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 UNITED STATES DEPARTMENT OF AGRICULTURE

 Grain Inspection Advisory

Committee Meeting

+ + + + +

 Wednesday, August 30, 2023

8:30 a.m.

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 USDA AMS FGIS

 10383 N Ambassador Drive

 Kansas City, MO 64153 

PRESENT: 

Barbara Grove, Chair

Arthur Neal, Deputy Administrator

Denise Ruggles, Executive Program Analyst

Karla Whalen, Director - Quality Assurance &

Compliance Division

Charles Parr, Acting Director - Field

Management Division

Dr. Ed Jhee, Director - Technology &

Science Division 

Dr. Charles Hurburgh

Charles Bird 

Philip Garcia

Christopher Frederking

Robert Sinner 

Janice Cooper

John Morgan

Shayleen Rambur

Nicholas Friant

Kia Adams-Mikesh 

Jimmy Williams

Mark Heil

Curtis Engel 

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 CONTENTS 

Call to Order. . . . . . . . . . . . . . . . . . . 3 

Call to Order. . . . . . . . . . . . . . . . . . . 3 

FGIS Program Updates

Arthur Neal, Deputy Administrator. . . . . . . . . 8

Karla Whalen, Director, Quality Assurance

& Compliance Division. . . . . . . . . . . .26

Charles Parr, Acting Director, Field

Management Division. . . . . . . . . . . . .40

Byron Reilly, Director, International

Affairs Division . . . . . . . . . . . . . .48 

Dr. Ed Jhee, Director, Technology and

Science Division . . . . . . . . . . . . . .59 

Discuss Industry Issues. . . . . . . . . . . . . .81 

Public Comments. . . . . . . . . . . . . . . . . 276 

Wrap-Up Discussion . . . . . . . . . . . . . . . 252 

Adjourn 

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P-R-O-C-E-E-D-I-N-G-S

 (8:30 a.m.)

 CHAIR GROVE: It is 8:30 and we are 

going to head -- go ahead and call our meeting to 

order.

 I want to welcome everybody here, the 

Committee. We've got a lot of people online, so 

that's really awesome. It's great that we can 

utilize technology to have more people involved 

with us. We do have one committee member online 

also. And again, welcome to everybody in the 

gallery. Appreciate you being here.

 I'm going to start off with roll call. 

And what I would like everybody to do is state 

your name as we go around the table. All right. 

And I will start with you, Dr. Charlie.

 DR. HURBURGH: Charlie Hurburgh. Oh, 

sorry. Too much technology. Charlie Hurburgh, 

Iowa State University. I run the grain extension 

program at Iowa State University. And won't tell 

you how long I've been at Iowa State, 'cause then 

I'll date myself. But thank you for inviting me 

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to come.

 MR. BIRD: Chuck Bird, Neogen 

Corporation. Been with Neogen 37 years and help 

represent the technology around mycotoxin testing 

and other technology.

 MR. GARCIA: Phillip Garcia with the 

Washington State Department of Ag.

 MR. FREDERKING: Chris Frederking, 

general manager at Zen-Noh Grain Corporation, 

here representing exporters.

 MR. SINNER: Bob Sinner, SB&B Foods 

North Dakota, representing container industry and 

producer.

 MS. COOPER: Janice Cooper, formerly 

of the Wheat Marketing Center, now in California.

 MR. MORGAN: John Morgan with Supreme 

Rice in Crowley, Louisiana. I'm representing the 

rice industry.

 MS. RAMBUR: Shay Rambur, JD Heiskell 

& Company.

 MR. FRIANT: Nick Friant, Cargill, 

representing exporters, domestic and GFA -- grain 

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industry.

 MS. MIKESH: Kia Mikesh with North 

Dakota Grain Inspection, representing official 

agencies and the American Association of Grain 

Inspection and Weighing Agencies.

 MR. WILLIAMS: Jimmy Williams, 

Missouri Department of Agriculture.

 MR. HEIL: Mark Heil. I'm with 

Prairie Central Cooperative in Chenoa, Illinois, 

and we're a grain -- local grain elevator 

cooperative that loads shuttle trains of corn and 

soybeans.

 MR. ENGEL: Curt Engel, Northridge and 

Hills, Texas. I'm retired from The Scoular 

Company.

 CHAIR GROVE: I'm Barbara Grove, 

chairing this committee, and I work for Central 

Valley Ag, a locally owned cooperative in Kansas, 

Nebraska, Iowa, and South Dakota. And I'm 

representing NGFA, GEAPS, and the inland market 

of our industry.

 And Curt -- Dr. Curt if you are able 

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to unmute online and introduce yourself.

 Actually, I'm not sure I see Curt's 

name online, so when he comes on, you just go 

ahead and let us know. We do have a quorum to 

complete our business today. Thank you all for 

being here.

 A few quick clean-up items, or meeting 

protocol items. As we just heard one, please 

make sure you have your cell phones shut off, in 

silent mode. That way we aren't interrupting the 

proceedings today.

 Also, if you happen to -- we all know 

our businesses do go on, so if you have to take a 

call, please don't answer it till you have 

stepped out, cleared the -- the closed door. 

That way, again, you aren't interrupting the 

meeting. And this is a public forum. It is 

being recorded, so somebody else talking may --

may just kind of put a little bit of a mess in 

what -- what we're trying to do here and what 

should be on public record.

 During the meeting today, again, 

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everybody is part of the Committee. Obviously, 

we will be using our mics, so please press your 

mic. The red will come on when you are live. 

And then when you are done, make sure to click it 

off so that it doesn't disrupt somebody else 

being able to talk.

 Those that have joined us online, 

again, thank you. You can put in the chat to the 

National Grain Center if you have a question or 

comment. And I will try to watch the comments, 

or they will make sure to signal me that there is 

somebody online. And if it is an appropriate 

time, we may let them unmute you to ask your 

question verbally, or we will handle it through 

the chat.

 Those of you that are in the gallery. 

We do have a public comment section at the end. 

But if you have something that is very relevant 

to the conversation or a topic and you would like 

to comment, please raise your hand and until 

addressed to be given the floor, please hold off. 

But come over to the mic. We don't have our mic 

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there yet? Okay. We will have a mic there. And 

when you come to the mic, please state your name, 

and please spell it for the record, and who you 

are representing. And then proceed with your 

comment or question after you've been given the 

floor.

 So this morning, we are going to go 

ahead and start our agenda with FGIS program 

updates. So Arthur if you would like to go ahead 

and lead us off.

 And I will, again, any speaker today, 

please make sure to state your name and your 

purpose, or who you're representing for the 

record.

 MR. NEAL: Good morning everyone. 

It's good to see you. It's been since December 

we've last gathered together. Some of us have 

been running into each other in different 

meetings and conferences, and so it's good to be 

back here at the National Grain Center for 

another Grain Inspection Advisory Committee 

meeting. Our goal was to have two meetings this 

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year. We'll see what happens. But for this 

meeting we are grateful because we do have some 

business to attend to.

 Want to get right into it with FGIS 

updates. I'm going to kind of kick it off with 

updates regarding Grain Inspection Advisory 

Committee recommendations, as well as some other 

general activities that are happening in the 

program.

 One of the things that has transpired 

since we've last gathered is that we've published 

a review on geographic boundaries. It was one of 

the recommendations that came from the -- the 

Committee back in 2022. And it's birthed out of 

the U.S. Grain Standards Reauthorization Act.

 And so we've completed this by taking 

a look at all the geographic boundaries that --

under which all of our official agencies operate 

and provide service. To ensure or assess whether 

or not any changes need to -- needed to be made 

to boundaries and how we're facilitating the 

review, and the assignment of those boundaries. 

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One of the things we've also done as 

a result of this particular report. We published 

an online map that identifies where each official 

agency is operating their territory, as well as, 

you know, some of the customers that they serve. 

Not all, but some. Based on the data that we 

have available to us.

 Another recommendation that we've 

closed out is we've published a final rule 

regarding soybeans of other colors. I think 

everybody's aware that over the past several 

years -- well, over the past year and a half, 

rather, we've had a presence upsurge, in the 

presence of soybeans of other colors.

 Didn't quite know how to deal with it 

in the immediate presence of it. However, we 

worked collaboratively with the Grain Inspection 

Advisory Committee, as well as the industry, to 

figure out a path forward on how do we address 

this occurrence, such that it does not impact the 

grade of soybeans and contracts that have already 

been established. And so what we've done is 

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we've removed soybeans of other colors as a 

grading -- official grading factor for yellow 

soybeans. It remains a criteria that can be 

requested and evaluated upon request by the 

customer. But it allows us to still trade our 

soybeans without them being impacted by this 

factor. Until it crosses the threshold of 10 

percent, which it becomes mixed soybeans. And so 

that becomes effective tomorrow. We wanted to 

make sure that we got that completed before this 

year's harvest. Is it tomorrow? No. On Friday. 

Sorry. I'm thinking today's the 31st. On 

Friday.

 So this has been closed out. We're 

going to be working with Foreign Agricultural 

Service to ensure that they've got all of the 

attaches fully up to date on the changes that 

have been made in case any countries have any 

questions. And Byron will probably provide some 

updates. 'Cause we have had some conversations 

with countries like Indonesia, just wanting to 

make sure that this change will not affect them 

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if they buy a lot of food grade soybeans. But to 

date, we've heard no concerns about the changes 

that have been made.

 We also published a final rule that 

changes how, or clarifies how we make decisions 

regarding requests for exceptions to geographic 

boundaries. This has been a longstanding issue 

from what I understand. And when I came in in 

2019, this is one of the first issues that was 

brought to me.

 It took us a minute to figure out what 

was the problem. But I think we figured out what 

was the problem. I think it was transparency. 

How do we understand the process works. And so 

what we've done is we've built a process that --

that specifies when official agencies, when 

customers can request changes to their 

boundaries. And so this rule does that. Carla 

will probably share a little bit more about that 

in her updates from the Quality Assurance and 

Compliance Division. That rule became effective 

August 1st. 

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The directive on FDA action levels. 

This is another issue that came to us in 2019. 

Kind of took us a minute to figure out the right 

approach, and then the various impacts of it. 

I'm happy to say that we're making progress. I 

think the last conversation we had with industry 

about this was in end of May of this year. And 

FDA was present for our exporter meeting down in 

New Orleans in terms of virtually. They were 

virtually present.

 And Barry Gomoll, who's been the point 

of contact for FDA, has been working very closely 

with -- with -- he's a point of contact for FGIS. 

He's been working closely with FDA on this issue. 

And we're hoping to have a draft directive on 

this updated, probably by the end of this month, 

early next month that we can begin reviewing.

 The finalization of that draft may 

take us a little while. But we'll be consulting 

with you all as we get it in our hands, so that 

we can see if we can kind of take this down the 

road further, close it out, and have a little bit 

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more clarity around how we will deal with issues 

like animal filth being called in in lots, 

response times. If we've had any flexibility on 

preapproved methods to remediating those before 

we have to engage with FDA, just to try to 

streamline the process, make it more efficient. 

So I -- I consider that progress since May of 

this year.

 There was a recommendation also from 

the Committee regarding the user fee cap that's 

been placed on the Federal Grain Inspection 

Service. For every annual appropriation that we 

receive, there's a cap put on our collective user 

fee line items. That's our grain. That's our 

rice. That's our commodities, and our 

supervision account from our official agencies. 

And that cap says -- or the language says that 

FGIS cannot spend more than $55 million of its 

user fees.

 What we have done with respect to 

this, we've made a formal request to Congress to 

adjust this language to only connect it to our 

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user fees collected from our grain activities. 

Instead of all of our user fee activities, 

including rice and commodities. And what that 

would do is give us the opportunity -- not that 

we're spending at this level -- but it does not 

unnecessarily include activities that -- that 

don't have anything to do with grain.

 We've also asked that the cap be 

lifted to $60 million. Not sure if it's going to 

be accepted. One of the reasons why we need to 

have this cap modified -- part of our discussion 

today is going to around the budget and fees. If 

we -- right now, FGIS is not collecting the 

revenue that it needs to cover all of its costs. 

When we do start collecting the fees to 

adequately cover our costs, that means that our 

revenue will increase, and we'll probably need to 

spend more to cover all of our costs. And we 

need to make sure that we've got the flexibility 

to do that without being hindered by that 

particular cap.

 Another update I'd like to share is 

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around technology. The Grain Inspection Advisory 

Committee did make a recommendation around 

technology and asked us to develop a strategy by 

which we would explore new technology and work 

collaboratively with industry to do so. We did 

publish a process for evaluating new technology 

last year. That has been very helpful. You'll 

hear a little bit more about that from Ed Jhee 

during his update for technology and science 

division.

 But what we've done since our last 

meeting, we've collaborated with all of our 

grading programs within the agriculture marketing 

service. Because we're -- FGIS is not the only 

grading program that has a need to innovate. And 

so in November -- around November the 8th and 

9th, we're going to be gathering at Lubbock, 

Texas, at Texas Tech to have an innovation summit 

for all of our grading programs. And that's going 

to be Federal Grain Inspection Service. That's 

going to be cotton and tobacco programs. It's 

going to be livestock and poultry. And our 

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specialty crops program, which is basically 

fruits and vegetables, tree nuts and the like.

 Meeting with various customers who 

have implemented grading technology in their 

operations. For instance, the livestock 

industry's using cameras for grading beef 

carcasses. Fruit and vegetable industry, they 

use 360 degree cameras -- the customers are --

for grading and sorting their commodities before 

they ask USDA to grade it.

 We're going to be learning from 

industry partners. And also having a 

conversation with industry. We're going to be 

asking, you know, certain members of industry to 

participate. It's going to be a small group so 

that we can learn from each other, and figure out 

where do we go from here. Because things are 

changing all around us. Markets are changing. 

We have to change as well to become more 

efficient. To be more accurate. Also to reduce 

the burden that comes from the manpower that we 

currently pull on. And so these are some things 

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that we're going to be discussing at this summit.

 And I think we're going to also, for 

us, for the grain industry, look at how we can 

use -- and we've talked about this in the past --

how can we use imaging technology for our coarse 

grains. And that's soybeans, corn, and wheat. 

Those are -- are our largest commodities that 

we're exporting that we're grading. And the more 

we can do to lean on technology to support the 

work that we're doing, we want to explore that as 

soon as we can. And I don't think we've been shy 

about that. 

I'll pause here, and just take 

questions before I move on to the next slide. 

questions. 

Other general updates. The Grain 

Inspection Advisory nomination process is 

currently open. We opened it on August 8th. 

No 

It 

closes on September 22nd. We are still looking 

for nominations to come in. We have five at 

present. Which is good. Some people applied 

before we even opened the nomination. I want to 

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thank Nick and Barb for helping us with our 

outreach efforts. We've done some different 

things this year. We did a webinar that we 

published and -- and promoted. And we had about 

roughly close to 30 people that participated in 

that. Names that I've never seen or heard of 

before. So that was positive. I've been out on 

the road attending producer events, educating 

them about the Grain Inspection Advisory 

Committee. And encouraging them to -- to submit 

an application for consideration. So for those 

who are online, we thank you for being a 

participant in today's meeting. But if you're 

also interested in serving on the Grain 

Inspection Advisory Committee, we ask you to do 

so. I extend that same invitation to those in 

the room today that are eligible.

 Staffing. There have been some 

changes that have recently been made. One of the 

biggest changes I think is that Mr. Tony Goodman. 

Tony Goodman has served in the field management 

division of FGIS, I think, for his entire career. 

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We've made a transition with Tony a couple of 

weeks ago. He's going to be working out of the 

office of the deputy administrator as my senior 

policy advisor. So that will be a change. What 

that does, it vacates Tony's old role as the 

field management division director. Currently, 

Mr. Charles Parr is acting in that position. 

We'll be announcing a new acting director this 

week. His name is Mr. Jorge Vasquez. And while 

Jorge is acting, we're hoping that that vacancy 

announcement for the field management division 

director will be announced so that we start 

receiving applications for it.

 We also had a change down in our 

largest field office. The New Orleans field 

office. We had hired Ms. Sherry Williams to -- to 

lead that field office. I guess last year, she 

reported around November. She left us last 

month. That was not anticipated. However, we 

are working feverishly to get that job announced 

so that we can begin receiving new applications 

to fill that vacancy. Mr. Andy Ping, who's 

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associate deputy administrator for FGIS. I don't 

think I see Andy. But he's acting in New Orleans 

until we fill that vacancy.

 You know, I -- I said this yesterday 

to AGUA, and I'll say it again today. One of 

things I -- and I'm not exaggerating -- I get 

teary-eyed every time I think about it. Is that 

Mr. Pat McCluskey, who served FGIS for over 20 

years -- he's planning on retiring this next 

month. And if anybody's met Pat, you know Pat is 

a class act. He's a -- he's a different kind of 

fella that gives you his best in every room. His 

smile changes the -- it just changes the dynamic. 

His perspectives are always thoughtful, fresh, 

thorough. He's always helpful. And he's -- he's 

got some big shoes to fill. Or we've got big 

shoes to fill when he leaves us.

 And so Pat's going to be leaving. And 

so we've announced his position to be filled. We 

have had some applications and some interviews, 

and so we're hoping that we can soon announce who 

that next person will be. 

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But I just want to say publicly, Pat 

McCluskey, you have been a integral part of FGIS. 

We value you. We will always value you. We 

appreciate what you've done for this industry and 

for this service. We wish you nothing but the 

best as you go on to do great things with your 

family.

 Our current field office status in 

terms of staffing, we're about 85 percent 

staffed. This year we've not hired many people at 

all. And a lot of that is because of our 

financial posture. We did not want to make 

commitments to hire more staff. Long-term 

commitments, that is, to hire more staff, not 

knowing what's going to happen in terms of 

adjusting our fees. And so the -- the largest 

number of vacancies that we really have are down 

in our New Orleans area where we have the 

greatest demand. But we've got about 60 

vacancies that we need to fill. That our field 

office, or our field offices want to fill. But 

we are trying to be as careful as possible in 

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terms of extending ourselves. And it -- it kind 

of hasn't helped that we've had a -- a decline in 

-- in volume this -- it has helped from the 

standpoint we've not hired. Because if New 

Orleans was running full blast as it typically 

would, we'd need more people. And with our fees 

being set so low, we still wouldn't be -- we'll -

- we'll be paying out more than we're recovering. 

So we're hoping that through this dialogue we 

have today and tomorrow, we can get some insight 

in terms of how we can move going forward with 

respect to our -- our hiring posture.

 A new venture we will be exploring 

this coming fiscal year '24, is we're partnering 

with our national organic program within the 

agricultural marketing service. One of the 

things I think that we're going to have to start 

doing as a Federal Grain Inspection service is 

potentially diversifying what we do. 'Cause 

we're not quite sure how things are evolving. 

And so we're going to be exploring how we can 

help the National Organic Program strengthen 

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their organic enforcement.

 One of the things that's been 

experienced here in the United States is organic 

grain fraud. Folks how are purchasing nonorganic grain, but marketing it as organic grain. 

And it's coming in from overseas. It's also 

happening -- happening here domestically. And so 

the organic program has asked us to help them 

with a sampling protocol and program that we can 

begin to help them monitor. And these monitors 

will be sent to another lab for evaluation 

regarding organic integrity. So that's something 

we're doing at a very small level. It's a --

it's a pilot. And we're only going to start when 

we have FGIS field offices. That may expand if 

it's successful. We'll be bringing more 

information to you about that initiative over 

time.

 Cyber security threats. This is a 

kind of ongoing effort. Lee Capper, who's our 

chief innovation officer, has been working 

closely with USDA's information technology staff. 

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As well as talking to a number of the grain 

elevators that we work with. Cyber security 

attacks are growing every day. Even on our own 

systems. USDA and FGIS were successful in 

warding them off. However, it brings into 

question other aspects of our operation. We have 

a lot of official agencies that are connected to 

the work that we do. And questions are being 

asked of us. How well are we connected to their 

systems. The security about those systems, 

security about the elevators, and more. And so 

we're working closely with USDA to begin 

developing a strategy to strengthen the current 

position of our information -- of our cyber 

security related to our information systems in 

the collective body of the official system. So 

stay tuned about that. I think our information 

technology service is looking at doing surveys 

sometime in the future of our customers and our 

official agencies to learn more about how things 

are set up. So I wanted to share that as -- I 

want to say a project -- but a goal that's 

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occurring. And we want to make sure everybody's 

aware.

 And that is it for me in terms of 

general updates from my level. Before you come, 

Karla, are there any questions? No questions. 

I'll bring Karla Whalen up to the microphone, who 

is our director for quality assurance and 

compliance.

 MS. WHALEN: Okay. Good morning. As 

Art just said, I'm the division director for 

quality assurance and compliance division. I've 

been with FGIS for about the past two years.

 Just a quick briefing about QACD. 

There a four divisions within FGIS, which many of 

you know. But QACD division primarily focus on 

the field office and official agency audits. We 

also administer the quality programs. SIMS and 

STEPS, which many of you will be familiar with. 

We are the ones responsible for the designation 

and delegation opportunity notices, applications, 

recommendations to ODA, and assistance to 

official agencies. We regularly field and 

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research regulatory questions for other parts of 

FGIS. Also support the office of the deputy 

administrator in that area. And my staff is also 

responsible for investigations.

 On the investigations front, we 

primarily are focused on the USGSA violations. 

If there is a criminal matter, we do refer that 

out and work with AMS CARS (phonetic) branch. 

And in addition, any kind of personnel matters, 

we generally are going to work with the broader 

AMS investigators.

 Arthur had mentioned there was not a 

lot of hiring in most of FGIS to fill certain 

needs. We were the aberration to that situation. 

So I wanted to pop this up here. In the last --

less than the last year, we've hired 75 percent 

new staff. They are coming from very diverse 

backgrounds. It's a very eager, skilled, and I 

would say, very diverse group that we're pulling 

together. And I'm actually thrilled with what 

I'm seeing out of this group. So out of eight 

compliance officers, six of them are brand new, 

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with less than a year's experience. We are 

making tremendous strides on many needs within 

FGIS with this group.

 I also want to mention Silvey Parker. 

Many -- many of you have probably known her from 

the past few years. She's been doing a -- a 

national detail on sustainability grants with the 

department. So she will be in that role, we 

expect, until next April. I have had Jacob Tyne 

(phonetic) act with me. And currently, we have 

Micah Malbroux, who is the AFOM from New Orleans, 

and he is assisting me right now.

 We also brought over Jennifer Hill. 

She normally works for Byron in the international 

affairs division. She is on detail with us for 

the next six months, till December, helping us on 

export registration needs.

 During COVID, the staff had to do 

their audits virtually, so that was a massive 

shift that occurred before I came to FGIS. 

However, we will be returning to what we're 

terming "hybrid audits" in the fall. That's 

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where we're going to do portions of our audits 

that are much better done onsite with hands-on 

equipment, procedures, some processes. We will 

do those onsite, and then the parts of the 

virtual audits that worked very well and were 

very efficient, we are going to keep that. So 

we're terming that a "hybrid audit." We will be 

testing and trying out that process starting in 

the fall.

 This is the schedule that we intend to 

get through for official agency and field office 

audits in the coming fiscal year. Obviously, 

this can shift a little bit depending on needs 

and other issues that might crop up. But once we 

get through this cycle, we should be caught up 

from staffing challenges, COVID delays, et 

cetera. And then we'll start a new five-year 

cycle. So this upcoming year is a really 

important one for QAC to get FGS -- FGIS back 

online with audits.

 Okay. When we were at the annual 

meeting. Some of you that were there, this is 

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going to be a repeat. But we had the staff do a 

-- kind of look at what were the audit trends, 

where the challenges that we were seeing. I'm 

going to pull my notes up on this one. What we 

want to highlight for you is, they pulled out 

some details for the last four years of audits. 

And we're going to highlight just the top three 

areas of challenges. The top three areas of 

challenges, in the blue color, what we are 

representing is official recordkeeping. The 

orange color represents issues in regards to 

facilities, testing, and equipment. The gray 

color is certain compliance issues. Most of them 

minor with USGSA, the regs, and FGIS 

instructions.

 The next slide digs into those three 

areas, with a little bit more specificity. And 

again, this is representing four years of audits. 

On this particular slide, we did pull out 

findings where there were less than three 

findings on a particular matter over the course 

of four years. We did that so any areas of issue 

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were much more prevalent in the way we 

represented this to you.

 So by again, looking at the official 

recordkeeping requirements, this chart breaks 

down and shows that most of the issues in this 

area were related to stowage examination. 

Twenty-five percent of the time there was an 

issue. Not maintaining FGIS 944s, approximately 

16 percent of the time there was a noncompliance. And the third area there was 

fumigation records not being maintained. And 

that occurred about 11 percent of the time.

 The orange is the next largest area. 

And that's facility, equipment, and personnel. 

In this area, the subcategories where there was 

most of a challenge is the testing value to the 

10th or 100th value. That's an issue that we 

have addressed a number of times over the past 

two years. F&D is working on getting the 

instructions corrected there. So right now we do 

not count that as a non-compliance, but that is a 

issue and confusion that we regularly see. 

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And the next two areas in that are 

equipment not being tested in time and recorded 

in the system, as well as lab scale tapes not 

being attached when there is a -- such equipment 

testing.

 To assist the official agencies, we 

also presented this at AGUA, and then later sent 

out a message to all official agencies. This is 

taking those problematic areas and trying to give 

a quick educational or instructional reference 

back. So that it's easier for OAs to retrain on 

the areas that we're kind of seeing across the 

country in challenges. So we've just put that --

these two slides in your packet, which obviously, 

you can look at in more detail if any is needed.

 FGIS, over the past year -- more than 

a year -- had worked with a serious situation 

with one official agency, Northeast Indiana Grain 

Inspection based out of Decatur, Indiana. This 

is a longstanding official agency that had a 

rapid change in operations due to, I would say, 

personal and professional challenges, that kind 

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of imploded on that company. FGIS started to 

receive complaints from customers. We started to 

look into that situation more -- in more detail. 

We conducted a number of site visits. We offered 

assistance to that OA to try and get their 

challenges turned around. But ultimately, that 

was not successful.

 As a result of that, FGIS went through 

the process to suspend their designation. USGSA 

designation. And we also filed a litigation 

complaint against NEI, as that is the mechanism 

that we have under that statute and another 

statute, of how we can actually try to revoke a 

designation when there is a problem with an 

official agency.

 So we have gone through that entire 

litigation process. And as of last -- I don't --

I forget what date, what day it was -- but as of 

August 21st, this revocation of their USGSA 

designation has become final and effective. So 

there will be a notice to the trade coming out 

about this. It's -- it's going through clearance 

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right now.

 If by any chance someone wants to know 

more details on that, we would refer you to the 

hearing clerk, 'cause they have the complete 

litigation record. I -- I'm not really able to 

provide that to you, but I can get you to the 

judge's office that can. And again, this is just 

mentioning the NTT.

 One other thing I want to mention 

about that. When the designation is revoked, we 

will go through the process to readvertise that 

area. So we do have a opportunity notice for the 

Decatur, Indiana geographic area, which will be 

coming out as soon as we can get it through 

clearance.

 Two other areas I don't have slides 

for definitely want to mention to you are the 

exceptions. Arthur had mentioned that became 

effective on August 1st. If you need more 

information on that, I know some of you were on 

the webinar that occurred. You can go to the 

website, and we've -- we've uploaded the webinar. 

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There's helpful guidelines. There's new forms. 

Instructions that you can look at how -- how that 

process works. We -- to date, as of yesterday --

I don't know about today -- as of yesterday, we 

have not had any requests for exceptions. So 

that's where we are right now. We have had a 

couple interesting questions come in. And two of 

them I'm going to share.

 One of the questions that came in was 

can the challenge feature be applied to previous 

exceptions, or exceptions that are already in 

place. And we have answered that "no." There was 

not a mechanism to do that at the time. So any 

challenges on exceptions would have to be 

something that's coming in prospectively.

 Secondly, there was a question to us 

-- another interesting one -- can someone get a 

non-use of service exception to try and get a 

lower fee. And how we want to answer that one is 

it depends. Right? But is does depend. It's 

going to depend on all the circumstances of that 

exception request. What is the need? Where --

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where is the service? What are the different OAs 

able to provide, et cetera? So we would look at 

that in a holistic manner. And that's really the 

only way we can answer that at this time.

 The other area I want to mention that 

we don't have a slide for is Arthur had mentioned 

the congressional geographic boundary study that 

was done. About, I'm going to say, three-plus 

years ago, prior to my time coming into QACD, the 

staff had started to look at the geographic areas 

of each of the official agencies. Some of those 

are quite dated. They might even go back 40, 50 

years. Consequently, some of the landmarks, some 

of the street names, some of the items that kind 

of describe these territories out in the rural 

area, don't exist anymore, or have been overtaken 

by other development events, et cetera. So there 

was a pretty detailed process over the last, I'm 

going to say two -- I'm going to say about 18 

months of working with the official agencies on 

our suggested updates to those descriptions. I 

would guess we had about 60 percent participation 

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rate from official agencies on our updated 

language, but not 100 percent. We have decided 

it's best -- again, Arthur speaks about 

transparency -- it's best if we put that national 

view out to the public for comment. So we will 

have an FR coming out. I anticipate that will be 

in the fall. We've got -- we -- we did have 

staff member that had good mapping skills, but 

they have moved on to other items. So that new 

crew, I've got a couple of them getting trained 

up, and we'll get there. But that FR should be 

coming out. We'll provide a national view to 

everyone at the same time in regards to the 

changes that we're recommending. In addition, 

once we deal with those comments, put out that 

final FR, it's going to help all of us for 

efficiency purposes because we'll only have one 

FR, not, honestly, 30 or 40 from the past that we 

have to reference in future FRs. So I'm really 

happy with that project and hopefully, it will --

will help to iron out and bring some issues that 

maybe we don't know about that we can actually 

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deal with.

 So that's my update. Last thing is, 

if anyone wants more information on compliance, 

we did do a pretty detailed email out. So that 

has all of things that this new staff has been 

able to accomplish over approximately the last 

year. I'd be happy to share that if you give me 

a email, and you can take a look at that. But 

TMI for this format. Okay? Good? Questions?

 MR. FRIANT: Karla, Nick Friant with 

Cargill. On the Northeast Indiana revocation, 

what's the plan to cover facilities that are in 

that designated area?

 MS. WHALEN: Okay. Great question. 

So at the time of the suspension, FGIS has to 

take over that territory. Right? So we had 

preplanned all that when we knew what was coming. 

So at -- at that moment, when that company was 

served with the suspension letter, Dial, as the 

overseeing official FGIS office, overtook that 

office. They worked with Toledo. We had staff 

preplaced to take care of any customer needs at 

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that moment. That went pretty seamless, I would 

say. We were pretty happy with how that worked.

 And then, subsequently, as soon as 

Dial could, they worked with surrounding official 

agencies that were in good standing, to -- to --

for us to deal service agreements. So that the 

official agencies could assist that area. And 

that is how it has been operating since the 

situation started. So at the point of 

suspension, on through the litigation, up to 

today. We will readvertise that through the FR. 

That's the legal process that we have to try and 

get someone else back in there.

 Janice?

 MS. COOPER: I have a question about 

your audit schedule. Very aggressive, and looks

 MS. WHALEN: Yes.

 MS. COOPER: -- looks really good. 

How would that be affected by various funding 

challenges, including a government shutdown?

 MS. WHALEN: Well, government 

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shutdown, we -- we -- our -- our portion is 

appropriated. We are not a fee-for-service 

portion of FGIS. But we would be shut down 

during a government shutdown. You don't see the 

exact dates on there. I have built in about 

three weeks in October, just in case that 

happens. But we -- we would not be able to work 

and it would delay us some. Thank you.

 Okay. So Charlie Parr is up next. 

Thank you for your attention.

 MR. PARR: First of all, I'd like to 

say good morning to the Grain Inspection Advisory 

Council and express my gratitude for the 

opportunity to address you this morning. I'd 

also like to express my thank you to Mr. Neal, 

who has given me the opportunity to serve as the 

acting field management division director for 

FGIS.

 My name is Charles Parr. My normal 

position within FGIS is the deputy director of 

the technology and science division under Dr. Ed 

Jhee. I am not new to grain inspection. I 

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joined FGIS in 2016 as a quality assurance 

specialist for a domestic inspections operations 

office. But prior to that I had 16 years a 

licensed inspector for an official service 

provider. And I've held various roles within 

FGIS.

 Getting into our field management 

division updates. Arthur briefly touched on some 

of our -- our staffing changes. He mentioned the 

New Orleans field office manager. That position 

is now vacant, but it is being held by our 

associate deputy administrator Mr. Andy Ping. 

Andy has a lot of experience as a export field 

office manager. He previously held a position as 

the FOM in -- in our Portland field office. So 

it's nothing new for him to -- to take on those 

operations management duties.

 As Arthur also mentioned, we will be 

having an upcoming vacancy for our policies, 

procedures, and market analysis branch, thanks to 

the retirement of Mr. Pat McCluskey. And for me, 

personally, I like the fact that I have the 

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opportunity to go on public record and express my 

thanks and gratitude to Mr. McCluskey. Since I 

first met him, even prior to being an employee of 

-- of FGIS, Pat has served as a great mentor for 

me personally. And he's a great friend.

 We have other various acting details 

throughout the agency. We mentioned briefly our 

-- one of our assistant field office managers, 

Micah Malbroux, who normally serves our New 

Orleans field office, is on an acting detail with 

the quality assurance and compliance division. 

It's a wonderful development opportunity for him 

to get some leadership experience in a -- in a 

different direction under Ms. Whalen. It'll be a 

-- a good opportunity for Micah and we all look 

forward to -- to seeing that play through.

 We've recently had some policy 

reorganizations within PPMAB. Probably of most 

note is our policy bulletin boards. If you're 

relatively unfamiliar, policy bulletin board 

notices are kind of our fastest instruction that 

we can get out there. Historically speaking, most 

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of the time, those policy bulletin notices have 

been kind of internal to the agency. They're not 

really -- they haven't historically been shared 

too much, but now we are posting those on our AMS 

public website. There's a couple that are -- are 

going to remain behind the FGIS firewall, and 

it's simply because it has content that needs to 

stay -- some of it has example forms and things 

like that, that we need to -- to keep behind the 

-- the firewall just for security purposes.

 We have 23 policy bulletin boards that 

are being posted to the AMS website. And at the 

same time that we were conducting those updates, 

we identified 24 other policy bulletin notices 

that were retired. And by retired, that doesn't 

mean that they -- they went away. A lot of those 

instructions were rolled up into higher-level 

instructions, handbooks, directives, et cetera.

 Just some basic data on our U.S. grain 

exports. This chart here shows this information 

is in metric tons and it is approximately a week 

old. This is the information that comes out. 

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Mr. Rob Dorman, from our policies, procedures, 

and market analysis branch makes this information 

publicly available every Monday morning. And you 

can see that our export levels are down across 

the board, with the exception of Canola. Canola 

is having a -- a -- I would assume a record 

export year with those percent changes. Next 

year's projections are unfortunately expected to 

be about the same or potentially even lower.

 FGIS released our directive for 

detection of fecal matter. Our biotechnology 

branch developed a fecal determination assay for 

verifying the detection of fecal matter outside 

of a -- it's basically a reference method to 

verify the presence of fecal matter in grain 

samples. Large animal filth, especially, is FDA 

actionable under our memorandum of understanding. 

As Arthur previously mentioned, we've got Barry 

Gomoll with our policies, procedures, and market 

analysis branch, currently engaging with FDA to 

update that directive. We expect the -- the 

draft of that update to -- to be in our hands 

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fairly soon.

 When we went out with the -- the 

directive for actually performing this fecal 

determination assay, after the first couple of 

requests, it was -- became very apparent that we 

needed to make some updates to the directive. So 

we went back out with a -- a revised version. We 

worked with our -- my FGIS group to include a 

service request. That service request allows us 

internally to kind of track the -- the lifecycle 

of that -- that request. It also initiates a lot 

of our -- our billing activities. And it's our 

mechanism for capturing all the data related to 

the -- the requested test.

 The updates to the directive also 

provided a little bit more clarity on the roles 

and responsibilities of what individuals were 

going to do at the field office to that sample 

being sent here to the National Grain Center, 

where the fecal determination assay is to be 

performed. And then, also the roles within the 

technology and science division on how to receive 

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that sample, perform the analyses, and then for 

us to certify the final results. We also added 

clarity that the test is to be used as the 

reference method for it being a board appeal. So 

it's part of the review inspection process that 

we've already have for the review inspection of -

- of grain. It also clearly defined what 

accompanying documentation needed to be included 

with the -- with the samples.

 I don't have a -- a number of the 

total number of -- of determinations that we've 

made. But so far, we have not overturned any 

results from the field. So as of today, 100 

percent of the assays that have been run have 

substantiated the -- the visual determinations 

made by the field.

 Arthur also mentioned our soybeans of 

other colors update. What we have here is a --

just a screenshot of a soybeans of other colors 

resource page that Ms. Cline has worked to -- to 

have posted. This page will eventually expire, 

go away. As we -- I believe he said by the end 

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of the calendar year, this page will probably 

come down. By then, the -- the final rule will 

have -- have been enacted, because that comes 

into play, as we previously mentioned, on Friday, 

September 1st.

 And what that final rule did, is it 

eliminated SPOC as an official factor. But it is 

still utilized for classing soybeans. The -- so 

it's qualitatively used to determine class, and 

then SPOC is still available, upon request, as 

official criteria, should it be needed by 

applicants for service.

 And that is all I have for your 

updates for the field management division. 

Again, I'd like to express my thanks for the 

opportunity to -- to speak this morning. And 

again, to Mr. Neal for the opportunity to serve 

as the -- the acting director of field management 

divisions.

 And I'd be open to have any questions 

that you may have at this time. Hearing none, 

thank you very much. 

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And now I'd like to introduce our 

director of international affairs, Mr. Byron 

Reilly.

 MR. REILLY: Good morning. Good 

morning. It's a pleasure to be here again and 

see familiar faces that I've known for many 

years. I have been with FGIS now for 47 years, 

going on 48. So my boss says I can't retire 

anytime soon. So I'm still hanging in there.

 First line I'd like to talk about is 

updates to China Decree 177 that you've heard 

from me for many years now. We have recently 

made progress with regards to exporter 

registration. China Decree 177 used to be 

covered under China's GACC, general 

administration for customs. And there was also 

Decree 248, which was covered by GACC under the 

food safety office. So a lot of the programs, a 

lot of the grains related, that were used for 

food, such as edible sorghum -- the new 

administration in China, the animal and plant 

quarantine, APQ, has transitioned any of the 

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grains that are even edible, from 248 back to 177 

registration. Which then falls back onto FGIS 

registering them, versus a direct registration to 

GACC with the -- from the exporters.

 We still provide a list with the list 

of exporters from annual registration, going 

through QACD process. We have established a 

streamlined method of getting that electronically 

from the source, FGIS online, and registration. 

It includes, also, export facilities where FGIS 

does our inspections. We have also gotten 

requests from several exporters to "Oh, can you 

also register these following facilities, because 

those names of those facilities appear on the 

export documents." So that there'll be less 

confusion and interruption on China, we have 

honored those requests. We also include 

exporters that register under the 15,000 ton 

metric exemption, particularly, containerized 

shipments.

 So we want to be all-inclusive. So 

help facilitate the trade and not disrupt any 

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imports. Recently, GACC has removed the pulses 

from 248; put that back under 177. Then became a 

big question working with FAS "Well, gee. 

They're under our Agricultural Marketing Act, 

which we have no requirements to require 

registration with these exporters." So working 

back and forth with FAS Beijing, FAS decided to 

become the quote "competent authority" to 

register these applicants, exporters. Currently, 

there are 50. China had asked for unique 

identifying numbers for these companies, and they 

have chosen to use the last four digits of their 

tax identification number.

 So I heard that we are having a record 

number of pulse inspections this year. And the 

list has just become -- I got notice today that 

it has been officially published on the GACC 

website. So get ready. We anticipate a lot more 

inspections of pulses going over to China.

 FAS has requested FGIS, if we're able 

to, to also register exporters of various oil 

seeds, such -- particularly in cottonseed, 

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popcorn, mustard seed, sesame, and a few other 

miscellaneous items that are covered under our 

Agricultural Marketing Act. So we're still 

having internal conversations with FAS and 

amongst -- here in FGIS.

 Now I'll move on to some of our 

outreach activities. Mr. Neal mentioned that 

dealing with the SBOC issue, my office has been 

in contact with FAS here in DC and with USEC 

(phonetic), and the soybean industry. And we had 

a general conference a couple months ago. And 

then recently, had one specifically with 

Indonesia importers, who seemed very concerned 

about the effect of removing these as a grading 

factor. "Oh, this is just giving exporters the 

opportunity to really load it up with the 

discolored coat soybeans." I found out that 

Indonesia is one of the only Asian countries that 

does not require -- that requires the removal of 

the soybean hulls to make tempeh. All the others 

will just go ahead and grind it up.

 But we had a good conversation. 

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Answered their questions, and suggested, you 

know, there's virtually no difference, no worry 

about it. Just put your specifications in the 

contract as you normally would, and we'll inspect 

it accordingly.

 We have worked this year with other 

USDA agencies and our customers to talk about 

FGIS services that we have to offer. I had 

conference calls with FAS field offices. We had 

particularly AFIS, who took very much interest in 

that and learned a lot about FGIS. You'd think 

they would know about us, other than just doing 

their inspections. But they were very 

interested. And because of our meeting there, we 

had requests from their offices in Asia to come 

visit them. Barry Gomoll from FGIS is leaving 

this Saturday to start his trip -- one-month 

detail in Asia. So particularly in Japan and 

Korea, they had questions they wanted to ask him 

about FGIS and some trade issues. These will 

still be internal discussions, not involving 

industry while he's in-country. 

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We've conducted briefings this year 

with 13 visiting trade teams from 13 different 

countries. We've updated and translated numerous 

presentations into Arabic, Chinese, French, 

Japanese, Korean, and Spanish. And these are 

available to anyone of our customers asking for 

particular information on various subjects. 

Whether it be mycotoxins, or container 

inspections, or stowage exams, we have all these 

separate in different languages. They are only 

available upon request through my office because 

they take up too much server space. So -- but 

those are available to anyone interested.

 We have worked this year -- because 

we've lost a lot of qualified inspectors that did 

international travel for us and were familiar 

with the -- what goes on with involving 

international travel. Safety concerns, et 

cetera. So we conducted a FGIS training session. 

We went out and requested -- you know, announced 

that we had positions for study. So we developed 

six different training modules that were 

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available to them online. For in their off times 

when they could go ahead and take the training. 

We then had interviews and gave practice sessions 

for their presentation skills. So we have 

developed a cadre of -- we had 14 applicants and 

we're getting ready to send out passport 

applications to those people.

 And what we have done to get them --

get their feet wet, so to speak, is when Barry 

goes over to Asia, we have one of the new 

applicants, who will accompany him on the last 

week of his trip, which will be in the 

Philippines. The Philippines always has a wide 

diversification, as far as who they speak to. 

And they'll make numerous stops with different 

customers. So this is the greatest experience 

for a new traveler. So then next year, that 

person will then go out on their own, again to 

Asia for a month. And we'll select another new 

applicant to accompany them on the last week.

 U.S. Wheat Associates has asked us to 

go to Panama. They are working with Venezuelan 

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millers that they're trying to get visas for to 

go to Panama. As well as train the Panamanians, 

millers there. It was scheduled for October, but 

because of possible shutdown and continuing 

resolution, we've convinced U.S. Wheat to see 

about doing it later in September. So they're 

working on that, and they said if they can get 

the visas for the Venezuelans, that'll be great. 

And U.S. Wheat is picking up the costs for FGIS.

 Likewise, we got a request from U.S. 

