DeNtP,r SMIIH, EsQ.

64 Main Street P.O. Box 801

MontPelier, VT 05601

(802)229-6661 phone dsmj!þ(ù:1a\1vg\\1\t21$-L'e!a email

Mr. Paul KYburz

Federal Order # 30 Market Administrator

4570 West 77th Street, Súite ztO

Minneapolis, MN 55435-5037

May 4,2009

Dear Mr. KYburz.

The Maine Dairy Industry Association (MDIA) submitted Proposal No' 18 inthe class

III and IV price trearingsîeld in ZOOZ and offeied data, views and arguments in its

supporr at the Pittsburih, PA session of the hearing, July 9-1 1,2007 (tr' pp' 2593-2745)'

Your office generously provided data for the Federal order # 30 marketing area that

helped illumìnate our proposal, and we are grateful for that.

However, a number of questions arose at the hearing about data that would expand the

understanding of interested parties about the proposãl and its effects' These data were not

available to MDIA prior to the hearing'

We hereby request that your office assist us assembling data that is available to you' but

not to us. This information could then be used to inform interested parties, who could

then further evaluate our proposal.

I-Iere is a list of the information that was identified at the hearing that woulcl be useful,

but we were not able to Provide:

lvlore complef,g o€rlnluurl u.r luç su'rl'eulrv v pr rvv """

ch a significant amount of

äñili;r i.¡r pÃ¿"cer milk took place. 'we chose to measure this by selecting

, r rr----c-l^Ll .i-'lo ;u||,i;;ilïrti.ír irr" regulated pur"hur"r, of milk represented a Herfindahl index

of .33 or less. A Herfindãhl index is obtailed by squàring the market shares of

eách of the participants in the market, in this case a county, and then summing

them. For example, a Herfindahl index of .33 represents represents a minimum of

three equal-sizeã competitors. Market shares wcre based on milk volume' not on

the number of Producers.

Unfortunately, we only had data for the Upper Midwest market' Please make your

best efforts to collcct ,irnilul. data for the milk procurement areas for all Federal

milk orders. Specifically, we would like to identify all the counties in the nation in

which three or more, foui ot more and five or more handlers regulated by any

F-ederal order purchase milk during a representative month, such as the most

recent December or May for which dataare available'

he t' itive We identified the
ln addition, we would like to identify all the counties for which a Herfindahl

index of .25 or less, .33 or less, an¿ 'S0 or less can be calculated'

Each of tl.rese definitions: three or more handlers competing, four 9t Tott^ ^-

handlers competing;fi;; ";;"re handlers competing, Flerfindahl index of '25 or

less, Flerfinclalrl indlx of .33 or less, ancl Herfinclail lndex of '50 or less' could be

considered an alternative "competitive price zoîe" '

2.

:tlïi1:Tpetitive ffir"*;;t ;"pä".u,i"" of the national T?tk:t f"î ltll Ït::]:1y ä:,äí#;;;. ä;;i"e this, but it is possible- to calculate the proportion or

,.,: - - ---! ^^ -^^¿ ilïä;"i'riri. *ä"r r"pprv of milk repiesented bv t!"-competitivg Pricezone'

both in total and by:t"t". V/ä request thåt once each of the competitive price

zones has been determined in (1), above, that the milk included in that

competitive price ron" U" ¿iviàé¿ by the total federal order milk in each state and

in total.

milk . Concern was

/s/ Paul Christ

Paul Christ

;îäääiã îot accurately reflect geogåp'hic dilferénces in the value of

¿^ *^-1.^+^ ^lnop tn ä;;;f;;;ri"g -iil. This concern was "tp""iaty 

relevant to markets close to

California.

While we cannot predict the variation that would exist if our proposal was

adopted, it is possible to measure the amount of producer price variation that

exists today. we request that you and the other market administrators compile

weighted average pay prices to producers by state, net ofthe current producer

price differ"ntiã., to ,,'"urur" th. residual manufacturing value of milk' This

would proviáe "uíd"n"" 

of "*isting 

differences in the mãnufacturing value of milk

in different Parts of the countrY'

As we have discussed, we would like similar data for milk that is not Federally

regulated, such as in Iáaho or California. We realizethat you do not collect such data'

and are working to gather that data on our own. We will keep you informed about our

progrcss with this effort.

Thank you for your consideration of this request'

Sincerely,

/s/ Daniel Smith

Daniel Smith

on behalf of MDIA