12,21 

41:5 111:19 112:3 

120:15 126:14 130:3 

171:20 

WSDA's 40:8 

X

Y

year 7:12 9:19 12:9,10 

15:9,12 21:3,3,4,5 

25:11 27:4 29:7 31:9 

32:2,3,18 33:10 34:7 

34:11 35:9,17,18 

38:17,18,18 40:13 

47:1,17,18 51:17 52:7 

52:8 57:6 64:9 70:20 

88:16,19 134:18 

168:14 

year-and-a-half 145:2,3 

years 19:11 20:5 24:8 

26:5,9 38:8 40:1 48:7 

61:1 63:5 80:21 83:12 

90:3 97:13 99:10 

160:21 169:8 

yellow 115:14 131:21 

yesterday 117:6,19 

yield 44:6 

yielded 158:21 

you- 5:17 12:15 13:9,13 

you-all 5:21 6:8,20 8:13 

11:5 13:17,19 14:3 

15:8 19:20,21 71:2,10 

72:19 105:1,4 106:1 

154:6 171:6 

young 26:6 

Z

zero 7:3 115:15 152:13 

zone 106:20 

Zoom 4:5 74:17 78:8 

102:8 

0

1

1.1 30:3 

1.2 34:1 

1.4 30:1 

1:00 172:19 

1:15 107:1 

1:25 106:22 

1:26 107:16 

10 31:16 122:9 152:15 

10.2 152:18 

100 118:17 167:7 

1000 151:6 

109 3:15 

11 19:11 

11:00 1:8 4:2 177:17 

110 165:8 

115 146:6,7 

12 1:5 152:22 153:3 

154:11 

12:25 107:22 

12:27 107:22 

12:30 76:14 

12:45 76:7 

12:49 76:15 

12119 35:7 

13.4 31:15 

13.5 117:20 134:13 

13.7 110:22 111:20 

13.8 110:10,14 111:3,18 

112:2,7,8 134:13,15 

13.8s 134:14 

14 32:20 134:16 144:20 

145:16 152:6,9,11,16 

157:22 

14.0 110:8,20 112:6,9 

117:18 

14.1 134:16 

140 31:10 

144 3:17 

1475 34:13 

15-minute 75:20 

15-minutes 76:3 

15.8 31:22 

15s 135:2 

16 66:17 

169,000 34:6 

17 172:19 

17-minute 172:15 

173 3:19 

175,000 80:20 

177 3:21 

18 55:5 58:13 119:21 

18-months 144:12 

19 151:21 

1976 54:12 

1st 34:10 35:10 36:1 

2

2 32:20 47:3 115:13 

2.9 29:22 33:9,10 

2:25 107:13 

2:26 107:17 

20 3:6 17:5 26:10 32:16 

34:2 35:17 99:10 

123:20 153:21 167:7 

175:12 

20.2 29:10 

200,000 80:20 

2000 151:4 

2016 21:5 

2018 79:22 83:6 89:16 

95:14 99:22 

2019 56:9 109:1 150:20 

151:19 153:10 168:14 

2020 29:15 47:1,6 52:20 

53:7,13 64:7 

2021 1:5 29:8 31:21 

33:18 47:8,13 

2022 55:10 

20476 35:22 

21 34:2 35:19 

22 35:20 

22.6 29:9 

225 166:13 

24 58:14 

24-hour 75:3 

24th 26:14 

25 122:1,3,10 123:19 

250 163:18 166:10 

28 3:8 26:9 

292 152:11 

2nd 35:6 

3

3 47:3 

3.4 31:12 

3:43 172:22 

30 26:4 

30-day 64:8 

300 145:10,12 

305 152:18 

31st 29:15 

320 153:22 

340 152:14 

4

4 3:2 

4.6 33:12 

4:00 172:16,20 

4:01 173:1 

4:07 177:22 

42.1 31:11 

43 24:8 

45 3:10 75:19 

474 29:13 

5

5 3:4 31:17,19 34:13 

37:17 123:18 156:21 

157:1,2 

50 92:18 147:14 

500 23:5 150:22 

55 49:14,20 50:1,4,6,7 

58 107:19 

580 50:21 

6

60 21:2 92:18 147:15 

65 146:8 

7

7.3 32:3 

7.6 29:11 

70,000 92:18 

78 3:12 

8

8:00 177:17 

824,000 32:19 

86 34:12 35:7,21 

889,0000 29:13 

8th 34:11 

9

9:45 76:6 

90 16:6 

903,000 32:17 

90s 154:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
 

199

C E R T I F I C A T E 

This is to certify that the foregoing transcript 

In the matter of: Grain Inspection Advisory Committee

Before: USDA

Date: 05-12-21

Place: teleconference

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

-----------------------

Court Reporter 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com