Wheat to send a person over to Kenya, Nigeria, 

and South Africa to give a talk. So -- but they 

wanted that in November. I told them that was a 

no-go. And I did a recorded video presentation, 

which I sent to U.S. Wheat and I suggested that 

they try using that in a virtual conference. I 

was only supposed to go there for a one-hour 

presentation, which didn't make sense to travel 

all that distance for one hour. Thanks to modern 

technology, we're able to handle those requests.

 Now with -- I mentioned Barry Gomoll's 

going to be going to Asia. He's leaving 

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Saturday. It was for four weeks to meet with 

importers, millers, processors, and government 

officials. This year is the first year that 

we've expanded. Typically, it's been to just 

countries in Southeast Asia. We had that program 

going since 2002. We've been doing it every 

year, and then COVID hit. So now this is the 

first year that we're -- it's reactivated. So 

this year, we went and contacted AFIS officials 

and the other overseas offices, as well as FAS 

offices, to say "Hey. Do you have issues? Would 

you like for us to come visit?" And prior to 

this, we only talked to the USDA cooperative 

groups; wheat, corn, soybeans. And they arranged 

the conferences. So this year, we're going to 

North Asia as well. We're visiting China, Japan, 

Singapore, South Korea, Philippines, and Vietnam.

 As I said, we had a request from AFIS 

to go to Japan to talk about Japan's new request 

for phytosanitary certificates and their concerns 

on costs for fumigation using recirculation. We 

are very anxious to go to North Asia and include 

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them in our training. This is the first time 

we've did a training in China in all those years. 

So this will be in Guangzhou, and it'll be a 

three-day training session with U.S. Wheat. 

We're holding seminars on grain standards, our 

services offered, and grain grading workshops.

 I just met with the Chinese group last 

Thursday where the FAS people that were there 

with the group, as well as USEC, learned about 

the roles of FGIS where they were unaware of it 

before. And we mentioned the SBOC; there were no 

questions or concerns from the Chinese.

 Some of the other activities that my 

office participates in internationally. We hold 

a position with the Codex Alimentarius executive 

and technical committees. Recently, there's been 

no activity dealing with grains, but we're 

talking about aspartame and other products, as 

well as concern with Codex to get any movement 

with a proposal moving forward. There's several 

conflicting bodies within FOA and other 

international agencies that want to have their 

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say on it. Where we're saying "no," it should 

only be one agency to review it. Because 

authority was pretty much outside the 

jurisdiction of these other groups. So we're 

meeting in Geneva to present our paper to them.

 We're a member of the sanitary, 

phytosanitary, and technical barriers to trade 

committees. Every week, there's a meeting. A 

member of USDA biotechnology coordinating group. 

We are actively involved in the interdepartmental 

coordination committee on international affairs, 

with FAS sponsor. And we're also a member of the 

global- level president's initiative on the 

acceptance of biotech grains at low levels. So 

we actively involve private sector to get their 

input and recommendations.

 Wherein complaints, we've had a total 

of six this year so far. Ends today. And those 

complaints are China. We had one on soybean and 

three on corn, involving damaged kernels. We had 

an Algerian wheat ergot complaint, and a Vietnam 

wheat protein complaint. Barry Gomoll is going 

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over to the flour mill in Vietnam during his 

visit to talk about the differences between 

Kjeldahl versus NIRT.

 Thank you. Any questions? Okay. 

Appreciate it.

 Next up, we have Dr. Ed Jhee with the 

FGIS Technology and Science Division. 

DR. JHEE: Okay. We're not ready.

 All right. Well, this morning, I'm 

going to talk a little bit about TSD's efforts to 

promote greater inspector alignment. I'll talk a 

little bit about technology and some of the 

activities that TSD undertook this fiscal year. 

A little bit about expanding our testing services 

in a couple of different areas, as well as some 

numerous process improvements to become more 

efficient and effective.

 In fiscal year '23, the Board of 

Appeals and Review, or the BAR, created and 

distributed referee samples, or training samples, 

for corn, soybean, and wheat. The samples were 

produced to promote inspection alignment between 

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quality assurance specialists, or QAS, and the 

BAR, and were created with common damages 

typically found in corn, soybean, and wheat. The 

data collected from the referee are used to 

determine the QAS's ability to identify damage in 

these grains, and recognize opportunities for 

improvement, to insure alignment across the 

official inspection system.

 This year, the BAR, as well as our 

digital media group, updated FGIS's online wheat 

variety library with 24 new varieties that are 

grown and inspected in the Pacific Northwest 

region. The library is a collection of multiple 

varieties for three different wheat classes. And 

this update included varieties for hard red 

winter, hard red spring, and soft white wheat. 

Each variety is photographed from multiple 

angles, and are supported with descriptive terms 

to assist inspectors with identification.

 The BAR and digital media also issued 

new visual reference images for lentils. The new 

image was create with input from the lentil 

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industry. And the VRI was created to give 

improved guidance on how to assess insect damage 

more accurately in lentils. And the new VRI was 

well-received by the Dry Pea and Lentil Council.

 And now to transition over the 

technology. There are as many as 2,000 licensed 

and authorized inspectors in the official grain 

inspection and weighing system that have to 

maintain agreement with the board of appeals and 

review. TSD has explored the use of new video 

microscope technology in support of increasing 

the number or quality of inspections performed in 

the official system -- in the official system and 

support quality assurance specialists in 

maintaining the quality line standards 

established by the BAR.

 New procedures are in draft, or 

instructions are completed, and a pilot project 

is actually underway at FGIS's largest field 

export office in New Orleans. The goal is to 

enhance communication remotely with the BAR 

through the use of these ten megapixel video 

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cameras. It is important to note that the 

microscopes are not intended to make remote grade 

determinations, as they do have limitations in 

achieving color and standardization.

 All right. Mycotoxin test kits. In 

this past fiscal year, FGIS evaluated 16 test 

kits, and 15 were approved for use in the 

official system. FGIS also incorporated two 

improvements to the test kit evaluation program. 

The first is to promote transparency in the 

verification process. We announced the option 

for representatives from the test kit 

manufacturers to participate in the verification 

studies, alongside FGIS personnel here at the 

National Grain Center. And to improve robustness 

of the test kit evaluations, we now require the 

verification study to use three separate 

instruments to account for variation between the 

instruments of the same model.

 Now the fun stuff. All right. GE is 

not CRISPR. Since the commercialization of the 

first genetically engineered crop in the U.S. in 

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1992, there've been over 130 GE crop products 

deregulated for cultivation in the U.S. To 

facilitate U.S. trade of these grains, accurate 

detection and quantification techniques are 

needed. However, more exquisite gene editing 

techniques have been developed in the past few 

years, challenging existing detection platforms.

 FGIS needs to develop technical 

expertise in new detection platforms to 

accurately detect and quantify trades derived 

from new technology such as CRISPR. Currently, 

no USDA lab has the capability or the capacity to 

identify and quantify CRISPR products. The 

ongoing uncertainty about the acceptance of 

CRISPR could lead to trade disruptions, as in the 

previous decade with GE rise and GE wheat.

 Over the past 20 years, PCR, or 

polymerase chain reaction-based detection has 

been the most widely used DNA-based detection 

method. This method allows us to identify and 

quantify specific foreign DNA. A sensitivity of 

PCR detection has been challenged, as more 

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complex products enter the market. Stacked 

traits, with as many as eight different traits in 

one crop plant, and CRISPR-derived traits are 

also on the horizon.

 All right. CRISPR stands for -- you 

ready? Clustered regularly interspaced short 

palindromic repeats. Say that three times fast. 

All right. CRISPR gene editing technology --

actually, let me pause for a second so you guys 

can take a look at this slide. CRISPR gene 

editing technology works similar to antivirus 

software in your computer. It searches and 

destroys target DNA that matches the CRISPR 

reference molecule. So if you look at the far 

left, you've got a target DNA on the lefthand 

side, and a created CRISPR molecule that is a 

complimentary strand to that target DNA.

 Scientists have modified the system to 

make precise modifications, or edits, in many 

organisms. This is done by replacing the native 

DNA sequence with the CRISPR molecule. An 

example of this is -- is a commercial salad blend 

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that contains a CRISPR-edited mustard green like 

kale. Only the bitterness has been removed. 

They were able to find the target DNA that 

confers bitterness, cut the DNA out, and which, 

effectively, was the kill switch to that 

bitterness flavor. Currently, CRISPR products 

can't be detected by traditional methods to 

detect genetic events, such as typical herbicidetolerant varieties of corn and soybean.

 We've been collaborating with the 

University of Missouri, who has the most current 

technology to sequence DNA, called next 

generation sequencing. FGIS is exploring next 

generation sequencing, which is a powerful 

technique, with thousands to millions of 

individual DNA sequences can be analyzed from a 

given sample. Unlike traditional PCR, when using 

next generation sequencing, the precise -- excuse 

me -- the precise mutation doesn't have to be 

known, providing that the gene that has been 

modified has been identified. In fiscal year '23 

we were able to detect the presence of CRISPR 

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edits using next generation sequencing. Our next 

step is to determine if this method can be used 

to quantify the amount of gene-edited material 

present.

 All right. Imaging technology. In 

fiscal year '22, FGIS solicited manufacturers of 

imaging systems applicable to grains to determine 

if a commercially available instrument could 

support the California medium grain rice 

industry. In this past fiscal year, we entered a 

cooperative research and development agreement, 

or CRADA, with the company Sea Grain, based out 

of Sweden, to determine if their grain imaging 

instrument could effectively and efficiently 

analyze medium grain rice brokens. The first 

step was determining proof of concept, and 

building the library of images into what's called 

an artificial neural network, which is database 

or a catalog of images. This is cool. Great.

 All right. This is a figure for 

duplicated data that shows both the repeatability 

and reproducibility of the instrument when 

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compared to the reference, which in this study, 

was the BAR. Notice that the samples that 

contain -- 85 to 95, or greater than 95 per 

sample kernels are very, very tight along the 

zero. Also please make note of the Y axis in the 

scale. So based off of over 40 samples, we have 

very, very tight alignment at the higher end. 

All right? We did have about ten to twelve 

samples as part of our study on the lower end of 

average, so we actually see additional variation 

there, which is actually -- all right. A 

statistical treatment was applied to determine a 

range in which 95 percent of individual 

measurements between the Sea Grain instrument and 

the BAR would fall. 

Our statisticians in this case used 

what's called a Monte Carlo simulation to model -

- excuse me -- a model Monte Carlo simulation 

that's based off of 100 single measurement 

comparisons between the board of appeals and 

review, and the test instruments. The data 

analysis of the study indicated that 95 percent 

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of the time, the maximum difference between the 

two measurements would be plus or minus 1.7. 

Again, please note that the difference --

differences decrease with the higher percentage 

of whole kernels increasing.

 All right. Here's a simplified 

version of the last figure. Again, the data 

wasn't distributed normally, so a statistical 

treatment was applied to the data set in order to 

properly establish a tolerance limit. And the 

estimated tolerance limits are curved to account 

for the change in variation over the range of 

whole kernels. So the plus/minus 1.7 maximum 

difference that one would expect between two 

measurements occurs 95 percent of the time. When 

I also looked at data going back to 2021, over 80 

percent of our inspections were within the 80 to 

95 range.

 Now this is what's cool. Even though 

it's handwritten, it's -- a fancy little graph. 

So this is a monitoring program for an existing 

instrument that's out in California. All right? 

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I want you guys to focus on this third line, 

which is called "hand-picked." All right? So 

these four samples were hand-picked by the board 

of appeals and review. We had two Sea Grain 

master instruments in our basement -- instrument 

one, instrument two. We took several 

measurements and took the average. I want you 

guys to look at the alignment. Just to prove a 

point.

 All right. With all of this data 

considered, we are granting approval for the use 

of this instrument in the official system, with 

some conditions. Which includes sending samples 

back to TSD as part of an ongoing monitoring 

program, to collect additional data to ensure the 

performance meets our expectations.

 And now about expanding testing 

services. I mentioned last year that the U.S. 

Agency for International Development partnered 

with FGIS to expand our testing capability and 

reliability of our services. Under this 

agreement, FGIS stood up a suite of analytical 

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testing services for grain based commodities. We 

validate over 16 analytical methods for 

determination of various factors, such as 

pesticide residues, mycotoxins, heavy metals, and 

fortified nutrients across various commodities. 

These testing services are now available to all 

USAID producers to ensure the food-aid products 

meet specifications and contracts. And some of 

these new methods developed can actually be 

applied to grains under the USGSA, and serve as 

market opportunities for fee-for-service testing.

 And lastly, in fiscal year '23 we 

began the process of improving our operating 

procedures and work constructions in various lab 

to TSD. This year, the biotechnology group 

achieved another year of ISO 17025 accreditation. 

And in addition, the commodities testing lab, 

trace analysis lab, and mycotoxin labs will begin 

-- they began -- excuse me -- conducting internal 

reviews of their processes and procedures, with a 

goal of identifying areas of improvement, as well 

as streamlining processes and insuring operating 

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procedures generate reliable and consistent 

results.

 Our ongoing efforts will go into 

fiscal year '24, where we'll be conducting a gap 

analysis of what do we have, and what else do we 

need in order to achieve an expanded ISO 17025 

scope.

 With that, I'd be happy to take any 

questions. I knew you --

MS. COOPER: I know you're very 

familiar with the impact on trade of unexpected 

GE events in, for example, wheat. How would you 

characterize the current acceptance of, or 

resistance to the use of CRISPR technology in 

grain such as wheat, or rice?

 DR. JHEE: You know, I think the 

possibilities out there are endless. When I was 

taking some time for this presentation to even 

learn what CRISPR stood for, the technology 

that's being explored right now includes 

everything from agronomic properties to herbicide 

tolerance. I think most of what we've seen so 

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far is primarily in specialty crops. Not so much 

in row crops yet. At least that's based off of 

what I've looked, in terms of some research.

 You know, market acceptance, I think 

because it's not adding foreign DNA, seems to be 

more of an acceptable approach. I think another 

challenge that any organization would face is 

that if you delete something, how do you find it? 

So I think that's an unanswered question that 

scientists are going to be trying to figure out. 

Organizations such as ours, I think we're doing 

our best to partner with other universities, 

other leading experts in this industry, to find 

ways to be able to kind of maybe assuage 

concerns.

 MS. COOPER: A question on a separate 

topic. Last year you published a method for 

evaluating new technology. Have you received any 

applications from any companies to evaluate 

devices for use in the official system?

 DR. JHEE: Not new applications or 

proposals, but we have engaged with two 

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manufacturers on some preliminary discussions. 

Primarily, they've been asking us about the data 

submission requirements. What is the length of 

time? What are some of the additional data and -

- and verification and validation studies that 

they should be conducting? We've had these types 

of conversations with a couple of grain analyzer 

industry -- or manufacturers, hoping to receive 

some proposals maybe in the third or fourth 

quarter this year.

 Yes, sir.

 DR. HURBURGH: A few years ago --

sorry. A few years ago -- ten, I think. FGIS --

GIPSA then -- funded a study on the equivalence 

of NIR machines. And I'm biased. We did the 

study in the day. But -- but what happened to 

the results? I think the results showed that 

with all practical effectiveness, you could get 

makes and models of instruments to read alike. 

What happened to that?

 DR. JHEE: That's a good question. 

I've have to look into that a little bit more. 

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But my understanding about the challenge between 

having multiple instruments --

DR. HURBURGH: Right.

 DR. JHEE: -- is the potential for 

variation and indifferences. One of the most 

important factors that we look for when we're 

looking at, or evaluating an instrument is the 

reproducibility.

 DR. HURBURGH: Yes.

 DR. JHEE: And -- and I think that's 

what's most important. And then when you're 

comparing one instrument against another, how 

well are they aligned in terms of any type of 

bias? And -- and do adjustments need to be made? 

We've been pretty successful with moisture meters 

in a couple of these grain analyzers that are on 

the market. But I do know that there's other 

technologies out there. Other ways of going 

about this. And so we fully anticipate looking 

at these instruments as well.

 DR. HURBURGH: Ours was done with NIRT 

machines. 

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DR. JHEE: Mm-hmm.

 DR. HURBURGH: We got to within .01 

agreement among -- among makes and models with a 

small standard deviation. I just wondered what 

happened. Anyway.

 DR. JHEE: And a lot of these 

instruments go through the, what's called the 

national type evaluation program as well.

 DR. HURBURGH: Yes. I'm on the 

Committee --

DR. JHEE: Anything else? All right. 

Thank you very much.

 CHAIR GROVE: I do have one here 

quick. Just -- I'm very interested in some of the 

-- the imaging technology. But actually, kind of 

the -- the camera in use that you were talking 

about. So that -- you are using this technology 

for training purposes. Correct? I think you 

have to -- about 30 slides back. Yeah. So 

you're using that for more training and 

verification --

DR. JHEE: Correct. 

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CHAIR GROVE: -- of your QAS --

DR. JHEE: Correct. Correct. It's --

it's intended to support, augment, and really, 

enhance communication. I think what the BAR, and 

actually, this is -- this effort's being 

spearheaded by Charlie Parr here, our deputy 

director. And I think we had initial concerns 

about, you know, would this be used for grading. 

Nah. We can't use it for grading.

 But with the number, and the 

importance of alignment, and -- and when we look 

at who we've been able to bring onboard into the 

FGIS family over the last couple of years, the 

QASs are relatively new. I don't say new, as in 

new in their position, but they're -- well, 

they're new in their position. And we've had a 

number of, I guess you could call, experienced 

QAS that retired. So that institutional 

knowledge left with them. So this is an 

opportunity for us -- at least the BAR -- to be 

able to connect with all of these new QASs, 

answer questions. You know, you can take a look 

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-- you can take some tweezers into a 3D 

rendering, take a look at the kernels, and be 

able to explain the damage a little bit better.

 CHAIR GROVE: I -- I think that's a 

good use of technology. As we talked, obviously, 

the -- the next topic, or you know, on our 

program is about our budget. An efficient use of 

our people. And again, getting to people in a 

timely manner. When you have new people, I -- I 

find in -- in our system, people get left behind. 

And so I -- I think that's a very good use.

 DR. JHEE: And I believe the -- these 

microscopes are relatively affordable. Charlie, 

what was the price point?

 MR. PARR: Sorry. Trying to follow 

the -- trying to follow the rules here. Charles 

Parr.

 The cost of those microscopes is very, 

very insignificant. They're like 50 bucks a 

piece.

 DR. JHEE: Pretty high resolution. 

Ten megapixels? 

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MR. PARR: Yes.

 DR. JHEE: So -- a little bit less 

than an iPhone, but still pretty good.

 MR. PARR: And the -- the big thing 

with those, is that they're -- they're really 

meant to facilitate a conversation around the --

the samples. The -- a lot of times when you're 

inspecting grain, it's not necessarily a color 

determination that you need to make. It may be -

- you could be having a discussion with somebody 

about the -- kind of the nomenclature of the 

kernel. Maybe some of the things that you're 

observing, you can describe. These video 

microscopes can be used via Microsoft Teams, so 

they're actually having a -- a live conversation 

about those kernels.

 They can be used in in-person 

training. We have -- the board of appeals and 

review has training boxes, where normally, during 

alignment opportunities, people can answer which 

-- whether they think it's -- it's damage or not. 

And then, they have conversations later on about 

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the results of those boxes. And when you can put 

that image up on the screen and everybody can 

look at it at the same time, instead of having to 

pass a box around, it just helps dramatically.

 Another use that the New Orleans field 

office -- the QAS staff there -- they're really 

excited about the use of them. They're using 

them to also conduct outreach with their -- their 

stakeholders. So when they give, kind of those -

- those grain grading classes for people taking 

in, you know, inbound grain at elevators, if 

they're offering training opportunities, it's a -

- a good use of technology there as well.

 DR. JHEE: Thanks, Charlie.

 CHAIR GROVE: Yeah, thank you for 

that. Again, you know, I think, you know, in 

numerous meetings in this room, we've talked 

about that technology piece. You know, most of 

the time, we think about, you know, that imaging 

technology that you were using. But utilizing 

any type of technology to, just make our industry 

more efficient, FGIS is part of that industry. 

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So making yourself more efficient, that's very 

good.

 DR. JHEE: Well, Arthur mentioned the 

technology and innovation summit that's going to 

be in Texas this -- this fall. Exciting 

opportunities there, especially, from what we've 

been able to learn from the cotton and tobacco 

program, and what technologies are available. 

We're going to definitely be open to hearing what 

some of the industry manufacturers have to say, 

and see if there's an opportunity to partner with 

them for FGIS and this industry.

 MR. PARR: And I just wanted to add 

one more minor thing about the use of the video 

microscopes, is that it also enhances some of the 

current procedures that we have. Right now, all 

licensed inspectors and authorized inspectors at 

FGIS can submit opinions to the board of appeals 

and review. So now they can kind of have a -- a 

conversation around those suspect kernels, and 

then immediately next-day air those kernels for 

that final determination. So we're not making 

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that final determination remotely. But we are 

expediting the -- to see if the -- we need to do 

-- go through that opinion process.

 DR. JHEE: Okay. Yes.

 CHAIR GROVE: Any other questions?

 Thank you very much. And we are going 

to go ahead and take our break at this time. And 

that way, we can put Denise on ice a little bit, 

and have her think -- till she brings her 

presentation. So thank you. And 15 minutes, be 

back in the room.

 THE REPORTER: Off the record at 10:05 

a.m.

 (Whereupon, the above-entitled matter 

went off the record for a brief recess.)

 CHAIR GROVE: We are back in session, 

for everybody online.

 MS. RUGGLES: Hi. I'm Denise Ruggles. 

I'm going to go over FGIS's financial overview. 

This year marks 30 years with FGIS. I've gone 

through two reorganizations. So just to kind of 

give some of my experience. 

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So we will jump right into it. I'm 

going to go kind of slow on each slide, so 

everybody can ask their questions as we're going 

through it. So we can -- we can always back up 

if we need to if there's some more questions as 

we go forward as well.

 FGIS's funding. We are comprised of 

actually two components. One is of the 

appropriated funding that we receive, as well as, 

we have user fee funding. The user fee, as 

described this morning, we have a cap in the 

appropriations bill, the 55 million on our user 

fee cap that applies to all of our user fee 

accounts. It's not limited to just grain 

exports. We have submitted that request. We --

and we've also asked to increase it to 60 

million.

 Of the 20 million in appropriations 

that we receive annually, we only get about --

this last time was 17.45 million of that 

appropriation. In the U.S. Grain Standards Act, 

you will see that we are authorized up to 23 

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million, but we have not received those since the 

reauthorization in 2020. We've only been getting 

about 20, and of that, we've been getting between 

16 and 17 million for FGIS use.

 PARTICIPANT: Denise?

 MS. RUGGLES: Yes.

 PARTICIPANT: -- just a basic question. 

Where's the difference going between 20 and 

17.45?

 MS. RUGGLES: Overhead costs. So part 

of it is related to GSA building rent for the 

south building, the National Grain Center 

facility, some overhead costs for the 

administrators group, the department, and things 

like that, that come out of AMS's budget.

 MS. COOPER: And then you and I have 

worked on the user cap -- the user fee cap 

allocation issue for, I would say, decades. And 

this committee has -- has weighed in before. 

What was the result of, kind of that effort to 

raise and -- and modify that cap? Can you just 

give a little historical background? Because 

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this -- not a new issue, in other words.

 MS. RUGGLES: So the reason we went --

we were requesting 60 million?

 MS. COOPER: Well, just --

MS. RUGGLES: To do the U.S. Grain 

Standards Act limitation.

 MS. COOPER: Yeah. What -- what 

happened to previous efforts to try and -- and 

give you more flexibility with that -- with that 

fee cap?

 MS. RUGGLES: So -- did you want to 

take it, Arthur?

 MR. NEAL: Arthur Neal, for the 

record. So we've gone through couple 

administration changes. So Denise and I both 

tried to work a department budget -- office 

budget and program analysis to get that lifted 

through Congress, but there's a extensive 

education process. Everybody doesn't understand 

the fee process. Everybody doesn't understand 

the cap.

 By the time we got people educated, 

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administrations changed. So you start all over 

again. So we're going directly to Congress. And 

so part of our update was to ask Congress to 

decouple the rice, the -- the pulses from that 

cap so they were only focused on grain. I think 

the intention was always grain. And so we're 

waiting to hear back from Congress on whether or 

not they will accept that request for a technical 

change.

 MS. RUGGLES: So on our user fees 

programs, we have the -- the user fee accounts 

for the U.S. Grain Standards Act. We have the 

inspection and weighing program, often called the 

export program. We have the supervision of 

official agencies program, which is our 

supervision account. We have our AMA rice 

inspection program, and our AMA commodity 

inspection program.

 For our user fees for the USGSA, we 

have actually three components. We have the 

grain inspection weighing, which has the 

hourlies, the unit fees, and the tonnage fees 

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associated with the grain market for FGIS 

services performed. We have the grain 

supervision account, which is services performed 

under grain for delegated states and designated 

agency, which also includes the -- which includes 

the supervision metric tonnage fee that we have.

 And we have the USGSA miscellaneous 

fees for other services. That component is our 

registration -- export registration program, as 

well as our designation amendments program. 

Those fees were just updated April 1st for our 

annual review. And that's the current fee 

schedule we're under right now.

 This is an historical graph of the 

supervision of official agencies program. As you 

can see, the yellow is the operating reserve, 

where we were in 2014, how it continued to climb 

in '15 and '16. And then, we implemented, as you 

can see, there's no green. We implemented a 

freeze on the assessment of the supervision fee 

at that time in 2017. So as you can see, there 

was no revenue brought in in '17, '18, '19, and 

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'20. That -- that supervision fee assessment was 

expired. And so then it was reinstated at its 

1.1 cent.

 So in the next fee change, we were 

able to change the metric -- the supervision 

tonnage fee amount. So then, the revenue, we 

were able to drop it down to a lower level to 

still continue to build -- to burn those --

operating reserve resources, to try to bring it 

to the -- we're trying to four and half months.

 Where we are right now for quarter 

three, is the 2023 level. We have brought in $88 

million -- or $88,000 of the 1.2 in expenses we 

had. And the reserve was down to $85,000. That 

is only through quarter three. So the 

obligations are often higher by now because we 

have booked entire years of some expenses, such 

as rent, agreements that we have with our HR 

services, IT services, et cetera. Those are 

booked for the entire year by now, by third 

quarter.

 So here we are with the revenue. As 

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you can see, we had '18, '19, and '20 -- as I 

said, we didn't bring in any revenue. We brought 

in 1.6 -- almost $1.7 million in '21. We were 

able to bring that fee down, so we only brought 

in $390,000 in '22. And as of quarter three, 

we've only brought in $90,000. Those will 

continue to come in as we bill -- after a month 

closes. So right now, we're preparing in 

September to bill for August supervision fees. 

So we have continuing revenue coming in on those 

streams.

 Is there any question about third 

quarter? We -- we're at one month of operating 

reserve by the end of third quarter this year. 

Okay.

 Here's the historical graph for the 

inspection and weighing program. As you can see, 

the revenue -- we were bringing in '14, '15, and 

'16, and '17 was extremely high. We were doing 

the reduction in fees, starting with the 

reauthorization in 2015, but they actually didn't 

-- the fee change didn't happen till 2017 fiscal 

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year. And the -- the reduction started 

occurring. And you can see the costs remained 

pretty steady, but we did have some increases, 

and we did have to compensate with other 

resources.

 As of the end of quarter three, with 

the tonnage dropping -- is dropping 

significantly, we were at a negative 4.8 million 

in the reserve amount for the grain account 

alone. Again, as I mentioned before, some of the 

obligations are booked for an entire year. So we 

have agreements -- maintenance agreements and 

rent, et cetera, that are all booked up for the 

whole year. So those will - the costs will stay 

stagnant on those amounts, as the revenue 

continues to come in for those months.

 Any questions on this graph?

 MS. COOPER: Just interested in 

historical export tonnage. Whether -- what 

percentage of the annual comes in in that fourth 

quarter?

 MS. RUGGLES: It is harvest for fourth 

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quarter. I don't know exactly how much of it. 

Usually, between August to January, is usually 

our largest portions of the year of tonnage. But 

this year, with the -- the tonnage is already --

is been less this year, than it has been in 

previous years. So I'm not sure how that --

exactly what our outcome's going to be.

 MS. COOPER: So it did --

MS. RUGGLES: We're still down 21 

percent.

 MS. COOPER: It may improve, but not 

enough to bring it up? Okay.

 MS. RUGGLES: Yeah. Yeah, we're down 

21 percent compared to last year alone.

 DR. HURBURGH: What is the contingency 

if that number stays negative?

 MR. NEAL: That's part of this 

conversation, Dr. Hurburgh, is that --

DR. HURBURGH: Okay.

 MR. NEAL: This -- this presentation's 

going to talk about way forward -- potential way 

forward. 

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DR. HURBURGH: Okay.

 MR. NEAL: Great question.

 MR. WILLIAMS: Denise. So what was 

the actual balance -- the fund balance at the end 

of 2022?

 MS. RUGGLES: I think there's a graph 

in here for that. You mean for the --

CHAIR GROVE: She's going to get to it

 MS. RUGGLES: Yeah. The operating 

reserve. I think I have that as another slide.

 MR. WILLIAMS: Okay. That's fine.

 MS. RUGGLES: So -- so history of 

fees, I just wanted to give a -- questions have 

come up about when did metric tonnage fee come 

into play, some different things like that. So 

in October 1st of 1996 is when they broke the --

the fees for this inspection and weighing program 

into three categories. They had the hourly rate, 

which covered our direct labor costs. The unit 

tests and service type rates, which is like our 

stowage rates, aflatoxin testing, et cetera. And 

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then our metric tonnage administrative charge to 

recover indirect costs for field offices and 

headquarters.

 They would publish that and it would 

be a set amount for everybody across the board. 

Then in October 1st of -- also in October 1st of 

1996 till 2004, the administrative tonnage was 

based on a six-tier tonnage rate. Meaning, after 

you ship so much it was a certain rate. After 

you shipped more, it was a lower rate, and it 

continued down for six levels. So the more you 

shipped, the lower your tonnage rate went.

 Then in 2004 there was a review done 

and they wanted to change the fee based on a 

regional rate, so that certain areas weren't 

supplementing other areas for their tonnage 

levels. So that's when we broke it down to be, 

like, the Pacific Northwest, Toledo, League City, 

and New Orleans. All had their own local tonnage 

rate. As well as, we had a national rate for all 

the other exports coming out of the domestic 

market. 

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That went on until 2016, when the 

reauthorization rule went into effect, which 

changed in 2017, January 1st, with the 

implementation of the five-year rolling average 

for tonnage. And using only prior-year national 

local costs in that formula that was created.

 So here's the annual review that we 

often talk about. So the annual review, with the 

2020 reauthorization, we dropped it back to it 

doesn't have January 1st as the effective date 

anymore. It just has a year. So in 2021, we 

published -- I think it was February 1st -- the 

new fees that went into place.

 The first thing we do is we look at 

our tonnage rates. We take the national tonnage 

and we figure out what the national costs were, 

and we do a formula calculation on what the 

national tonnage rate would be. That's our first 

component of the fee review that we do annually.

 Then the second component is when we 

talk about the local. So I'm going to go into 

the national first. Oh, and I want to mention 

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that when we talk about tonnage -- export 

tonnage. Land-based carriers to Canada and 

Mexico shipped by official agencies are excluded 

from the national tonnage rate. Those are covered 

under the supervision program's supervision fee. 

So those land-based carriers to Canada and Mexico 

are not assessed the national tonnage rate for 

what official agencies are doing. Just wanted to 

bring that clear, so -- yes?

 MR. NEAL: Hey, Denise, I just wanted 

to also add a -- a comment on the -- you know, 

for each calendar year, starting with 2021, the 

service will review fees, including the section, 

and publish fees each year, according to the 

following.

 So what was happening -- and we've 

talked about this in other settings -- every 

year, our fee schedule -- fee schedule was 

getting approved and posted later and later. And 

so we were in automatic violation of our own 

regulation, that we couldn't control. So our 

goal is still to get the fees published at the 

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beginning of the year. It may not be January 1, 

but by January, February. That's still the goal. 

And that still has to be communicated. But what 

we didn't want to be is in a position where we 

are knowingly not meeting our own regulation. 

And so I just wanted to give context for that.

 MS. RUGGLES: Thank you. And also, we 

ran into a challenge where there was a question 

about whether we should be retroactive. And we 

didn't want to do that industry. To -- to 

publish late, and then go back and charge the fee 

as of an earlier date.

 So the national tonnage rate in the 

2023 review that we did for the national tonnage 

rate has the five years of -- the tonnage for 

each of the years, and what the rolling average 

was. This was all published in the Federal 

Register. It also has what our national cost is 

for a historical purpose.

 So you can see where we were for a 

national cost for each of these years, and where 

we were in '22. As of right now, we don't have 

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the final numbers for '23. But this is where the 

calculated fees were each of those years for the 

national tonnage.

 Also mentioned is the effective 

national tonnage fee. This was the last time we 

published under the prior formula before we 

implemented the five-year rolling average. So 

this was published. Then we did the five-year 

rolling average, and then we had -- the decision 

was based on the reserve amount, that we had a 5 

percent maximum reduction. So here's what the 

fee calculated. And this is what the fee 

actually was.

 So each year, we would calculate, and 

then we would have to do a reduction based on the 

operating reserve portion. Which I will discuss 

the operating reserve part of the fees. But I 

wanted to show why -- what calculated versus what 

people were paying doesn't always seem to match. 

It was always a question. So the calculation, 

then we did a reduction. Calculation, and we did 

a reduction. 

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This year, we only did 2 percent. 

This year, we had to do a maximum 5 percent 

increase. So with calculation, then the 5 

percent increase. The calculation; the 5 percent 

increase. This year was the calculation and a 5 

percent increase. So this is what we implemented 

on April 1st, this 3.3 cents for the national. 

Any questions on the national part?

 Here's the local. So the local fee --

tonnage fee -- as you can see, is the tons for 

the five years for each of the office. The 

Pacific Northwest, formerly known as Portland 

office, with the merger that we did of there, 

between the Olympia office closing and the North 

Dakota office closing. We renamed it to the 

Pacific Northwest. Toledo, New Orleans, and 

League City. Here's their five years. And here's 

what the five-year rolling average for each of 

those offices was. For this 2023 local tonnage 

review.

 Here's what their '22 local 

administrative costs for each of those offices. 

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And here's what the calculated fee was prior to 

the operating reserve adjustment. So Pacific 

Northwest calculated at the -- the 11.9 cent per 

ton, but then we had to adjust that to add 5 

percent. Is there any questions on that?

 This is just the local. That's not 

what you would pay -- if you were going to League 

City, you wouldn't be paying seven and half cents 

because this is just the local. The local and 

the national get added together when the fee is 

actually assessed. Any questions on the local?

 Okay. So here's the portion -- the 

section of the regs where we do the operating 

reserve. And one of the areas I wanted to point 

out is the -- that we are adjusting the fees 

based on each million dollars by 2 percent, 

rounding down if we need to. Rounding down, 

meaning -- so if it's like 1.1 million, it's 1 

million. If we're excess of -- of four and a 

half times -- if it's less than four and a half 

times, we have a maximum increase of 5 percent.

 What that means is if we are at $3 

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million under our four and a half reserve amount, 

we can still only go up 5 percent. Even though 

the calculation would be -- three million would 

be -- would be 6 percent. We are maxed at 5. We 

cannot go more than 5.

 Same with when the reserve is greater 

than four and a half months. For each million we 

do 2 percent, but with a maximum of 5. So if we 

were over by three million, we still could only 

reduce by 5 percent. Any questions on that?

 MR. NEAL: So John Morgan's in the 

room and I have to be very careful how I say 

this. Just kidding. So we did something very 

similar with the rice industry couple of years 

ago. We had an excess in our operating reserves 

for the rice account. But what we did for the 

rice account -- we reduced -- we had two years of 

a 20 percent reduction, and then we -- we started 

gradually right-sizing their fees.

 So they didn't drag on five, six 

years. We tried to do it quickly, and return it 

back to a regular operating state. And I think 

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their last increase should go into effect 

starting in October. But this was a little 

different for us.

 MS. RUGGLES: So here's the historical 

levels of the operating reserve that was asked. 

So here's where we were for revenue in '16, '17, 

'18, '19, through '22. This is where are 

estimating '23 to be at. We're just putting in 

some estimates, 'cause it was part of the fee 

rule conversation we're going to have later about 

this periodic fee review that we've did.

 Here's where the obligations were for 

the program. As you see, we have some notes. In 

'21, we did adjust the obligations by 2.471 

million, with using some Cares Act funding. That 

helped offset some of the staffing that had 

gotten ill. Some additional costs we had 

involved with people having to travel to cover 

areas where we had some shortages in staffing, 

and things like that. So we used the CARES Act -

- CARES Act funding to offset some of those costs 

for this program. 

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And then in 2022, we had some 

additional appropriated funds that we hadn't used 

because of some staffing that didn't happen, 

travel was restricted, things like that. So we 

were able to offset some of our overhead 

obligations with those resources we still had 

available. Such as IT, some service level 

agreements that we had, some other items as well. 

This year, we're doing the same review for 

staffing, where we had some staffing shortages, 

where we didn't fill some positions, where we 

were able to move people around. We're looking 

to see if we have some extra resources that we 

can rebalance this account, so we don't close at 

this serious four and a half million dollars. So 

we're looking at seeing what funds we have 

available. So this is still ongoing. That's --

'cause we're still in the year.

 So here's where we were with our 

surplus or deficit. So we had a surplus in 2016. 

So that caused -- the fees were at five -- five 

months -- 5.7 months, so that triggered the next 

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year to have a 5 percent reduction. In '17 we 

had a surplus again. This brought the reserve 

even higher. And of course, that was because we 

had that already defined fee revenue. So then, 

by the time we implemented it on January 1st, 

we'd already three months, which was our busy, 

you know, harvest. October through December 

brought in a lot more tons under the old rate. 

So then we had another 5 percent, 'cause we were 

at seven months of reserve.

 In '18 we were at 6.6, which triggered 

another 5 percent reduction. But in '19, we were 

down to five. So we were only a half of a month 

too high from our trigger. So we only did a 2 

percent adjustment.

 Then in '20, we -- we were -- dropped 

below. We were down to 3.4 months. And we had 

to increase by 5 percent. That didn't cover our 

costs, so we had a further drop. We were down to 

2.2 months, so we needed to do another 5 percent 

increase. In '22, we dropped down to having, 

like, just one month, so we did another 5 percent 

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increase.

 This triggered our periodic review, 

because we can't -- the 5 percent is not going to 

cover it. And I'm going to go into some of the 

challenges we've had on what's causing some of 

these increases. Any questions on the chart?

 MR. FRIANT: Nick Friant with Cargill. 

So on the -- I just want to better understand 

your footnote B. So obligations in the chart 

show thirty- five eight. So does that mean --

that number would have been bigger if you hadn't 

rebalanced with appropriated funds?

 MS. RUGGLES: Correct.

 MR. FRIANT: Okay.

 MS. RUGGLES: And this year would be 

higher if we didn't rebalance as well.

 MR. FRIANT: Okay.

 MS. RUGGLES: Yeah.

 MR. NEAL: So our objective has been 

to slow down the hemorrhaging. And so we --

we've tightened our belts into the appropriated 

areas and we've moved overhead costs and 

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administrative costs that are not necessarily 

being directly experienced at the field office 

level, but are coming from other areas. And 

we've been paying for that with appropriated 

funds so that we could take some of the pressure 

off of the user fee account. And we've been 

doing that since '20 at least. So that -- that's 

kind of been our method until we could figure out 

how to get the fees adjusted.

 MS. RUGGLES: And those funds have 

become available because of the staffing 

shortages we've had. We've had a reduction of 

some positions that use appropriated funding. 

Travel restrictions, things like that. So we've 

had some of those resources. We've also had 

people move on details, which freed up some 

funding as well. So those resources have come 

available towards the end of the year. We see 

those resources and we can redo that rebalancing.

 So here's where we are at the end of 

the third quarter. This is published on our 

public website. We publish each quarter, just so 

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you can monitor how we're doing in our user fee 

programs. This is where we were with revenue at 

the end of our third quarter, which was June 

30th. Obligations, where our losses were, what 

our operating reserve is for each of the 

accounts.

 So this is the supervision account, 

the rice program, the commodity program. And 

this is our entire account as a whole. So the 

entire user fee program as a whole, is $1.98 

million in the hole at the end of the third 

quarter. Any questions on that?

 MR. MORGAN: So that's -- that's nine 

months into --

MS. RUGGLES: Yes.

 MR. MORGAN: -- you have three months 

to go? Okay.

 MS. RUGGLES: The supervision account 

is actually -- the revenue is -- is not nine 

months, it's eight months because we bill a month 

later. So it's actually the -- so the 

supervision revenue is short an extra month. 

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MR. MORGAN: Okay.

 MS. RUGGLES: So here's the breakdown 

of costs to help you understand how our spending 

is occurring. So here's what the five-year 

rolling average tonnage would have calculated as. 

We put that up here just to give you an idea. 

Where we are right now at third quarter, compared 

to the previous year. And then our metric tons --

that's -- no. Excuse me. Let me back up.

 This is the five-year rolling average 

calculation for the fee reviews. This is what 

'23 calculated that it should be for the fees 

that we implemented on April 1st. Here's where 

we are by third quarter. So the only year that 

the five-year rolling average and the fiscal year 

matched was '22.

 So if you look at all these other 

years, in 2016, the five-year rolling average 

that we should have been at 105 million, we were 

actually at 122. In '17, it said -- the fee 

review said we should be at 107. We were 

actually at 135 million. '18, the one hundred --

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114 million, but we were actually at 129 million. 

So you can see what's -- how some of these shifts 

have happened.

 Then in '19, because we had these big 

years of -- of tonnage, it drove up what our 

rolling average is going to be, but in actuality, 

we actually had lower years. So then we dropped 

down to actually only bringing in on 107, 110. 

This year was a -- an -- the opposite. And then, 

this year, we were only matching. So this year, 

we're anticipating 21 percent lower than the 

previous year. So 21 percent lower than this --

this year -- '22.

 MR. SINNER: Denise. How do we 

explain this? How -- how do -- how do we explain 

this lower tonnage? Where is it? What's 

happening? Is it crushing? What -- what's going 

on there? Do we -- do we know?

 MS. RUGGLES: I don't know. Maybe 

Arthur can explain it, or --

MR. NEAL: I mean, honestly, I think 

the -- the export -- exporters in the room could 

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probably explain it better. But the reality is 

that we're just moving less. Some of it is going 

to domestic markets. China's cancelled a lot of 

contracts. They're purchasing from Brazil. And 

so we're just moving less grain. There are more 

refineries going up across the country. So 

domestic grain is moving to those refineries.

 Part of the conversation we had with 

some industry yesterday was about, you know, how 

do we look moving forward. If -- if markets 

don't realign to what they used to be. So these 

are some conversations that we'll have to have 

down the road.

 MS. RUGGLES: So then, below is all 

the categories of our expenses. So as you can 

see, of 17, 39 -- 39 and a half million dollars -

- 33.6 of that was just salaries and benefits for 

FGIS staff. So of our categories, it shows you 

where our expenses are for the total balance of 

our -- our total obligations. Where those 

categories are. And as you can see, salaries and 

benefits is our largest category for all of our 

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spending.

 Travel can come in about -- come in 

high sometimes, depending on how much travel we 

have to do. A lot of those travel costs are 

reimbursable. Some of them are related to maybe 

relocation costs. And then our other services are 

related to -- that's our ticket item where our 

overhead obligations are placed. Maintenance 

agreements, service agreements that we have with 

other departments, like IT, et cetera. Those --

those categories fall under other services. So 

any questions on that?

 MR. FRIANT: Where -- so -- so first 

of all, thank you. Thank you for providing the 

breakdown of costs. We've been asking for more 

clarity on that. And absolutely appreciate having 

-- having this information.

 How does -- how does what's on this 

chart, breakdown of costs -- where do the 

national admin costs factor into this?

 MS. RUGGLES: The national tonnage 

costs? 

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MR. FRIANT: Yeah. The -- yeah --

yeah, that's used to calculate national tonnage 

fee?

 MS. RUGGLES: Yes. So -- so that does 

fall under salaries and benefits. That would be, 

you know, our -- our directors, our associate 

deputy administrator, my expenses, FGIS online. 

We're in that salaries and benefits category, 

along with the direct service labor as well. But 

-- but our component is a part of that.

 We also have travel expenses for 

different industry meetings, et cetera. We have 

other services, which is the administrator's 

office, their support staff, central charges, 

which are departmental. Green Book fees. I'm 

trying to think what other things could be out of 

there -- kind of help you understand some of 

those items. So those are categories that would 

go against the -- the national tonnage rate, as 

well as if we had any supplies for our local 

groups.

 Oh, the IT for FGIS online falls in 

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the other services. We're not really in the rent 

and utilities, 'cause as I explained, the south 

building is under the appropriated portion that 

we don't get. And I'm housed at the National 

Grain Center, which is also covered under the 

appropriated. So a lot of that isn't -- we don't 

have any rent.

 So the largest portion -- there's a 

portion here under salaries and benefits for, 

like, FGIS staff. And then, like I said, the 

administrator's office for AMS, departmental 

charges, Green Book fees, et cetera. And those 

service level agreements we have. Does that 

answer --

MR. FRIANT: So it's spread across 

multiple --

MS. RUGGLES: It can be. Yeah. 

Different categories -- we have different 

components. 

MR. FRIANT: Great. Thank you. 

MS. RUGGLES: Any other questions on 

this one? 

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Okay. So challenges we have with the 

annual fee review. I know that's come up. Why 

can't we post faster. One of the challenges I 

have is the fee review cannot start until all 

tonnage is reported. We have a delay of up to two 

weeks with industry deciding, are they done 

loading? Have they figured out all of the 

services that they're finishing on those 

shipments? And once they finalize that, then 

they finalize the tonnage billing.

 So if a ship finishes and they've 

decided that September 30th services is the last 

time any new services are going to be done on 

that load, they will put it in the system. I --

I have the tonnage coming in up till October 15th 

as industry's deciding how they want to finish 

those loads.

 If they add more to it or add more 

services, then it shifts to the next fiscal year 

because then the ship is not completed in this 

fiscal year. It doesn't complete till the next 

fiscal year. So then that ship moves. So it 

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might have started in one year, but it doesn't 

actually finish till the next year. So we're 

kind of in a two-week holding pattern on that.

 The second challenge is the fiscal 

financial reporting is not completed until 

October 31st. We close the books on the 30th, 

but then there's a lot of documents that they 

finish up through October completing the process. 

It's called period 13. They're finishing that 

up. So we get final financial numbers, not until 

November 1st. So we're dealing with tonnage and 

those financial numbers not coming in till -- so 

we can start it on November 1st.

 Then the other challenge we have is 

that the Reauthorization Act of 2015 -- the 

regulation that was put in place only lets us 

look backwards. Doesn't let us look forward. So 

we are in -- and I'm going to talk about this 

coming up -- COLAs. We've already had been given 

-- and we're supposed to estimate our COLA, our 

increase of staffing for January 1st.

 (Off-microphone comments.) 

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MS. RUGGLES: Cost of living 

adjustment. That's coming up -- it's -- I'm 

going to explain it a little bit further here --

about those different adjustments that we -- so 

we know that's coming. We don't know exactly the 

amount, but we can't figure that into those 

annual fee reviews. So when we do know 

something's happening, we're only looking back. 

We don't look forward.

 The other challenge we have is the 

limitation on the 5 percent increase or 

decreases. That's a challenge. You know, you saw 

on some of those categories, we should have done 

larger decreases, we should have done larger 

increases with the changes in costs. Or with the 

reserves being too high.

 And the other challenge is, often 

times, some people are looking at our export 

tonnage rates that we're publishing each week. 

And they don't understand that you need to remove 

the -- the rail and the land-based carriers to 

Canada and Mexico, which is our rail and trucks 

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being services by official agency. So those are 

reported in our export numbers, but they do not -

- are not assessed the national tonnage rate or -

- so that's another challenge.

 Historical hourly rates. I wanted to 

go over that to show you where we are for the 

different contract and non-contract. Oh, do you 

need me to go back?

 MR. FRIANT: On the -- on the delay in 

tonnage reporting. I know that there's been --

and I -- I don't know all the correct terms. But 

I know there's been some challenges in the 

reporting system that is used by -- help me, 

Chris. The -- watching post -- I know there's an 

electronic reporting system and there's been 

challenges with that reporting system being 

rolled out. I think it's through ERS? I'm 

wondering if that would -- if that impacts the 

reporting that you're getting for tonnages?

 MS. RUGGLES: Well, our delay is 

because they can't close out those inspection 

logs until all final --

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MR. FRIANT: Okay.

 MS. RUGGLES: -- and that builds the 

tonnage.

 MR. FRIANT: Okay. So it's FGIS 

inspection logs --

MS. RUGGLES: Yes.

 MR. FRIANT: Not an external report. 

Okay.

 MS. RUGGLES: Now but I don't know 

what challenges on why the decision, or delayed 

on making decisions on when to close those ships 

out. I don't know if they're still really 

evaluating, can they get more grain on? Should 

they take grain off? I'm not -- you know, I 

don't know if there's more inspection services. 

Maybe they want to do aflatoxin. I don't know 

what's delaying the -- up to two weeks for those 

ships to finish.

 MR. SINNER: Denise. One -- one other 

question. On that last point, why are land 

carriers assessed? Explain when that change --

or when that was implemented, or what -- why is 

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that?

 MS. RUGGLES: It was implemented at 

the time they did the breakdown for the regions. 

So when they decided they were going to do 

national and local tonnage back in -- I'd have to 

back up -- prior to the rolling tonnage average 

that we put into place. So on that first chart 

we talked about it, when they talked about 

regions. It was decided at that time to not 

assess it on land-based carriers to Canada and 

Mexico. They were separated out in that 

rulemaking.

 MR. SINNER: Okay.

 MS. RUGGLES: Containers, though, are 

-- are assessed export tonnage, regardless if 

they're offloaded domestically. Because the 

intention of using that conveyance is to export. 

But there might be a challenge where you loaded 

and it didn't make grade, so the container cannot 

leave the country. We still charge the export 

tonnage, 'cause the intent was to export it.

 Historical hourly rates. So this is 

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the component of the direct service rates. This 

is your contract and non-contract. We used to 

have three months, six months, and we dropped it 

down to just one-year contracts, and no 

contracts. So here's the historical view of 

where we were in 2016 before the regulations were 

implemented with the Reauthorization Act of 2015. 

And then these are the rates that were a part of 

those components.

 So what I'm saying by that is we 

calculated the tonnage fees and everything, and 

then we looked at our operating reserve. And 

then we adjusted this rate up or down 5 percent. 

So that's where this 5 percent is coming into 

play, up or down. So we figured out where the 

reserve was. We reduced the hourly rate by 5 

percent. We figured out what the reserve was. 

We reduced it by 5 percent. You can see that 

here. So this was prior to the formula change. 

These are the reductions that we implemented each 

year. Or increases.

 So this shows you the trend of where 

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we were. The last time this was our highest 

contracted rate at the time before we 

implemented. The other we want to point out is 

that I don't know if anybody's noticed, but our 

one-year holiday -- contract holiday has always 

been the same rate for all non-contract rates. 

Meaning, there is no adjustment done if a noncontracted facility wants to work holidays. They 

pay the same rate whether they do it Monday 

through Friday during regular time. They pay the 

same rate. There's no -- there's no incentive for 

them to work during regular hours. The rate is 

the same, regardless.

 MR. NEAL: Denise, and just to also 

clarify, or illustrate. If our employees work on 

the holiday, we pay them double.

 MS. RUGGLES: So is there any 

questions on this historical of what our rates 

have been, and what we implemented on April 1st? 

This is what our rates are right now. So as you 

can see, right now, as of '16 -- as of our April 

1st, we still haven't brought ourselves up to 

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even what the '16 level was yet. Any questions?

 So here is a comparison to the other 

AMS programs that are under a different model of 

fee adjustments. So here's where we were in '16; 

here's where we are in '23. Here's where the 

dairy program is for contract; here's where the 

fruit and vegetables for processed -- they don't 

have a contract rate for their fresh vegetables -

- fruits and vegetables. They only have it for 

processed. The meats program, which I would 

suspect is livestock and poultry, but they call 

it meats. And then the egg and poultry -- or 

livestock, I guess. So there's where they are in 

their contracted rates versus their noncontracted rates.

 As a comparison of FGIS's 2016, '23, 

our current rates, and where those programs are 

at this time. And this was as of the fees that 

are in place right now. They are having a fee 

adjustment done on October 1st. They publish at 

the same time we publish our rice ones. Any 

questions? Just trying to give you a concept of 

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where FGIS is standing compared to some of the 

other programs.

 So for the periodic fee review. This 

year we implemented the periodic fee review. We 

brought together a team that was assembled with 

FGIS staff, that included division 

representation, field office representation from 

all of the different areas in the country. And 

they brought -- they brought together what their 

costs are, locally, for doing various services.

 To give you an example. How long does 

it take -- what kind of grade level are you using 

to do an aflatoxin? What -- what's the cost of 

the -- the equipment you're using? What are your 

consumables? Is there any training you have to 

do? We had them put that all together for all the 

different services that they offer in their area.

 And then we weighted it and compared 

it. I'm not going to those comparisons in our 

scenario as to what we did, but that's what we 

did. We brought together the groups across the 

country, and they all put in their input. Even 

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the BAR participated. Different labs here 

participated that do grain testing. They all 

participated and brought back feedback on what it 

would cost to recover their costs of doing these 

services.

 That was scenario one. And then we 

adjusted it because we -- you know, they were 

just covering what their costs would be. Then we 

have to add in for all the other costs. You 

know, different groups overseeing it. Like Ed 

Jhee's costs for being the director of the 

building, the AMS -- the admin staff for TSD, 

things like that.

 Scenario two that we did. We 

implemented AMS's standard formula with a 

reduction in the rates. Because the original 

calculation, which is what we did in scenario 

four -- we did do a reduction for the calculated 

rates based on that formula. The formula we're 

talking about, I will describe later what that 

AMS formula is. It is a formula that the AMS 

implemented for all of their AMA programs. We 

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implemented it with rice two years ago. This is 

the third year we're using it for the rice 

program. We will also implement that on the 

commodity program when that one gets completed.

 The difference between scenario one 

and scenario two with the standard formula, with 

the reduction of the rate calculation, is related 

to the overtime and holiday calculations. The 

formula, as written, says that the overtime rate 

will be one and a half times the regular 

calculated rate and the holiday is two times. We 

have a little bit of lenience on that, and we did 

do some adjustments for that in our rice program 

as well. So the scenario three is actually 

taking the overtime at one and a quarter, with 

holiday being one and a half times the regular 

rate. Any questions on those scenarios that we 

did, how we came together?

 MR. NEAL: And part of the reason why 

we modified the overtime and holiday rate is 

because we knew that the industries that we're 

servicing -- they had not been experiencing these 

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type of wide swings in fees. And so we wanted to 

mitigate some of the impact on the rates. And so 

that's why we modified those overtime and holiday 

pay rates.

 MR. MORGAN: John Morgan. I -- I 

believe rice is using scenario two.

 MS. RUGGLES: Correct. But I -- I 

would have to look.

 MR. MORGAN: I'm looking at them right 

now. It's definitely scenario two.

 MS. RUGGLES: Yeah. But I don't think 

we reduced the regular rates. I think we 

actually calculated the rate, and then we did one 

and a quarter and one and a half.

 MR. MORGAN: It looks like one and a 

half and two.

 MS. RUGGLES: Oh. Did -- it is 

scenario three?

 MR. MORGAN: Yeah.

 MS. RUGGLES: Or scenario two, I mean.

 MR. MORGAN: Yeah. Just --

MS. RUGGLES: It -- I think the second 

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year, we did -- stuck with the --

So here is the AMS formula -- standard 

formula that's published -- and there's -- and I 

have the federal rice -- 'cause we have it in our 

regulations now. 'Cause we are following that 

same formula with the rice. So this is out of 

our regulations for the rice. So this is the 

steps.

 So each year we calculate the regular 

rate based on the person performing -- the 

personnel performing direct services, divided by 

the number of direct hours. And then we multiply 

it by the cost of living increase for the next 

year. So that takes consideration what's going 

to happen for next year. And then we add a 

benefits rate to it. We also add an operating 

rate to it, and we also add for bad debt 

allowance.

 FGIS's bad debt allowance is really 

small, because we have three components on making 

sure we get -- are collecting our fees before we 

have to refer somebody to U.S. Treasury. So we 

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have a lot of efforts put in on debt management. 

So our allowance for bad debt is like nothing, 

really.

 And then we don't include travel 

expenses in our hourly rate, because our -- we 

charge for travel. It's a one-to-one 

reimbursement for those costs. The overtime 

rate, again, is the calculation of -- and you're 

right, John -- we did do one and a half, and the 

two. So that takes the regular rate calculation 

and takes it by one and a half. And then we do 

the holiday rate and take it times two. That's 

the standard formula.

 In addition to that, it also looks at 

how you calculate a benefit rate. There's a 

formula for that. And then there's the operating 

rate, how you calculate that. And then the 

allowance for bad debt. It talks about those 

components that were mentioned before. And then 

we also adjust for economic factors that are 

released by OMB, for inflation and -- and other 

factors that are used. The cost of living is 

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figured in the hourly rate part. Any questions on 

the formula? Yes, Jimmy.

 MR. WILLIAMS: Denise, I have a 

question. Could you go back a few slides? Back 

to that slide where you show the salary and the 

salary costs for like the last six or seven 

years? So here's what I don't understand. So 

that -- that chart shows that salary and benefit 

costs were over 33 million in FY16? Is that 

correct?

 MS. RUGGLES: Correct.

 MR. WILLIAMS: Okay. And in FY23 

they're -- or at this rate, anyway, they're at 

21.9 million. What -- how do you explain that? 

How -- what's -- I mean, have you all reduced 

your staffing to that extent?

 MS. RUGGLES: Significantly. You saw 

all the vacancies we have. Plus, we are 

rebalancing. So you're seeing these rebalances 

we're doing. It's 'cause to offset some of those 

cost of living increases as well. We're going to 

talk about what all those cost of living 

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increases we've been absorbing over the years, 

that have been implemented on us every year by 

budgets -- the President's budget.

 MR. NEAL: Denise if you can go to 

volume.

 MS. RUGGLES: Go back to volume?

 MR. NEAL: By -- by office -- field 

office. Just to give you some perspective. 

We're working our people extremely hard. This --

you know, I wish we weren't. And I was sharing 

earlier, that -- you know, our employees would 

love for us to hire, so they wouldn't have to 

work seven days a week. You know, almost 12 to 

16-hour shifts. That's been the sacrifice that 

folks have been making so that we do not continue 

to add additional burden on the program. But we 

can't operate like that any longer, 'cause people 

are burning out.

 And so it -- it's -- and if you look 

at where the work is happening the most, it's --

it's New Orleans and -- and League City. And --

and look -- look at 2021. Seventy-two million 

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metric tons flown out of New Orleans. That's a 

lot of work. And -- and those are the folks who 

are asking for help. But we've got to get 

ourselves in a better position so we can give 

them help in a responsible way.

 MS. RUGGLES: And we've been trying to 

adjust to hold those costs down, just because --

where we can to help the industry.

 Try not to make everybody dizzy 

scanning back through these. So here's the 

financial impacts that we've been absorbing. So 

the financial impacts since the reauthorization 

of 2015. So the cost of living adjustments that 

we've experienced was 2017, we had a 1 percent, 

'18 was a 1.4, '19 was a 1.4. And then in '20 we 

got a 2.6. Then we got a 1 percent in '21. In 

'22 we got a 2.2. And then last year we got a 

4.1. Well, we're only adjusting fees by 5 

percent. A 4.1 is a huge increase on -- and when 

you saw our categories. Our largest cost 

category is salaries and benefits.

 This year's President budget --

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presidential budget request is 5.2. So you can 

see, a 5 percent increase wouldn't even cover the 

COLA alone. Not even talking inflation, or any of 

the staffing that has occurred that's going to be 

paid full-year next year, some of those items. 

So that's one of the challenges we're dealing 

with.

 And as I wanted to show again, is --

here's our salaries and benefit category, and 

this is the percentage that that category is of 

our total obligations. These years, again, we 

have assisted by offsetting some of those costs 

with CARES Act funding or available appropriated 

resources where staff can be rebalanced. Any 

questions on this one?

 And -- and also, our -- we have 

payroll distributors for TSD, FMD headquarters, 

the two branches of that, the director's office, 

PPMAB, and then the office of the deputy 

administrator. So we also look at those to 

rebalance if we can.

 The rate fee categories. I wanted to 

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show these. What are the challenges in our fee 

reviews. So the -- so the rate, fees, revenue 

categories. We have our hourly rates to recover 

direct costs. Those unit tests and service rate 

types and our metric tonnage. As you can see, in 

'22 our hourly onsite and applicants facility is 

64 percent of our revenue to cover our costs. 

Sixty-four percent comes from our contract and 

non-contract onsite hourly rates.

 One percent is for our other -- other 

hourly rate category, which is where we're doing 

testing, not an applicant's facility. That would 

be for, like, the labs here where they have an 

hourly rate. It only makes up 1 percent. So of 

our revenue, 65 percent of it is all just from 

hourly rates.

 Then we have our unit and service 

types. Which is our services per carrier, which 

is your weighing per carrier, stowages per 

carrier, those kind of fees. As well as 

aflatoxin texting. Grading factors like a factor 

-- factor only, board appeals, appeals, et 

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cetera. As well as export registration. The --

that component in 2022 was 6 percent of our 

revenue resource.

 And then our direct amount 

reimbursement. Those are services like travel, 

mailing costs, et cetera. Those are our straight 

hourly reimbursements. Not hourly. Actual cost 

reimbursements. That only made up 1 percent of 

the revenue resource.

 Metric tons. For our national and 

local tonnage, that brings in 28 percent of our 

revenue. So our two largest revenue components 

is the hourly onsite, contract and non-contract, 

and our tonnage rate. The rest of those units 

are not -- they don't bring in the revenue 

resources as those other two components. Just 

wanted to break that out on where the revenue has 

to come from to cover a lot of the costs. Any 

questions on this? Yes.

 DR. HURBURGH: How does the COLA 

percentage that you listed there match with the 

actual wage settlement changes with your 

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employees? Are the -- are the employees' 

salaries going up at the -- does that reflect the 

increase in the employee salaries, or are they 

going up faster than -- than what you are allowed 

for COLA?

 MS. RUGGLES: The COLA is our -- our 

cost of increase. That's what everybody makes. 

That's what we get.

 DR. HURBURGH: Okay. So that's an 

actual number?

 MS. RUGGLES: That's an actual number.

 DR. HURBURGH: Okay. All right.

 MS. RUGGLES: When they publish our 

new salary tables on January 1st, it has those --

whatever's been approved, and all of --

everybody's wage table increases by that amount. 

And then we have a little bit of locality pay 

adjustments.

 DR. HURBURGH: All right.

 MS. RUGGLES: Any other questions on 

this?

 So here was our period review 

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scenarios that we talked about earlier. The 

scenario one, the scenario two, three, and four. 

I -- and I put down below to -- I don't know if I 

killed the little thing here -- where the 

scenario would bring the operating reserve, and 

the number of months the scenarios do.

 So here's where we were in '16 again. 

Here's where we are right now at '23. Here's 

that scenario one, where we had that team that 

came together, said here's what it costs us to do 

this business. This is what our, you know, unit 

-- our equipment is, our maintenance agreements, 

our consumables, and then we increased it for all 

the components that we need to assist with that. 

So -- such as staff like Ed's group, the 

director's office administrative staff to do 

TNAs, et cetera, all that stuff. We adjusted 

that and inflation.

 Scenario two was the one and a half. 

Taking the regular rate calculation, applying one 

and a half, and two to the holiday. So you can 

see, 60 times 2 is 120. This is the contracted. 

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And then scenario three, we -- we changed it to 

be one and a quarter versus one and a half. And 

then scenario four is -- unmodified, this is what 

the AMS formula calculated that the hourly rate 

should be to -- to recoup our costs.

 So as you can see here -- and then I'd 

put in a comparison for the low program and --

the low program and the high program are the AMS 

programs. Where they are right now, today, 

compared to FGIS on these scenarios. If we 

implemented scenario one, the reserve would still 

be at a negative $1 million, with less than .3 

months. We wouldn't even get out of the hole 

that we're going to be in when we close '23.

 Scenario two would bring the reserve 

up to 2.8 million, or only .9 months. Scenario 

three would bring us up to .3 million, or .1 

months of reserve. And scenario four would bring 

us completely out of the hole, and put us at 13.7 

million and 4.4 months. So that was the scenario 

that -- to do it all at one time, in one year. 

And it actually only would be, like, nine months 

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of the fee adjustment, because you know, we can't 

get the fees in place October 1st. So we would 

lose, though, that busy season of October, 

November, and December. So this is a nine-month 

increase. Any questions on these scenarios?

 Okay. So also, in the same scenario 

basis we did the tonnage rate. What would the 

tonnage rate be on each of those scenarios. So 

as I explained earlier, about how the actual 

payment is always based on a component of local 

versus national. So here's what the published 

rates were in '16. Here's what the fees are 

currently in place. Right now, as of April 1st, 

the national is 3.3. This was the calculated 

rate for League City with that 5 percent 

increase, plus the national. This is what the 

League City customers pay for national -- or 

their tonnage fee, regional tonnage fee. Here's 

what you'd pay in New Orleans. Here's what they 

pay at Pacific Northwest. And here's what they 

pay in Toledo, currently.

 Scenario one. This is what it 

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calculated to be. Scenario two, the same thing. 

Scenario three, and then scenario four. Scenario 

four would be bringing the rate -- so we would 

get the full four, almost four and a half months 

of reserve. This is based on the five-year 

rolling average of the tonnage and what we're 

anticipating the costs are going to be for the 

national and local amounts. So this is following 

the similar process of the calculation of the 

tonnage fee and the five-year rolling average.

 So there really is no change between 

these three scenarios on the tonnage rate if its 

tonnage rate change is here. And that's to dig 

us out of the hole and bring us to the full, 

almost four and a half months of reserve. Any 

questions on that?

 MR. FRIANT: Sorry, Denise. I need to 

go back to the previous slide. I wasn't able to 

catch up with you. Can you explain -- well, I --

I have two questions.

 MS. RUGGLES: Okay.

 MR. FRIANT: One question, two parts, 

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 MS. RUGGLES: Okay.

 MR. FRIANT: So my first question --

so you -- the -- you've got the proposed change. 

The one-year contract, regular Monday to 

Saturday, 6 a.m. to 6 p.m.

 MS. RUGGLES: Correct.

 MR. FRIANT: And then, the -- the 

proposed overtime change. So my question is, if 

-- to Arthur's point, we've been working people 

12 and 16- hour shifts. So -- so if a person 

works, for example, a six to six shift -- 6 a.m. 

to 6 p.m. shift, they'd get eight hours regular 

time and four hours of overtime?

 MS. RUGGLES: So you would assume 

that, but we have three different scheduling 

components. So some people can be first 40. So 

then they don't -- they don't get overtime till 

that. And then we have -- Andy or Arthur 

probably could explain some of those other ones, 

but we do have, like, three different scheduling 

items. 

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We are removing -- so right now, you 

would pay -- so if we had a person work 16 hours, 

the industry pays eight hours at the regular 

rate, and then they pay the next eight hours at 

the overtime rate. That's what it is right now. 

We're looking to move to a time of day, not the 

person specific.

 So whether -- so meaning, you wouldn't 

need to worry about Billy working 16, versus 

Billy working eight, and Tommy working eight. 

You know, you're only -- you're going to pay 

based on a clock. We are also moving Saturday to 

become a regular day, which right now, it's not. 

Right now, it's an overtime day. So anybody 

working anytime on Saturday is automatically 

overtime right now.

 So we're looking to move to more -- to 

automate, so -- to automate the process where the 

system is calculating based on when somebody is 

working, not who the person is, how much time 

they've already worked, to calculate the rate. 

Does that make sense what I'm trying to say, 

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 MR. FRIANT: Yes --

MS. RUGGLES: We're trying to move so 

that in our online system for service requests, 

you would be able to see what that's doing in 

calculating your bills, based on a clock.

 MR. FRIANT: Yeah. Okay. That --

that makes more sense now. And then, based on 

what you just said, regardless of the time of 

day, Sunday is overtime?

 MS. RUGGLES: Correct.

 MR. FRIANT: And then holiday is --

MS. RUGGLES: Holiday.

 MR. FRIANT: -- also separate?

 MS. RUGGLES: Correct.

 MR. FRIANT: Got it. Thank you.

 MS. RUGGLES: Yep.

 So we took these scenarios, and we 

gave -- we picked one, and we picked scenario 

three. Scenario three is the one we picked. It's 

going to leave us at the end of '24 at the .3 

million reserve, with .1 months. We picked that 

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scenario and we forecasted going forward.

 So this is an outlook of what we think 

would happen if we implemented that. So here's 

where we are right now. And where -- what we've 

estimated we think this year's going to look like 

when we close. I am still addressing the 

rebalancing of the appropriated, 'cause I --

we're still trying to figure out what resources 

we have available right now. So we're still 

doing that.

 So this could be lower. And then, of 

course, revenue could be higher if something were 

to suddenly change that I -- you know, we 

suddenly get a lot of ships all at one time, we 

don't know. And then with the reserve amount. 

So this is that calculation -- what we're 

anticipating this year's going to be. 

Estimating, to implement the -- the scenario 

three, with the hourly rates and the unit rates 

and the tonnage rates. Which we didn't share 

every unit rate. There's a lot of them.

 What -- what it would bring in for the 

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reserve for the nine-month increase that we would 

be implementing. We would bring in this much 

revenue. This is what we're anticipating our 

obligations are going to be with the 5.2 cost of 

living adjustment that's in the President's 

budget. If we were to get something less, of 

course, that adjusts our costs. It totally 

changes the forecast. And then, what our surplus 

would be, where our -- we would end at the .3 for 

million reserve, with the .1 month reserve.

 If we continued on the next year for 

the rates, with doing a minimal increase just for 

cost of living of 2.9 percent, and holding the 

rates, we were looking at this amount. We would 

be at three months, and then we would be at 5.5. 

That's holding, only getting cost of living 

raises of only those amounts. If they're less, 

we would have to implement something different. 

But this was just a outlook, to see how it would 

look, looking forward. Where would we -- so it 

would take almost two years to get back to where 

we needed to be. 

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MR. SINNER: Denise, what did you do 

with tonnages -- projections?

 MS. RUGGLES: We held them.

 MR. SINNER: Okay.

 MR. NEAL: But when I -- when I've 

said this -- we left the tonnage fee calculation 

alone. So whatever the -- whatever the result 

from the tonnage fee formula is, we didn't 

manipulate it.

 MS. RUGGLES: Yeah. The five-year?

 MR. NEAL: Right. Using the five-year 

rolling average. We didn't add on any operating 

costs reserve recovery. We didn't add on any 

cost of living increase. We didn't do anything 

like that. We just let the calculation be what 

it is for tonnage fee.

 MS. RUGGLES: So this is what the 

rates would look like for those scenarios. For 

scenario three, if we did it in the out years. 

So this does have the 5 percent increase for the 

hours, and we held the 5 percent here. And then 

we held the tonnage with the calculation for 

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those two years.

 MR. FRIANT: And -- and that's just 

the straight calculation?

 MS. RUGGLES: For scenario three.

 MR. FRIANT: Yeah. Not -- not taking 

the calculation and adjusting it up? That's 

scenario four.

 MS. RUGGLES: We adjusted for the 5 

percent, 'cause we know we're going to be under, 

so we're going to do a 5 percent for the hourly. 

But that was it.

 MR. FRIANT: But not the tonnage. 

Sorry -- I meant --

MS. RUGGLES: The tonnage is 

calculated based on what we think the five-year 

rolling average is, and what -- and we were 

holding the cost for the -- the administrative 

tonnage -- the national tonnage rate and the 

local fees. We were -- we were holding them, 

except for the 2.9 percent increase. And then we 

held them. We didn't adjust them again.

 'Cause if we'd allowed them to adjust 

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again, 'cause we know we're going to be in the 

negative here. 'Cause we're still going to be 

under the four and a half. If we adjust the 

tonnage rates again, it -- it would be way too 

much. See how we're going to -- if we hold them, 

we're going to be at 5.5. But again, this is 

assuming, you know, the 5.2. If we don't get a 

5.2 and we get less. If we get more than 2.9. 

Those things can affect it.

 MR. FRIANT: Yeah. Okay.

 MR. NEAL: One thing I'd like to 

share, too, for consideration. So our current 

reserve target is four and a half months. Other 

programs have a six-month target or a year 

target. And it's to help them deal with these 

wide swings in volume. Because to -- to let 

people go if we don't have enough to cover shifts 

in -- in export volume, it's hard to get people 

back. And I just wanted to -- you know, as we 

think about ways to move forward, you know, are 

there opportunities to adjust the -- the reserve 

target? Or -- 'cause we continue to monitor it 

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closely. We'll just have to keep making these 

type of shifts to -- to ensure that we don't 

exceed it, or have less than enough to cover our 

-- our goal.

 MS. RUGGLES: Yes Chris.

 MR. FREDERKING: Yeah. Chris 

Frederking with Zen-Noh Grain. So certainly 

appreciate the background and -- and all the 

information that -- that has led to these 

different scenarios that were proposed. And I 

guess, as I'm sitting here thinking of probably 

being the tip of the spear as far as shouldering 

the expenses from the industry side, even 

scenario three, in a average year, probably for a 

regular export elevator, specifically down in the 

Gulf is probably somewhere in the neighborhood of 

a million dollars of extra expenses at the 

elevator level.

 So as we're looking at length of time 

to -- to get these new fees added in, or to 

right-size that operating reserve, sounds like 

you're projecting more of a three-year approach, 

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versus what I had heard, maybe with the rice 

industry, was a five to six-year timeframe. And 

just, maybe a little bit more perspective on 

what's the urgency with this scenario, or the 

scenarios proposed here, with the three-year 

versus a longer-term six-year -- five or sixyear?

 MS. RUGGLES: So the rice, we 

implemented quickly. They had two rejection 

years, and then went increases really quickly --

the opposite direction. That industry is like 

our third-sized program, or second-sized program 

when you look at our expenses. The grain is the 

bread and -- you know, it's our biggest program. 

It -- it's very large.

 So just -- a little bit of cost 

increase, really, it's -- it affects us 

significantly, because it is such a large 

program. $33 million, you know, is this program. 

Where the rice isn't that large.

 MR. NEAL: And the other thing, too, 

Chris. This is a proposal, like I said, we are 

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anticipating tolerability. What can -- what 

could industry tolerate. Well, not what can. 

What will they tolerate. We're trying to propose 

a way forward that is reasonable. We're not 

trying to recover all, knowing that the costs 

could be -- the expense that you have to carry 

would be far greater.

 The other thing, too, is the approval 

process we discussed. How do we make sure that 

we're taking something forward through the 

briefing process that has to get approved by the 

Secretary, that seems to be reasonable to him as 

well. So we're -- we tried to balance it. You -

- you may have other thoughts of how we should 

approach it. We're just sharing with you what we 

think we can go forward with to potentially get 

us into a better place.

 MS. RUGGLES: And one of the other 

areas that I heard all the other presentations 

talk about, you know, staffing challenges. We 

have vacancies. As those get filled, you know, 

it does affect costs. QACD being at their full 

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level now. Some of those resources we've been 

using, we won't have those available next year. 

And also, updating technology. You know, the 

cost involved in updating technology. We're 

investigating technology as well. So some of 

those resources won't be available.

 CHAIR GROVE: John, I'm going to have 

you hold your question. In keeping with the 

schedule that we have -- and we have some very 

specific timeframes we need to meet this 

afternoon because of online speakers, we are 

going to go ahead and break at lunch at this 

time.

 If you have questions, write them 

down. We still know there's a lot of people who 

want to talk about this. And we also then have 

an industry issue that attaches to this. So I 

would like to make sure everybody -- again, bring 

your questions yet.

 But we're going to break for lunch. 

And we have a very specific schedule at one 

o'clock. We have somebody coming on and 

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presenting for fumigation. So when we come back 

from lunch, one o'clock, we will start regardless 

of who's in the room. We're not -- because we 

have somebody online, and then after that -- and 

then that discussion, we will come back and start 

again with user fees. Okay? So gives you lunch 

to mull over some other questions. So again, at 

this time, online, gallery, and -- and committee, 

we will break and be back in here to start right 

at one o'clock with our online presentation.

 (Whereupon, the above-entitled matter 

went off the record for a brief recess.)

 CHAIR GROVE: All right. We were 

going to start with Dr. Walls here at one 

o'clock, but he's not on yet. So what we are 

going to do --

MR. NEAL: He's on.

 CHAIR GROVE: Oh. Okay, so he is on. 

So we will -- we will have Dr. Walls present. 

And then we will go into Chris presenting with 

the fumigation piece. And after that, we will 

then move back to any other questions we have for 

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Denise. And then, into FGIS user fees that Nick 

will present. If everybody's fine. So our AV 

team -- if you want to go ahead and bring up Dr. 

Walls.

 DR. WALLS: Hello. Can you guys hear 

me?

 CHAIR GROVE: Yes, we can. Do you 

have a presentation to share?

 DR. WALLS: I -- I really don't have 

a -- a presentation to share. I, you know, was 

asked to revise Table 3 of the FGIS manual. And 

it was my understanding that -- that that's what 

we were going to be reviewing. I'd be happy to 

do so.

 MR. NEAL: Yeah. Thanks, Dr. Walls. 

This is Arthur. I don't know if you can see me. 

So this may be a great opportunity for us to kind 

of let Chris kind of give a summary of the -- of 

the fumigation issue brought to the Grain 

Inspection Advisory Committee.

 Chris, you think you're ready to do 

that? And then after that, we can turn to Dr. 

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Walls.

 CHAIR GROVE: Okay. So if -- AV team, 

you want to bring up Chris's policy that he 

submitted? Can we do that side-by-side? Okay. 

Chris, you go ahead and go. We do -- we do have 

it --

MR. FREDERKING: Yeah. Absolutely. 

Thank you. So recently, because of changes with 

phytosanitary certificate requirements for -- in 

the country -- designation country of Japan, we -

- we have ran into a bit of a nuance issue with 

fumigation practices, and what is required to get 

proper fumigation per the fumigation policy 

handbook. To get a clean phytosanitary 

certificate on bulk shipments.

 So specifically, this applies to 

scenarios where the cargo depth is between 12 and 

20 meters, which a lot of times can be -- can 

result in a slack hold situation. That slack 

hold situation is a -- creates some -- some 

risks, some dangers for fumigators accessing the 

top of that cargo. So getting down into a hole 

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to apply subsurface fumigation in accordance with 

the handbook Table 3 creates those safety 

challenges. Additionally, because of the 

destination -- the issues at destination with 

having holds tubed for recirculation. Having to 

dispose of those tubes at destination is creating 

a real problem for customers. So they just are 

not equipped for it and aren't prepared to -- to 

handle the amount of tubing that is coming their 

way.

 So that is, in turn, making us 

uncompetitive, which of course, brings extra 

scrutiny to the Table 3 in the fumigation policy 

handbook. So specifically in that table, I 

wanted to open it up to the Committee, and 

certainly up to review on fumigation practices. 

The difference between surface versus subsurface 

application for those holds with cargo depths 

between 12 and 20 meters. Is there really a 

difference in efficacy of the fumigant, with --

with those cargo depths.

 And then also, the transit time from 

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the U.S. to Japan, typically, is going to be much 

greater than the 18 days listed on the -- on the 

Table. So is there a possibility to also review 

and discuss the -- the possibility of having 

additional transit time windows added to the 

table as well. So with that, entertain any 

questions, or certainly turn it over.

 MR. NEAL: Thanks, Chris. And so what 

we've done -- kind of, ahead of the meeting, we 

started partnering with Agricultural Research 

Service, who helped the Federal Grain Inspection 

Service draft the original fumigation handbook 

policy. And Dr. Walls was so kind to spend his 

time looking at the handbook, the specific Table 

3 as it pertains to fumigation application rates 

and slack hold applications.

 And so I'm going to turn it over to 

Dr. Walls. I think you all have seen the 

proposed, or draft changes. So he can walk us 

through his thought process for recommending or 

proposing what he's done.

 Dr. Walls, we'll turn it over to you. 

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DR. WALLS: Thank you so much. So my 

understanding that -- that the audience is -- has 

the revised Table 3 in front of them? Or am I 

supposed to share?

 MR. FRIANT: Arthur, I don't believe 

we've seen it. What's posted on the website is 

the current Table 3.

 DR. WALLS: Okay. Well then, let me 

request to share screen. Okay? Are we -- are we 

sharing the Table 3?

 MR. NEAL: Yes, sir.

 DR. WALLS: Okay, great. All right. 

Well, thank you for the --

CHAIR GROVE: But you rolled it up 

just a little bit.

 DR. WALLS: I'm sorry?

 CHAIR GROVE: Okay. No. You're fine.

 DR. WALLS: Okay. Yeah. Well, thank 

you for the very brief introduction. Yeah, I was 

-- was given a call. And you know, kind of 

unfortunately, over the years, the USDA's postharvest treatment group has kind of shrunk. I'm 

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-- I'm out in Fresno, California now. Kind of 

handle the whole -- handle the whole country. 

And you know, phosphine fumigations have -- have 

changed quite a bit in the last, I would say, 

decade or so. And I really kind of relish the 

opportunity to take another look at this table. 

This actually dovetails very nicely, too, with 

some recent work we've been doing for USAID, and 

kind of reevaluating the verbiage and the 

recommended -- the phosphine application 

parameters.

 So when I first set out to do this a 

week or two ago, you know, the first place I go 

is -- is to industry, and try to gauge and gather 

as much information as possible about the 

problem. And one of the things that we 

recognized was exactly what the gentleman before 

me had said. You know, there's a safety issue 

going in and doing subsurface trenching in 

certain applications.

 And then also, there were some key 

target markets that were -- were actually 

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requesting that recirculation tubes were -- were 

not in place. And so what we tried to do was 

accommodate that, and -- and make this revised 

table as much as -- or embrace business-as-usual 

as much as possible, while making these new 

accommodations.

 And as I -- as I went around to 

various industry members, I think one of the 

first things that -- that leapt off the page was 

revising in -- in each of the far left column. 

The verbiage with respect to how much phosphine 

was applied. In the former table, you simply had 

metal phosphides. And that's very confusing. 

And so we clarified that in this revised table, 

by -- by referring just to the amount of 

phosphine per thousand cubic feet. So I think 

that that's an improvement.

 Another thing that -- that became 

evident, was that the fumigation service 

providers wanted to make the decision on whether 

or not it would be surface or subsurface. And 

you know, that's a -- that's a choice where I 

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think the fumigation service providers, you know, 

they can look at the label, and they can -- they 

can, I think, best gauge the particular scenario. 

The hazards and the -- and the safety factors 

associated with that. So instead of having two 

headings -- one for surface, and one for 

subsurface -- we simply combined those. So you 

can do either a surface or subsurface 

application.

 So in the top column. I guess, the 

surface or subsurface application -- 45 grams of 

phosphine per thousand cubic feet. As we're 

reading left to right, basically hold depth in 

meters -- the only box that is effectively 

changed from the last table, is the 12 to 20 

meter. We are now allowing surface applications 

of phosphine in those holds. This basically 

addresses the situation in Japan. Which, at least 

from my perspective, was one of the -- one of the 

-- the issues that kernelized this -- this 

revision. We're still not allowing them in 

greater than 20 meter hold depths -- surface or 

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subsurface applications, without recirculation.

 The next -- the next row down. 

Surface or subsurface application with 

recirculation. This is, again, kind of business 

as usual. Thirty-three grams of phosphine per 

thousand cubic feet. None of those times have --

have changed at all.

 And then, finally, as we go down to 

surface or subsurface application with 

recirculation, we have greater than or equal to 

45 grams of phosphine. The increase, basically, 

a dose of phosphine -- applied dose of phosphine 

-- it should, in fact, direct, or -- or would 

say, achieve the same amount of efficacy in a 

shorter period of time. This also allows to 

accommodate with the -- the new USAID 

recommendations of -- of 60 grams of phosphine 

per thousand cubic feet. Okay. So if you go 

with the higher rate in recirculation, you can 

reduce the treatment times required for efficacy. 

Incentivize, so to speak, if you have that 

ability to do so. 

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Okay. We also looked at the -- added 

a double asterisk. Fumigant quantity is 

calculated by total volume of the empty cargo 

hold. As it turns out, the fumigators were 

basically using that calculation anyway. Even 

though the old, or former Table 3 had 

calculations of -- of hold, basically, volumes 

based on the amount of commodity in there. And 

that's really not how we do things in the 

fumigation world. We -- we keep it to the volume 

of the geometry that you are fumigating, and you 

-- you don't calculate hold geometry. Which the 

speaker before me indicated is sometimes a very 

difficult to do anyway. So we're just going with 

hold -- empty hold volumes as the -- the index 

for -- for application rates.

 The first note recommended that the --

the hold remain closed during the entire voyage. 

There's no modification to this. We did put in a 

note that when possible -- and it's not always 

possible -- but when possible, recirculation 

methods are recommended. And I -- I think that 

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this was important to include. And not -- not so 

much from -- from a safety perspective. 'Cause 

again, that -- that's going to be first and 

foremost in the hands of the fumigation service 

providers. What really, the FGIS manual and --

and ARS research, and -- and really, research 

abroad, has -- has shown that the recirculation 

method -- you know, taking the time to distribute 

the gas as -- as quickly and as homogeneously as 

possible, is the route towards a better 

fumigation. And -- and that's generally the 

message that we're trying to -- to convey here.

 And then, there was another note that 

was included. For dosage rates greater than 45 

grams, a dual fan recirculation is recommended. 

And this really just builds upon the previous 

statement by saying, you know, if you're going to 

go for reduced treatment times, which accompany a 

-- a higher applied dosage of phosphine, then the 

more circulation that you have, the better. 

Again, these are not requirements. There's a big 

distinction between requirements. These are 

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simple -- simply recommendations.

 And then finally, we've got -- we've 

got reference specifically to slack holds and 

slack tanks, saying that the surface or 

subsurface applications may be used as specified 

in the chart above. So that's - this line really 

just kind of links slack holds with -- with full 

holds, and -- and anchors everything to this --

to this table.

 And I'm certainly happy to entertain 

feedback, positive or negative, but I -- I think 

this is a step in the right direction. And --

and I've -- I've talked also, too, about how --

how ARS would be willing to -- to engage, at 

least, in a -- in a -- a kind of quick overview, 

or take another look at the FGIS manual, to, 

let's say, update it and modernize it to -- to be 

consistent with current, kind of, fumigation 

practices.

 With that, thank you so much. I'm --

I'm happy to entertain questions. And it was my 

pleasure to be here. 

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MR. NEAL: Thank you, Dr. Walls.

 MR. HEIL: I've got a question here. 

Mark Heil, Prairie Central Coop. Was it -- what 

-- particular to the ag year -- was it a change 

in the label or best practices by industry, or 

was it a request based off things that had always 

been done from a international buyer that is 

creating this request for the changes?

 DR. WALLS: As far as I know -- and 

again, I -- I was approached by this. I -- I --

I'm not AFIS or -- or FGIS. I -- I just do the 

research. I -- I was handed some -- some 

information about one of the importers on a key 

market, had -- had requested this change. And 

then also, the -- the language in the former 

Table 3, I guess, you know, was not -- was not 

accurate, in the sense that requirement of 

subsurface applications in slack holds just 

really doesn't make much practical sense.

 MR. HEIL: I would agree with that. 

And then the -- the addition of phytosanitary 

requirements going into Japan really brought this 

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all to a head for us in the Gulf, on needing to -

- to meet those -- those requirements without 

tubing of vessel holds. Which they are very 

sensitive to those tubes being discharged -- or 

disposed of at destination.

 CHAIR GROVE: Chris, do you feel that 

these proposed changes in this draft answer some 

of the questions to the proposal written and 

submitted, in answering the questions or concerns 

for you?

 MR. FREDERKING: Yes. I feel like 

what has been proposed in this table certainly 

addresses the concerns from industry, as well as 

eliminates some of the gray area that we had seen 

in some of the variability on application 

practices in the Gulf from time to time. So this 

is certainly a great step forward. So would --

would love to see it continue.

 CHAIR GROVE: Any questions for Dr. 

Walls?

 MR. NEAL: Dr. Walls, thank you for 

taking time to join this meeting. I think that 

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you've addressed all the concerns. We appreciate 

your effort in this space. Have a great rest of 

your trip.

 DR. WALLS: Appreciate it. Thank you.

 MR. NEAL: All right. Take care.

 CHAIR GROVE: Thank you.

 We definitely appreciate Dr. Walls 

taking his time from his trip in Alaska to join 

us to help us through this process. Obviously, 

this helps Chris with what you're looking at and 

proposing for the industry.

 Do we feel -- I should have asked this 

to Dr. Walls -- do we feel this then also doesn't 

create any safety risk if we have this as a 

surface application -- it does say the -- the 

vessel needs to stay sealed, even if it is met 

that 18-day or greater requirement -- that table 

does say it needs to stay sealed. So are there 

safety concerns?

 MR. NEAL: One of the things that he 

did mention to us is that surface application, 

you know, is permitted at some of the larger 

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cargo hold depths. However, that's why the note 

about recirculation is recommended. Not that 

something will happen, but when you do surface 

application at those larger cargo hold depths, 

there's a higher probability for there to be, you 

know, fire because of the gases.

 MR. FRIANT: So I -- it -- I think I 

would agree it appears that it -- it's addressing 

the questions and concerns that we have for 

fumigation of export vessels. Has, or when will 

AFIS be approached to see if this will still meet 

their requirements to issue a clean phytosanitary 

certificate?

 MR. NEAL: It'll be after we come out 

of this meeting.

 Hey, Chris, from a practical 

standpoint, without recirculation, do you move to 

the higher dose for the full holds?

 MR. FREDERKING: I would assume that 

we -- we stick with the 45 grams. Yeah. So I 

guess, procedurally, if we're in agreement, what 

are the next steps as far as formal 

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recommendation coming out of the GAIC, and then 

engaging AFIS? And then from there, how long 

will the process continue?

 MR. NEAL: I think as soon as we 

confer with AFIS about the changes, it's really 

about us getting the word out and modifying the 

handbook. Shouldn't take extremely too long, 

because we're only updating the chart -- Table 3.

 MR. FREDERKING: Yeah. The -- I would 

say to that end, we -- we should also ensure that 

key industries stakeholders have a little bit 

more awareness than just -- get notified that the 

handbook has changed. I think, particularly NGFA 

and NAEGA would appreciate some opportunity to at 

least review it, and check with membership, that 

-- that everyone's comfortable with it.

 MR. NEAL: Makes perfect sense.

 CHAIR GROVE: Any other discussion on 

this topic? Questions? Again, to make sure we 

have - - right now, the recommendations after 

this and agreeing to the new draft, engaging AFIS 

to look at this, but also in assuring key 

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industry stakeholders have the information. Any 

other thoughts that we need to make sure to 

address?

 MR. FRIANT: Well, and -- and I 

believe this has already been done. And I --

sorry. I just don't remember if Dr. Walls said 

it or not, but the major fumigation companies 

have had a chance to review and weigh in on this?

 So for the record, Arthur is shaking 

his head "yes."

 MR. NEAL: Yeah. He -- he has 

consulted with all the major fumigation 

companies.

 CHAIR GROVE: So with that -- again, 

the same, I guess, notification that it has 

changed after AFIS has approved, you know, again, 

just making sure everybody has that 

communication. It is good to know that they were 

contacted ahead of time.

 For those people that have the 

expertise in it, to be able to weigh in on, 

again, the safety and efficacy of this. 

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MR. NEAL: Yeah. And -- and that's 

just another thing to remember as things have 

evolved over time, people that were here back in 

the -- in the early 80s when this fumigation 

handbook policy was established are no longer 

here. And -- and expertise moves, and so I think 

the more we lean on people who have the expertise 

and space that are outside of, like, the 

technical grading and inspection work, I think 

that's -- we need to integrate them more into the 

business that we're facilitating. So that we 

don't find ourselves coming to FGIS for expertise 

that we no longer have.

 MR. FREDERKING: Not sure if there's 

much more in discussion, but would just say thank 

you to FGIS for -- for getting ahead of this 

issue, and for dealing with it. And bringing it 

to the forefront and engaging the right people in 

such a timely manner. It is much appreciated by 

industry.

 CHAIR GROVE: Okay, Chris. So if 

you'll go ahead and handle that for us, and 

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you'll put that -- that revised proposal 

together. And then we can do that vote tomorrow. 

Thank you again, for the time you put into this 

and bringing that to our attention.

 With that -- with no other questions, 

we are going to move back to any questions that 

we may have for Denise in the budget discussion. 

So questions for Denise that we put on hold. And 

then we will move Nick into your proposal, so if 

you want to be prepared to upload that proposal 

onto the screen for the FGIS user fees and 

budget, that would be appreciated.

 John, did you still have a question?

 MR. MORGAN: No, it was mostly a 

comment. So I -- I think it can wait for the 

discussion.

 CHAIR GROVE: Again, specifically, any 

questions -- we do still have the presentation. 

We can go back to any slides, if there's anybody 

who had any other questions for Denise.

 MS. RAMBUR: Hi, this is Shay. Just 

wanted to make sure that I understood that the 

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volumes -- you used the five-year projection, and 

then you kept them steady for the three years?

 MS. RUGGLES: So for the -- for the 

scenario we did, we did the projection, what we 

thought the five-year average, adding '23 to it 

for the '24 calculation. And then we added it 

for '25, and then we held steady.

 MS. COOPER: While you're up there, 

Denise, could you pull up the slide that shows 

the different scenarios?

 MS. RUGGLES: This was for the hourly. 

Or do want the -- what -- what the scenarios were 

comprised of? I think it's back here further 

where we talked about the different scenarios. 

Is that what the -- the text, where we talk about 

the group we got together, and the scenarios what 

they represented?

 MS. COOPER: Okay. And then you -- in 

your analysis, it looked like you only analyzed 

scenario three?

 MS. RUGGLES: Yeah. We only did -- so 

we had a recommendation from our administrator to 

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take scenario three and provide that as a -- a 

forecast out for '25 and '26.

 MS. COOPER: Okay.

 MS. RUGGLES: So we only did scenario 

three.

 MR. NEAL: So part of the rationale 

here -- go back, Denise, to the table with the 

scenarios and the -- and the operating reserve.

 MS. RUGGLES: Oh, with all the 

scenarios? I don't think --

MR. NEAL: Uh-huh.

 MS. RUGGLES: I don't think we did one 

with all the scenarios.

 MR. NEAL: The figures, the fees.

 MS. RUGGLES: We just have this. We 

didn't do all the scenarios for the --

MR. NEAL: You -- you have a table 

with the fees. Right there.

 MS. RUGGLES: Here, we did the 

projection with hourlies, at the bottom, the 

footnotes say --

MR. NEAL: Yeah. Right. 

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MS. RUGGLES: Okay.

 MR. NEAL: So this is the reality. 

We're negative $4.7 million in the hole. We got 

a shutdown potentially coming. How do we operate 

with no money? If we don't change fees, how do 

we operate for another year with no money? It's 

fiscally irresponsible. We can't do it. So what 

we were -- moving -- what we are showing to you 

in terms of a possible route forward, is one 

where we don't try to recover the entire 

operating reserve loss or deficit rapidly, so 

that we can at least be fiscally responsible in 

being in the black. Break even, so to speak. 

That's all we're really trying to do. So that we 

can operate. Otherwise, we have to explore some 

other options for how FGIS survives the next 

year.

 MS. RUGGLES: So that's why we picked 

scenario three to do -- so we at least get out of 

the hole for '24. And then we bring us to the --

the minimum goal, and then we -- we should be 

around the four and a half. It's about five and 

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a half right now, for the calculation for '26. 

By the end of '26. So just to let you know, these 

are at the end of those fiscal years at close.

 MR. FREDERKING: I probably missed it, 

but when would the fee increase go into effect?

 MS. RUGGLES: We're trying for January 

1.

 MR. NEAL: More realistically, you're 

talking about late February.

 MR. FREDERKING: Again, at -- can 

certainly have an impact on marketing years, 

right? And sales that -- as this is -- can be a 

significant cost, right? For industry?

 MR. NEAL: It -- it's not ideal. It's 

just not ideal. But we've got to take a step 

forward. And we're trying to -- we're -- we're 

suggesting a path forward to minimize -- and 

that's a loose use of that term -- minimize the 

impact as much as we can. For -- we're working 

inside of AMS now, to make sure we've got what we 

need to continue operations in case of a 

shutdown. But we're still going to have to plan 

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to dig out of the hole we're in, in our forward 

years.

 CHAIR GROVE: You know, while nobody 

in the industry wants to see fees go up, it's a 

reality of the business we do that all our costs 

are raising. Other -- you know, whether it's our 

inputs, other services -- those do raise. We 

know that's going to happen. I -- I appreciate 

that you were doing data- driven, instead of 

saying "Hey. We need to -- we just need to get 

to a number. Here's what we need to do." Looking 

at the true costs of all of your fees, to me, is 

important. That you're putting some true numbers 

behind what we need to charge for particular 

items.

 You know, sometimes we -- we set fees 

and we put them in place, and those costs to 

ourselves -- those costs for the kits you are 

using, your person's time -- they all go up, and 

we don't readjust, and we don't do it in timely 

fashion. So hopefully, those are some things 

that we're reassessing sooner than nine years 

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after maybe a last review of -- of fees. Or in 

2016, 2015. You know, those are some things we 

start putting in place to -- to keep us more 

relevant on our costs. Appreciate a little bit 

that we're doing a three-year plan to try to 

catch up, versus -- it's all at once. But I 

think as we talked, that still, that's a very big 

raise. You know, and a -- and a hard one to 

stomach. So I think, again, as the industry -- I 

think it's going to be a bit of a shockwave. So 

maybe some things Nick's going to talk about --

how do we make sure, and for you, what can we 

help you with to ensure we don't get in this 

place again. And I do see some other lights on, 

so please go ahead.

 MR. SINNER: I appreciate you looking 

at the -- the most conservative scenario. I -- I 

think that's -- I mean, obviously, we're -- we're 

worried about it. But I got to be honest, that 

I'm -- I'm concerned about the tonnages. And I 

know you've laid it flat. I -- I mean, with all 

the crushing of soy that's coming online, I -- I 

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just don't see the -- the tonnages being 

consistent. Even with the rolling averages. And 

it's going to put us in a -- another compromising 

situation. So we may have to adjust this again 

next year.

 MR. NEAL: The reality is that for 

every -- we have to do a annual fee review every 

year. Every grading program does. So there be 

some small adjustments every year. Not these big 

swings. What we were attempting to do -- we 

weren't trying to be negligent in making 

adjustments. We were trying to operate within 

the 5 percent threshold that we had. And the 

reality is that the 5 percent threshold just 

wasn't enough to cover the rising costs that we 

were experiencing in other areas, as well as 

facilitating full cost recovery. We also have 

statutory obligation to charge fees that recover 

the costs of providing a service. So it's a --

it's a -- like I said, it's a tough pill to 

swallow. I don't want to be in this position; 

neither do you. So the purpose of us having the 

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conversations here today is to get input on how 

we think we could move forward in the most 

beneficial way.

 DR. HURBURGH: Given the rather large 

variability of, kind of, just, across years, from 

-- over the last five years or ten -- very large 

variability -- this doesn't allow operation 

within that variability. That point one at the 

bottom of the graph that you just showed. That's 

effectively zero. What happens if -- if, at the 

end of FY24, that number's not zero, it's minus 

again? What happens?

 MR. NEAL: It's a great -- great 

question. And it's a possible reality.

 DR. HURBURGH: -- think so.

 MR. NEAL: Like I said, ideally, we're 

supposed to -- we're supposed to aim for the four 

and a half month target of reserve. So what 

happens if we don't break even? You know, we're 

not there today. We will not be able to operate 

in perpetuity the way we're currently postured. 

So the question will become, will a review of our 

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accounts take place by the government? Will we 

be deemed fiscally deficient? And they'll be 

other conversations to have. I think ultimately, 

we, collectively, have to decide on what we want 

to do to move forward the way we're supposed to. 

Now if we're negative next year, I can't say 

what's going to happen. Will there be a review 

of this program and its -- its effectiveness? 

I'd have no -- there's no other grading program 

operating like this.

 DR. HURBURGH: Well, I was on this 

committee a number of years ago. And I can tell 

you that we went to that point of potential 

shutdown. In fact, shutdown procedures had 

begun. We don't want it. And I think this 

scenario is too thin to be -- it's my opinion, 

and I know that there are others that are having 

to pay the fees. I understand what the issue is. 

But this is too thin to have a reliable chance of 

success. My opinion.

 CHAIR GROVE: Something, Denise, you 

said back on the slide about the challenges. 

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That the reauthorization act in 2015 only allows 

you to look backwards. It allows you to look 

backwards at last years, versus to be able to use 

projections and things going forward. So how can 

we affect that? Because all of us, in doing our 

day-to-day business, when we're doing strategic 

planning, you are projecting for the future. So 

if all you're looking at is the past, you 

obviously aren't able to make good decisions on 

that. How can we affect that?

 MR. NEAL: You know, that's a great 

question. I -- I've consulted with all of the 

other grading programs, too, and they -- they 

also look backwards. Because none of us have 

access to what companies are contracting. We 

have no idea what the market is going to do. We 

could use mass data to project, but even that's 

got lags to it. So I'm not quite sure. There 

may have to be a -- a dialogue around how would 

projection look for us. But even those 

projections could be, you know, off 

significantly. 

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I don't know if there's a perfect fix, 

other than monitoring, well in advance, what the 

revenue and costs are related to the operating 

reserves. Taking action well before we've done 

now. We're being in communication about the 

status on a regular basis, so that we are aware. 

The other thing is -- you know, considering what 

do we need as an industry to facilitate trade. 

That's another option to consider. If -- if this 

is not a type of conversation folks want to have. 

Because we can't provide the service for free.

 MR. FRIANT: Well, and I think, Barb, 

partially to answer your question, and I think 

maybe other than Charlie, I may have been the 

only other person in the room before this was 

done. The estimates that were used. So under 

the -- under the old process it was all noticeincumbent rulemaking. And the -- and the swings 

were massive in tonnage fees and other Schedule A 

fees. And it was because trying to do the 

projections was just -- it -- it was just too 

hard. Right? I mean, we -- we could use WAZDEE 

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(phonetic). We could use whatever was out there 

and it -- I mean, it'd be off by millions of 

metric tons. And it's just a symptom of -- of 

the process. And so that's why the -- going to 

that five-year rolling average was implemented. 

A, it -- it gave the agency power to do something 

annually, instead of waiting five, or ten, or 

more years, and then -- and it gave them the 

power to make the changes outside of the full 

rulemaking process. So it provided some 

flexibility to the process. I did not know, 

Arthur, and that was interesting to hear that 

other inspection programs do the same -- well, or 

at least a relatively similar process. I would -

- I would argue that the calculation for tonnage 

fee is working because we have seen overhead 

costs, or the national admin costs continue to --

to decrease. And so that is reflective in the 

tonnage fee being paid. I think the missing gap 

is -- and several folks have heard me say this --

it's all of the rest of the Schedule A fees, and 

not being able to adjust the -- particularly the 

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contract and non-contract rates to be more --

more market responsive, they're coupled, and then 

subject to that -- that 5 percent cap. And I 

would be remiss if I didn't say that during the 

2016 reauthorization, NGFA and NAEGA did suggest 

not having a cap. And you're -- and so I 

understand, Arthur, you weren't around for all 

this. Leadership at that time said "No. We need 

the cap to provide more stability to those 

changes." So believe it or not NGFA and NAEGA 

said "no cap." Which I -- I can't believe we 

did, but we did. So -- but that's what we're 

stuck with today. And so I think that's where 

we've got some opportunity.

 MR. NEAL: I'm chuckling, Nick, 

because no cap is a -- is a thing now in urban 

culture.

 CHAIR GROVE: Just because we don't 

want to keep her -- keep her on ice up here, any 

specific questions for Denise? 'Cause she's been 

up at the front of this room for a very long time 

today. 

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MS. RUGGLES: Well, the rule -- the 

rule that Nick's talking about, it was back in 

2013. It was actually like a four-year, and it 

was the 80 million metric tons. And then that's 

when we skyrocket and we bring in hundreds of 

millions of metric tons. But yet the fees were 

set for 80 million, so we were booming. And 

that's what the operating reserve went crazily 

high, is 'cause we were -- we were gangbusters 

with tons.

 PARTICIPANT: I do -- I'm glad that 

you reminded me, Barb, 'cause I do have question. 

Just -- and Denise, I think you answered this 

before the break, but I didn't quite follow. So 

if you can go forward to the periodic tonnage 

rate scenarios slide. One more I think. Yeah, 

this one.

 I just want to understand. So I know 

that the fiscal '23 national tonnage fee, the 

0.33 -- that was adjusted the 5 percent up. The 

next three -- scenarios one, two, and three --

the 0.58. That's based on the straight 

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calculation of the five-year -- of the fees 

divided by the five-year rolling average. Not 

adjusted up or down by the 2 or 5 percent?

 MS. RUGGLES: Right. That's --

PARTICIPANT: Okay. Scenario four --

MS. RUGGLES: And then scenario four 

was wide open, to try to bring us to the full 

four and a half months at one time. One year. 

The nine months.

 PARTICIPANT: Yeah. Okay. Thank you.

 CHAIR GROVE: Okay. And I'm going to 

take a question or comment from the gallery. If 

you could please make sure to state your name, 

spell it, and also then, who you represent.

 MR. MCCLUER: Thank you for the 

opportunity to ask a couple of questions. So 

Jess McClure J-E-S-S M-C-C-L-U-E-R with the 

National Grain and Feed Association. So thank 

you for this very informative presentation. A 

couple of questions.

 At the very beginning, when you 

talking about the increase in the -- the cap. 

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Right? The user cap and appropriations. When 

you were saying that request, was that made to 

the House and Senate Appropriations committees, 

or was that to the Secretary of Agriculture?

 MR. NEAL: Good question, Jess. It's 

still getting cleared through USDA right now to 

go to Congress.

 MR. MCCLUER: I got you. Okay.

 MR. NEAL: Mm-hmm.

 MR. MCCLUER: So you've made the 

request internally to raise the user cap from 55 

to 60. Then once that is approved, that will 

then go to the -- that will then be proposed to 

the House and Senate Appropriations committees to 

then be included in the respective USDA 

appropriations bill for fiscal year '24?

 MR. NEAL: That's the -- that's the 

game plan. That's -- I think the -- I think the 

approach may be as to in deciding what to send to 

-- to the hill. Because it's a two-part request. 

It's basically to decouple the cap from the other 

user fee accounts. That really should provide us 

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enough space to operate.

 MR. MCCLUER: Got you.

 MR. NEAL: Without being concerned 

about expenditures exceeding the cap. So that's 

the first one. The $60 million increase to the 

cap would be the second thing they consider 

whether or not do we need it.

 MR. MCCLUER: So the request is going 

to be the language to be included to decouple as 

we've been talking about. And then on top of 

that, that'll be the increase in the cap. And 

then as you mentioned, to the increase in the 

appropriations. Now just curious, too. It's a 

little late in the process for the fiscal year 

'24, isn't it?

 MR. NEAL: And almost '25, too. But 

not necessarily for this change. It still can --

it still can be adopted. We've not seen the --

you know, we've seen drafts of approps language, 

but it still can be adopted.

 MR. MCCLUER: Sure. Well, and that's 

very helpful to know. As you know, NGFA, we're 

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located in Washington, D.C. area and work with 

Capitol Hill quite a bit, so that's good to know 

kind of what this process is, so we can kind of 

stay on top of that as well, on -- on how that 

proceeds moving forward.

 The second question I had, then. So 

-- and I don't know if this is for Denise. I 

think it is for Denise. I think it's going to 

get -- it's goes back to pre-2015. Right? So I 

think, had -- and not very many of us were 

involved in this process. But what were the 

requirements then pre all the changes made in the 

U.S. Grain Standards Act. Right? What was the 

process then, if you came in a similar situation 

as far as reviewing fees, or something that we're 

currently dealing with right now? What was the 

process then?

 MS. RUGGLES: Okay. So the -- the 

rule that Nick was bringing up about the 80 

million metric tons. It was a full regulatory 

change rule. So we'd have to do a proposed rule, 

and we would put out sometimes three to four 

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years of anticipated prices for effective dates 

in a table. So they would try to forecast out 

what our -- we were going to need for the 

program. When they did that last rule, which is 

what triggered the reauthorization, the 

calculations were done on 80 million metric tons. 

It was not going to change for those three or 

four years in those fee tables.

 We -- so we -- proposed rule goes out. 

It has all of the fees for those multiple years. 

It's published. We get comments. We respond to 

the comments, and then it becomes a final rule, 

and it would show up in the federal -- the CFR --

the regulations. It would be posted in there for 

all those multiple years what the fees were going 

to happen. What they didn't anticipate was that 

the 80 million was way too low. So those fees 

being set based on it bringing 80 million in --

we were bringing in 100s of millions. So the 

tonnage rate being set for only bringing in 80 

million, and we're bringing in hundreds, the --

the revenue was just coming in extremely high. 

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So that's when, during the reauthorization of 

2015, it was requested by industry, and -- to put 

a pause, to stop that rule, and re -- change the 

process of how we were doing fees. Because it 

was taking -- we were doing it so many years. So 

there could be many years before we had a fee 

change.

 For an example, for the commodity 

program. The fees haven't changed since 2001 for 

the commodities for one of the fee tables, and I 

think 2003 for the other fee table. It just 

takes a long time sometimes to get those tables 

changed and those fees done. So they were doing 

multiple years to try to head off, and be 

prepared for what was going to happen in the 

future, so you would be able to know what the 

fees were going to be.

 So that's great if what we forecasted 

in those fee tables were accurate. You -- you 

hadn't -- you knew what your hours were going to 

be and what your tonnage work is going to be for 

contracts and stuff. But when you miss the mark, 

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and it's not 80 million metric tons, it's 

hundreds of -- you know, a hundred -- I don't 

even remember what the first year was. Like 110, 

or something like that. I'd have to go back and 

look. You know, that's -- we just bring in way 

too much revenue. It was -- it was a large 

surplus of revenue.

 MR. MCCLUER: And just to add what 

Nick said, too. The comments that NGFA and NAEGA 

submitted back in 2016 on the proposal to 

implement the changes on the 2015 

reauthorization, wholly supported a periodic 

review of the Schedule A fees on an annual basis, 

without a cap.

 MR. NEAL: Okay. That's good to know, 

Jess. I thought I could point my finger at NGFA 

for this problem.

 MR. MCCLUER: Just -- is -- is that on 

the record?

 MR. NEAL: Yes, it is. I just put it 

on the record.

 MR. MCCLUER: Thank you for the 

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opportunity to -- I do have more questions. I 

could save it, though.

 CHAIR GROVE: Are your questions for 

Denise, or are -- are they going to relate for 

the published proposal? Because then I would 

say, let's wait till Nick presents the published 

proposal, or industry issue. So you tell me --

or no -- is it to Denise or presentation.

 MR. MCCLUER: No. I -- I was going to 

say. I just did have one other follow-up 

question for Denise, just based on -- based on 

the information up here. So -- so obviously, 

with the -- those -- the fees that you had 

described, for obviously, the -- the first -- the 

user fee cap, the appropriations. The one 

follow-up question I have on the appropriated 

funds -- where it's the -- I know the 23.5 versus 

-- I guess, that's what I just -- so there's 

authorized appropriated for 23 million. But I 

know we've had -- well, that was the 

appropriations is 20 million. So is the 23 

million -- when was that -- I guess, that's the -

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- I was just curious about that. Was that from 

this current year appropriation? Last year's 

appropriation?

 MS. RUGGLES: So the 23 million was 

added in the 2020 reauthorization of the U.S. 

Grain Standards Law. When the -- when the 

changes were made to the -- the appropriated 

section became funding section, where it was 

separated out about how user fees could be used 

or could not be used. And that's when the law 

was changed to put in that we were -- the funding 

for authorization for appropriations was for 23 

million. To start in 2021, through 2025, which 

is our next reauthorization period. We've not 

gotten that. So I brought it up to be clear that 

while it says it in the law, we're only getting 

20 million in the budget appropriations.

 MR. NEAL: So this -- this 23 million 

came a part -- became a part of the 2020 

reauthorization as a result of dialogue with the 

hill concerning FGIS's needs. And so we talked 

about the need to innovate, the need to 

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modernize, and the need to develop methodologies. 

So that we could explore the use of technology 

for providing service. So they authorized more 

funding so that we could explore what we're 

talking about here -- technology. And how do we 

also do more outreach, where industry concerning 

the marketing of agricultural commodities, such -

- Byron mentioned -- we should do a lot of 

surveys with the U.S. Soybean Export Council, 

U.S. Wheat, and so forth, using appropriated 

dollars. We can't afford to do that anymore. 

And so then, we're trying to make authorizations 

so we continue to partner and facilitate trade 

through innovation. And that type of support.

 MR. MCCLUER: So it's been 

appropriated, but you haven't receive it yet?

 MR. NEAL: It's been authorized, but 

there's been no appropriation towards it.

 MR. MCCLUER: Okay. Got you. All 

right. Thank you. That's very helpful. 

Appreciate it.

 CHAIR GROVE: Thank you, Jess. Again, 

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anymore questions to what Denise has presented to 

us? If none, then Nick, I would give you the 

floor.

 Thank you very much. Thank you for 

taking this -- this extra time. Again, being 

very thorough. And -- and that is kind of what 

we talked about ahead of time. Hey, let's go 

slow on this. A lot of information to digest. 

So thank you for being patient with us.

 And Nick if you would want to then go 

ahead. And if you're able, to go ahead and pull 

up his industry --

MR. FRIANT: So I'll start by echoing 

Bob's -- or Barb's comments on -- you know, thank 

you for all the information. Thank you for the 

time, certainly. And I said it earlier today, 

we've been requesting more detailed data for a 

few years. And appreciate you sharing the more 

detailed information. And it helps us be able to 

do some additional analysis, and help figure out 

a way forward on this. So thank you for that.

 So as far as for the advisory 

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committee, you can see here on the screen the --

the discussion paper, or position paper. A lot 

of this is, frankly, background here at the 

beginning, around what happened in -- in the 2015 

reauthorization, and what was -- what was 

required with respect to official fees for 

official inspection and weighing. And the annual 

review -- the three to six-month operating 

reserve, with a -- with a target of four and a 

half months. And then the -- the tonnage fee 

being calculated using the five-year rolling 

average, and actual administrative costs from the 

previous year.

 It goes on to talk about how those 

were implemented in the calendar year, beginning 

January 1st. But then points out -- and I think 

we saw that in one of the early slides that 

Denise presented -- that that operating reserve 

has been on a negative trend line since that 

time. Also pointing out -- and this I've shared 

-- I think I shared it earlier today -- we have 

seen the national administrative costs from 

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inspection and weighing services be on that 

negative trend line. Which is something that 

industry has been pushing for, even before 2015. 

And so again, I -- and I've said this in other 

forums -- you know, I commend the agency for 

finding ways to continue to decrease those 

overhead costs, and certainly appreciate that.

 Additional facts from -- from the 

position paper. It just talks about -- and we 

saw this in what Denise presented earlier today -

- those tonnage fee adjustments have ranged from 

5 percent decreases to 5 percent increases. And 

as we saw, it was a 5 percent increase over the 

last three years. What this paper does not talk 

about is the -- the distinction between the 

tonnage fees and the rest of the Schedule A fees. 

Which, certainly, I feel like we've got a much 

better understanding of now, today, after all of 

the additional information and conversation. But 

what the -- the question that raised, and -- and 

that we've really been talking about for this 

topic all day is, we've got decreased 

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administrative costs, tonnage fees have been 

doing whatever they've been doing, and yet, the 

operating reserve continues to -- to be on the 

negative trend line. And so we needed this more 

in-depth review of tonnage fees. And -- and 

clearly, the rest of Schedule A fees, as we've 

learned and gotten more information. And so the 

-- the request -- part -- the request from this 

position paper so that the Committee could have 

further discussion and develop some 

recommendations is more in-depth information to 

be able to do some more of that analysis. And so 

I feel like we've got a lot more of that 

information today. We've had a lot of good 

conversation so far on the topic. And so I think 

it is leading us towards some sort of 

recommendation back to the agency. I'm not sure 

we know what that's going to be quite yet. But I 

think it's provided better opportunity for the 

Committee, and then interested stakeholders to 

provide some -- some more analysis and -- and 

recommendations. 

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And then if you can scroll just a 

little bit more, Kendra. The last piece was 

around the timeliness. And the importance for 

timeliness. So particularly, handlers, exporters 

can manage those changes. And that was, I think, 

well eluded to. And -- and again, I would thank 

you, Denise, for the -- for the explanation on 

why it's so difficult. Speaking for myself, I 

frankly had no idea that there was all the bits 

and pieces. So I actually feel like that portion 

of the request was -- was addressed.

 So yeah. So I mean, that's -- I think 

maybe I'll just leave it there. That's what's in 

the position paper. And I guess we'll probably 

open for additional discussion or comment from 

the Committee.

 CHAIR GROVE: So I am going to ask you 

something, Nick. You -- you just made a comment 

on, you know, bringing this to stakeholders, 

letting people have input. Arthur, just a few 

moments ago discussed that process, just to bring 

it into review and -- and clearance. So that 

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does put more time on these projections if we're 

looking at a timeliness, a hope-to's. Denise 

said have this affected in -- in January, put in 

place in February. A timeframe of -- of bringing 

it to the -- all the industry stakeholders. And 

not that they shouldn't be aware. Everybody 

should be aware. What are you thinking of a 

review and comment from industry stakeholders? 

Because that does put this -- or does it? You 

can still start the process while people are 

commenting? I guess a question for either one of 

you.

 MR. NEAL: Ideally, we'd like to have 

some sense. So say for instance, with the rice 

industry. Before we moved the proposal into the 

clearance process, we talked with the rice 

industry to gauge their -- their perspective on 

and response to the potential rates. We got 

feedback. We adjusted, we shared our adjustment, 

we -- you know, we came to a hesitant agreement 

to move forward before we moved forward with it. 

You know, it -- it -- they didn't want it. Yet, 

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they also understood the business side of it, 

too. I mean, when you -- when you look at it, 

they were in a very similar position, such that 

they rates they were paying were less than what 

they were in 2019. You know, we're paying --

we're paying a smaller hourly rate than what we 

were in 2016 in grain. Realistically, nobody can 

stay in business that way.

 And so we got that feedback, so we 

knew when they asked, what's industry's response 

to this, we could share that with truth, you 

know? And we could share that, you know, they're 

not necessarily desiring this increase. However, 

they understand. In this case, we're in a 

different situation. 'Cause we were in a 

negative posture with rice. We still had a 

positive operating reserve. And we were just 

trying to prevent getting to this point with the 

rice industry. Which we did. 'Cause the only 

two accounts we've got in the positive right now 

-- well -- we've got rice, and we've got -- we've 

got pulses. And you know, we were able to -- and 

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-- and then, the supervision. But we were able 

to -- to prevent this from getting here. Now 

we're at a place where we're operating at a 

deficiency, which raises a different type of 

alarm bell. 'Cause it's really -- I think it's -

- Dr. Hurburgh said we should be shutting down. 

Literally, we should be shutting down. We should 

be laying people off. We should be shutting down 

our doors. But we're working within the agencies 

to make sure that doesn't happen. We -- we can't 

stay in that posture.

 MR. FRIANT: Yeah. And -- and we 

certainly don't want that -- that to happen. I 

am not familiar with the process for how rice 

works. Or just, I'm not familiar with it. But I 

think Barb, to answer your question, we could 

probably get some -- get some understanding of 

what might be needed for the grain-handling 

industry, based on what happened with rice. You 

know, I can't -- I can't speak for other handlers 

in the room, but I mean, even just within 

Cargill, I've got key stakeholders that I need to 

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socialize this with before we just -- see on 

January 1st that there's going to be a new rate 

change. I would like to think, as we bring 

together, you know, the key trade associations 

for the grain handlers, we can generally get 

comments, and get in front of the respective 

boards pretty quickly. So I think we've got time 

to do that, Barb. And especially to your point, 

Arthur, to -- to make sure the messaging is 

correct.

 MR. NEAL: I'll also add, Nick, we 

don't want to -- so we can't sit on it for an 

extremely long period of time. And when I say 

"we," talking about us. What's reasonable? 

What's a reasonable timeframe? This is what --

September basically. I think if we could get 

this into the -- the clearance process by 

October, we'd be doing good. So if we got 

feedback by October, that -- that would be --

when I say -- really, by the end of September, 

that would be pretty -- pretty good. 'Cause we 

will all want to be experiencing the fiscal 

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yearend closeout. It's going to be busy. We 

probably wouldn't get it up to the Secretary's 

office by end of -- end of the fiscal year. They 

probably wouldn't entertain it that soon. So I 

think that's -- that's reasonable from -- from 

our end. Because it's -- it's going to take us a 

while to probably get it cleared. Next year --

CHAIR GROVE: Pushes us -- pushes us 

back from the administration of it, or the -- the 

proposal of going into effect Jan-Feb.

 MR. NEAL: Maybe. Maybe not. Maybe, 

maybe not.

 CHAIR GROVE: Okay.

 MR. MORGAN: Just a comment on -- on 

our experience with this process, Nick. It was 

basically proposed to us -- you don't want us to 

grade rice or not. I mean, that was pretty much 

how it was proposed. But the way we approached 

it -- it's a little easier, 'cause we're one 

commodity. You guys got multiple commodities to 

push through on your association boards. But we 

did get together at the lowest level of our 

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committee, that -- our chair, and we -- we heard 

the proposals, we pushed it up, and we reported 

it to the respective boards and USA Rice, the 

federation, the merchants, the millers, and the 

producers. And kind of fast-tracked it that way. 

The initial -- the initial fees that were 

proposed versus what was -- came out was a bit of 

a compromise. However, would -- would I see even 

more compromise on this is, you guys are really 

pushing hard for the one and half and two times 

rates, 'cause that's how you pay your employees 

for the overtime and holiday rate. So it worked 

out fairly quick with us. We are still at rates 

that we did not see back in '18 and '19.

 So -- my only -- my only -- what I 

didn't like about the process from the start to 

the finish was how fast they reduced our surplus 

over two years. Which was somewhat out of USDA's 

control, 'cause the office of management and 

budget was the one pushing it. But I would 

encourage that you find a more smooth transition 

from surpluses to negatives, potentially, in your 

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-- in those -- in those operating budgets. 

'Cause we -- we had a drastic reduction. They cut 

our fees in half for a year. And then we're 

going back to where we were couple years ago.

 So it's -- it would be nice if it was 

smoothed out a little more. Whether it was going 

up or down, it -- you know, it'd be smoothed out. 

So that -- that's my only part of the process 

that I thought was -- was tough. But we moved 

pretty quick. But we are one grain. So -- much 

easier for us to that than -- than you guys have 

to get all the grains on board. It's a little 

bit of a bigger challenge.

 CHAIR GROVE: So in this -- with --

Nick, what you're looking for a possible proposal 

in very definitely wanting key stakeholder input 

-- is we would need from FGIS -- you already have 

the slides in place. But what is -- we would 

need that -- that verbiage, that good 

presentation on why. Because we -- we need to --

we need to state the why. So that was -- we 

would need that from you as part of our proposal. 

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I'm -- I'm assuming, so that we can bring that 

and get together industry stakeholders, and 

bringing back that communication as soon as 

possible. So we would need a good summary draft. 

And Nick, I'll let you say what pieces are going 

to be beneficial. I mean, Jeff's in the room so 

he's already heard it. So that helps.

 MR. FRIANT: Well yeah. And -- and 

that's part of what I was going to say, is it 

might be easier said than done. But it's simple 

as Denise and/or Arthur are given some 

presentations to grain grades and weights 

committee, and grades and inspections committee. 

I -- I think -- you know, this -- I mean, Monday 

was the first time that the Committee even saw 

the proposal. So I -- maybe there's still folks 

on the Committee that need time to chew through 

it. And then some opportunity for all of us to 

share with our key stakeholders. I mean, 

certainly, timing is of the essence. We fully 

understand that. I guess I'm not prepared right 

now to say if the end of September is feasible. 

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It feels like it. But I would -- I mean, we get 

it. We -- we also -- the agency can't continue 

operating the way it is either. We know that, 

too. So --

MR. NEAL: This was the other I wanted 

to add. Next year is a big year for potential 

transition. So that affects everything, too.

 CHAIR GROVE: So and again, it's a 

very, very important input on keeping this 

timely, so the possibility of getting this 

brought through. You know, as Charlie pointed 

out a number of years ago, the -- the process was 

being put in place to close the doors and shut 

down. Nobody wants that, 'cause what that does 

is, it totally affects all of our trade. It 

affects our businesses. And it does -- just --

just because official inspection may have to 

close the door, it -- it -- yes, there are 

private inspections. But do we think those rates 

are going to be cheaper. If that's the only 

option.

 So we want to keep that in mind that 

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we have to have you solvent, because it still 

facilitates our trade and our businesses. It's a 

great affect to my business if I don't have 

somebody to -- to come take care of my shuttles. 

Come take care of my food grade cars, I don't 

have business if you're not there. So assessing 

and make sure, I think as -- as John talked about 

-- making sure this is a little more fluid, and 

we -- we are keeping a little more current, and 

not all the sudden, you know, watching that 

decline and not correcting it.

 Aside from raising fees, you have 

given us a lot of good information today on some 

of your challenges. I think, looking at, again, 

all of those other expense -- everybody is always 

doing that. I know. What are our expenses? 

What can we change?

 I'll go back to, you know, Ed's 

presentation on some of the technology pieces. 

To continue to assess those things are important. 

Those bring down costs, but still makes you 

efficient. Bring -- takes down some of that stuff 

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out of your travel when you can do things 

virtually. We all like to see each other faceto-face, but sometimes bringing our expenses down 

is an important piece, too. So appreciate those 

thoughts and looks into that.

 Nick, some other suggestions, or 

questions. Or anybody else to the group to Nick? 

Go ahead, Chris.

 MR. FREDERKING: Yeah. Just -- and as 

Nick had said, it was a bit of a -- a surprise I 

think to most, to realize how coupled the tonnage 

fees were with the rest of those Schedule A fees. 

As far as some recommendation. With wages of the 

workforce being the highest percentage of your 

guys' spend, is there a way forward to decouple 

those, to allow for more consistency on -- on 

that per-hour rate versus the tonnage rate that 

should -- could fluctuate?

 MR. FRIANT: Let me take your question 

a step further. Is there a way to decouple 

without going through notice and comment 

rulemaking? Based on how -- and maybe you don't 

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know that answer today, but -- I think that might 

be the key.

 MR. NEAL: So that's what that --

without changing the regulations to this periodic 

review, that's basically what we're trying to do 

with the fee adjustment. We changed the contract 

rates; we didn't touch tonnage. That's how I 

would project and try to see if we can move 

forward. How we'd do it? We'd have to assess 

that. I think the step one is to get -- let's --

let's get out the hole. And then we'll try to 

make modifications if we need to do rulemaking to 

make that change, we can definitely facilitate 

that. In such a way, there's -- there's no 

surprise to what we're doing, 'cause we're 

talking about it now. We know that the intent is 

not to try to generate more revenue for anything 

other than covering the operating reserve. So I 

think we can definitely explore that. But that's 

why we -- another reason why, when we project it 

out from the option three -- the projected years 

do not affect the tonnage rate. This is purely 

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the calculation from the formula that's in the 

regulation.

 MR. WILLIAMS: Arthur, I have a 

question. The -- the four and a half month 

operating reserve. Is that -- is that set forth 

in -- in U.S. Grain Standards Act? Or what --

where -- where does that rule come from?

 MR. NEAL: And Pat's back there 

smiling. I just learned the history about the 

four and a half month reserve. It seemed like 

that was set by previous administration. We need 

to look at -- I think we need to look at the 

whole provision and change it. But that's --

that's my take.

 MS. RUGGLES: It's -- to answer your 

question, Jimmy, it's in the regulations. It's 

in the -- the annual fee review. That four and a 

half is the trigger that's in there for the 

operating reserve adjustments. That's in the 

regulations.

 CHAIR GROVE: Any other thoughts, 

questions, comments, on this? Nick, do you have 

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some -- do you feel you have what you need at 

this point?

 MR. FRIANT: I'll let you know 

tomorrow morning.

 CHAIR GROVE: Part -- part C of 

question one. Is that where you're at?

 MR. FRIANT: No, I -- I mean, I will 

talk with other members of the Committee, but I 

think pieces of a recommendation are coming 

together. Thank you.

 CHAIR GROVE: Anything else from you, 

Arthur? You're fine with where we're at right 

now?

 MR. NEAL: For the record, no, I'm not 

fine. But I think we've covered -- we've covered 

everything.

 CHAIR GROVE: You know, that -- that 

was a long -- a long discussion and long-needed. 

Again, like you said, Nick -- you know, we took 

the whole morning session, really to talk about 

the budget and fees. So obviously, much needed 

for us. So thank you again for your time. And 

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Nick, for the -- the thoughts on this issue. I 

look forward what you're going to bring to us 

tomorrow morning.

 I think then, at this point -- is Ryan 

ready? If Ryan is ready, we are going to move 

into lab scales. We had a little bit of an 

update on this last week to prepare us. Ryan, 

again, will come on and go ahead and present that 

issue to us again today.

 THE REPORTER: What's Ryan's last 

name?

 CHAIR GROVE: Seapy S-E-A-P-Y.

 And whenever you're ready, Ryan. Go 

ahead.

 MR. SEAPY: So as Karla mentioned 

earlier when talking about QACD, there've been 

some problems with lab scales being calibrated, 

then certified to either 1/10, or 1/100 of a 

gram. To correct this and align FGIS with NIST 

standards -- additionally, to consolidate 

regulations, we're proposing to update the 

requirements for lab, or more specifically, 

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grading scales.

 Currently, a requirement is that lab 

scales that are used for grading be certified to 

1/10 of a gram, even though they display to 

1/100. Given that the hundredth is actually used 

in the calculations to determine grade, the 

scales should be certified to 1/100 of a gram to 

comply with broader industry standards and 

specifically, NIST guidelines.

 The -- the new standard that we're 

proposing would not apply to other scales used in 

the process of sampling and comparing the sample, 

but only for officially weighing small portions 

and separations, typically under 100 grams. This 

update is most important for smaller grains with 

tight tolerances. It's seen in the wheat --

specifically, in the wheat market is an area 

where it is pretty significant. For example, 

when you have a sample size of 60 grams and a 

separation of .1 grams, which might occur when 

picking heat-damaged wheat. The current scales 

have an allowable error range of .3 percent --

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just over .3 percent. And the scales under the 

new proposal would be -- would have an error of 

.03 percent.

 Given the breakpoint between a U.S. 

number one and a U.S. number three is 2/10 of a 

percent. Having an error of 3/10 of a percent in 

the scale is -- is significant. So it would be -

- there would be a possibility for -- under the 

current standard -- for a U.S. number three grade 

be issued on U.S. number one grain, despite 

having a scale that's operating within its design 

specifications. We don't have evidence of this 

happening on a regular basis, but it's within 

this spec tolerance of those scales which is 

concerning.

 By updating the scale standard, we can 

reduce the possibility of equipment-inducing 

grading error, and better align FGIS policy with 

NIST and general metrology standards. Many 

locations, as I mentioned, particularly in the 

wheat marketing areas where these small errors 

can have large impacts, already are using these 

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proposed scales. It does create a problem when 

QACD is doing their reviews because the way that 

the guidelines are currently written, it would 

cause a write-up for somebody who's using more 

precise equipment, as Karla was mentioning.

 Additionally, state agencies often 

require NIST standards be used across the state. 

And by trying to maintain a different standard 

for FGIS, there can be confusion in trying to 

meet two separate standards. The FGIS standard 

and the state standard, which is a higher 

standard if they're following NIST. And they can 

be mutually exclusive at times.

 Lastly, with the proposed standard, 

we'd like to update the check test procedure and 

use ASTM Class 4 weights, instead of the -- the 

current standard weights, which are NIST Class F. 

Which NIST has discontinued using, in that they 

are no longer allowing them to be sold -- or new 

ones to be sold for use in legal-for-trade 

applications.

 These ASTM Class 4 weights would be 

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appropriate based on the newly proposed standard, 

and would keep us in line with NIST, so that FGIS 

wouldn't have to maintain a separate weighing 

group to support a different standard. And we 

can defer to NIST on -- on matters of metrology. 

These changes would result in some increased 

costs to agencies. Because it would -- some of 

the agencies would have to buy new scales.

 But if we give it a three to five-year 

transition window, as some of the scales that are 

currently in operation cycle out, we can reduce 

the -- the added costs to the official agencies. 

To -- and these scales, they do cost more than 

the -- the current 1/10 scales, but it's not 

exorbitantly more. So it's something to -- to 

keep in mind. But yeah, as -- as scales cycle 

out at the end of their useful life, if they're 

then replaced with these higher precision scales, 

we can significantly reduce the cost to the 

official agencies.

 I believe Karla's going to pull up the 

memo and if there are any questions, we can 

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discuss them, or go through any particular 

details in the memo. There were a couple of 

options in there. One being the full proposal 

that I just mentioned. One being just replacing 

the weights, and one being maintaining the status 

quo. Even maintaining the status quo would not 

be a -- would not be trivial, because there are 

disagreements between the regs, the handbooks, 

and NIST.

 So we would need to rework the 

handbooks at the very least, to address those, 

even if no change is going to be made. The --

the kind of middle of the road option would be 

update the weight sets, but maintain the existing 

scales. It would allow for some improved 

precision and verification of the scales. But it 

doesn't bring us within compliance for NIST.

 That's all I've got. The -- the memo 

-- or the abbreviated memo, is available at the -

- at the GIAC site, so everybody should have that 

available to them. And if you all would like to 

discuss or ask any questions? 

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CHAIR GROVE: Okay. Now any -- any 

questions right now for Ryan? Any -- and then 

any comments or discussion that you have.

 MR. WILLIAMS: I have a question, 

Ryan. Can you explain to the Committee how you 

arrived at the -- for option A -- how you arrived 

at the cost of $10,000 or less?

 MR. SEAPY: Yeah. So what we did was 

we looked at the equipment list that's active 

across all FGIS and official agency sites. 

Because all equipment goes through a TRN check 

test procedure. So we pulled all the locations, 

and all of the equipment lists. Looking at the 

equipment, we can tell which equipment does meet 

the standard and which doesn't. And as I 

mentioned, not all scales would need to meet the 

standard.

 So if a site has only one grading 

desk, and it has one scale of this -- of the 

higher standard onsite, then that site would not 

need to purchase any new scales. Some places 

have chosen to change out all the scales in the 

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lab, both for sampling and grading so that 

they've got interchangeable replacements. But 

that wouldn't be required. So when you add up 

the -- the total number of sites, minus the total 

number of high-precision scales at those sites, 

you can get to a -- a rough -- I mean, it's not 

perfect, because we don't know exactly how many 

grading sites there are at each location. But in 

general, it's -- it's pretty accurate.

 And you can work up the math for --

per official agency what the predicted cost would 

be to at least have one high-precision grading 

scale at each grading location. And then, 

assuming that a scale costs approximately $2,000, 

that's where the -- the average of $10,000 -- or 

less than $10,000 per official agency estimate 

came from. Obviously, the bigger agencies could 

have more.

 Some of the smaller agencies might 

have, you know, only one scale that would need to 

be replaced. And some agencies have none, 

because they've either already replaced all their 

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scales, just because they're in a wheat market 

and due to the nature of their market, it's 

important to have that precision. Or they do 

have a couple of those scales and they're -- you 

know, as long as they're at the correct sites, 

there would be no added cost.

 MR. ENGEL: Ryan, Curt Engel. 

Question for you. Did you take into any kind of 

consideration what the onsite numbers look like 

and the number of scales that industry would have 

to acquire, particularly in the having two -- two 

scales onsite? On each particular site to have a 

backup for failures, what that expenditure would 

look like?

 MR. SEAPY: We didn't specifically 

look at having a backup scale at each location. 

Because we don't -- we didn't have data 

specifically on how many grading stations there 

were per facility.

 MR. ENGEL: No, I'm asking about the 

onsite labs. The -- the industry onsite labs at 

customer's facilities. 

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MR. SEAPY: Sorry. I -- I might be 

missing something here. So we're talking, say, 

at an export facility?

 MR. ENGEL: At -- at an interior 

facility.

 MR. SEAPY: Okay.

 MR. ENGEL: Train -- stations.

 MR. SEAPY: So we -- we accounted for 

anything that is getting check-tested into ECT. 

So I -- I don't know the specific answer to your 

question because I don't know whether or not 

those -- the scales that you're referring to get 

officially check tested, and that data gets put 

into ECT and FGIS online. If it get -- if it's a 

scale -- a lab scale that gets check-tested and 

put into ECT, then we accounted for it.

 CHAIR GROVE: So thank you, Ryan, for 

this information. You know, even though this was 

put in as an industry issue, this is one for us 

that FGIS is bringing to us for informational 

purposes, to let us know what's going on. So we 

don't have to write a proposal today, if this is 

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something that we would like to further to 

another meeting so we can have that discussion. 

But we do have some time here if we want to look 

at -- he does have three options. Which, again, 

thank you for, instead of saying "Hey. This is 

what we want you to do." You put some proposals 

offered to us.

 So to me, the toughest part is the 

piece where it says FGIS regulations are in a 

sense out of specs with both NIST and what state 

agencies or state regulatory has in -- has in 

place. So if we say "You know what? FGIS -- you 

just -- you just need to get in line." What it 

does is it automatically is saying "Okay. Now 

we're replacing everything." So putting a 

proposal together or having this discussion to 

say we want this to happen, you need to get in 

line, we can't be out of date. Especially if 

you're saying we're referring to an old handbook 

that is no longer the current standard. That has 

to be fixed.

 And you know, in my opinion, I think 

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we need to look at not just lab scales, but 

again, all of our equipment -- do we have other 

places where we have this same concern that we 

probably are not meeting, you know, the -- the 

NIST standards or state regulatory. So that's 

something -- a food for thought -- that we don't 

want to look at just one piece. Again, all the 

equipment in general. Where are we not -- where 

are we not meeting up?

 I was just looking at gram scales that 

we were doing, and -- and I think, I know, Kia, 

you had sent me what you guys were using and I 

think we have that anyway -- that can be set to -

- to .01. But it depends on what its tolerance 

is for calibration. So what are some more 

thoughts on this in affecting our -- our industry 

and our trade?

 MS. MIKESH: Kia Mikesh with North 

Dakota Grain Inspection. After this -- our 

initial meeting with this packet -- we -- Phil 

and I called a meeting with the AAGIWA, American 

Association of Grain Inspection Weighing 

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Agencies, to discuss -- to bring more information 

to the Committee on what type of impact it would 

have, both on onsite labs, but for the agencies. 

We feel that it is -- we don't want to be out of 

standards and everything like that.

 However, we do feel that it is to 

industry, to bring forth recommendations on 

whether or not you guys feel it has an impact on 

your business. Heat damage was one of the, I 

would say, one of the biggest impacts it has. So 

a few different areas that we discussed. And 

there were, I'd say probably six, seven agencies 

on the phone call. So a sampling.

 So some of the -- some of the areas 

that were looked at was -- and asked of agencies 

-- how many of your scales would you need to 

replace if it was just wheat immediately, since 

that's where the biggest impact is. There are a 

lot of agencies that primarily just do corn and 

soybeans. And even if they do some wheat, it is 

a lot of times done in the office in one area. 

And -- or maybe just one office of an agency. 

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So we then looked at how many -- if it 

were all of just your agency scales -- and then, 

also how many onsite labs -- lab scales would 

need replacing. We had a wide range, but there 

was, on average -- a few of them had noted their 

take before the agency, for only wheat, would be 

around ten to twelve scales that they would need 

to replace within their agency, so that would be 

the agency cost.

 I did not look up every scale that was 

on the approved equipment list, but I did look at 

the one that we do currently use, and it's just a 

little -- it's a little bit over $2,000 to get 

everyone a -- a frame of how much that is. So 

the -- so you're looking at over $20,000 for, 

what I would say, the average of our sampling 

was. Then there were some that, if it were 

wheat, corn, and soybeans, they would have to 

internally, as an agency, replace 30 scales. But 

only if -- if it was only wheat, there would be 

two to three scales.

 Then we have some that are completely 

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compliant. Some others that I believe are agency 

because we were a part of -- we were a part of 

the -- seeing that there was differences between 

the instructions, so we had actually been 

starting to do the switch anyways. I think we 

maybe have six or seven left that we need to 

replace. All of them would be regarding wheat.

 But there is one of the agencies 

online, just internally as an agency would need 

to replace 50 scales as an agency, and upwards of 

100 when you start including onsite labs. So --

and all of those are wheat -- have to do with 

wheat, from what I gathered. And we aren't -- it 

was made clear in the meeting we were only 

talking about grading scales. So that number 

would obviously be substantially higher if you 

talking about the technician scales, et cetera. 

So that -- that was made clear in the meeting.

 And so we had some thoughts for you 

guys to just to consider -- is that there could 

be different options involving -- maybe it is 

wheat scales that are looked at immediately, and 

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corn and -- corn and soybean scales from used for 

grading, would be grandfathered in, and when 

they're at replacement, then you just wouldn't be 

able to repurchase those. Then maybe having 

timelines for those that do have 50 scales. That 

two to three-year timeline is a very, very large 

sum of money. And that impacts industry as well, 

as agency costs go up.

 So those were a few items that we 

thought about. Even just grandfathering. If you 

felt that it didn't have enough of an -- an 

impact, but we wanted to get onto having -- being 

in line with NIST standards. Maybe all of 

grading scales could be grandfathered in, and as 

replacement, you'd replace them as we go.

 CHAIR GROVE: I think some -- somewhat 

if we look at -- gosh, was that in this proposal 

-- see about grandfathering -- grandfathering 

some in. Do you think that grandfathering some in 

to wait for replacement -- 'cause I tell you 

what, we have a lot of scales that may have been 

industry -- in the industry as long as I have. 

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You know, you -- you take care of them and you 

get them serviced regularly, they last a long 

time.

 So do you think that puts us at an 

inconsistency? Versus, you know, we look at a 

plan that -- not necessarily about 

grandfathering, but whether it's a three to five, 

six to ten, whatever that is, it -- it could 

bring consistency sooner.

 'Cause you are right. You know, 

onsite labs, as Curt mentioned. You know, our 

company has a lot of them that we would need to 

switch out. Now, I like what you thought about. 

Not all of them have wheat. All of our Kansas 

locations and some of our Nebraska locations. 

Even, like, Kansas Grain Inspection. They're 

going wheat, soybeans, corn, sunflower, milo. So 

realistically, they would -- they would almost 

need to change them all out in their labs to be 

efficient. You know, instead of "Oh, which desk 

do I sit at?"

 Now our in house labs -- guess we're 

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buying that equipment -- I think some of them 

have already been replaced with those, just 

because we're going forward. So I'll go ahead.

 Curt, what do you want to --

MR. ENGEL: I think one of the 

important things to acknowledge here is that once 

you start making this transition, for every one 

of these onsite labs, everywhere that -- that's 

in a remote location, you end up having to have 

two of the same pieces of equipment. Because you 

cannot fail. If -- if -- if she shows up --

train -- and your -- your fixed scale is down, 

you better have another one, or they're hauling 

all your samples back --. And you lose your --

you lose your shuttle incentive. You lose 

everything -- you know, everything that's 

providing the revenue stream for having that 

onsite lab.

 So this isn't just a question of 

whether you get to buy one of these. You get to 

buy two of them. Every time that you upgrade. 

And it's -- and then the agencies and the offices 

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all have the -- the luxury, if you will, of 

having multiple scales in one spot. So that if 

you do -- you know, if you do get something that 

is non-compliant, you've got a backup there to 

use. And that was the basis of my earlier 

question. About how does this affect industry. 

And you've got to have that.

 And you know, in -- in my former life, 

we -- we were buying what the grain inspection 

used, and we were buying the test weights that 

the grain inspection were using. We were using 

everything that the grain inspection used, 'cause 

then it was no argument about the methodology.

 And my -- so and you know, I look at 

this and I ask myself the question "What's the 

value proposition here? Is it about complying 

with NIST rules? Is it about more accurate 

information? What's the value prop here and 

who's the beneficiary of this expenditure?" And 

I'd like to have somebody give me a different way 

of thinking about that.

 CHAIR GROVE: Again, very valid, Curt. 

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'Cause you're right. If you don't have a backup, 

you're -- you're in trouble. And a backup that 

they've already tested and certified prior. So -

- so that is a -- a valid thought for industry. 

I -- I think, you know, Ryan had said "Yes, it 

can affect wheat." That's probably one of the 

bigger players, being a small grain.

 But do we -- do we have statistics 

behind it? I guess that would be very 

interesting. And if -- and if -- that's again, 

something we don't have to say "Today we have --

or tomorrow, we have to have a proposal and voted 

on." If we need to look at this and say "This 

needs to be part of the next agenda item so we 

can get more data." Because if it -- if we don't 

have statistics on who's truly been affected, it 

could push you into number one, to number three -

- have there been complaints about that, I guess, 

for FGIS. Has that been a concern that somebody 

contested grades saying "No. We're not getting 

number three wheat." But it's the tolerance of 

the machine. So do we -- find data. 

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MR. ENGEL: That -- that was going to 

be my next question. Does anyone have their hand 

in the air with a -- an example of where this has 

turned into something that this would be a remedy 

for a situation? It is my understanding about 

the wheat pieces -- we're talking about ones to 

threes, and it's about heat damage. If -- is 

that one sample in the thousands and one sample a 

ten thousand? You know, I -- I don't have that 

information, and that's why -- would like to see 

that kind of information.

 I'm not against accuracy. I love 

accuracy. But accuracy for the sake of accuracy 

doesn't make a lot of sense to me, particularly 

when you start talking about hundreds of these 

scales needing to be purchased to do this -- this 

compliance piece.

 CHAIR GROVE: So personally, as having 

happened? Yes. Have had that happen. That 

official origin weights and grades -- and we had, 

I'll say numerous cars -- not every car on the 

shuttle -- we started getting higher heat damage 

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on the wheat. Did we contest it? We may have 

asked for a re-grade.

 MR. ENGEL: Sure.

 CHAIR GROVE: We'd ask -- yeah. 

Regrade the sample.

 MR. ENGEL: You should.

 CHAIR GROVE: And we did. We were 

still getting high. We didn't feel we had it. 

Thing is -- you know what? In -- in order to get 

the -- the shuttle done and on time, we dumped 

and reloaded. So how many times has it happened? 

Has it -- has it stopped trade and devastated us? 

I won't say not at this point, but if I'm keeping 

my grade in good condition, I don't have that 

problem.

 MR. ENGEL: Having -- having suffered 

that same malady over and over and over again, 

but you don't know the difference about whether 

or not this spread would have -- would have cured 

your problem.

 CHAIR GROVE: Right. Did they, Mark? 

You look like you had a comment. 

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MR. HEIL: Yeah. Just not sure if we 

wanted -- make the differential between the --

the wheat, the corn, and the beans. If we're 

going to go to the scales, go to the scales would 

-- would be my thought on that. But it is going 

to be a cost. I mean, not only in our situation. 

We're bringing, you know, about purchasing the 

new scales for our labs, but we also try to --

even in our other grain elevator sites and where 

we're -- we try to match that up as much as we 

can so we're consistent all the way across.

 So there -- there will be added costs 

for this. If it was over a period of time "Hey, 

we're going to be, you know, making this change 

over a period of time." You know, that -- that 

seems reasonable. But doing it in all in one 

shot would -- would be a shock, at least from my 

perspective on it.

 CHAIR GROVE: I just want to say, I do 

want us to make sure that we are considering 

"Yes. Nobody wants to have added cost." We are 

all watching our expenses. I know from my 

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company's predicament -- I don't know if that's 

the right word. But we are second year of fairly 

widespread extreme drought. So of course you 

want to watch expenses.

 But let's go back to moisture meters 

and in changing to the new technology. Did 

everybody in the industry first go "Uh. I've got 

a 2100b here. I've got a -- I've got a GAC 2, God 

forbid, sitting here on my counter, and it's 

still good enough." But when you start thinking 

about the operational pieces of moisture -- high 

moisture coming and it being wrong, using those 

same moisture reading meters for drying and overdrying, because you're not using technology 

that's giving you the accuracy.

 Did grain inspection switch over to 

the new technology -- after proven -- that this 

was what was best for us per trade? Yes. Now 

did we all purchase brand new machines across the 

board in one year? No. We probably waited until 

an end user started affecting our trade, to who 

we were selling to. But the technology proved 

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itself.

 So keep in mind, whatever we choose, 

we've brought up many times "Let's look at 

technology. Let's do what's better and not just 

sit back and say we always have these and they're 

good enough." Make sure we're looking forward to 

technology, I think.

 MR. HEIL: But I also wouldn't want to 

be too -- by half on something. Where is it, 

just -- is it the tenth, the hundredth or the 

thousandth, or whatever one you want to get out 

to, versus being the real world of is it just the 

sample itself. And -- and a lot of times -- most 

of the time, that's what it comes down to. Is it 

one in a thousand, one in ten thousand 

situations, versus complicating and financially 

having a potential impact back on industry. And 

no doubt, we all want to be correct. But there 

are consequences of these decisions back out in 

industry.

 MS. MIKESH: Like I said, we had 

starting going through this transition about two 

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or so years ago. And one of our main concerns 

was that at the time, we had been using the same 

scale for the technician functions, test weight, 

for -- as for the grading. And I want to say, in 

Ryan's report it said that prior to 2002, this 

was -- what they are proposing is how it was. Is 

that -- does everyone remember it correctly from 

-- okay.

 So somewhere around 2002, it started 

changing. And if I -- if I remember correctly, 

it was blocked for that redundancy. If one went 

down, then you'll at least have one you could use 

for both functions. And so we started doing that 

for our onsite labs, because then it wouldn't 

hold you up when you're -- when you're loading 

your train.

 And so as of right now, as we've done 

this transition, I will say it has not happened 

nearly as much as I was anticipating it to 

happen. Needless to say, it does. And it -- say 

your location is two hours away from our agency 

where we have the backup -- because your -- yours 

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isn't going to work as our backup, because we 

haven't check-tested it. And those weights are 

also back at the agency, and we can't have 

multiple weights out everywhere, et cetera.

 So it could upwards delay, a train 

being graded, approximately four hours. That, I 

would say, on most agencies, is on the higher end 

for shuttle trains. And then we'd be able to 

bring out a -- a backup scale. But that's 

something to consider with this. But like I 

said, we have essentially already gone through 

this transition. And it doesn't -- it does not 

happen frequently. But when it does, it could 

cause demerge. It could -- it could be very 

costly --

CHAIR GROVE: So Ryan or Arthur, or 

another member of FGIS, do you have any data or 

statistics on -- that you feel that this is 

happening? That you've had somebody contest that 

heat damage grade, to tell us statistically how 

often this is truly happening, to know -- you 

know, again, do I feel this is very relevant to 

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say "We need to -- we -- we need to look at 

state. We need to look at NIST. We need to look 

at FGIS. And we need to make sure that our --

we're -- we're all on the same page." I still 

think that has to happen.

 But is this a three to five-year, or 

is this a -- you know, it's godfathered in on the 

change. You know, when they need to replace it, 

it needs to replace with something. Knowing that 

there's statistics behind it makes a difference 

in that decision.

 PARTICIPANT: Yes, it does.

 CHAIR GROVE: I think it does. Yeah. 

If we know it's happening a lot. Yeah. Then, 

sure, maybe there's a little more say "Uh. Okay. 

We better get going on this." If we don't feel 

it's happening that much, or nobody has 

complained about it. If I haven't complained 

about it -- because we just went ahead and dumped 

and reloaded, just for the -- it was quicker than 

contesting the grade. Because I just needed to 

get the train out. Then -- then we don't know. 

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MR. NEAL: Yeah. So staff can correct 

me if I'm wrong. I've not heard this to be 

anything that customers are complaining about. I 

do know one issue that emerges from this. Our 

check-testing procedures for scales; that will 

need to change. Depending on the scale that an 

official agency or lab may have, some of the 

check-testing procedures that they may be using 

may not be appropriate for the scale. They might 

be using the wrong weights for the scale. So 

when an audit is being conducted, they're failing 

that component of check testing.

 With respect to us bringing this issue 

to you, is -- you know, we found out there's a 

misalignment in terms of, you know, where we have 

these protocols specified in our regulation, as 

to compared to NIST. So we wanted to make sure 

that before we even, you know, made a change, we 

brought this issue to you to weigh in, to see how 

big of an issue is this for industry. Because at 

the end of the day, this -- this is your 

industry. We're working with you to facilitate 

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trade. So we weren't going to make a decision to 

make a change unilaterally.

 You will definitely -- you know, if 

this is something that we take action on, you'll 

have to take time to -- to take the issue back to 

your respective members that you represent just 

to get feedback, so that you can come back to the 

table, have dialogue on what you think we should 

do. And one of the options in Ryan's proposal is 

status quo. Do nothing. So we're not saying we 

-- we have to make the change. We're saying 

these are the things -- these are options we 

believe we have in front of us to -- to address 

this issue or not address it. But we do not -- I 

do not think we have statistics on how often this 

is occurring, if it is occurring on a regular 

basis, to help you make that decision.

 MS. MIKESH: One thing we did also 

discuss, there was the second part about the --

whether or not to continue using the Class F 

weights. That does impact us as agencies, if 

they're not available for sale if legal trade, et 

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cetera. And the one thing, too, that -- in that 

particular piece, I mean, the number is nominal. 

But you go from thirteen weights to four, and 

that -- that is good. And it -- I do believe --

I'm not the one that does the check- testing of 

our scales, but I have heard concerns that it's -

- it's been hard to get some scales in line with 

the F weights. And I -- from the research we 

were doing, it seems like this switching over the 

weights to ASTM Class 4 could help -- help 

mitigate some of that.

 MR. FREDERKING: I would just say it 

does seem significant if this is the only point 

in FGIS policies, handbooks, that does not follow 

NIST. To leave that hanging out there seems --

seems concerning. But having a plan in place to 

replace upgrade scales with end of life. So --

seems to make sense, opposed to forcing some 

arbitrary three to five-year compliance period. 

Is there something within -- that industry could 

come up with that would say, average scale lasts 

ten years. We have a ten- year window now to --

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as you have scales reach end of useful life, as 

you find new ones that you're not coming out of 

pocket for whole new scales, you're just 

replacing the ones that you have already. Just 

to a higher standard. So -- would sure seem 

there would be a reasonable approach to become 

compliant with -- with NIST. Which seems to make 

sense. 

CHAIR GROVE: Ryan, are you still 

there? 

MR. SEAPY: Yes. 

CHAIR GROVE: Yeah. So to -- I think 

we might have asked it last week. But to Chris's 

point, is -- is this the only section that 

doesn't align, or you haven't addressed others 

yet, you're just starting the review?

 MR. SEAPY: Just starting the review. 

We've identified for this one. I -- I couldn.t 

tell you whether there are other places where 

FGIS policy deviates from NIST. And there was 

some conversation about corn and soy not being 

impacted as much. That is very much the case. 

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Partially, because the smallest portion size in 

soy or corn -- so I think it's 125 grams. Which 

gets you out of that really tight -- excuse me --

you know, small portion size, where a small 

error, it could make a significant impact. So 

the idea that, you know, this is really a -- an 

area where, say, sorghum or wheat are going to be 

impacted more than corn and soy is definitely the 

case.

 CHAIR GROVE: Okay. Thank you for 

that input. Sorry -- I just -- we don't have to 

have a proposal this meeting. If this is 

something that we feel we would like a few more 

answer to, as Ryan is doing a review, say, how 

many other places do we not align with NIST. I 

think that would be some good information because 

I think this is important to align across 

standards brings to us an integrity of the -- the 

U.S. system. Somebody's questioning "Well, what 

are you using?" And -- and states have one 

thing. They hear NIST -- people go to NIST 

handbook to look at things, but FGIS is 

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different. So I think that does have to be 

something that we are looking at.

 I think we need to look at aligning 

and probably in wording not referring to a 

specific volume, like Handbook 44, which has now 

made our -- our handbooks and our regulations out 

of date. But making it a little more evergreen. 

And also, I think to give our industry a little 

bit of time, or give us a little bit of time to 

come -- go back to our own sector of the industry 

and say "Is this impacting us?" And I -- I like 

what you talked about, Chris, in saying we need 

to -- we need to figure out what is that lifespan 

plan. If it's not affecting us greatly, but 

really, it's a better alignment, how will this 

affect us?

 So would anybody have objections to 

say this would be a topic that we can move to the 

next agenda? That a proposal doesn't need to 

happen at this time. But it is something we 

still want to consider looking at. And maybe 

instead of just lab scales, that is an updated 

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instrumentation of the policy for the -- for the 

next agenda. Would you feel comfortable with 

that?

 DR. HURBURGH: Realize that that's 

going to get into quite a number of more issues 

than just scales. I'm just thinking of moisture 

meters as an example. And Jimmy, you know that 

we go through this on the moisture meter 

taskforce with NIST. The standards aren't the 

same. And it can go both ways. That is, tighter, 

or less restrictive. Just recognize that there's 

a lot things if you make an open-ended statement 

like that.

 CHAIR GROVE: Right. I just feel right 

now, from the comments, nobody feels strongly 

enough that this is something that we are ready 

to make a "Hey, let's go with A, B, and C. Or 

let's amend an A, B, and C." I'm not sure anybody 

feels that we're ready for that. So even if we 

just say -- stay with lab samples -- say we need 

to -- we're going to move that to an ongoing next 

agenda item so we have time to think about this 

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more. And think about the impact, or get some 

information on what is that impact going to be.

 MR. WILLIAMS: Well, Barb, in the very 

least, I would -- I think it would be good for 

folks to be able to go back and, like, really 

crunch the numbers. And I'm not being -- being 

critical of the -- of the estimate that FGIS came 

up with at all. But I strongly suspect that 

number is going to be greater than $10,000. So -

- so again, I think it would be beneficial to 

give folks some time to just go back and truly 

see what the cost is going to be.

 MS. MIKESH: Another piece of 

information that I think would be helpful for the 

Committee, would be a list of factors that it 

does make a statistical impact on. Heat damage 

is the one that has been used, and I -- it seems 

like probably has the biggest impact on. But are 

there other -- are there other factors that --

the list of factors that are in the 60 grams --

anything really below that 125 grams in the 

smaller grains. So you could see if those make a 

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big impact for you as well.

 CHAIR GROVE: So Arthur, I think that 

this is one -- actually, we can put a proposal 

together that we move this as an open -- keep 

this as an open agenda item, but we have asked of 

-- of FGIS. First of all, you know, so -- we'll -

- we can bring tomorrow some -- again, lists of 

other factors. One factor doesn't seem as 

concerning that it's hurting the industry. But 

there are a lot of other small grades. So other 

-- other grains or factors that this is 

affecting.

 And -- and then also -- that's not 

part of the -- the proposal, but the rest of us 

can go back and -- and look at what is that true 

financial impact. So we can be better prepared to 

look at some different options. And even 

amending some options that were given us.

 Thank you again, Ryan. You know, 

thank you for your time last week, and -- and 

giving us a heads up to help us understand what 

this is. Again, the review today -- so again, 

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those that are in the -- the gallery and online 

can help understand where this come from. So 

that can be something later. We'll look at 

agenda items for proposed next time.

 If there are no other comments on this 

particular item?

 I think we are prepared to move on. 

Chris, if you would like to present to us the --

the data standards.

 MR. FREDERKING: Absolutely.

 MR. FRIANT: Hey, Barb. Do we have 

room in the agenda for a quick break?

 CHAIR GROVE: Yes. Yes, we do. We do 

have room. So if we would take a -- we can take 

a 15- minute break. Right now it is three 

o'clock. So perfect timing. Thank you, Nick. 

So 15-minute break. Be back at 3:15 and Chris 

will present to us.

 (Whereupon, the above-entitled matter 

went off the record for a brief recess.)

 MR. FREDERKING: Okay. So as part of 

our last meeting, we had talked about technology 

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initiatives. Specifically around FGIS and one 

thing, certainly from the exporter side that 

seemed to definitely have some merit is how we 

can facilitate some of that technology growth and 

make the data that is being generated useful for 

industry.

 So in the write-up, as many of you 

have read, there's a few discussion topics 

brought up that are relevant to this. Of course, 

we want to ensure that FGIS continues to improve 

and supply industry with data that is useful and 

facilitates grain trade by -- and it need to be 

accurate. It needs to be secure. And it 

certainly needs to be timely.

 So how do we get that information out 

of a lot of these systems that are being used 

throughout the -- the Federal Grain Inspection 

Service and maybe official agencies as well --

out to industry. Out to end users in a -- in a 

useful manner, that again, helps facilitate that 

grain trade.

 So with that, I know there's been some 

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work done, certainly within some different 

industry groups, but felt relevant to bring it up 

here to -- to the Grain Inspection Advisory 

Committee. So as far as discussion topics. 

Certainly, first and foremost, was cybersecurity 

being a concern with a lot of these systems at 

export houses being tied into plant controls 

networks. Just the inner workings of the 

facilities' security must be paramount.

 And so working with FGIS and other 

service providers to ensure that vulnerabilities 

are evaluated. That all federal requirements are 

being met in order for this information that will 

be provided -- that there aren't new security 

issues brought about because now all of a sudden 

we're looking to share that.

 Additionally, seeking industry's input 

would be another point that I'd bring up. To 

establish standards around data types. So what 

kind of information do we want to see, in what 

format. Giving away APIs, Application Program 

Interfaces, to allow for that data exchange 

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between interested parties and official agencies. 

And then, just even taking the time to decide 

what that data package should look like. Whether 

that's for a barge. Maybe it's for a railcar, 

it's for a vessel. Whatever have you.

 Additionally, on the AWMS side -- so 

the Automatic Weight Management System -- and a 

lot of export houses. As far as data handling is 

concerned, there's information going into those 

AWMSs to reduce the amount of data entry 

performed by FGIS personnel. But there's very 

little information coming out of those system. 

That, in turn, creates a lot of work for the 

people out in the field. Specifically, on barge 

certificates, vessel paperwork and whatnot. So 

are there ways to have that as a more secure twoway communication between systems, both on the 

AWMS and other -- other systems.

 And then, of course, as we look to 

incorporate additional technologies, can they 

integrate to these accounting packages, these 

oversight packages, FGIS online, whatever have 

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you. How can these new technologies talk to 

what's already out there to reduce keystrokes, 

and to ensure accuracy. So had a -- a few 

examples on that in the write-up.

 And then taking the time to look at 

FGIS online and evaluating is that as useful of a 

tool as -- as we want it to be. And where and 

how should -- should the functionality improve to 

continue to meet shareholder needs. And then, of 

course, as we've been talking about all day, the 

funding to get all this done. So it's -- it's a 

lot of heavy lifting. I know a lot of this --

none of it comes for free. So how can we ensure 

that FGIS is dedicating dollars to 

standardization of data, the availability of it, 

ensuring that it comes to stakeholders in a 

secure and consistent way.

 So with that, that's the background. 

The sketch and topics that wanted to bring to the 

Committee. And would certainly open it up to 

discussions, questions.

 CHAIR GROVE: So Chris, I -- I think 

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last meeting, when you -- you brought this up as 

an agenda item, you were giving a few specifics 

on, you know, that -- that data transfer. 

Especially, I -- I'm going to say, probably with 

your AWMS system and your barge loading -- about 

-- and it revolved around having the data in a 

timely manner. Or -- weights. And I think it was 

specifically more -- again, with your -- the 

weights -- that sometimes you weren't getting 

that in a timely fashion back from the official 

system, for you to make determinations. Is that 

accurate?

 MR. FREDERKING: Timeliness is 

certainly important. But what I would say more 

than anything, is that it's not coming to us in 

an electronic format. Right? It is getting 

printed out on a piece of paper, and then scanned 

and copied, and emailed over to -- to us as end 

users. So is there a way -- obviously, that --

that data is being generated somehow, someway in 

the system that already exists. Is there a way to 

ensure that those systems are talking to each 

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other to where that data comes over 

automatically.

 With that, of course, we need 

consistency across all systems as well, to where 

certain -- certain pieces aren't in place for 

specific locations or certain data streams, if 

you want to call it that. So, yeah. Not 

necessarily timeliness of getting reports. But 

getting those reports electronically is where I'd 

focus.

 MR. MORGAN: This is John Morgan. 

Chris, I'm just -- are you guys also looking to 

potentially tap into the automation technology on 

the scales? Is that one of the things that 

you're looking at?

 MR. FREDERKING: On bulk weighers, or 

grading scales?

 MR. MORGAN: I mean, you -- you fought 

through scales. Now you're -- weights.

 CHAIR GROVE: Yeah. So the -- the 

scales are monitored by the AWMS already. So 

that data is available. And actually, for -- for 

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insight as to how that works, even at our 

facility, or AWMS will basically print out a 

piece of paper with all the relevant barge unload 

information. Then that barge unload information 

gets handed to a supervisor. And then that 

supervisor -- that FGIS supervisor will take that 

and then type it manually into FGIS's system.

 So that sure seems like an extra step 

in there. How do we eliminate that extra step? 

It's where -- and for some facilities -- for the 

-- certainly, for the Gulf as a -- as a whole, 

that's thousands of entries a year.

 MR. MORGAN: Is your scale data tied 

into your automation system for, like, opening, 

closing your gates, and --

MR. FREDERKING: Correct. Full --

full automation. Yeah.

 MR. MORGAN: Okay. Yep.

 CHAIR GROVE: So I'm going to bring in 

a little bit from the other side of it. From 

conversations I had with some official agencies 

at that AAGIWA conference here earlier this year. 

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And I presented on some things that, you know, 

maybe supped from the industry. Some things that 

we were seeing that, you know, could be better. 

Or we could have better asks from the official 

agencies.

 And one of those was, you know, 

keeping up "Hey. It's -- they're not keeping up 

with shuttle times," and things like that. And -

- and some scheduling. And sat down after the 

meeting with numerous agencies, and we sat there 

and chatted about it. And they brought up one of 

the same things that you were talking about.

 Then from there -- and when we are 

sending some of the agencies our car lists, or 

weight, things like this -- I'm going to be 

emailing a pdf, or printing it out and here it 

is. So somebody's having to retype that into the 

system.

 So I think some of the things that 

you're asking work both ways for efficiency, in 

that if we -- if we were going it at least 

electronically in some format, that we are making 

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somebody's job more efficient. So I -- I think 

this is very relevant to me from both sides of 

the point of view.

 MS. MIKESH: The thing I'd say we have 

-- I didn't see this previously when introducing 

myself -- but I'm a part of a company that does 

software development for grain inspection 

agencies. And we do different software platforms, 

just, to aid in efficiencies, basically. And one 

thing that is helpful when looking at -- I agree 

with you Barb -- there's -- it goes both ways for 

being able to enter in that data. And we are 

constantly, as an agency, and also on the 

software development, trying to find ways where 

we can lessen keystrokes for us and our customers 

because labor is not -- there's not an endless 

amount of it right now. And that's just one 

simplified way we can -- we can really work with 

that.

 And from -- from my perspective, if we 

were to do something of getting in carless 

weights, the information from you -- from 

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industry and vice versa, it would be nice to have 

it standardized. There are a lot of -- there are 

a lot of third-party software programs that 

official agencies use. So you're primarily with 

export, so you are going to be using FGIS online 

system, I would gather. Most internal domestic 

agencies -- agencies that are dealing with the 

domestic market -- are likely using a third-party 

software. And there are numerous out there.

 And we have -- we have outputs -- it's 

the IDW directive. I can't remember the numbers. 

But we -- all the information that comes from our 

program has to go through a certain output into 

FGIS online. And so every single night our 

information has gone in there, and it's in a 

standardized manner. If there were ways that 

industry was wanting to input into other -- other 

software, it would be nice if it was standardized 

in that manner, so that industry didn't have to 

do it in multiple different ways depending on 

what the program was. Because that's something I 

hear currently, as well -- in this area, I need 

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to send information this way, or I scheduled this 

way. And in this area, it's completely 

different. And I think that would be really 

helpful for industry, too. So just a thought as 

we're exploring these items.

 CHAIR GROVE: From FGIS or official 

system, some input. You know, even from the --

the gallery back there on -- on thoughts of how 

this affects you.

 MR. NEAL: I don't think it's new to 

us. I think before I came onboard, there was a 

desire to -- to modernize our -- our system such 

that we could warrant -- reduce the manual input 

of data. And it would be more useful to -- for 

us, as well as our customers and industry. But 

we didn't have money to keep that up. So -- so 

we had to stop that -- that project. We stopped 

it in two thousand -- I think twenty. Yeah. We 

stopped it around 2020. We didn't have the -- we 

didn't have the contracting dollars to keep it 

up. It could probably be picked up, but we'd 

have to have money for it. We decided to make 

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sure we had money to continue operations.

 Denise, you mentioned it earlier. I 

have no problem with what we're proposing to do. 

We just have to make sure we've got the resources 

to get it done. If we do that, we can -- we can, 

you know, develop a project plan and work with 

industry to prioritize what do we want to work on 

first. How does that look?

 Definitely got to work out the kinks 

between communicating between both -- the systems 

and the cybersecurity component. So that's some 

things we'd have to work out. But I think it's a 

great goal for us. And we definitely need to do 

it. Should -- should be there. But we're not 

there. Once we address, I think, the biggest 

elephant in the room.

 If we can begin -- say, for instance, 

if we could generate revenue such that we could 

be able to save some of the -- the revenue for 

these types of projects. That's another thing. 

If there's an agreement on how we could approach 

that, there are ways that we could do it. But 

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ideally, the main thing right now is going to be 

resources to get it done.

 MS. MIKESH: I -- I would agree with 

that. Even on the private side. Is -- I have 

everything outlined on how to automate a lot of 

our systems. How to go to electronic work 

records that automatically go into the 

certification program. All the way from 

scheduling to paying your bill. Everything along 

the lines and -- one.

 But in order -- us, working on behalf 

of the USDA, we're constantly working to make 

sure that our costs are in line, so that we're 

not raising our fees as well. And so we've 

always been interested in knowing where is that 

prioritization from the agency standpoint of how 

much is that worth it to everybody, and what type 

of priorities would you want around that. So we 

have leaned towards really, the items that people 

talk about very frequently. You know, working 

with our system, working API, and things of that 

nature. Trying to make it so don't have as many 

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keystrokes.

 But there is so much more to bring it 

in line. It's just whether or not it works 

within the industry. So if -- there's definitely 

a desire there from, I think, all parties.

 MR. FRIANT: And typically, Arthur, 

would IT-related funding -- is that typically 

appropriated funds that would go towards that?

 MR. NEAL: It depends. So typically, 

they could be used for it. User fees could be 

used for it, with agreement. If it's enough of 

it. It -- it just depends, Nick. There's --

there's no restriction because it's all being 

deployed to provide direct service. Some 

agencies and some programs even within AMS, 

Congress will provide specific funding for them 

to -- to develop some enterprise system to 

facilitate trade. That hasn't been the case with 

FGIS.

 I think what -- what had happened in 

the past, FGIS tried to, you know, use any excess 

appropriations that they had to fund IT projects. 

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I'm not sure what they used in terms of -- or 

what we used in terms of user fees. But I think 

they used appropriated funds. Am I correct, 

Denise? Yeah.

 So -- so to try not to put a burden on 

the customers. But I think it's a -- it's a 

shared expense. It -- it could be shared across 

both, but we've got to be efficient in the 

buildout. We got to be efficient in the 

prioritization, the design, the buildout.

 So I'll be honest with you. 

Contracting is very difficult when you're working 

in the federal government. Because there's so 

little control we have once we get them. So 

sometimes, their priority is not really, you 

know, helping us get to where we want to be the 

most efficient way. It's to keep us on the hook. 

You know, so it doesn't -- you know, keep -- keep 

taxing us and taxing us. And I think that's what 

happened.

 So us -- if we work together in 

agreement, to figure out how to prioritize, how 

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to build, design -- you know, not -- not spend 

anything until we're sure we -- this is the way 

we want to go, so that there's no confusion and 

no banter. I think we could get there, but we've 

got to address the, like I said, the elephant in 

the room first, and that's -- that's the funding 

of this organization and how we move in our out 

years.

 MR. FRIANT: And I would certainly 

hope that there's some foundational building 

blocks that were established, as you eluded to, 

back in 2020 when it just kind of fell flat. And 

help in minimizing some of the financial impacts 

on some -- there may be some real low-hanging 

fruit that we can very easily address with 

minimal spend that -- through the dialogue 

between engaging industry and FGIS, maybe in a 

collaborative manner, we could -- we could make 

some real headway in a short -- short amount of 

time.

 MR. NEAL: We're open. Not closeminded 

to it. Like I said, if there's -- if there's 

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small, low-hanging fruit that we can address and 

pluck off the tree, to benefit the, you know, the 

whole system, let's -- let's figure it out. But 

let's do it where everybody's in -- in the know, 

and we agree this is what we want to spend the 

resources on. I have no problem with that.

 Some of the -- some of what's 

mentioned in here is big stuff. Some may be 

small. It may be a little data package. You 

know, API situation. I'm not sure, you know, 

what data, specifically. I know some of it may 

be scaled information, but I don't know what's 

needed to make that -- that connection between 

our system so that you can grab it and use it the 

way you want to. But let's just -- let's just 

prioritize it and figure it out. And we can come 

back and say "Hey, this is possible. This is 

what we anticipate the costs will be -- or for us 

to handle this." Or how many people we may need 

to get it done. But I see no problem with us 

having those dialogues.

 CHAIR GROVE: So I would be very 

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interested in -- and whether it's at this moment 

-- although we do have the time for it -- to --

or if it's something that maybe Kia could present 

to this group, that you've already said you have 

somebody that's doing some of that research. 

You're part of a -- a group and organization 

doing that.

 Seems to me, first of all, you -- you 

do have, again, some studies, and some things 

about -- with -- with prioritization that we 

could look at. I think that's -- that's very 

good information to know and a good place for us 

to start. Cybersecurity, you know, in FGIS 

updates, there's -- that was mentioned a couple 

of times. You know, very important.

 I look at it, you know, rural 

organizations, again, have been targeted --

targeted very heavily. And I know our company, 

when targeted with a ransomware attack, you know, 

it came in and it was thwarted very quickly. But 

it started because somebody was using old 

computers, old operating systems. Operating 

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systems that were not current enough to be able 

to handle new virus ware protection.

 So think of our industry facilities 

and computers we may be using, 'cause they get it 

done, in the -- in the rail-loading scale house. 

Let's put the old computer up there, or maybe we 

don't have to do it. Or at the scales that we 

utilize those things. Those are very important. 

You know, and you did, Chris, mention how can we 

do it securely. Assess that vulnerability. That 

is very important.

 So I think in that, some standards 

would have to be put in place as Chris mentioned. 

You know, what are those vulnerabilities 

evaluated for cybersecurity -- you have that in 

place for us to -- to have that efficiency, and 

to say "Hey, let's our computers talk." Both 

sides, obviously have to have that in place. 

Where does that fit within your current budgeting 

of your department? That you have somebody 

working on that already, that's a big first step.

 MR. NEAL: Yeah. I think it's -- it's 

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easy as identifying low-hanging fruit, 

establishing a goal, assessing it for reality. 

And then -- and then pursuing it with agreement. 

It's as simple as that. I don't think it's overly 

difficult.

 The reality, too, is that every --

every elevator may be different. And so it --

that data standard, you know, what works for 

everybody, so that we don't have to have 

different versions for every -- every elevator. 

So that's another type of conversation. So for 

some people, they may be wherever they need to be 

for us to tap into, or for them to tap into the 

data. Others, there may be some growth that they 

have to do. They have to get there.

 But it can be agreed "Now this is --

this is the approach. This is the standard that 

we want to set to facilitate this exchange of 

information or data." And we work toward it. 

And so I think that can be an easy topic to put 

on -- on the agenda, you know, for conversation. 

Such as, you know, what would potentially be lowNeal R. Gross and Co., Inc.

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hanging fruit? Something that we could set as a 

goal and strive for the next year or so. And we 

provide updates on it to see if we can get there.

 MR. HEIL: Yeah. Mark at Prairie. So 

just -- just as I'm listening to the discussion, 

it just -- right in the middle of the stream 

here, we got an upstream and downstream. A lot 

of times, I'm not exactly what somebody may need 

to want to have up or down from me. And we just 

don't know.

 And I just -- as I was thinking here 

-- is there -- has there been any pilot projects? 

Has there been any, you know, successes along the 

way that we, you know, we can just learn from 

that, or watch that? You know, before you try to 

take it across the whole system, let's just find 

somebody that's having success with it and just 

build on it.

 MR. NEAL: And I think that's kind of 

why Chris is bringing it up. I know Chris has 

been talking to Lee Capper, our chief innovation 

officer, just about an exchange of information. 

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And I think Chris is bringing it to the Committee 

because he doesn't want it to be a one -- oneperson benefit. But if we could think about 

something that could work, and we -- we do pilot 

it, establishing a standard for it, sharing that. 

You know, agreeing, is this something that we 

want to pursue for all -- make available to all. 

I think that's kind of where you're getting at. 

Right, Chris?

 MR. FREDERKING: Yeah. Correct. It's 

-- it's universal and it's not just on the export 

side. It's not just on barges or vessels or 

railcars, or maybe even trucks or containers, 

whatever have you. Right? The -- I think the --

the overall driver is -- industry as a whole is -

- is headed this direction. Right? And to be 

able to -- as far as data standardization, 

transfer of data. Easing that and having central 

repositories for all barge and load data. Right? 

That's something that I know NGFA has been 

working on. Having the processes of systems in 

place on the FGIS side to facilitate all that is 

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going to be key for the success of a lot of those 

projects. So and you're -- yeah. Exactly right. 

There's -- there's probably a lot of things we 

don't know. So engaging all industry, as well as 

FGIS, to where nobody's working in a vacuum 

certainly would be a good action item going 

forward.

 MS. COOPER: Seems like this is, you 

know, very much related to the technology 

discussion, generally. I think it kind of came 

out of that discussion. So maybe it's something 

that could be included in the technology summit? 

Or not. Something at least to consider. How --

how that -- introducing that efficiency in -- in 

the system relates to an overall effort to -- to 

improve efficiency.

 MR. FREDERKING: And I -- I would add, 

there is real competency already within FGIS on a 

lot of these topics. And certainly like you --

you had mentioned, dealing with talking to Leroy 

and trying to come up with some solutions that 

aren't just isolated again to just one elevator, 

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but rather to the system as a whole. And 

identifying that growth pattern, hopefully. 

There's a lot that we can lean on amongst the 

group already, within the FGIS team, to help 

develop some of this. And maybe that innovation 

summit, too.

 CHAIR GROVE: Any other thoughts and 

comments on this?

 I think, Chris, this is -- this was 

really, to me, again, well thought out. You're 

asking for industry input, you know. And you're 

also asking "Hey, FGIS, where can we look for 

it." So definitely a continued topic. Because 

we have to be able to gather the information to 

know where we can start.

 If there's no other comments on this 

particular at this time. Do you feel you have 

enough to start to -- to look for something for 

tomorrow?

 MR. FREDERKING: Yeah. I feel like I 

have enough to develop a recommendation, just on 

a path forward to, again, continue that 

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conversation and try and prioritize, and engage 

industry. All that good stuff.

 CHAIR GROVE: Okay.

 We have checked in. We have no online 

industry comments at this time. But we are at a 

place in our agenda that we would accept any 

comments from the gallery. If you have input on 

-- yet, on any of these topics that we have had 

so far today.

 Again, even if it's "Hey. On this 

data standard, you might think about this." So 

again, this is the time for you. We do have time 

allotted tomorrow morning if somebody mulls over 

this tonight and says "I think I have something 

we may -- may be able to add to you." So again, 

I'll give a last call for anybody with public 

comments.

 All right. So no other comments. 

Again, we do have time starting at 8:40 tomorrow 

morning for public comment. And we do welcome 

those before we'd start discussing 

recommendations at nine o'clock. 

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So our -- our schedule for tomorrow. 

Again, looking about 8:40 to give us some time 

for some public comment. If there -- if there 

are none, we will move on to discussing the 

recommendations that we've talked about today. 

And giving and voting on final recommendations. 

We will have our officer elections. And 

definitely put some thought in tonight on 

discussing those agenda items for the next 

meeting. And keeping in mind that in setting our 

next meeting, you know, we did talk about, 

yesterday in a business meeting, and it was again 

mentioned this morning.

 If we're trying to have two meetings 

this year, yet, you know, we're looking at 

probably a November, December. That's a very 

quick turnaround in needing a 30-day public 

notice. So these are things that we would want 

to come to the table with and be able to do our 

write-ups in a -- in a timely manner so Kendra 

can get that posted.

 I -- I have been kind of keeping a 

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list of some things that we did talk about 

yesterday -- of some things. And a few things 

today that we're going to keep as open agenda 

items. We also need to keep in thought for next 

meeting, ideas of if we have some subcommittees 

that we want to officially make, we need to have 

that on next agenda. So if there are these 

topics, whether it's data, whether it's 

technology, that we need ongoing discussions from 

a smaller group, we want that on next agenda.

 All right. Well, thank you for your 

time today. You know, we -- we really put Denise 

through the ringer today. Thank you for 

tolerating us and -- again, sometimes --

sometimes those things are very hard. None of us 

wants to see it, but we also know the value of 

what we have and we want to keep going forward.

 So thank you for your time today. We 

will adjourn and convene tomorrow morning again 

at 8:30. Thank you.

 (Whereupon, the above-entitled matter 

went off the record at 5:16 p.m.) 

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A

a.m 1:4 3:2 81:13 138:6

138:12

AAGIWA 225:21 258:22

abbreviated 219:19

aberration 27:14

ability 60:5 159:22

able 5:22 7:6 34:5 36:2

38:6 40:7 50:20 55:20

65:3,22 72:14 76:12

76:21 77:3 80:7 87:5

87:7 88:4 101:5,12

137:18 140:5 168:21

178:20 180:3,9

182:22 190:16 195:11

195:19 198:12 201:22

202:1 229:4 240:8

249:5 260:12 263:19

270:1 273:17 275:14

276:15 277:19

above-entitled 81:14

150:11 251:19 278:21

abroad 161:7

absolutely 109:16

152:7 251:10

absorbing 128:1

129:11

accept 85:8 276:6

acceptable 72:6

acceptance 58:14

63:14 71:13 72:4

accepted 15:10

access 180:15

accessing 152:21

accommodate 157:3

159:16

accommodations

157:6

accompany 54:11,20

161:18

accompanying 46:8

accomplish 38:6

account 14:16 62:18

68:11 85:16 86:3 89:9

99:16,17 101:14

104:6 105:7,9,18

accounted 223:8,16

accounting 254:21

accounts 82:14 85:11

105:6 179:1 186:22

201:20

accreditation 70:16

accuracy 234:12,13,13

234:13 237:15 255:3

accurate 17:20 63:3

163:17 190:19 221:9

232:17 252:13 256:12

accurately 61:3 63:10

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achieved 70:16

achieving 62:4

acknowledge 231:6

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act 9:15 21:11 28:10

50:4 51:3 82:21 84:6

85:12 100:15,20,21

113:15 118:7 130:13

180:1 188:13 212:6

acting 1:12 2:6 20:7,8

20:10 21:2 40:17 42:6

42:10 47:18

action 13:1 181:4 243:4

274:6

actionable 44:17

active 220:9

actively 58:10,15

activities 9:8 15:1,2,6

45:12 51:7 57:13

59:13

activity 57:17

actual 91:4 132:7,22

133:10,11 136:9

196:12

actuality 107:6

Adams-Mikesh 1:18

add 80:13 94:11 98:4

112:18,18 122:9

125:15,16,17 128:16

143:12,13 191:8

203:11 208:6 221:3

274:17 276:15

added 46:2 98:10

146:20 154:5 160:1

171:6 193:5 218:12

222:6 236:12,21

adding 72:5 171:5

addition 27:9 37:14

70:17 126:14 163:21

additional 67:10 69:15

73:4 100:17 101:2

128:16 154:5 195:20

197:8,19 199:15

254:20

additionally 153:3

214:20 217:6 253:17

254:6

address 10:19 40:14

168:3 219:11 243:13

243:14 263:15 267:5

267:15 268:1

addressed 7:21 31:18

165:1 199:11 245:15

addresses 158:18

164:13

addressing 141:6 166:8

adequately 15:16

adjourn 2:12 278:19

adjust 14:22 98:4

100:14 126:20 129:7

144:21,22 145:3,21

177:4 182:22

adjusted 104:9 118:13

122:7 134:17 144:8

184:20 185:3 200:19

adjusting 22:16 98:15

129:18 144:6

adjustment 98:2 102:15

114:2 119:7 120:20

136:1 142:5 200:19

211:6

adjustments 74:14

114:4 120:4 123:13

129:13 133:18 177:9

177:12 197:11 212:19

adjusts 142:7

admin 109:20 122:12

182:17

administer 26:17

administration 48:16

48:21 84:15 204:9

212:11

administrations 85:1

administrative 92:1,7

97:22 104:1 134:16

144:17 196:12,22

198:1

administrator 1:10 2:4

20:3 21:1 27:3 41:12

110:7 130:20 171:22

administrator's 110:13

111:11

administrators 83:14

adopted 187:18,20

advance 181:2

advisor 20:4

advisory 1:1 8:21 9:6

10:18 16:1 18:17 19:9

19:15 40:12 151:20

195:22 253:3

affairs 2:7 28:15 48:2

58:11

affect 11:22 145:9

148:22 180:5,10

209:3 211:22 232:6

233:6 247:16

afford 194:11

affordable 77:13

AFIS 52:10 56:9,18

163:11 166:11 167:2

167:5,21 168:16

aflatoxin 91:22 116:16

121:13 131:21

AFOM 28:11

Africa 55:12

afternoon 149:11

ag 4:7 5:18 163:4

agencies 5:4,5 9:18

12:16 14:16 25:7,20

26:22 32:6,8 36:11,20

37:1 39:5,7 52:7

57:22 85:15 86:15

94:3,8 202:9 217:6

218:7,8,12,20 221:17

221:19,21 224:11

226:1,3,12,15,19

228:8 231:22 240:7

243:21 252:18 254:1

258:21 259:5,10,14

260:8 261:4,7,7

265:15

agency 10:4 26:16

29:11 32:18,20 33:15

42:7 43:2 58:2 69:19

86:5 115:1 182:6

197:5 198:17 208:2

220:10 221:11,16

226:22 227:2,6,8,9,19

228:1,9,10 229:8

239:21 240:3 242:7

260:13 264:16

agenda 8:8 233:14

247:19 248:2,22

250:5 251:4,12 256:2

271:21 276:6 277:9

278:3,7,10

aggressive 39:16

ago 20:2 36:9 51:11

73:12,13 99:15 123:1

156:13 179:12 199:21

206:4 208:12 239:1

agree 163:20 166:8

260:10 264:3 268:5

agreed 271:16

agreeing 167:21 273:6

agreement 61:9 66:11

69:22 75:3 166:21

200:20 263:21 265:11

266:22 271:3

agreements 39:6 87:18

89:12,12 101:8 109:9

109:9 111:13 134:12

agricultural 11:15

23:16 50:4 51:3

154:10 194:7

agriculture 1:1 5:7

16:13 186:4

agronomic 71:21

AGUA 21:5 32:7

ahead 3:4 6:4 8:8,9

51:21 54:2 81:7

149:12 151:3 152:5

154:9 168:19 169:16

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195:11,11 210:8

214:8,14 231:3

241:19

aid 260:9

aim 178:17

air 80:21 234:3

alarm 202:5

Alaska 165:8

Algerian 58:21

align 214:19 216:18

245:15 246:15,17

aligned 74:13

aligning 247:3

alignment 59:11,22

60:7 67:7 69:8 76:11

78:20 247:15

alike 73:19

Alimentarius 57:15

all-inclusive 49:21

allocation 83:18

allotted 276:13

allow 178:7 210:16

219:15 253:22

allowable 215:22

allowance 125:18,19

126:2,18

allowed 133:4 144:22

allowing 158:16,21

217:19

allows 11:5 45:9 63:20

159:15 180:1,2

alongside 62:14

AMA 85:16,17 122:22

Ambassador 1:7

amend 248:18

amending 250:18

amendments 86:10

American 5:4 225:21

amount 66:3 87:6 89:9

92:5 96:10 99:1 114:6

132:4 133:16 141:15

142:14 153:9 157:15

159:14 160:8 254:10

260:17 267:19

amounts 89:15 137:8

142:17

AMS 1:6 27:8,11 43:4

43:12 111:11 120:3

122:12,21,21 125:2

135:4,8 174:20

265:15

AMS's 83:15 122:15

analyses 46:1

analysis 41:20 44:2,20

67:22 70:18 71:5

84:17 171:19 195:20

198:12,21

Analyst 1:10

analytical 69:22 70:2

analyze 66:15

analyzed 65:16 171:19

analyzer 73:7

analyzers 74:16

anchors 162:8

and/or 207:11

Andy 20:22 21:2 41:12

41:13 138:19

angles 60:18

animal 14:2 44:16

48:21

announce 21:21

announced 20:12,20

21:19 53:20 62:11

announcement 20:11

announcing 20:8

annual 14:12 29:21

49:6 86:12 89:20 93:7

93:8 112:2 114:7

177:7 191:13 196:7

212:17

annually 82:19 93:19

182:7

answer 6:14 35:19 36:4

76:22 78:20 111:14

164:7 181:13 202:16

211:1 212:15 223:10

246:14

answered 35:12 52:1

184:13

answering 164:9

anticipate 37:6 50:18

74:19 189:16 268:18

anticipated 20:19 189:1

anticipating 107:11

137:7 141:17 142:3

148:1 239:19

antivirus 64:11

anxious 56:22

anybody 139:14 170:19

210:7 247:17 248:18

276:16

anybody's 21:10 119:4

anymore 36:16 93:11

194:11 195:1

anytime 48:9 139:15

anyway 75:5 127:13

160:5,14 225:13

anyways 228:5

API 264:21 268:10

APIs 253:21

apparent 45:5

appeal 46:4

appeals 59:19 61:9

67:20 69:4 78:18

80:18 131:22,22

appear 49:14

appears 166:8

applicable 66:7

applicant 54:20

applicant's 131:12

applicants 47:12 50:9

54:5,11 131:6

application 19:11

153:18 154:15 156:10

158:9,11 159:3,9

160:16 164:15 165:15

165:21 166:4 253:21

applications 20:13,21

21:20 26:20 54:7

72:19,21 154:16

156:20 158:16 159:1

162:5 163:18 217:21

applied 18:21 35:10

67:12 68:9 70:10

157:12 159:12 161:19

applies 82:13 152:16

apply 153:1 215:11

applying 134:20

appreciate 3:12 22:4

59:5 109:16 146:8

165:1,4,7 167:14

175:8 176:4,16

194:21 195:18 197:7

210:4

appreciated 169:19

170:12

approach 13:4 72:6

146:22 148:15 186:19

245:6 263:21 271:17

approached 163:10

166:11 204:18

appropriate 7:12 218:1

242:9

appropriated 40:2 82:9

101:2 103:12,21

104:4,13 111:3,6

130:13 141:7 192:16

192:19 193:7 194:10

194:16 265:8 266:3

appropriation 14:12

82:21 193:2,3 194:18

appropriations 82:12

82:18 186:1,3,14,16

187:13 192:15,21

193:12,17 265:22

approps 187:19

approval 69:11 148:8

approved 62:7 94:19

133:15 148:11 168:16

186:12 227:11

approximately 31:8

38:6 43:21 221:14

240:6

APQ 48:22

April 28:9 86:11 97:7

106:13 119:19,21

136:13

Arabic 53:4

arbitrary 244:19

area 22:18 27:3 31:6,10

31:13,15 34:12,13

36:5,16 38:13 39:7

121:17 164:14 188:1

215:17 226:21 246:7

261:22 262:2

areas 30:8,8,17,22 32:1

32:9,12 34:16 36:10

59:15 70:21 92:15,16

98:14 100:19 103:22

104:3 121:8 148:19

177:16 216:21 226:11

226:14

argue 182:15

argument 232:13

arranged 56:14

arrived 220:6,6

ARS 161:6 162:14

Art 26:10

Arthur 1:10 2:4 8:9

27:12 34:18 36:6 37:3

41:8,18 44:18 46:17

80:3 84:12,13 107:20

138:1,19 151:16

155:5 168:9 182:12

183:7 199:20 203:9

207:11 212:3 213:12

240:16 250:2 265:6

Arthur's 138:10

artificial 66:18

Asia 52:15,18 54:10,19

55:22 56:5,16,22

Asian 51:18

Aside 209:12

asked 15:8 16:3 24:8

25:9 50:10 54:21

82:16 100:5 151:11

165:12 201:10 226:15

235:2 245:13 250:5

asking 17:14 53:6 73:2

109:15 129:3 222:20

259:20 275:11,12

asks 259:4

aspartame 57:18

aspects 25:6

assay 44:12 45:4,20

assays 46:14

assembled 121:5

assess 9:19 61:2

117:10 209:20 211:9

270:10

assessed 94:7 98:11

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assessing 209:6 271:2

assessment 86:20 87:1

assignment 9:22

assist 32:6 39:7 60:19

134:14

assistance 26:21 33:5

assistant 42:8

assisted 130:12

assisting 28:12

associate 21:1 41:12

110:6

associated 86:1 158:5

Associates 54:21

association 5:4 185:18

204:21 225:22

associations 203:4

assuage 72:14

assume 44:6 138:15

166:19

assuming 145:7 207:1

221:14

assurance 1:11 2:5

12:20 26:7,11 41:1

42:11 60:1 61:14

assuring 167:22

asterisk 160:2

ASTM 217:16,22 244:10

attached 32:4

attaches 11:17 149:17

attack 269:19

attacks 25:3

attempting 177:10

attend 9:3

attending 19:8

attention 40:10 170:4

audience 155:2

audit 29:7 30:2 39:16

242:11

audits 26:16 28:19,22

29:1,5,12,20 30:6,18

augment 76:3

August 1:4 12:22 18:18

33:19 34:19 88:9 90:2

authority 50:8 58:3

authorization 193:12

authorizations 194:12

authorized 61:7 80:17

82:22 192:19 194:3

194:17

automate 139:18,18

264:5

automatic 94:20 254:7

automatically 139:15

224:14 257:2 264:7

automation 257:13

258:14,17

AV 151:2 152:2

availability 255:15

available 10:7 44:3

47:10 53:6,11,13 54:1

66:8 70:6 80:8 101:7

101:17 104:11,18

130:13 141:9 149:2,6

219:19,21 243:22

257:22 273:7

average 67:10 69:7

93:4 95:16 96:7,9

97:18 106:5,10,15,18

107:6 117:6 137:6,10

143:12 144:16 146:14

171:5 182:5 185:2

196:12 221:15 227:5

227:16 244:21

averages 177:2

aware 10:11 26:2 181:6

200:6,7

awareness 167:12

awesome 3:8

AWMS 254:6,18 256:5

257:21 258:2

AWMSs 254:10

axis 67:5

B

B 103:9 248:17,18

back 8:20 9:14 29:19

32:11 36:12 39:13

45:7 49:1,2 50:2,7

68:16 69:14 75:19

81:11,16 82:4 85:7

93:9 95:11 99:22

106:9 114:8 115:8

117:5,6 122:3 127:4,4

128:6 129:10 137:18

142:21 145:19 150:1

150:5,9,22 169:3

170:6,19 171:13

172:7 179:22 184:2

188:9 191:4,10

198:17 204:9 205:14

206:4 207:3 209:18

212:8 231:14 237:5

238:5,17,19 240:3

243:5,7 247:10 249:5

249:11 250:15 251:17

256:10 262:8 267:12

268:17

background 83:22

146:8 196:3 255:18

backgrounds 27:18

backup 222:13,16

232:4 233:1,2 239:22

240:1,9

backwards 113:17

180:2,3,14

bad 125:17,19 126:2,18

balance 91:4,4 108:19

148:13

banter 267:4

BAR 59:19 60:2,9,20

61:16,21 67:2,15 76:4

76:20 122:1

Barb 19:1 181:12

184:12 202:16 203:8

249:3 251:11 260:11

Barb's 195:14

Barbara 1:9 5:16

barge 254:4,14 256:5

258:3,4 273:19

barges 273:12

barriers 58:7

Barry 13:11 44:18

52:16 54:9 55:21

58:22

based 10:6 32:19 66:12

67:6,19 70:1 72:2

92:8,14 96:10,15

98:16 122:19 125:10

136:10 137:5 139:12

139:19 140:6,8

144:15 160:8 163:6

184:22 189:18 192:11

192:11 202:19 210:22

218:1

basement 69:5

basic 43:19 83:7

basically 17:1 44:14

158:13,17 159:11

160:5,7 186:21

203:16 204:16 211:5

258:2 260:9

basis 136:7 181:6

191:13 216:13 232:5

243:17

beans 236:3

beef 17:6

began 70:13,19

beginning 95:1 185:21

196:4,15

begun 179:15

behalf 264:11

Beijing 50:7

believe 46:22 77:12

124:6 155:5 168:5

183:10,11 218:21

228:1 243:13 244:4

bell 202:5

belts 103:21

beneficial 178:3 207:6

249:10

beneficiary 232:19

benefit 126:15 127:8

130:9 268:2 273:3

benefits 108:17,22

110:5,8 111:9 125:16

129:21

best 21:12 22:6 37:3,4

72:12 158:3 163:5

237:18

better 29:2 77:3 103:8

108:1 129:4 148:17

161:10,20 197:18

198:19 216:18 231:13

238:4 241:16 247:15

250:16 259:3,4

bias 74:14

biased 73:15

big 21:16,16 50:3 78:4

107:4 161:21 176:7

177:9 208:6 242:20

250:1 268:8 270:21

bigger 103:11 206:13

221:17 233:7

biggest 19:20 147:14

226:10,18 249:18

263:15

bill 82:12 88:7,9 105:20

186:16 264:9

billing 45:12 112:10

bills 140:6

Billy 139:9,10

biotech 58:14

biotechnology 44:11

58:9 70:15

Bird 1:14 4:2,2

birthed 9:14

bit 6:19 12:19 13:22

16:8 29:13 30:17

45:16 59:10,12,14

73:22 77:3 78:2 81:8

114:3 123:12 133:17

147:3,16 152:11

155:15 156:4 167:11

176:4,10 188:2 199:2

205:7 206:13 210:10

214:6 227:13 247:9,9

258:20

bits 199:9

bitterness 65:2,4,6

black 173:13

blast 23:5

blend 64:22

blocked 239:11

blocks 267:11

blue 30:9

board 42:20 44:5 46:4

59:18 61:9 67:20 69:3

78:18 80:18 92:5

131:22 206:12 237:20

boards 42:19 43:11

203:7 204:21 205:3

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
282

Bob 4:11

Bob's 195:14

bodies 57:21

body 25:16

Book 110:15 111:12

booked 87:17,20 89:11

89:13

books 113:6

booming 184:7

boss 48:8

bottom 172:20 178:9

boundaries 9:12,17,21

9:22 12:7,18

boundary 36:7

box 79:4 158:14

boxes 78:19 79:1

branch 27:8 41:20 44:2

44:12,20

branches 130:18

brand 27:22 237:19

Brazil 108:4

bread 147:14

break 81:7 132:17

149:12,20 150:9

173:13 178:19 184:14

251:12,15,17

breakdown 106:2

109:15,19 117:3

breakpoint 216:4

breaks 31:4

brief 81:15 150:12

155:19 251:20

briefing 26:13 148:11

briefings 53:1

briefly 41:8 42:7

bring 26:6 37:21 76:12

87:9 88:2,4 90:12

94:9 132:15 134:5

135:15,17,18 137:14

141:22 142:2 149:18

151:3 152:3 173:20

184:5 185:7 191:5

199:21 203:3 207:1

209:21,22 214:2

219:17 226:1,7 230:9

240:9 250:7 253:2,18

255:19 258:19 265:2

bringing 24:16 88:18

107:8 137:3 169:17

170:4 188:19 189:18

189:19,20,21 199:19

200:4 207:3 210:3

223:20 236:7 242:13

272:20 273:1

brings 25:5 81:9 132:11

153:12 246:18

broader 27:10 215:8

broke 91:17 92:17

brokens 66:15

brought 12:10 28:13

86:22 87:12 88:2,4,6

102:2,8 119:22 121:5

121:9,9,21 122:3

151:19 163:22 193:15

208:11 238:3 242:19

252:9 253:15 256:1

259:11

bucks 77:19

budget 15:12 77:7

83:15 84:16,17 128:3

129:22 130:1 142:6

170:7,12 193:17

205:20 213:21

budgeting 270:19

budgets 128:3 206:1

build 87:8 267:1 272:18

building 66:17 83:11,12

111:3 122:12 267:10

buildout 266:9,10

builds 116:2 161:16

built 12:15 40:5

bulk 152:15 257:16

bulletin 42:19,20 43:1

43:11,14

burden 17:21 128:16

266:5

burn 87:8

burning 128:18

business 6:5 9:3

134:11 159:4 169:11

175:5 180:6 201:1,8

209:3,6 226:9 277:12

business-as-usual

157:4

businesses 6:13

208:16 209:2

busy 102:6 136:3 204:1

buy 12:1 218:8 231:20

231:21

buyer 163:7

buying 231:1 232:9,10

Byron 2:7 11:19 28:14

48:2 194:8

C

C 213:5 248:17,18

cadre 54:5

calculate 96:14 110:2

125:9 126:15,17

139:21 160:12

calculated 96:2,12,18

98:1,3 106:5,12

118:11 122:18 123:11

124:13 135:4 136:14

137:1 144:15 160:3

196:11

calculating 139:19

140:6

calculation 93:17 96:20

96:21 97:3,4,5 99:3

106:11 122:17 123:7

126:8,10 134:20

137:9 141:16 143:6

143:15,22 144:3,6

160:5 171:6 174:1

182:15 185:1 212:1

calculations 123:8

160:7 189:6 215:6

calendar 47:1 94:12

196:15

calibrated 214:17

calibration 225:15

California 4:15 66:9

68:22 156:1

call 2:2,3 3:4,13 6:14

76:17 120:11 155:20

226:13 257:7 276:16

called 14:2 65:12 66:17

67:17 69:2 75:7 85:13

113:9 225:21

calls 52:9

camera 75:16

cameras 17:6,8 62:1

Canada 94:2,6 114:22

117:10

cancelled 108:3

Canola 44:5,5

cap 14:10,13,17 15:8,11

15:21 82:11,13 83:17

83:17,21 84:10,21

85:5 183:3,6,9,11,16

185:22 186:1,11,21

187:4,6,11 191:14

192:15

capability 63:12 69:20

capacity 63:12

Capitol 188:2

Capper 24:20 272:21

capturing 45:13

car 234:21 259:14

carcasses 17:7

care 38:22 165:5 209:4

209:5 230:1

career 19:22

careful 22:22 99:12

Cares 100:15,20,21

130:13

Cargill 4:21 38:11 103:7

202:22

cargo 152:17,22 153:18

153:21 160:3 166:1,4

Carla 12:18

carless 260:21

Carlo 67:17,18

carrier 131:18,19,20

carriers 94:2,6 114:21

116:21 117:10

carry 148:6

cars 27:8 209:5 234:21

case 11:18 40:6 67:16

174:21 201:14 245:22

246:9 265:18

catalog 66:19

catch 137:19 176:6

categories 91:19

108:15,18,21 109:11

110:18 111:18 114:13

129:20 130:22 131:3

category 108:22 110:8

129:21 130:9,10

131:11

caught 29:15

cause 3:21 11:20 23:19

34:4 100:9 101:18

102:9 111:2 117:21

125:4,5 127:20

128:17 141:7 144:9

144:22 145:1,2,22

161:2 183:20 184:9

184:12 201:15,19

202:5 203:21 204:19

205:11,19 206:2

208:14 211:15 217:4

229:20 230:10 232:12

233:1 240:14 270:4

caused 101:21

causing 103:5

cell 6:9

cent 87:3 98:3

Center 4:15 7:9 8:20

45:19 62:15 83:12

111:5

central 5:9,17 110:14

163:3 273:18

cents 97:7 98:8

certain 17:14 27:13

30:13 92:9,15 156:20

257:5,5,6 261:13

certainly 146:7 153:16

154:7 162:10 164:12

164:17 174:11 195:16

197:7,17 202:13

207:20 252:2,14

253:1,5 255:20

256:14 258:11 267:9

274:6,19

certificate 152:9,15

166:13

certificates 56:20

254:15

certification 264:8

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
283

certified 214:18 215:3,7

233:3

certify 46:2

cetera 29:17 36:2,17

43:18 53:19 87:19

89:13 91:22 109:10

110:12 111:12 132:1

132:6 134:17 228:17

240:4 244:1

CFR 189:13

chain 63:18

chair 1:9 3:3 5:16 75:13

76:1 77:4 79:15 81:5

81:16 91:8 149:7

150:13,18 151:7

152:2 155:14,17

164:6,19 165:6

167:18 168:14 169:21

170:17 175:3 179:21

183:18 185:11 192:3

194:22 199:17 204:8

204:13 205:1 206:14

208:8 212:21 213:5

213:11,17 214:12

220:1 223:17 229:16

232:22 234:18 235:4

235:7,21 236:19

240:16 241:13 245:9

245:12 246:10 248:14

250:2 251:13 255:22

257:20 258:19 262:6

268:22 275:7 276:3

chairing 5:17

challenge 31:16 35:10

72:7 74:1 95:8 113:4

113:14 114:10,12,17

115:4 117:18 206:13

challenged 63:22

challenges 29:16 30:3

30:8,9 32:13,22 33:6

35:14 39:21 103:5

112:1,3 115:12,16

116:10 130:6 131:1

148:20 153:3 179:22

209:14

challenging 63:7

chance 34:2 168:8

179:19

change 11:22 17:19

20:4,14 32:21 68:12

85:9 87:4,5 88:22

92:14 116:21 118:19

137:11,13 138:4,9

141:13 163:4,14

173:5 187:17 188:21

189:7 190:3,7 203:3

209:17 211:13 212:13

219:12 220:22 230:19

236:14 241:8 242:6

242:18 243:2,11

changed 85:1 93:3

135:1 156:4 158:15

159:7 167:13 168:16

190:9,13 193:11

211:6

changes 9:20 11:17

12:2,5,17 19:19,20

21:13,13 37:14 41:9

44:7 84:15 114:15

132:22 142:8 152:8

154:19 163:8 164:7

167:5 182:9 183:10

188:12 191:11 193:7

199:5 218:6

changing 17:18,18

211:4 237:6 239:10

characterize 71:13

charge 92:1 95:11

117:20 126:6 175:14

177:18

charges 110:14 111:12

Charles 1:12,14,14 2:6

20:7 40:19 77:16

Charlie 3:16,17,18 40:9

76:6 77:13 79:14

181:14 208:11

chart 31:4 43:20 103:6

103:9 109:19 117:7

127:8 162:6 167:8

chat 7:8,15

chatted 259:11

cheaper 208:20

check 167:15 217:15

220:11 223:13 242:12

check- 244:5

check-tested 223:9,15

240:2

check-testing 242:5,8

checked 276:4

Chenoa 5:9

chew 207:17

chief 24:21 272:21

China 48:11,14,21

49:16 50:10,19 56:16

57:2 58:19

China's 48:15 108:3

Chinese 53:4 57:7,12

choice 157:22

choose 238:2

chosen 50:12 220:22

Chris 4:8 115:14 146:5

146:6 147:22 150:20

151:18,21 152:5

154:8 164:6 165:10

166:16 169:21 210:8

247:12 251:8,17

255:22 257:12 270:9

270:13 272:20,20

273:1,9 275:9

Chris's 152:3 245:13

Christopher 1:15

Chuck 4:2

chuckling 183:15

circulation 161:20

circumstances 35:21

City 1:7 92:18 97:17

98:8 128:21 136:15

136:17

clarified 157:14

clarifies 12:5

clarify 119:15

clarity 14:1 45:16 46:3

109:16

class 21:11 47:9 217:16

217:17,22 243:20

244:10

classes 60:14 79:10

classing 47:8

clean 152:14 166:12

clean-up 6:7

clear 94:9 193:15

228:14,18

clearance 33:22 34:15

199:22 200:16 203:17

cleared 6:15 186:6

204:7

clearly 46:7 198:6

clerk 34:4

click 7:4

climb 86:17

Cline 46:20

clock 139:12 140:6

close 13:22 19:5 101:14

113:6 115:21 116:11

135:14 141:6 174:3

208:13,18

closed 6:15 10:9 11:14

160:18

closely 13:12,14 24:22

25:12 146:1

closeminded 267:21

closeout 204:1

closes 18:19 88:8

closing 97:14,15

258:15

Clustered 64:6

coarse 18:5

coat 51:17

Codex 57:15,19

COLA 113:20 130:3

132:20 133:5,6

COLAs 113:19

collaborated 16:12

collaborating 65:10

collaborative 267:18

collaboratively 10:17

16:5

collect 69:15

collected 15:1 60:4

collecting 15:13,15

125:21

collection 60:13

collective 14:13 25:16

collectively 179:4

color 30:9,11,13 62:4

78:8

colors 10:10,14 11:1

46:18,19

column 157:10 158:10

combined 158:7

come 4:1 7:3,22 8:2

18:20 26:4 35:7 47:2

52:15 56:12 83:15

88:7 89:16 91:15,15

104:17 109:2,2 112:2

132:18 150:1,5

166:14 209:4,5 212:7

214:8 243:7 244:21

247:10 251:2 268:16

274:21 277:19

comes 6:3 17:21 43:22

47:3 89:20 131:8

238:14 255:13,16

257:1 261:12

comfortable 167:16

248:2

coming 23:14 24:6

27:17 29:12 33:21

34:14 35:15 36:9 37:6

37:12 38:17 88:10

92:21 104:3 112:15

113:12,19 114:2,5

118:14 149:22 153:9

167:1 169:12 173:4

176:22 189:22 213:9

237:12 245:2 254:12

256:15

commend 197:5

comment 7:10,17,20

8:5 37:5 94:11 170:15

185:12 199:15,18

200:8 204:14 210:21

235:22 276:20 277:3

commenting 200:11

comments 2:10 7:10

37:15 113:22 189:11

189:12 191:9 195:14

203:6 212:22 220:3

248:15 251:5 275:8

275:16 276:5,7,17,18

commercial 64:22

commercialization

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
284

62:21

commercially 66:8

commitments 22:13,14

committee 1:2 3:7,10

5:17 7:1 8:21 9:7,14

10:18 14:10 16:2

19:10,15 58:11 75:10

83:19 150:8 151:20

153:15 179:12 196:1

198:9,20 199:16

205:1 207:13,13,15

207:17 213:8 220:5

226:2 249:15 253:4

255:20 273:1

committees 57:16 58:8

186:3,14

commodities 14:15

15:3 17:9 18:7 70:1,5

70:17 190:10 194:7

204:20

commodity 85:17 105:8

123:4 160:8 190:8

204:20

common 60:2

communicated 95:3

communicating 263:10

communication 61:21

76:4 168:18 181:5

207:3 254:17

companies 50:11 72:19

168:7,13 180:15

company 4:20 5:15

33:1 38:18 66:12

230:12 260:6 269:18

company's 237:1

compared 67:1 90:14

106:7 121:1,18

135:10 242:17

comparing 74:12

215:12

comparison 120:2,16

135:7

comparisons 67:20

121:19

compensate 89:4

competency 274:18

competent 50:8

complained 241:18,18

complaining 242:3

complaint 33:11 58:21

58:22

complaints 33:2 58:17

58:19 233:18

complete 6:5 34:4

112:21

completed 9:16 11:10

61:18 112:20 113:5

123:4

completely 135:19

227:22 262:2

completing 113:8

complex 64:1

compliance 1:11 2:5

12:21 26:8,11 27:22

30:13 31:10 38:3

42:11 219:17 234:17

244:19

compliant 228:1 245:7

complicating 238:16

complimentary 64:17

comply 215:8

complying 232:16

component 86:8 93:19

93:20 110:10 118:1

132:2 136:10 242:12

263:11

components 82:8

85:20 111:19 118:9

125:20 126:19 132:12

132:16 134:14 138:17

comprised 82:7 171:13

compromise 205:8,9

compromising 177:3

computer 64:12 270:6

computers 269:22

270:4,17

concept 66:16 120:22

concern 57:19 225:3

233:19 253:6

concerned 51:13

176:20 187:3 254:9

concerning 193:21

194:6 216:15 244:16

250:9

concerns 12:2 53:18

56:20 57:12 72:15

76:7 164:9,13 165:1

165:19 166:9 239:1

244:6

condition 235:14

conditions 69:13

conduct 79:8

conducted 33:4 53:1,19

242:11

conducting 43:13

70:19 71:4 73:6

confer 167:5

conference 51:11 52:9

55:16 258:22

conferences 8:19 56:15

confers 65:4

conflicting 57:21

confusing 157:13

confusion 31:22 49:16

217:9 267:3

Congress 14:21 84:18

85:2,3,7 186:7 265:16

congressional 36:7

connect 14:22 76:21

connected 25:7,9

connection 268:13

consequences 238:19

Consequently 36:13

conservative 176:17

consider 14:7 181:9

187:6 228:20 240:10

247:21 274:13

consideration 19:11

125:14 145:12 222:9

considered 69:11

considering 181:7

236:20

consistency 210:16

230:9 257:4

consistent 71:1 162:18

177:2 236:11 255:17

consolidate 214:20

constantly 260:13

264:12

constructions 70:14

consulted 168:12

180:12

consulting 13:19

consumables 121:15

134:13

contact 13:12,13 51:9

contacted 56:9 168:19

contain 67:3

container 4:12 53:8

117:19

containerized 49:19

containers 117:14

273:13

contains 65:1

content 43:7

CONTENTS 2:1

contest 235:1 240:19

contested 233:20

contesting 241:21

context 95:6

contingency 90:15

continue 87:8 88:7

128:15 145:22 164:18

167:3 174:21 182:17

194:13 197:6 208:2

209:20 243:20 255:9

263:1 275:22

continued 86:17 92:11

142:11 275:13

continues 89:16 198:3

252:10

continuing 55:4 88:10

contract 52:4 115:7

118:2 119:5 120:6,8

131:8 132:13 138:5

183:1 211:6

contracted 119:2,8

120:14,15 134:22

contracting 180:15

262:20 266:12

contracts 10:21 70:8

108:4 118:4,5 190:22

control 94:21 205:19

266:14

controls 253:7

convene 278:19

conversation 7:19 13:6

17:13 51:22 78:6,15

80:20 90:18 100:10

108:8 181:10 197:19

198:15 245:21 271:11

271:21 276:1

conversations 11:20

51:4 73:7 78:22

108:12 178:1 179:3

258:21

convey 161:12

conveyance 117:17

convinced 55:5

cool 66:19 68:19

Coop 163:3

Cooper 1:16 4:14,14

39:15,19 71:10 72:16

83:16 84:4,7 89:18

90:8,11 171:8,18

172:3 274:8

cooperative 5:9,11,18

56:13 66:11

coordinating 58:9

coordination 58:11

copied 256:18

corn 5:11 18:6 56:14

58:20 59:21 60:3 65:9

226:19 227:18 229:1

229:1 230:17 236:3

245:21 246:2,8

Corporation 4:3,9

correct 75:18,22 76:2,2

103:13 115:11 124:7

127:10,11 138:7

140:11,15 203:10

214:19 222:5 238:18

242:1 258:16 266:3

273:10

corrected 31:20

correcting 209:11

correctly 239:7,10

cost 77:18 95:18,21

114:1 121:13 122:4

125:13 126:22 127:21

127:22 129:13,20

132:7 133:7 142:4,13

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
285

142:16 143:14 144:17

147:16 149:4 174:13

177:17 218:13,19

220:7 221:11 222:6

227:9 236:6,21

249:12

costly 240:15

costs 15:14,16,18 55:9

56:21 83:10,13 89:2

89:14 91:20 92:2 93:6

93:16 97:22 100:17

100:21 102:19 103:22

104:1 106:3 109:4,6

109:15,19,20,22

114:15 121:10 122:4

122:8,9,11 126:7

127:6,9 129:7 130:12

131:4,7 132:6,18

134:10 135:5 137:7

142:7 143:13 148:5

148:22 175:5,12,17

175:18 176:4 177:15

177:19 181:3 182:17

182:17 196:12,22

197:7 198:1 209:21

218:7,12 221:14

229:8 236:12 264:13

268:18

cotton 16:21 80:7

cottonseed 50:22

couldn.t 245:18

Council 40:13 61:4

194:9

count 31:21

counter 237:9

countries 11:18,21

51:18 53:3 56:5

country 32:13 108:6

117:20 121:8,22

152:10,10 156:2

couple 20:1 35:7 37:10

43:5 45:4 51:11 59:15

73:7 74:16 76:13

84:14 99:14 185:16

185:20 206:4 219:2

222:4 269:14

coupled 183:2 210:11

course 30:21 102:3

141:12 142:7 153:12

237:3 252:9 254:19

255:10 257:3

cover 15:14,16,18

38:12 100:18 102:18

103:4 130:2 131:7

132:18 145:17 146:3

177:15

covered 48:15,17 51:2

91:20 94:4 111:5

213:15,15

covering 122:8 211:18

COVID 28:18 29:16

56:7

CRADA 66:12

crazily 184:8

create 60:22 165:14

217:1

created 59:19 60:2 61:1

64:16 93:6

creates 152:20 153:2

254:13

creating 153:6 163:8

crew 37:10

criminal 27:7

CRISPR 62:21 63:11,13

63:15 64:5,8,10,13,16

64:21 65:6,22 71:14

71:19

CRISPR-derived 64:3

CRISPR-edited 65:1

criteria 11:3 47:11

critical 249:7

crop 29:14 62:22 63:1

64:3

crops 17:1 72:1,2

crosses 11:7

Crowley 4:17

crunch 249:6

crushing 107:17 176:22

cubic 157:16 158:12

159:6,18

cultivation 63:2

culture 183:17

cured 235:19

curious 187:13 193:1

current 22:8 25:13

65:11 71:13 80:16

86:12 120:17 145:12

155:7 162:18 193:2

209:9 215:21 216:9

217:17 218:14 224:20

270:1,19

currently 17:22 18:18

20:6 28:10 44:20 50:9

63:11 65:6 136:13,21

178:21 188:16 215:2

217:3 218:11 227:12

261:22

Curt 5:13,22,22 222:7

230:11 231:4 232:22

Curt's 6:2

Curtis 1:20

curved 68:11

customer 11:5 38:22

customer's 222:22

customers 10:5 12:17

17:3,8 25:19 33:2

52:7 53:6 54:16

136:17 153:7 242:3

260:15 262:15 266:6

customs 48:16

cut 65:4 206:2

cyber 24:19 25:2,14

cybersecurity 253:5

263:11 269:13 270:15

cycle 29:15,18 218:11

218:16

D

D.C 188:1

dairy 120:6

Dakota 4:12 5:3,19

97:15 225:19

damage 60:5 61:2 77:3

78:21 226:9 234:7,22

240:20 249:16

damaged 58:20

damages 60:2

dangers 152:21

data 10:6 43:19 45:13

60:4 66:21 67:21 68:7

68:9,16 69:10,15 73:2

73:4 180:17 195:17

222:17 223:13 233:15

233:22 240:17 251:9

252:5,11 253:19,22

254:3,8,10 255:15

256:3,6,20 257:1,6,22

258:13 260:12 262:14

268:9,11 271:8,14,19

273:17,18,19 276:11

278:8

data- 175:9

database 66:18

date 3:22 11:17 12:2

33:18 35:3 93:10

95:12 224:18 247:7

dated 36:12

dates 40:5 189:1

day 25:3 33:18 73:16

139:6,13,14 140:10

197:22 242:21 255:10

day-to-day 180:6

days 128:13 154:2

DC 51:9

deal 10:15 14:1 37:15

38:1 39:6 145:15

dealing 51:8 57:17

113:11 130:6 169:17

188:16 261:7 274:20

debt 125:17,19 126:1,2

126:18

decade 63:16 156:5

decades 83:18

Decatur 32:19 34:13

December 8:16 28:16

102:7 136:4 277:16

decide 179:4 254:2

decided 37:2 50:7

112:12 117:4,9

262:22

deciding 112:6,16

186:19

decision 96:9 116:10

157:20 241:11 243:1

243:17

decisions 12:5 116:11

180:9 238:19

decline 23:2 209:11

decouple 85:4 186:21

187:9 210:15,20

decrease 68:4 182:18

197:6

decreased 197:22

decreases 114:12,14

197:12

Decree 48:11,14,17

dedicating 255:14

deemed 179:2

defer 218:5

deficiency 202:4

deficient 179:2

deficit 101:20 173:11

defined 46:7 102:4

definitely 34:17 80:9

124:10 165:7 206:16

211:13,19 243:3

246:8 252:3 263:9,13

265:4 275:13 277:8

degree 17:8

delay 40:8 112:5 115:9

115:20 240:5

delayed 116:10

delaying 116:17

delays 29:16

delegated 86:4

delegation 26:20

delete 72:8

demand 22:19

demerge 240:14

Denise 1:10 81:8,18

83:5 84:15 91:3 94:10

107:14 116:19 119:14

127:3 128:4 137:17

143:1 151:1 170:7,8

170:20 171:9 172:7

179:21 183:20 184:13

188:7,8 192:4,8,11

195:1 196:18 197:10

199:7 200:2 207:11

263:2 266:4 278:12

department 1:1 4:7 5:7

28:8 83:14 84:16

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
286

270:20

departmental 110:15

111:11

departments 109:10

depend 35:20,21

depending 29:13 109:3

242:6 261:20

depends 35:20 225:14

265:9,12

deployed 265:14

depth 152:17 158:13

depths 153:18,21

158:22 166:1,4

deputy 1:10 2:4 20:3

21:1 27:2 40:20 41:12

76:6 110:7 130:19

deregulated 63:2

derived 63:10

describe 36:15 78:13

122:20

described 82:11 192:14

descriptions 36:21

descriptive 60:18

design 216:11 266:10

267:1

designated 38:13 86:4

designation 26:19 33:9

33:10,14,20 34:10

86:10 152:10

desire 262:12 265:5

desiring 201:13

desk 220:19 230:20

despite 216:10

destination 153:4,4,6

164:5

destroys 64:13

detail 28:7,15 32:15

33:3 42:10 52:18

detailed 36:18 38:4

195:17,19

details 30:6 34:3 42:6

104:16 219:2

detect 63:10 65:8,22

detected 65:7

detection 44:11,13 63:4

63:7,9,18,19,22

determination 44:12

45:4,20 70:3 78:9

80:22 81:1

determinations 46:11

46:15 62:3 256:11

determine 47:9 60:5

66:2,7,13 67:12 215:6

determining 66:16

devastated 235:12

develop 16:3 63:8

194:1 198:10 263:6

265:17 275:5,21

developed 44:12 53:21

54:5 63:6 70:9

developing 25:13

development 36:17

42:12 66:11 69:19

260:7,14

deviates 245:20

deviation 75:4

devices 72:20

Dial 38:19 39:4

dialogue 23:9 180:19

193:20 243:8 267:16

dialogues 268:21

difference 52:2 68:1,3

68:14 83:8 123:5

153:17,20 235:18

241:10

differences 59:2 68:4

228:3

different 8:18 19:2

21:11 36:1 42:14 53:2

53:10,22 54:15 59:15

60:14 64:2 91:16

100:3 110:12 111:18

111:18 114:4 115:7

120:3 121:8,17 122:1

122:10 138:16,21

142:18 146:10 171:10

171:14 201:15 202:4

217:8 218:4 226:11

228:21 232:20 247:1

250:17 253:1 260:8

261:20 262:3 271:7

271:10

differential 236:2

difficult 160:14 199:8

266:12 271:5

dig 137:13 175:1

digest 195:8

digital 60:10,20

digits 50:12

digs 30:16

direct 49:3 91:20 110:9

118:1 125:11,12

131:4 132:4 159:13

265:14

direction 42:14 147:11

162:12 273:16

directive 13:1,15 44:10

44:21 45:3,6,15

261:11

directives 43:18

directly 85:2 104:2

director 1:11,12,13 2:5

2:6,7,8 20:6,8,12 26:7

26:10 40:17,20 47:18

48:2 76:7 122:11

director's 130:18

134:16

directors 110:6

disagreements 219:8

discharged 164:4

discolored 51:17

discontinued 217:18

discuss 2:9 96:16

154:4 219:1,22 226:1

243:19

discussed 148:9

199:21 226:11

discussing 18:1 276:21

277:4,9

discussion 2:11 15:11

78:10 150:5 167:18

169:15 170:7,16

196:2 198:10 199:15

213:18 220:3 224:2

224:16 252:8 253:4

272:5 274:10,11

discussions 52:21 73:1

255:21 278:9

display 215:4

dispose 153:6

disposed 164:5

disrupt 7:5 49:22

disruptions 63:15

distance 55:19

distinction 161:22

197:15

distribute 161:8

distributed 59:20 68:8

distributors 130:17

diverse 27:17,19

diversification 54:14

diversifying 23:19

divided 125:11 185:2

division 1:11,12,13 2:5

2:6,7,8 12:21 16:10

19:22 20:6,11 26:10

26:11,15 28:15 40:17

40:21 41:8 42:11

45:22 47:14 59:7

121:6

divisions 26:14 47:19

dizzy 129:9

DNA 63:21 64:13,15,17

64:21 65:3,4,12,16

72:5

DNA-based 63:19

documentation 46:8

documents 49:15 113:7

doing 18:10 23:18

24:13 25:18 28:6

52:12 55:6 56:6 72:11

88:19 94:8 101:9

104:7 105:1 121:10

122:4 127:20 131:11

140:5 141:10 142:12

156:8,19 175:9 176:5

180:5,6 190:4,5,13

198:2,2 203:18

209:16 211:15 217:2

225:11 236:16 239:13

244:9 246:14 269:5,7

dollars 98:16 101:15

108:16 146:17 194:11

255:14 262:20

domestic 4:22 41:2

92:21 108:3,7 261:6,8

domestically 24:7

117:16

door 6:15 208:18

doors 202:9 208:13

Dorman 44:1

dosage 161:14,19

dose 159:12,12 166:18

double 119:16 160:2

doubt 238:18

dovetails 156:7

downstream 272:7

Dr 1:13,14 2:8 3:16,17

5:22 40:21 59:6,8

71:16 72:21 73:12,21

74:3,4,9,10,21 75:1,2

75:6,9,11,22 76:2

77:12,21 78:2 79:14

80:3 81:4 90:15,18,19

91:1 132:20 133:9,12

133:19 150:14,19

151:3,5,9,15,22

154:13,18,22 155:1,8

155:12,16,18 163:1,9

164:19,21 165:4,7,13

168:6 178:4,15

179:11 202:6 248:4

draft 13:15,18 44:22

61:17 154:12,19

164:7 167:21 207:4

drafts 187:19

drag 99:20

dramatically 79:4

drastic 206:2

Drive 1:7

driven 175:9

driver 273:15

drop 87:7 102:19

dropped 93:9 102:16

102:21 107:7 118:3

dropping 89:7,7

drought 237:3

drove 107:5

Dry 61:4

drying 237:13,14

dual 161:15

due 32:21 222:2

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
287

dumped 235:10 241:19

duplicated 66:21

duties 41:17

dynamic 21:13

E

eager 27:18

earlier 95:12 128:11

134:1 136:9 195:16

196:21 197:10 214:16

232:5 258:22 263:2

early 13:17 169:4

196:17

easier 32:11 204:19

206:11 207:10

easily 267:15

Easing 273:18

easy 271:1,20

echoing 195:13

economic 126:20

ECT 223:9,14,16

Ed 1:13 2:8 16:8 40:21

59:6 122:10

Ed's 134:15 209:18

edible 48:20 49:1

editing 63:5 64:8,11

edits 64:19 66:1

educated 84:22

educating 19:8

education 84:19

educational 32:10

effect 51:14 93:2 100:1

174:5 204:10

effective 11:9 12:21

33:20 34:19 59:17

93:10 96:4 189:1

effectively 65:5 66:14

158:14 178:10

effectiveness 73:18

179:8

efficacy 153:20 159:14

159:20 168:22

efficiencies 260:9

efficiency 37:17 259:20

270:16 274:14,16

efficient 14:6 17:20

29:6 59:17 77:7 79:22

80:1 209:22 230:20

260:1 266:8,9,17

efficiently 66:14

effort 24:20 83:20 165:2

274:15

effort's 76:5

efforts 19:2 59:10 71:3

84:8 126:1

egg 120:12

eight 27:21 64:2 103:10

105:20 138:13 139:3

139:4,10,10

either 158:8 200:11

208:3 214:18 221:22

elections 277:7

electronic 115:15

256:16 264:6

electronically 49:8

257:9 259:22

elephant 263:16 267:5

elevator 5:10 146:15,18

236:9 271:7,10

274:22

elevators 25:2,11 79:11

eligible 19:17

eliminate 258:9

eliminated 47:7

eliminates 164:14

eluded 199:6 267:11

email 38:4,8

emailed 256:18

emailing 259:16

embrace 157:4

emerges 242:4

employee 42:3 133:3

employees 119:15

128:11 133:1 205:11

employees' 133:1

empty 160:3,15

enacted 47:3

encourage 205:21

encouraging 19:10

endless 71:17 260:16

Ends 58:18

enforcement 24:1

engage 14:5 162:14

276:1

engaged 72:22

engaging 44:20 167:2

167:21 169:18 267:17

274:4

Engel 1:20 5:13,13

222:7,7,20 223:4,7

231:5 234:1 235:3,6

235:16

engineered 62:22

enhance 61:21 76:4

enhances 80:15

ensure 9:19 11:16

69:15 70:7 146:2

167:10 176:13 252:10

253:11 255:3,13

256:22

ensuring 255:16

enter 64:1 260:12

entered 66:10

enterprise 265:17

entertain 154:6 162:10

162:21 204:4

entire 19:22 33:16

87:17,20 89:11 105:9

105:10 160:18 173:10

entries 258:12

entry 254:10

equal 159:10

equipment 29:3 30:12

31:14 32:2,4 121:14

134:12 217:5 220:9

220:11,13,14,14

225:2,8 227:11 231:1

231:10

equipment-inducing

216:17

equipped 153:8

equivalence 73:14

ergot 58:21

error 215:22 216:2,6,18

246:5

errors 216:21

ERS 115:17

especially 44:16 80:6

203:8 224:18 256:4

essence 207:20

essentially 240:11

establish 68:10 253:19

established 10:22 49:7

61:16 169:5 267:11

establishing 271:2

273:5

estimate 113:20 221:16

249:7

estimated 68:11 141:5

estimates 100:9 181:16

estimating 100:8

141:18

et 29:16 36:2,17 43:18

53:18 87:19 89:13

91:22 109:10 110:12

111:12 131:22 132:6

134:17 228:17 240:4

243:22

evaluate 72:19

evaluated 11:4 62:6

253:12 270:15

evaluating 16:6 72:18

74:7 116:13 255:6

evaluation 24:11 62:9

75:8

evaluations 62:16

events 19:8 36:17 65:8

71:12

eventually 46:21

evergreen 247:7

everybody 3:6,11,14

7:1 79:2 81:17 82:3

84:19,20 92:5 129:9

133:7 149:18 168:17

200:6 209:15 219:20

237:7 264:17 271:9

everybody's 10:11 26:1

133:16 151:2 268:4

everyone's 167:16

evidence 216:12

evident 157:19

evolved 169:3

evolving 23:20

exact 40:5

exactly 90:1,7 114:5

156:17 221:7 272:8

274:2

exaggerating 21:6

examination 31:6

example 43:8 64:22

71:12 121:11 138:12

190:8 215:18 234:3

248:7

examples 255:4

exams 53:9

exceed 146:3

exceeding 187:4

exception 35:18,22

44:5

exceptions 12:6 34:18

35:5,11,11,14

excess 98:19 99:15

265:21

exchange 253:22

271:18 272:22

excited 79:7

Exciting 80:5

excluded 94:3

exclusive 217:13

excuse 65:18 67:18

70:19 106:9 246:3

executive 1:10 57:15

exemption 49:19

exist 36:16

existing 63:7 68:21

219:14

exists 256:21

exorbitantly 218:15

expand 24:15 69:20

expanded 56:4 71:6

expanding 59:14 69:17

expect 28:9 44:21

68:14

expectations 69:16

expected 44:8

expediting 81:2

expenditure 222:13

232:19

expenditures 187:4

expense 148:6 209:15

266:7

expenses 87:13,17

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
288

108:15,19 110:7,11

126:5 146:13,17

147:13 209:16 210:3

236:22 237:4

experience 28:1 41:13

42:13 54:16 81:22

204:15

experienced 24:3 76:17

104:2 129:14

experiencing 123:22

177:16 203:22

expertise 63:9 168:21

169:6,7,12

experts 72:13

expire 46:21

expired 87:2

explain 77:3 107:15,15

107:20 108:1 114:3

116:21 127:14 137:19

138:20 220:5

explained 111:2 136:9

explanation 199:7

explore 16:4 18:10

173:15 194:2,4

211:19

explored 61:10 71:20

exploring 23:13,21

65:13 262:5

export 28:17 41:13 44:4

44:7 49:10,15 61:20

85:14 86:9 89:19 94:1

107:22 114:18 115:2

117:15,17,20,21

132:1 145:18 146:15

166:10 194:9 223:3

253:7 254:8 261:5

273:11

exporter 13:8 48:13

252:2

exporters 4:10,22 49:4

49:6,12,18 50:6,9,21

51:15 107:22 199:4

exporting 18:8

exports 43:20 82:15

92:21

express 40:13,15 42:1

47:15

exquisite 63:5

extend 19:16

extending 23:1

extension 3:19

extensive 84:18

extent 127:16

external 116:7

extra 101:13 105:22

146:17 153:12 195:5

258:8,9

extreme 237:3

extremely 88:19 128:9

167:7 189:22 203:13

F

F 217:17 243:20 244:8

F&D 31:19

face 72:7

face- 210:2

faces 48:6

facilitate 49:22 63:3

78:6 181:8 194:13

211:13 242:22 252:4

252:20 265:18 271:18

273:22

facilitates 209:2 252:12

facilitating 9:21 169:11

177:17

facilities 30:12 38:12

49:10,13,14 222:22

258:10 270:3

facilities' 253:9

facility 31:14 83:13

119:8 131:6,12

222:19 223:3,5 258:2

fact 41:22 159:13

179:14

factor 11:2,7 47:7 51:15

109:20 131:21,22

250:8

factors 70:3 74:6

126:20,22 131:21

158:4 249:15,19,20

250:8,11

facts 197:8

fail 231:11

failing 242:11

failures 222:13

fairly 45:1 205:13 237:2

fall 28:22 29:9 37:7

67:15 80:5 109:11

110:5

falls 49:2 110:22

familiar 26:18 48:6

53:16 71:11 202:14

202:15

family 22:7 76:13

fan 161:15

fancy 68:20

far 46:12 54:14 58:18

64:14 72:1 146:12

148:7 157:10 163:9

166:22 188:15 195:22

198:15 210:13 253:4

254:8 273:17 276:9

FAS 50:3,7,7,20 51:4,9

52:9 56:10 57:8 58:12

fashion 175:21 256:10

fast 64:7 205:17

fast-tracked 205:5

faster 112:3 133:4

fastest 42:21

FDA 13:1,8,12,14 14:5

44:16,20

feasible 207:22

feature 35:10

February 93:12 95:2

174:9 200:4

fecal 44:11,12,13,15

45:3,20

federal 14:11 16:20

23:18 95:17 125:4

154:11 189:13 252:17

253:12 266:13

federation 205:4

fee 14:10,14 15:2 35:19

82:10,10,13,13 83:17

84:10,20 85:11 86:6

86:12,20 87:1,4,6

88:4,22 91:15 92:14

93:19 94:5,18,18

95:11 96:5,12,12 97:9

97:10 98:1,10 100:9

100:11 102:4 104:6

105:1,10 106:11,20

110:3 112:2,4 114:7

120:4,19 121:3,4

130:22 131:1 136:1

136:18,18 137:10

143:6,8,16 174:5

177:7 182:16,19

184:19 186:22 189:8

190:6,10,11,19

192:15 196:10 197:11

211:6 212:17

fee-for-service 40:2

70:11

Feed 185:18

feedback 122:3 162:11

200:19 201:9 203:19

243:7

feel 164:6,11 165:12,13

197:17 198:13 199:10

213:1 226:4,6,8 235:8

240:18,22 241:16

246:13 248:2,14

275:17,20

feels 208:1 248:15,19

fees 14:19 15:1,12,15

22:16 23:6 85:10,19

85:22,22 86:8,11 88:9

88:20 91:14,18 93:13

94:13,14,22 96:2,17

98:15 99:19 101:21

104:9 106:12 110:15

111:12 118:11 120:18

124:1 125:21 129:18

131:2,20 136:2,12

144:19 146:20 150:6

151:1 170:11 172:14

172:18 173:5 175:4

175:12,16 176:1

177:18 179:18 181:19

181:20 182:21 184:6

185:1 188:15 189:10

189:15,17 190:4,9,13

190:17 191:13 192:13

193:9 196:6 197:16

197:16 198:1,5,6

205:6 206:3 209:12

210:12,12 213:21

264:14 265:10 266:2

feet 54:9 157:16 158:12

159:6,18

fell 267:12

fella 21:12

felt 229:11 253:2

feverishly 20:20

FGIS 1:6 2:4 8:8 9:4

13:13 14:18 15:13

16:14 19:22 21:1,8

22:2 24:15 25:4 26:12

26:14 27:2,13 28:3,20

29:19 30:14 31:8

32:16 33:1,8 38:15,20

40:3,18,20 41:1,6

42:4 43:6 44:10 45:8

48:7 49:2,9,10 50:20

51:5 52:8,11,16,20

53:19 55:9 57:10 59:7

62:6,8,14 63:8 65:13

66:6 69:20,22 73:13

76:13 79:22 80:12,18

81:20 83:4 86:1

108:18 110:7,22

111:10 116:4 121:1,6

135:10 151:1,11

161:5 162:16 163:11

169:12,16 170:11

173:16 206:17 214:19

216:18 217:9,10

218:2 220:10 223:14

223:20 224:9,12

233:19 240:17 241:3

244:14 245:20 246:22

249:7 250:6 252:1,10

253:10 254:11,22

255:6,14 258:6 261:5

261:14 262:6 265:19

265:21 267:17 269:13

273:22 274:5,18

275:4,12

FGIS's 60:10 61:19

81:19 82:7 120:16

125:19 193:21 258:7

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
289

FGS 29:19

field 1:12 2:6 19:21

20:6,11,15,15,17 22:8

22:20,21 24:15 26:16

26:22 29:11 40:17

41:7,10,13,15 42:8,10

45:18 46:13,16 47:14

47:18 52:9 61:19 79:5

92:2 104:2 121:7

128:7 254:14

figure 10:19 12:11 13:3

17:16 66:20 68:7

72:10 93:16 104:8

114:6 141:8 195:20

247:13 266:22 268:3

268:16

figured 12:12 112:7

118:15,17 127:1

figures 172:14

filed 33:10

fill 20:22 21:3,16,17

22:20,21 27:13

101:11

filled 21:19 148:21

filth 14:2 44:16

final 10:9 12:4 33:20

37:16 46:2 47:2,6

80:22 81:1 96:1

113:10 115:22 189:12

277:6

finalization 13:18

finalize 112:9,10

finally 159:8 162:2

financial 22:12 81:19

113:5,10,12 129:11

129:12 250:16 267:13

financially 238:16

find 65:3 72:8,13 77:10

169:12 205:21 233:22

245:2 260:14 272:16

finding 197:6

findings 30:20,21

fine 91:12 151:2 155:17

213:12,15

finger 191:16

finish 112:16 113:2,8

116:18 205:17

finishes 112:11

finishing 112:8 113:9

fire 166:6

firewall 43:6,10

first 12:9 40:11 42:3

45:4 48:10 56:3,8

57:1 62:10,22 66:15

93:14,18,22 109:13

117:7 138:3,17

156:12,13 157:9

160:17 161:3 187:5

191:3 192:14 207:15

237:7 250:6 253:5

263:8 267:6 269:8

270:21

fiscal 23:14 29:12 59:13

59:18 62:6 65:21 66:6

66:10 70:12 71:4

88:22 106:15 112:19

112:21,22 113:4

174:3 184:19 186:16

187:14 203:22 204:3

fiscally 173:7,12 179:2

fit 270:19

five 18:20 95:15 97:11

97:17 99:20 101:21

101:21 102:13 103:10

147:2,6 173:22 178:6

182:7 230:7

five-year 29:17 93:4

96:7,8 97:18 106:4,10

106:15,18 137:5,10

143:10,11 144:15

171:1,5 182:5 185:1,2

196:11 218:9 241:6

244:19

fix 181:1

fixed 224:21 231:12

flat 176:21 267:12

flavor 65:6

flexibility 14:3 15:19

84:9 182:11

floor 7:21 8:6 195:3

flour 59:1

flown 129:1

fluctuate 210:18

fluid 209:8

FMD 130:17

FOA 57:21

focus 26:15 69:1

257:10

focused 27:6 85:5

folks 24:4 128:15 129:2

181:10 182:20 207:16

249:5,11

follow 77:15,16 184:14

244:14

follow-up 192:10,16

following 49:13 94:15

125:5 137:8 217:12

FOM 41:15

food 12:1 48:18,20

209:5 225:6

food-aid 70:7

Foods 4:11

footnote 103:9

footnotes 172:21

forbid 237:9

forcing 244:18

forecast 142:8 172:2

189:2

forecasted 141:1

190:18

forefront 169:18

foreign 11:15 63:21

72:5

foremost 161:4 253:5

forget 33:18

formal 14:21 166:22

format 38:9 253:21

256:16 259:22

former 157:12 160:6

163:15 232:8

formerly 4:14 97:12

forms 35:1 43:8

formula 93:6,17 96:6

118:19 122:15,19,19

122:21,21 123:6,9

125:2,3,6 126:13,16

127:2 135:4 143:8

212:1

forth 50:7 194:10 212:5

226:7

fortified 70:5

forum 6:17

forums 197:5

forward 10:19 23:11

42:16 57:20 82:6

90:21,22 108:10

113:17 114:9 141:1

142:20 145:20 148:4

148:10,16 164:17

173:9 174:16,17

175:1 178:2 179:5

180:4 184:15 188:5

195:21 200:21,21

210:15 211:9 214:2

231:3 238:6 274:7

275:22 278:17

fought 257:18

found 51:17 60:3

242:14

foundational 267:10

four 26:14 30:6,18,22

50:12 56:1 69:3 87:10

98:19,20 99:1,7

101:15 122:18 134:2

135:3,18 137:2,3,4,4

137:15 138:14 144:7

145:3,13 173:22

178:17 185:5,6,8

188:22 189:8 196:9

212:4,10,17 240:6

244:3

four-year 184:3

fourth 73:9 89:20,22

FR 37:6,11,16,18 39:11

Friant 1:18 4:21

frame 227:14 frankly

196:3 199:9 fraud

24:4 Frederking 1:15

4:8,8

146:6,7 152:7 164:11

166:19 167:9 169:14

174:4,10 210:9

244:12 251:10,21

256:13 257:16 258:16

273:10 274:17 275:20

free 181:11 255:13

freed 104:16

freeze 86:20

French 53:4

frequently 240:13

264:20

fresh 21:14 120:8

Fresno 156:1

Friant 4:21 38:10,10

103:7,7,14,17 109:13

110:1 111:15,20

115:9 116:1,4,7

137:17,22 138:3,8

140:2,7,12,14,16

144:2,5,12 145:10

155:5 166:7 168:4

181:12 195:13 202:12

207:8 210:19 213:3,7

251:11 265:6 267:9

Friday 11:11,13 47:4

119:10

friend 42:5

front 27:5 155:3 183:21

203:6 243:13

FRs 37:19

fruit 17:7 120:7 267:15

268:1 271:1 272:1

fruits 17:2 120:9

full 23:5 137:4,14

148:22 162:7 166:18

177:17 182:9 185:7

188:20 219:3 258:16

258:17

full-year 130:5

fully 11:17 74:19

207:20

fumigant 153:20 160:2

fumigating 160:11

fumigation 31:11 56:21

150:1,21 151:19

152:12,13,13 153:1

153:13,16 154:12,15

157:19 158:1 160:10

161:4,11 162:18

166:10 168:7,12

169:4

fumigations 156:3

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(202) 234-4433 Washington DC www.nealrgross.com
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fumigators 152:21

160:4

fun 62:20

functionality 255:8

functions 239:3,13

fund 91:4 265:22

funded 73:14

funding 39:20 82:7,9,10

100:15,21 104:13,17

130:13 193:8,11

194:4 255:11 265:7

265:16 267:6

funds 101:2,16 103:12

104:5,10 192:17

265:8 266:3

further 13:22 102:19

114:3 171:13 198:10

210:20 224:1

future 25:19 37:19

180:7 190:16

FY16 127:9

FY23 127:12

FY24 178:11

G

GAC 237:8

GACC 48:15,17 49:4

50:1,17

GAIC 167:1

gallery 3:12 7:16 150:8

185:12 251:1 262:8

276:7

game 186:18

gangbusters 184:9

gap 71:4 182:19

Garcia 1:15 4:6,6

gas 161:9

gases 166:6

gates 258:15

gather 156:14 261:6

275:14

gathered 8:17 9:11

228:13

gathering 16:17

gauge 156:14 158:3

200:17

GE 62:20 63:1,16,16

71:12

GEAPS 5:20

gee 50:3

gene 63:5 64:8,10

65:20

gene-edited 66:3

general 4:9 9:8 18:16

26:4 48:15 51:11

216:19 221:9 225:8

generally 27:10 161:11

203:5 274:10

generate 71:1 211:17

263:18

generated 252:5 256:20

generation 65:13,14,18

66:1

genetic 65:8

genetically 62:22

Geneva 58:5

gentleman 156:17

geographic 9:12,17

12:6 34:13 36:7,10

geometry 160:11,12

getting 31:19 37:10

41:7 49:8 54:6 77:8

83:2,3 94:19 115:19

142:16 152:22 167:6

169:16 186:6 193:16

201:18 202:2 208:10

223:9 233:20 234:22

235:8 256:9,16 257:8

257:9 260:21 273:8

GFA 4:22

GIAC 219:20

GIPSA 73:14

give 15:4 32:9 38:7

55:12 61:1 79:9 81:22

83:22 84:9 91:14 95:6

106:6 120:22 121:11

128:8 129:4 151:18

195:2 218:9 232:20

247:8,9 249:11

276:16 277:2

given 7:21 8:5 40:16

65:17 113:19 155:20

178:4 207:11 209:13

215:5 216:4 250:18

gives 21:12 150:6

giving 51:15 237:15

250:21 253:21 256:2

277:6

glad 184:11

global- 58:13

go 3:4,15 6:3,13 8:7,9

17:17 22:6 34:11,21

36:12 42:1 46:22

51:21 54:2,18,22 55:2

55:17 56:19,22 71:3

75:7 81:3,7,19 82:2,6

93:21 95:11 99:2,5

100:1 103:4 105:17

110:19 115:6,8 127:4

128:4,6 137:18

145:17 148:16 149:12

150:20 151:3 152:5,5

156:13 159:8,18

161:18 169:22 170:19

172:7 174:5 175:4,19

176:15 184:15 186:7

186:13 191:4 195:7

195:10,11 209:18

210:8 214:8,13 219:1

229:8,15 231:3 236:4

236:4 237:5,7 244:3

246:21 247:10 248:8

248:10,17 249:5,11

250:15 261:13 264:6

264:7 265:8 267:3

goal 8:22 25:22 61:20

70:21 94:22 95:2

146:4 173:21 263:13

271:2 272:2

God 237:8

godfathered 241:7

goes 53:17 54:10 188:9

189:9 196:14 220:11

260:11

going 3:4,13 8:7 9:5

11:15 15:9,12 16:17

16:19,21,22 17:11,13

17:15 18:1,2 20:2

21:18 22:15 23:11,17

23:21 24:14 27:10

29:1,6 30:1,4,7 33:22

35:8,21 36:8,19,19

37:16 43:6 45:18 48:8

49:6 50:19 55:22,22

56:6,15 58:22 59:10

68:16 72:10 74:18

80:4,9 81:6,19 82:2,3

83:8 85:2 90:7,21

91:8 93:21 98:7

100:10 103:3,4 107:6

107:17 108:2,6

112:13 113:18 114:3

117:4 121:19 125:14

127:21 130:4 133:2,4

135:14 137:7 139:11

140:21 141:1,5,17

142:4 144:9,10 145:1

145:2,5,6 149:7,12,20

150:14,16 151:13

154:1,17 156:19

160:14 161:3,17

163:22 170:6 174:22

175:8 176:10,11

177:3 179:7 180:4,16

182:4 185:11 187:8

188:8 189:3,7,15

190:15,17,20,21

192:4,9 198:18

199:17 203:2 204:1,6

204:10 206:4,6 207:5

207:9 208:20 210:21

214:2,5 218:21

219:12 223:21 230:17

231:3 234:1 236:4,5

236:14 238:22 240:1

241:16 243:1 246:7

248:5,21 249:2,9,12

254:9 256:4 258:19

259:15,21 261:5

264:1 274:1,6 278:3

278:17

Gomoll 13:11 44:19

52:16 58:22

Gomoll's 55:21

good 8:15,16,19 18:21

26:9 37:8 38:9 39:5

39:19 40:12 42:15

48:4,4 51:22 73:21

77:5,11 78:3 79:13

80:2 168:18 180:9

186:5 188:2 191:15

198:14 203:18,21

206:19 207:4 209:13

235:14 237:10 238:6

244:4 246:16 249:4

269:12,12 274:6

276:2

Goodman 19:20,21

gosh 229:17

gotten 49:11 100:17

193:15 198:7

government 39:21,22

40:4 56:2 179:1

266:13

grab 268:14

grade 10:21 12:1 17:10

62:2 117:19 121:12

204:17 209:5 215:6

216:9 235:14 240:20

241:21

graded 240:6

grades 207:12,13

233:20 234:20 250:10

grading 11:2,2 16:13,15

16:19 17:4,6,9 18:8

51:14 57:6 76:8,9

79:10 131:21 169:9

177:8 179:9 180:13

215:1,3 216:18

220:18 221:1,8,12,13

222:18 228:15 229:2

229:14 239:4 257:17

gradually 99:19

grain 1:1 3:19 4:9,22

5:3,4,10,10 7:9 8:20

8:21 9:6,15 10:17

14:11,14 15:1,7 16:1

16:20 18:3,16 19:9,14

23:18 24:4,5,5 25:1

32:18 40:12,22 43:19

44:15 45:19 46:7 57:5

57:6 61:7 62:15 66:9

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(202) 234-4433 Washington DC www.nealrgross.com
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66:12,13,15 67:14

69:4 70:1 71:15 73:7

74:16 78:8 79:10,11

82:14,21 83:12 84:5

85:5,6,12,21 86:1,2,4

89:9 108:5,7 111:5

116:13,14 122:2

146:7 147:13 151:19

154:11 185:18 188:13

193:6 201:7 203:5

206:10 207:12 212:6

216:10 225:19,22

230:16 232:9,11,12

233:7 236:9 237:16

252:12,17,21 253:3

260:7

grain-handling 202:18

grains 18:6 48:19 49:1

57:17 58:14 60:6 63:3

66:7 70:10 206:12

215:15 249:22 250:11

gram 214:19 215:4,7

225:10

grams 158:11 159:5,11

159:17 161:15 166:20

215:14,19,20 246:2

249:20,21

grandfathered 229:2,14

grandfathering 229:10

229:18,18,19 230:7

granting 69:11

grants 28:7

graph 68:20 86:14

88:16 89:17 91:6

178:9

grateful 9:2

gratitude 40:13 42:2

gray 30:12 164:14

great 3:8 22:6 38:14

42:4,5 55:8 66:19

91:2 111:20 151:17

155:12 164:17 165:2

178:13,13 180:11

190:18 209:3 263:13

greater 59:11 67:3 99:6

148:7 154:2 158:22

159:10 161:14 165:17

249:9

greatest 22:19 54:16

greatly 247:14

green 65:1 86:19

110:15 111:12

grind 51:21

group 17:15 27:19,21

28:3 45:8 57:7,9 58:9

60:10 70:15 83:14

134:15 155:22 171:16

210:7 218:4 269:4,6

275:4 278:10

groups 56:14 58:4

110:21 121:21 122:10

253:2

Grove 1:9 3:3 5:16,16

75:13 76:1 77:4 79:15

81:5,16 91:8 149:7

150:13,18 151:7

152:2 155:14,17

164:6,19 165:6

167:18 168:14 169:21

170:17 175:3 179:21

183:18 185:11 192:3

194:22 199:17 204:8

204:13 206:14 208:8

212:21 213:5,11,17

214:12 220:1 223:17

229:16 232:22 234:18

235:4,7,21 236:19

240:16 241:13 245:9

245:12 246:10 248:14

250:2 251:13 255:22

257:20 258:19 262:6

268:22 275:7 276:3

growing 25:3

grown 60:12

growth 252:4 271:14

275:2

GSA 83:11

Guangzhou 57:3

guess 20:17 36:22

76:17 120:13 146:11

158:10 163:16 166:21

168:15 192:18,22

199:14 200:11 207:21

230:22 233:9,18

guidance 61:2

guidelines 35:1 215:9

217:3

Gulf 146:16 164:1,16

258:11

guys 64:9 69:1,8 151:5

204:20 205:9 206:11

225:12 226:8 228:20

257:12

guys' 210:15

H

half 10:12 87:10 98:8

98:20,20 99:1,7

101:15 102:13 108:16

123:10,16 124:14,16

126:9,11 134:19,21

135:2 137:4,15 145:3

145:13 173:22 174:1

178:18 185:8 196:10

205:10 206:3 212:4

212:10,18 238:9

hand 7:20 234:2

hand-picked 69:2,3

handbook 152:14 153:2

153:14 154:12,14

167:7,13 169:5

224:19 246:22 247:5

handbooks 43:18 219:8

219:11 244:14 247:6

handed 163:12 258:5

handle 7:14 55:20

153:9 156:2,2 169:22

268:19 270:2

handlers 199:4 202:20

203:5

handling 254:8

hands 13:20 44:22

161:4

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handwritten 68:20

hanging 48:9 244:15

272:1

happen 6:12 22:15

88:22 101:3 125:15

141:3 166:3 175:8

179:7 189:16 190:15

202:10,13 224:17

234:19 239:20 240:13

241:5 247:20

happened 73:16,20

75:5 84:8 107:3 196:4

202:19 234:19 235:11

239:18 265:20 266:20

happening 9:8 24:7,7

94:16 107:17 114:8

128:20 216:13 240:19

240:21 241:14,17

happens 9:1 40:7

178:10,12,19

happy 13:5 37:20 38:7

39:2 71:8 151:13

162:10,21

hard 60:15,16 128:9

145:18 176:8 181:22

205:10 244:7 278:15

harvest 11:11 89:22

102:7 155:22

hauling 231:13

hazards 158:4

head 3:4 164:1 168:10

190:14

headed 273:16

headings 158:6

headquarters 92:3

130:17

heads 250:21

headway 267:19

hear 16:8 85:7 151:5

182:12 246:21 261:22

heard 6:8 12:2 19:6

48:11 50:14 147:1

148:19 182:20 205:1

207:7 242:2 244:6

hearing 34:4 47:21 80:9

heat 226:9 234:7,22

240:20 249:16

heat-damaged 215:21

heavily 269:18

heavy 70:4 255:12

Heil 5:8,8 163:2,3,20

236:1 238:8 272:4

Heiskell 4:19

held 41:5,11,14 143:3

143:21,22 144:21

171:7

Heil 1:19

Hello 151:5

help 4:3 23:22 24:8,10

37:16,21 49:22 106:3

110:17 115:13 129:3

129:5,8 145:15 165:9

176:13 195:20 243:17

244:10,10 250:21

251:2 267:13 275:4

helped 23:2,3 100:16

154:11

helpful 16:7 21:15 35:1

187:22 194:20 249:14

260:10 262:4

helping 19:1 28:16

266:16

helps 79:4 165:10

195:19 207:7 252:20

hemorrhaging 103:20

herbicide 71:21

herbicide- 65:8

hesitant 200:20

Hey 56:11 94:10 166:16

175:10 195:7 224:5

236:13 248:17 251:11

259:7 268:17 270:17

275:12 276:10

Hi 81:18 170:21

high 77:21 88:19

102:14 109:3 114:16

135:8 184:9 189:22

235:8 237:11

high-precision 221:5

221:12

higher 67:7 68:4 87:16

102:3 103:16 141:12

159:19 161:19 166:5

166:18 217:11 218:18

220:20 228:16 234:22

240:7 245:5

higher-level 43:17

highest 119:1 210:14

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
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highlight 30:5,7

hill 28:13 186:20 188:2

193:21

Hills 5:14

hindered 15:20

hire 22:13,14 128:12

hired 20:16 22:10 23:4

27:16

hiring 23:12 27:13

historical 83:22 86:14

88:16 89:19 95:19

100:4 115:5 117:22

118:5 119:18

historically 42:22 43:3

history 91:13 212:9

hit 56:7

hold 7:21 57:14 129:7

145:5 149:8 152:19

152:20 154:16 158:13

158:22 160:4,7,12,15

160:15,18 166:1,4

170:8 239:15

holding 57:5 113:3

142:13,16 144:17,19

holds 153:5,18 158:17

162:3,7,8 163:18

164:3 166:18

hole 105:11 135:13,19

137:14 152:22 173:3

173:20 175:1 211:11

holiday 119:5,5,16

123:8,11,16,20 124:3

126:12 134:21 140:12

140:13 205:12

holidays 119:8

holistic 36:3

homogeneously 161:9

honest 176:19 266:11

honestly 37:18 107:21

honored 49:17

hook 266:17

hope 267:10

hope-to's 200:2

hopefully 37:20 175:21

275:2

hoping 13:15 20:10

21:21 23:9 73:8

horizon 64:4

hour 55:19 138:11

hourlies 85:22 172:20

hourly 91:19 115:5

117:22 118:16 126:5

127:1 131:3,6,9,11,14

131:16 132:7,7,13

135:4 141:19 144:10

171:11 201:6

hours 119:12 125:12

138:13,14 139:2,3,4

143:21 190:20 239:21

240:6

house 186:3,14 230:22

270:5

housed 111:4

houses 253:7 254:8

HR 87:18

huge 129:19

hulls 51:20

hundred 106:22 191:2

hundreds 184:5 189:21

191:2 234:15

hundredth 215:5

238:10

Hurburgh 1:14 3:17,17

3:18 73:12 74:3,9,21

75:2,9 90:15,18,19

91:1 132:20 133:9,12

133:19 178:4,15

179:11 202:6 248:4

hurting 250:9

hybrid 28:22 29:7

I

ice 81:8 183:19

idea 106:6 180:16 199:9

246:6

ideal 174:14,15

ideally 178:16 200:13

264:1

ideas 278:5

identification 50:13

60:19

identified 43:14 65:21

245:18

identifies 10:3

identify 60:5 63:13,20

identifying 50:11 70:21

271:1 275:2

IDW 261:11

ill 100:17

Illinois 5:9

illustrate 119:15

image 60:22 79:2

images 60:21 66:17,19

imaging 18:5 66:5,7,13

75:15 79:19

immediate 10:16

immediately 80:21

226:17 228:22

impact 10:20 71:11

124:2 174:11,19

226:2,8,18 229:12

238:17 243:21 246:5

249:1,2,16,18 250:1

250:16

impacted 11:6 245:22

246:8

impacting 247:11

impacts 13:4 115:18

129:11,12 216:22

226:10 229:7 267:13

implement 123:3

141:18 142:18 191:11

implementation 93:4

implemented 17:4

86:18,19 96:7 97:6

102:5 106:13 116:22

117:2 118:7,20 119:3

119:19 121:4 122:15

122:22 123:1 128:2

135:11 141:3 147:9

182:5 196:15

implementing 142:2

imploded 33:1

importance 76:11

199:3

important 29:19 62:1

74:6,11 161:1 175:13

208:9 209:20 210:4

215:15 222:3 231:6

246:17 256:14 269:15

270:8,11

importers 51:13 56:2

163:13

imports 50:1

improve 62:15 90:11

252:10 255:8 274:16

improved 61:2 219:15

improvement 60:7

70:21 157:17

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62:9

improving 70:13

in-country 52:22

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231:15

Incentivize 159:21

include 15:6 45:8 49:17

56:22 126:4 161:1

included 46:8 60:15

121:6 161:14 186:15

187:9 274:12

includes 49:10 69:13

71:20 86:5,5

including 15:3 39:21

94:13 228:11

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incorporated 62:8

increase 15:17 82:16

97:3,4,5,6 98:21

100:1 102:18,21

103:1 113:21 114:11

125:13 129:19 130:2

133:3,7 136:5,16

142:1,12 143:14,20

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128:1 133:16 147:10

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increasing 61:11 68:5

incumbent 181:18

index 160:15

Indiana 32:18,19 34:13

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indicated 67:22 160:13

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51:18

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industry 2:9 4:12,18 5:1

5:21 10:18 13:6 16:5

17:7,12,13,14 18:3

22:4 51:10 52:22 61:1

66:10 72:13 73:8

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110:12 112:6 129:8

139:3 146:13 147:2

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156:14 157:8 163:5

164:13 165:11 168:1

169:20 174:13 175:4

176:9 181:8 190:2

192:7 194:6 195:12

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263:7 265:4 267:17

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38:3 43:20,22 44:2

53:7 109:17 146:9

156:15 163:13 168:1

192:12 195:8,15,19

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232:18 234:10,11

246:16 249:2,14

252:15 253:13,20

254:9,12 258:4,4

260:22 261:12,15

262:1 268:12 269:12

271:19 272:22 275:14

informational 223:20

informative 185:19

initial 76:7 205:6,6

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initiates 45:11

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input 58:16 60:22

121:22 178:1 199:20

206:16 208:9 246:11

253:17 261:17 262:7

262:13 275:11 276:7

inputs 175:7

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8:21 9:6 10:17 14:11

16:1,20 18:17 19:9,15

23:18 32:19 40:12,22

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88:17 91:18 115:21

116:5,15 151:20

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61:7 80:17,17

instance 17:5 200:14

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31:20 35:2 43:17,18

61:18 228:4

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67:14 68:22 69:5,6,12

74:7,12

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67:21 69:5 73:19 74:2

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integral 22:2

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intend 29:10

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intention 85:6 117:17

interchangeable 221:2

interdepartmental

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interest 52:10

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53:13 75:14 89:18

198:20 254:1 264:15

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182:12 233:10

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interior 223:4

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70:19 261:6

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227:19 228:9

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48:2 53:16,18 57:22

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274:14

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100:18 149:4 188:11

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58:20 228:21

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iron 37:21

irresponsible 173:7

ISO 70:16 71:6

isolated 274:22

issue 12:7 13:2,14

30:22 31:8,17,22 51:8

83:18 84:1 149:17

151:19 152:11 156:18

166:12 169:17 179:18

192:7 214:1,9 223:19

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issues 2:9 12:9 14:1

29:14 30:11,13 31:5

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248:22 250:5 251:6

256:2 274:6

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37:9 51:2 101:8

110:18 130:5 138:22

175:15 229:9 251:4

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J-E-S-S 185:17

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Jan-Feb 204:10

Janice 1:16 4:14 39:14

January 90:2 93:3,10

95:1,2 102:5 113:21

133:14 174:6 196:16

200:3 203:2

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152:10 154:1 158:18

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Jess 185:17 186:5

191:16 194:22

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40:22 59:6,8 71:16

72:21 73:21 74:4,10

75:1,6,11,22 76:2

77:12,21 78:2 79:14

80:3 81:4

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Jimmy 1:19 5:6 127:2

212:16 248:7

job 20:20 260:1

John 1:17 4:16 99:11

124:5 126:9 149:7

170:13 209:7 257:11

join 164:22 165:8

joined 7:7 41:1

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judge's 34:7

jump 82:1

June 105:3

jurisdiction 58:4

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kale 65:2

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160:10 176:3 183:19

183:19 208:22 218:2

218:16 238:2 250:4

262:16,20 266:17,18

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kernel 78:12

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80:20,21

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167:11,22 202:22

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211:2 274:1

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72:14 75:15 78:11

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113:3 121:12 131:20

151:17,18 154:9,13

155:20,22 156:1,5,9

159:4 162:7,15,18

178:5 188:3,3 195:6

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234:11 253:20 267:12

272:19 273:8 274:10

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190:20 201:10

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17:14 21:4,10 26:15

34:2,20 35:4 37:22

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76:22 77:6 79:11,16

79:16,18,19 90:1

94:11 102:7 107:18

107:19 108:9 110:6

112:2 114:5,5,7,12

115:10,11,12,14

116:9,12,14,15,16

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134:11 136:1 139:11

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149:3,15 151:10,16

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168:18 174:2 175:3,6

175:8,16 176:2,8,21

178:19 179:17 180:11

180:21 181:1,7

182:11 184:18 187:19

187:22,22 188:2,7

190:16 191:2,5,15

192:17,20 195:14

197:5 198:18 199:19

200:20,22 201:5,12

201:12,22 202:20

203:4 206:7 207:14

208:3,11 209:10,16

209:18 211:1,16

213:3,17,19 221:7,20

222:5 223:10,11,18

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225:4,11 230:1,5,10

230:11,20 231:16

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236:14,15,22 237:1

240:21,22 241:7,8,14

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260:16

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114:21 117:10

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166:4

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law 193:6,10,16

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League 92:18 97:17

98:7 128:21 136:15

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80:7 272:14

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198:7 212:9

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199:13 244:15

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55:22

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Leroy 274:20

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238:3,4 248:17,18

268:3,3,4,15,15 270:6

270:17 272:16

letter 38:19

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104:3 111:13 120:1

121:12 146:18 149:1

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92:11,17 100:5

library 60:11,13 66:17

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80:17

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245:1

lifecycle 45:10

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limitation 84:6 114:11

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197:2 198:4 218:2

224:13,18 229:13

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227:11 249:15,20

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Literally 202:7

litigation 33:10,17 34:5

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Micah 28:11 42:9,15

microphone 26:6

microscope 61:11

microscopes 62:2

77:13,18 78:14 80:15

Microsoft 78:14

mics 7:2

middle 219:13 272:6

Mikesh 5:2,2 225:18,18

238:21 243:18 249:13

260:4 264:3

mill 59:1

millers 55:1,3 56:2

205:4

million 14:18 15:9

82:12,17,18,20 83:1,4

84:3 87:13 88:3 89:8

98:16,18,19 99:1,3,7

99:9 100:15 101:15

105:11 106:19,22

107:1,1 108:16 127:9

127:14 128:22 135:12

135:16,17,20 140:22

142:10 146:17 147:19

173:3 184:4,7 187:5

188:20 189:6,17,18

189:21 191:1 192:19

192:21,22 193:4,13

193:17,18

millions 65:15 182:2

184:6 189:19

milo 230:17

mind 208:22 218:16

238:2 277:10

minimal 142:12 267:16

minimize 174:17,18

minimizing 267:13

minimum 173:21

minor 30:14 80:14

minus 68:2 178:11

221:4

minute 12:11 13:3

251:15

minutes 81:10

misalignment 242:15

miscellaneous 51:2

86:7

missed 174:4

missing 182:19 223:2

Missouri 5:7 65:11

mitigate 124:2 244:11

mixed 11:8

Mm-hmm 75:1 186:9

MO 1:7

mode 6:10

model 62:19 67:17,18

120:3

models 73:19 75:3

modern 55:19

modernize 162:17

194:1 262:12

modification 160:19

modifications 64:19

211:12

modified 15:11 64:18

65:21 123:20 124:3

modify 83:21

modifying 167:6

modules 53:22

moisture 74:15 237:5

237:11,12,13 248:6,8

molecule 64:14,16,21

moment 38:18 39:1

269:1

moments 199:21

Monday 44:3 119:9

138:5 207:14

money 173:5,6 229:7

262:16,22 263:1

monitor 24:10 105:1

145:22

monitored 257:21

monitoring 68:21 69:14

181:2

monitors 24:10

Monte 67:17,18

month 13:16,17 20:19

21:10 54:19 88:7,13

102:13,22 105:20,22

142:10 178:18 212:4

212:10

months 28:16 36:20

51:11 87:10 89:16

99:7 101:22,22 102:6

102:10,17,20 105:14

105:16,20,20 118:3,3

134:6 135:13,16,18

135:20,22 137:4,15

140:22 142:15 145:13

185:8,9 196:10

Morgan 1:17 4:16,16

105:13,16 106:1

124:5,5,9,15,19,21

170:14 204:14 257:11

257:11,18 258:13,18

Morgan's 99:11

morning 8:7,15 26:9

40:12,14 44:3 47:16

48:4,5 59:9 82:11

213:4,20 214:3

276:13,20 277:13

278:19

move 18:14 23:11 51:6

101:12 104:16 139:6

139:17 140:3 145:20

150:22 166:17 170:6

170:9 178:2 179:5

200:21 211:8 214:5

247:18 248:21 250:4

251:7 267:7 277:4

moved 37:9 103:22

200:15,21 206:9

movement 57:19

moves 112:22 169:6

moving 57:20 108:2,5,7

108:10 139:12 173:8

188:5

mull 150:7

mulls 276:13

multiple 60:13,17 74:2

111:16 189:10,15

190:14 204:20 232:2

240:4 261:20

multiply 125:12

mustard 51:1 65:1

mutation 65:19

mutually 217:13

mycotoxin 4:4 62:5

70:18

mycotoxins 53:8 70:4

N

N 1:7

NAEGA 167:14 183:5

183:10 191:9

Nah 76:9

name 3:15 6:3 8:2,12

20:9 40:19 185:13

214:11

names 19:6 36:14

49:14

national 7:9 8:20 23:15

23:22 28:7 37:4,12

45:19 62:15 75:8

83:12 92:20 93:5,15

93:16,18,22 94:4,7

95:13,14,18,21 96:3,5

97:7,8 98:10 109:20

109:21 110:2,19

111:4 115:3 117:5

132:10 136:11,14,16

136:17 137:8 144:18

182:17 184:19 185:18

196:22

native 64:20

nature 222:2 264:22

Neal 1:10 2:4 8:15

40:15 47:17 51:7

84:13,13 90:17,20

91:2 94:10 99:11

103:19 107:21 119:14

123:19 128:4,7 143:5

143:11 145:11 147:21

150:17 151:15 154:8

155:11 163:1 164:21

165:5,20 166:14

167:4,17 168:11

169:1 172:6,11,14,17

172:22 173:2 174:8

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
297

174:14 177:6 178:13

178:16 180:11 183:15

186:5,9,17 187:3,16

191:15,20 193:18

194:17 200:13 203:11

204:11 208:5 211:3

212:8 213:14 242:1

262:10 265:9 267:21

270:22 272:19

nearly 239:19

Nebraska 5:19 230:15

necessarily 78:8 104:1

187:17 201:13 230:6

257:8

need 9:20 15:10,17,19

16:15 22:20 23:6

34:19 35:22 43:9 71:6

74:14 78:9 81:2 82:5

98:17 114:20 115:8

134:14 137:17 139:9

149:10 168:2 169:10

174:21 175:10,10,11

175:14 181:8 183:8

187:7 189:3 193:22

193:22 194:1 202:22

206:17,19,20,21,22

207:4,17 211:12

212:11,12 213:1

219:10 220:16,21

221:20 224:13,17

225:1 226:16 227:4,7

228:6,9 230:12,19

233:13 241:1,1,2,2,3

241:8 242:6 247:3,12

247:13,19 248:20

252:12 257:3 261:22

263:13 268:19 271:12

272:8 278:4,6,9

needed 9:20 32:15 45:6

46:8 47:11 63:5

102:20 142:22 198:4

202:18 213:21 241:21

268:13

needing 164:1 234:16

277:17

Needless 239:20

needs 15:14 27:14 28:2

28:17 29:13 38:22

43:7 63:8 165:16,18

193:21 233:14 241:9

252:13,14 255:9

negative 89:8 90:16

135:12 145:2 162:11

173:3 179:6 196:19

197:2 198:4 201:16

negatives 205:22

negligent 177:11

NEI 33:11

neighborhood 146:16

neither 177:22

Neogen 4:2,3

network 66:18

networks 253:8

neural 66:18

never 19:6

new 13:9 16:4,6 20:8,15

20:21 21:2 22:18 23:4

23:13 27:17,22 28:11

29:17 35:1 37:9 38:5

40:22 41:10,16 42:9

48:20 54:10,17,19

56:19 60:11,21,21

61:3,10,17,20 63:9,11

70:9 72:18,21 76:14

76:14,15,16,21 77:9

79:5 84:1 92:19 93:13

97:16 112:13 128:21

129:1 133:14 136:19

146:20 157:5 159:16

167:21 203:2 215:10

216:2 217:19 218:8

220:21 236:8 237:6

237:17,19 245:2,3

253:14 255:1 262:10

270:2

newly 218:1

next-day 80:21

NGFA 5:20 167:13

183:5,10 187:22

191:9,16 273:20

nice 206:5 261:1,18

nicely 156:7

Nicholas 1:18

Nick 4:21 19:1 38:10

103:7 140:1 151:1

170:9 183:15 188:19

191:9 192:6 195:2,10

199:18 203:11 204:15

206:15 207:5 210:6,7

210:10 212:22 213:19

214:1 251:16 265:12

Nick's 176:11 184:2

Nigeria 55:11

night 261:14

nine 105:13,19 135:22

175:22 185:9 276:22

nine-month 136:4

142:1

NIR 73:15

NIRT 59:3 74:21

NIST 214:19 215:9

216:19 217:7,12,17

217:18 218:2,5 219:9

219:17 224:10 225:5

229:13 232:17 241:2

242:17 244:15 245:7

245:20 246:15,21,21

248:9

no-go 55:14

nobody's 274:5

nomenclature 78:11

nominal 244:2

nomination 18:17,22

nominations 18:20

non- 24:4 31:9 119:7

120:14

non-compliance 31:21

non-compliant 232:4

non-contract 115:7

118:2 119:6 131:9

132:13 183:1

non-use 35:18

normal 40:19

normally 28:14 42:9

52:4 68:8 78:19

North 4:12 5:2 56:16,22

97:14 225:18

Northeast 32:18 38:11

Northridge 5:13

Northwest 60:12 92:18

97:12,16 98:3 136:20

note 42:19 62:1 67:5

68:3 160:17,20

161:13 166:1

noted 227:5

notes 30:4 100:13

notice 33:21 34:12

50:16 67:2 210:21

277:18

notice- 181:17

noticed 119:4

notices 26:20 42:21

43:1,14

notification 168:15

notified 167:12

November 16:16,16

20:18 55:13 113:11

113:13 136:4 277:16

NTT 34:8

nuance 152:11

number 22:17 25:1

31:18 33:4 46:10,11

50:13,15 61:12 76:10

76:17 90:16 103:11

125:12 133:10,11

134:6 175:11 179:12

208:12 216:5,5,9,10

221:4,5 222:10

228:15 233:17,17,21

244:2 248:5 249:9

number's 178:11

numbers 50:11 96:1

113:10,12 115:2

175:13 222:9 249:6

261:11

numerous 53:3 54:15

59:16 79:17 234:21

259:10 261:9

nutrients 70:5

nuts 17:2

O

o'clock 149:22 150:2,10

150:15 251:16 276:22

OA 33:5

OAs 32:11 36:1

objections 247:17

objective 103:19

obligation 177:18

obligations 87:16 89:11

100:12,14 101:6

103:9 105:4 108:20

109:8 130:11 142:4

observing 78:13

obviously 7:1 29:12

32:14 77:5 165:9

176:18 180:9 192:12

192:14 213:21 221:17

228:16 256:19 270:18

occur 215:20

occurred 28:20 31:12

34:21 130:4

occurrence 10:20

occurring 26:1 89:2

106:4 243:16,16

occurs 68:15

October 40:6 55:3

91:17 92:6,6 100:2

102:7 112:15 113:6,8

120:20 136:2,3

203:18,19

ODA 26:21

Off-microphone 113:22

offer 52:8 121:17

offered 33:4 57:6 224:7

offering 79:12

office 20:3,15,16,17

22:8,21 26:16 27:2

29:11 34:7 38:20,21

41:3,10,14,15 42:8,10

45:18 48:18 51:8

53:11 57:14 61:20

79:6 84:16 97:11,13

97:14,15 104:2

110:14 111:11 121:7

128:7,8 130:18,19

134:16 204:3 205:19

226:21,22

officer 24:21 272:22

277:7

officers 27:22

offices 22:21 24:15

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
298

52:9,15 56:10,11 92:2

97:19,22 231:22

official 5:3 9:18 10:3

11:2 12:16 14:16 25:7

25:16,20 26:16,22

29:11 30:10 31:3 32:6

32:8,18,20 33:15

36:11,20 37:1 38:20

39:4,7 41:4 47:7,11

60:8 61:7,13,13 62:8

69:12 72:20 85:15

86:15 94:3,8 115:1

196:6,7 208:17

218:12,20 220:10

221:11,16 234:20

242:7 252:18 254:1

256:10 258:21 259:4

261:4 262:6

officially 50:17 215:13

223:13 278:6

officials 56:3,9

offloaded 117:16

offset 100:16,21 101:5

127:20

offsetting 130:12

Oh 3:17 49:12 51:15

93:22 110:22 115:7

124:17 150:18 172:9

230:20

oil 50:21

okay 8:1 26:9 29:21

38:9,14 40:9 59:4,8

81:4 88:15 90:12,19

91:1,12 98:12 103:14

103:17 105:17 106:1

112:1 116:1,4,8

117:13 127:12 133:9

133:12 136:6 137:21

138:2 140:7 143:4

145:10 150:6,18

152:2,4 155:8,9,12,17

155:18 159:18 160:1

169:21 171:18 172:3

173:1 185:5,10,11

186:8 188:18 191:15

194:19 204:13 220:1

223:6 224:14 239:8

241:15 246:10 251:21

258:18 276:3

old 20:5 43:22 102:8

160:6 181:17 224:19

269:21,22 270:6

Olympia 97:14

OMB 126:21

onboard 76:12 262:11

once 29:14 37:15 112:9

176:6 186:12 231:6

263:15 266:14

one- 273:2

one-hour 55:17

one-month 52:17

one-to-one 126:6

one-year 118:4 119:5

138:5

ones 26:19 120:21

138:20 217:20 234:6

245:2,4

ongoing 24:20 63:14

69:14 71:3 101:17

248:21 278:9

online 3:7,10 6:1,3 7:7

7:12 10:3 19:12 29:20

49:9 54:1 60:10 81:17

110:7,22 140:4

149:11 150:4,8,10

176:22 223:14 228:9

251:1 254:22 255:6

261:5,14 276:4

onsite 29:2,4 131:6,9

132:13 220:20 222:9

222:12,21,21 226:3

227:3 228:11 230:11

231:8,18 239:14

open 18:18 47:20 80:9

153:15 185:7 199:15

250:4,5 255:20

267:21 278:3

open-ended 248:12

opened 18:18,22

opening 258:14

operate 9:18 128:17

173:4,6,15 177:12

178:20 187:1

operating 10:4 39:8

70:13,22 86:16 87:9

88:13 91:10 96:16,17

98:2,13 99:15,22

100:5 105:5 118:12

125:16 126:16 134:5

143:12 146:21 172:8

173:11 179:10 181:3

184:8 196:8,18 198:3

201:17 202:3 206:1

208:3 211:18 212:5

212:19 216:11 269:22

269:22

operation 25:6 178:7

218:11

operational 237:11

operations 17:5 32:21

41:2,17 174:21 263:1

opinion 81:3 179:16,20

224:22

opinions 80:18

opportunities 60:6

70:11 78:20 79:12

80:6 145:21

opportunity 15:4 26:20

34:12 40:14,16 42:1

42:12,15 47:16,17

51:16 76:20 80:11

151:17 156:6 167:14

183:14 185:16 192:1

198:19 207:18

opposed 244:18

opposite 107:9 147:11

option 62:11 181:9

208:21 211:21 219:13

220:6

options 173:16 219:3

224:4 228:21 243:9

243:12 250:17,18

orange 30:11 31:13

order 2:2,3 3:5 68:9

71:6 235:9 253:13

264:11

organic 23:15,22 24:1,3

24:5,5,8,12

organisms 64:20

organization 72:7

267:7 269:6

organizations 72:11

269:17

origin 234:20

original 122:16 154:12

Orleans 13:9 20:15

21:2 22:18 23:5 28:11

41:10 42:10 61:20

79:5 92:19 97:16

128:21 129:1 136:19

outcome's 90:7

outlined 264:5

outlook 141:2 142:19

output 261:13

outputs 261:10

outreach 19:2 51:7 79:8

194:6

outside 44:13 58:3

169:8 182:9

over- 237:13

overall 273:15 274:15

overhead 83:10,13

101:5 103:22 109:8

182:16 197:7

overly 271:4

overseas 24:6 56:10

overseeing 38:20

122:10

oversight 254:22

overtaken 36:16

overtime 123:8,9,15,20

124:3 126:7 138:9,14

138:18 139:5,14,16

140:10 205:12

overtook 38:20

overturned 46:12

overview 81:19 162:15

owned 5:18

P

P-R-O-C-E-E-D-I-N-G-S

3:1

p.m 138:6,13 278:22

Pacific 60:12 92:18

97:12,16 98:2 136:20

package 254:3 268:9

packages 254:21,22

packet 32:14 225:20

page 46:20,21 47:1

157:9 241:4

paid 130:5 182:19

palindromic 64:7

Panama 54:22 55:2

Panamanians 55:2

paper 58:5 196:2,2

197:9,14 198:9

199:14 256:17 258:3

paperwork 254:15

parameters 156:11

paramount 253:9

Parker 28:4

Parr 1:12 2:6 20:7 40:9

40:11,19 76:6 77:15

77:17 78:1,4 80:13

part 7:1 15:11 22:2 46:5

67:9 69:14 79:22

83:10 85:3 90:17

96:17 97:8 100:9

108:8 110:10 118:8

123:19 127:1 172:6

193:19,19 198:8

206:8,22 207:9 213:5

213:5 224:8 228:2,2

233:14 243:19 250:14

251:21 260:6 269:6

partially 181:13 246:1

participant 19:13 83:5

83:7 184:11 185:5,10

241:12

participate 17:15 62:13

participated 19:5 122:1

122:2,3

participates 57:14

participation 36:22

particular 10:2 15:21

30:19,21 53:7 158:3

163:4 175:14 219:1

222:12 244:2 251:6

275:17

particularly 49:19

50:22 52:10,18

167:13 182:22 199:4

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
299

216:20 222:11 234:14

parties 254:1 265:5

partner 72:12 80:11

194:13

partnered 69:19

partnering 23:14

154:10

partners 17:12

parts 27:1 29:4 137:22

pass 79:4

passport 54:6

Pat 21:8,10,10 22:1

41:21 42:4

Pat's 21:18 212:8

path 10:19 174:17

275:22

patient 195:9

pattern 113:3 275:2

pause 18:13 64:9 190:3

pay 98:7 119:9,10,16

124:4 133:17 136:17

136:19,20,21 139:2,4

139:11 179:18 205:11

paying 23:8 96:19 98:8

104:4 201:4,5,6 264:9

payment 136:10

payroll 130:17

pays 139:3

PCR 63:17,22 65:17

pdf 259:16

Pea 61:4

people 3:7,9 18:21 19:5

22:10 23:6 54:7 57:8

77:8,8,9,10 78:20

79:10 84:22 96:19

100:18 101:12 104:16

114:18 128:9,17

138:10,17 145:17,18

149:15 168:20 169:3

169:7,18 199:20

200:10 202:8 246:21

254:14 264:19 268:19

271:12

per-hour 210:17

percent 11:8 22:9 27:16

31:7,9,12 36:22 37:2

44:7 46:14 67:13,22

68:15,17 90:10,14

96:11 97:1,2,4,4,6

98:5,16,21 99:2,4,8

99:10,18 102:1,9,12

102:15,18,20,22

103:3 107:11,12

114:11 118:13,14,17

118:18 129:14,16,19

130:2 131:7,8,10,14

131:15 132:2,8,11

136:15 142:13 143:20

143:21 144:9,10,20

177:13,14 183:3

184:20 185:3 197:12

197:12,13 215:22

216:1,3,6,6

percentage 68:4 89:20

130:10 132:21 210:14

perfect 167:17 181:1

221:7 251:16

perform 46:1

performance 69:16

performed 45:21 61:12

86:2,3 254:11

performing 45:3 125:10

125:11

period 113:9 133:22

159:15 193:14 203:13

236:13,15 244:19

periodic 100:11 103:2

121:3,4 184:15

191:12 211:4

permitted 165:22

perpetuity 178:21

person 21:22 54:18

55:11 125:10 138:11

139:2,7,20 181:15

273:3

person's 175:19

personal 32:22

personally 41:22 42:5

234:18

personnel 27:9 31:14

62:14 125:11 254:11

perspective 128:8

147:3 158:19 161:2

200:17 236:18 260:20

perspectives 21:14

pertains 154:15

pesticide 70:4

Phil 225:20

Philip 1:15

Philippines 54:13,13

56:17

Phillip 4:6

phone 226:13

phones 6:9

phonetic 27:8 28:10

51:10 182:1

phosphides 157:13

phosphine 156:3,10

157:11,16 158:12,17

159:5,11,12,12,17

161:19

photographed 60:17

phytosanitary 56:20

58:7 152:9,14 163:21

166:12

picked 140:19,19,20,22

173:18 262:21

picking 55:9 215:21

piece 77:20 79:18

150:21 199:2 210:4

224:9 225:7 234:17

244:2 249:13 256:17

258:3

pieces 199:10 207:5

209:19 213:9 231:10

234:6 237:11 257:5

pill 177:20

pilot 24:14 61:18

272:12 273:4

Ping 20:22 41:12

place 35:12 93:13

113:16 117:7 120:19

136:2,13 148:17

156:13 157:2 175:17

176:3,14 179:1 200:4

202:3 206:18 208:13

224:12 244:16 257:5

269:12 270:13,16,18

273:22 276:6

placed 14:11 109:8

places 220:21 225:3

245:19 246:15

plan 38:12 174:22

176:5 186:18 230:6

244:16 247:14 263:6

planning 21:9 180:7

plant 48:21 64:3 253:7

platforms 63:7,9 260:8

play 42:16 47:4 91:16

118:15

players 233:7

please 6:8,14 7:2,20,21

8:2,3,12 67:5 68:3

176:15 185:13

pleasure 48:5 162:22

pluck 268:2

plus 68:2 127:18

136:16

plus/minus 68:13

pocket 245:3

point 13:11,13 39:9

69:9 77:14 98:14

116:20 119:3 138:10

178:8 179:13 191:16

201:18 203:8 213:2

214:4 235:13 244:13

245:14 253:18 260:3

pointed 208:11

pointing 196:20

points 196:16

policies 41:19 44:1,19

244:14

policy 20:4 42:17,19,20

43:1,11,14 152:3,13

153:13 154:13 169:5

216:18 245:20 248:1

polymerase 63:18

pop 27:15

popcorn 51:1

portion 40:1,3 96:16

98:12 111:3,8,9

199:10 246:1,4

portions 29:1 90:3

215:13

Portland 41:15 97:12

position 20:7 21:19

25:14 40:20 41:10,14

57:15 76:15,16 95:4

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197:9 198:9 199:14

201:3

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104:13

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201:17,20

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208:10 216:8,17

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277:21

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179:13 200:18 208:6

238:17

potentially 23:19 44:9

148:16 173:4 205:22

257:13 271:22

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166:16

practice 54:3

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153:16 162:19 163:5

164:16

Prairie 5:9 163:3 272:4

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Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
300

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219:16 222:3

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251:7

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18:21 58:5 66:4

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251:8,18 269:3

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55:14,18 71:18 81:10

150:10 151:8,10

170:18 185:19 192:8

206:20 209:19

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148:19 207:12

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196:18 197:10 259:1

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President 129:22

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142:5

presidential 130:1

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221:9

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107:12 137:18 161:16

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print 258:2

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266:10 269:10

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13:16 15:17 28:5

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204:2,4,7 225:4

226:12 233:6 237:20

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262:21 274:3 277:16

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217:1 235:15,20

263:3 268:6,20

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220:12

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44:1,19 61:17 70:14

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179:14 242:5,8

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16:6 18:17 29:8 33:9

33:17 34:11 35:3

36:18 39:12 46:5 49:7

59:16 62:11 70:13

81:3 84:19,20 113:8

137:9 139:18 148:9

148:11 154:20 165:9

167:3 181:17 182:4

182:10,11,14 187:14

188:3,11,14,17 190:4

199:21 200:10,16

202:14 203:17 204:15

205:16 206:8 208:12

215:12

processed 120:7,10

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70:22 273:21

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producer 4:13 19:8

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products 57:18 63:1,13

64:1 65:6 70:7

professional 32:22

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8:8 9:9 16:15 17:1

23:15,22 24:8,9 56:5

62:9 68:21 69:15 75:8

77:7 80:8 84:17 85:13

85:14,15,17,18 86:9

86:10,15 88:17 91:18

100:13,22 105:8,8,10

120:6,10 123:3,4,13

128:16 135:7,8,8

147:12,12,14,19,19

177:8 179:8,9 189:4

190:9 253:21 261:13

261:21 264:8

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105:2 120:3,17 121:2

122:22 135:9 145:14

180:13 182:13 261:3

265:15

progress 13:5 14:7

48:13

project 25:22 37:20

61:18 180:17 211:8

211:20 262:17 263:6

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projecting 146:22

180:7

projection 171:1,4

172:20 180:20

projections 44:8 143:2

180:4,21 181:21

200:1

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272:12 274:2

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62:10

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191:10 192:5,7

200:15 204:10 206:15

206:22 207:16 216:2

219:3 223:22 224:16

229:17 233:12 243:9

246:12 247:19 250:3

250:14

proposals 72:22 73:9

205:2 224:6

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146:10 147:5 154:19

164:7,12 186:13

188:21 189:9 204:16

204:18 205:7 217:1

217:14 218:1 251:4

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165:11 214:21 215:11

239:6 263:3

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36:2 37:12 49:5 172:1

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198:21 265:14,16

272:3

provided 45:16 182:10

198:19 253:14

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177:19 194:3 231:17

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277:3,17

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93:12 94:22 95:17

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192:6

publishing 114:19

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171:9 195:11 218:21

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Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
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237:19

purchased 234:16

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purely 211:22

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177:22

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75:18 223:21

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pushing 197:3 205:10

205:20

put 6:19 7:8 14:13

32:13 37:4,15 50:2

52:3 79:1 81:8 106:6

112:14 113:16 117:7

121:16,22 126:1

134:3 135:7,19

160:19 170:1,3,8

175:17 177:3 188:22

190:2 191:20 193:11

200:1,3,9 208:13

223:13,16,19 224:6

250:3 266:5 270:6,13

271:20 277:8 278:12

puts 230:4

putting 100:8 175:13

176:3 224:15

Q

QAC 29:19

QACD 26:13,15 36:9

49:7 148:22 214:16

217:2

QAS 60:1 76:1,18 79:6

QAS's 60:5

QASs 76:14,21

qualified 53:15

qualitatively 47:9

quality 1:11 2:5 12:20

26:7,11,17 41:1 42:11

60:1 61:12,14,15

quantification 63:4

quantify 63:10,13,21

66:3

quantity 160:2

quarantine 48:22

quarter 73:10 87:11,15

87:21 88:5,13,14 89:6

89:21 90:1 104:21,22

105:3,12 106:7,14

123:15 124:14 135:2

question 7:9,14 8:5

25:6 35:16 38:14

39:15 50:3 72:9,16

73:21 83:7 88:12 91:2

95:8 96:20 116:20

127:4 137:22 138:3,9

149:8 163:2 170:13

178:14,22 180:12

181:13 184:12 185:12

186:5 188:6 192:11

192:16 197:20 200:11

202:16 210:19 212:4

212:16 213:6 220:4

222:8 223:11 231:19

232:6,15 234:2

questioning 246:19

questions 11:19 18:14

18:15 25:8 26:5,5

27:1 35:7,9 38:9

47:20 52:1,19 57:12

59:4 71:9 76:22 81:5

82:3,5 89:17 91:14

97:8 98:5,11 99:10

103:6 105:12 109:12

111:21 119:18 120:1

120:22 123:17 127:1

130:15 132:19 133:20

136:5 137:16,20

149:14,19 150:7,22

154:7 162:21 164:8,9

164:19 166:9 167:19

170:5,6,8,18,20

183:20 185:16,20

192:1,3 195:1 210:7

212:22 218:22 219:22

220:2 255:21

quick 6:7 26:13 32:10

75:14 162:15 205:13

206:10 251:12 277:17

quicker 241:20

quickly 99:21 147:9,10

161:9 203:7 269:20

quite 10:15 23:20 36:12

156:4 180:18 184:14

188:2 198:18 248:5

quo 219:6,6 243:10

quorum 6:4

quote 50:8

R

rail 114:21,22

rail-loading 270:5

railcar 254:4

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raise 7:20 83:21 175:7

176:8 186:11

raised 197:20

raises 142:17 202:4

raising 175:6 209:12

264:14

Rambur 1:17 4:19,19

170:21

ran 95:8 152:11

range 67:13 68:12,18

215:22 227:4

ranged 197:11

ransomware 269:19

rapid 32:21

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rate 37:1 91:19 92:8,9

92:10,12,15,20,20

93:18 94:4,7 95:13,15

102:8 110:19 115:3

118:13,16 119:2,6,9

119:11,12 120:8

123:7,9,11,17,20

124:13 125:10,16,17

126:5,8,10,12,15,17

127:1,13 130:22

131:2,4,11,14 132:14

134:20 135:4 136:7,8

136:15 137:3,12,13

139:4,5,21 141:21

144:18 159:19 184:16

189:20 201:6 203:2

205:12 210:17,17

211:22

rates 91:21,22 93:15

114:19 115:5 117:22

118:1,8 119:6,18,20

120:14,15,17 122:16

122:19 124:2,4,12

131:3,9,16 136:12

141:19,19,20 142:12

142:14 143:18 145:4

154:15 160:16 161:14

183:1 200:18 201:4

205:11,13 208:19

211:7

rationale 172:6

re-grade 235:2

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reactivated 56:8

read 73:19 252:8

reading 158:13 237:13

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ready 50:18 54:6 59:8

64:6 151:21 214:5,5

214:13 248:16,19

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267:14,19 274:18

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201:7 230:18

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175:5 177:6,14

178:14 271:2,6

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34:5 36:3 37:19 39:19

43:3 51:16 76:3 78:5

79:6 111:1 116:12

125:19 126:3 137:11

147:10,17 151:9

153:19 156:5 160:9

161:5,6,16 162:6

163:19,22 167:5

173:14 186:22 197:21

202:5 203:20 205:9

213:20 246:3,6

247:15 249:5,21

260:18 262:3 264:19

266:15 275:10 278:12

reason 84:2 123:19

211:20

reasonable 148:4,12

203:14,15 204:5

236:16 245:6

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83:2 88:21 93:2,9

113:15 118:7 129:12

180:1 183:5 189:5

190:1 191:12 193:5

193:14,20 196:5

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103:16 130:21

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130:14

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127:19 141:7

receive 14:13 33:2

45:22 73:8 82:9,19

194:16

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251:20

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153:5 157:1 159:1,4

159:10,19 160:21

161:7,15 166:2,17

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recommendation 10:8

14:9 16:2 167:1

171:22 198:17 210:13

213:9 275:21

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9:13 26:21 58:16

159:17 162:1 167:20

198:11,22 226:7

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
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160:17,22 161:15

166:2

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154:20

record 6:21 8:3,14 34:5

42:1 44:6 50:14 81:12

81:15 84:14 150:12

168:9 191:19,21

213:14 251:20 278:22

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55:14

recordkeeping 30:10

31:4

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131:3 148:5 173:10

177:18

recovering 23:8

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159:20 216:17 218:11

218:19 254:10 255:2

262:13

reduced 99:17 118:16

118:18 124:12 127:15

161:18 205:17

reduction 88:20 89:1

96:11,15,21,22 99:18

102:1,12 104:12

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206:2

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44:14 46:4 60:21

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224:19 247:4

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12:6 14:10 24:12

228:7

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119:13 140:9 150:2

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48:13

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50:21 95:18

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registration 28:17

48:14 49:2,3,6,9 50:6

86:9,9 132:1

Regrade 235:5

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243:16

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125:5,7 189:14 211:4

212:16,20 214:21

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224:11 225:5

Reilly 2:7 48:3,4

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132:5

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132:8

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related 25:15 31:6

45:13 48:19 83:11

109:5,7 123:7 181:3

274:9

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240:22 252:9 253:2

258:3 260:2

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261:11

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111:1,7

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81:21

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227:19 228:7,10

229:15 241:8,9

244:17

replaced 218:18 221:21

221:22 231:2

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229:20

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224:15 227:4 245:4

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115:2 205:2

REPORTER 81:12

214:10

reporting 113:5 115:10

115:13,15,16,19

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243:6

representation 121:7,7

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171:17

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4:17,22 5:3,20 8:4,13

30:10,18

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74:8

repurchase 229:4

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186:2,11,20 187:8

198:8,8 199:11

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50:20 53:20 163:14

190:2

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195:17

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49:12,17 52:15 55:20

140:4

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62:16 217:7

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196:6 221:3

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165:17 215:2

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73:3 152:9 161:21,22

163:22 164:2 166:12

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143:13 145:13,21

146:21 172:8 173:11

178:18 184:8 196:9

196:18 198:3 201:17

211:18 212:5,10,19

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181:4

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101:6,13 104:15,17

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Neal R. Gross and Co., Inc.

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73:17,17 79:1

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76:18

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89:15 100:6 102:4

105:2,19,22 131:2,7

131:15 132:3,9,12,12

132:15,17 141:12

142:3 181:3 189:22

191:6,7 211:17

231:17 263:18,19

review 9:12,22 46:5,6

58:2 59:19 61:10

67:21 69:4 78:19

80:19 86:12 92:13

93:7,8,19 94:13 95:14

97:20 100:11 101:9

103:2 106:21 112:2,4

121:3,4 133:22

153:16 154:3 167:15

168:8 176:1 177:7

178:22 179:7 191:13

196:8 198:5 199:22

200:8 211:5 212:17

245:16,17 246:14

250:22

reviewing 13:17 151:13

188:15

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114:7 131:2 217:2

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revised 45:7 155:3

157:3,14 170:1

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revocation 33:19 38:11

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66:9,15 71:15 85:4,16

99:14,16,17 105:8

120:21 123:1,2,13

124:6 125:4,6,7 147:1

147:8,20 200:14,16

201:16,19,21 202:14

202:19 204:17 205:3

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15:13 28:12 31:20

34:1 35:6,20 38:16

59:9 62:5,20 64:5,8

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68:22 69:2,10 71:20

74:3 75:11 80:16 82:1

86:13 87:11 88:8

95:22 106:7 119:20

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126:9 133:12,19

134:8 135:9 136:13

139:1,5,13,14,16

141:4,9 143:11 150:9

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169:18 172:18,22

174:1,12,13 181:22

185:4 186:1,6 188:9

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201:20 207:21 213:12

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235:21 237:2 239:17

248:14,14 251:15

256:16 260:17 264:1

272:6 273:9,14,16,19

274:2 276:18 278:11

right-size 146:21

right-sizing 99:19

ringer 278:13

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219:13

Rob 44:1

Robert 1:16

robustness 62:15

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57:10

roll 3:13

rolled 43:17 115:17

155:14

rolling 93:4 95:16 96:7

96:9 97:18 106:5,10

106:15,18 107:6

117:6 137:6,10

143:12 144:16 177:2

182:5 185:2 196:11

room 19:17 21:12 79:17

81:11 99:12 107:22

150:3 181:15 183:21

202:21 207:6 251:12

251:14 263:16 267:6

rough 221:6

roughly 19:5

rounding 98:17,17

route 161:10 173:9

row 72:2 159:2

Ruggles 1:10 81:18,18

83:6,10 84:2,5,11

85:10 89:22 90:9,13

91:6,10,13 95:7 100:4

103:13,15,18 104:10

105:15,18 106:2

107:19 108:14 109:21

110:4 111:17,21

114:1 115:20 116:2,6

116:9 117:2,14

119:17 124:7,11,17

124:20,22 127:11,17

128:6 129:6 133:6,11

133:13,20 137:21

138:2,7,15 140:3,11

140:13,15,17 143:3

143:10,17 144:4,8,14

146:5 147:8 148:18

171:3,11,21 172:4,9

172:12,15,19 173:1

173:18 174:6 184:1

185:4,6 188:18 193:4

212:15

rule 10:9 12:4,18,21

47:2,6 93:2 100:10

184:1,2 188:19,21,21

189:4,9,12 190:3

212:7

rulemaking 117:12

181:18 182:10 210:22

211:12

rules 77:16 232:17

run 3:19 46:14

running 8:18 23:5

rural 36:15 269:16

Ryan 214:4,5,7,13

220:2,5 222:7 223:17

233:5 240:16 245:9

246:14 250:19

Ryan's 214:10 239:5

243:9

S

S-E-A-P-Y 214:12

sacrifice 128:14

safety 48:18 53:18

153:2 156:18 158:4

161:2 165:14,19

168:22

sake 234:13

salad 64:22

salaries 108:17,21

110:5,8 111:9 129:21

130:9 133:2,3

salary 127:5,6,8 133:14

sale 243:22

sales 174:12

sample 45:18 46:1

65:17 67:4 215:12,19

234:8,8 235:5 238:13

samples 44:16 46:9

59:20,20,21 67:2,6,9

69:3,13 78:7 231:14

248:20

sampling 24:9 215:12

221:1 226:13 227:16

sanitary 58:6

sat 259:9,10

Saturday 52:17 56:1

138:6 139:12,15

save 192:2 263:19

saw 114:12 127:17

129:20 196:17 197:10

197:13 207:15

saying 58:1 118:10

161:17 162:4 175:10

186:2 224:5,14,19

233:20 243:10,11

247:12

says 14:17,17 48:8

123:9 193:16 224:9

276:14

SB&B 4:11

SBOC 51:8 57:11

scale 32:3 67:6 216:7

216:11,16 220:19

221:13,14,20 222:16

223:15,15 227:10

231:12 239:3 240:9

242:6,9,10 244:21

258:13 270:5

scaled 268:12

scales 214:6,17 215:1,3

215:7,11,21 216:1,14

217:1 218:8,10,13,14

218:16,18 219:15,16

220:16,21,22 221:5

222:1,4,10,12 223:12

225:1,10 226:16

227:2,3,7,19,21

228:10,15,17,22

229:1,5,14,21 232:2

234:16 236:4,4,8

242:5 244:6,7,17

245:1,3 247:22 248:6

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
304

257:14,17,19,21

270:7

scanned 256:17

scanning 129:10

scenario 121:20 122:6

122:14,17 123:5,6,14

124:6,10,18,20 134:2

134:2,5,9,19 135:1,3

135:11,15,16,18,20

136:6,22 137:1,2,2,2

140:19,20 141:1,18

143:19 144:4,7

146:14 147:4 158:3

171:4,20 172:1,4

173:19 176:17 179:16

185:5,6

scenarios 123:17 134:1

134:6 135:10 136:5,8

137:12 140:18 143:18

146:10 147:5 152:17

171:10,12,14,16

172:8,10,13,16

184:16,21

schedule 29:10 39:16

86:13 94:18,18 149:9

149:21 181:19 182:21

191:13 197:16 198:6

210:12 277:1

scheduled 55:3 262:1

scheduling 138:16,21

259:9 264:9

science 1:13 2:8 16:9

40:21 45:22 59:7

scientists 64:18 72:10

scope 71:7

Scoular 5:14

screen 79:2 155:9

170:11 196:1

screenshot 46:19

scroll 199:1

scrutiny 153:13

Sea 66:12 67:14 69:4

sealed 165:16,18

seamless 39:1

Seapy 214:12,15 220:8

222:15 223:1,6,8

245:11,17

searches 64:12

season 136:3

second 64:9 93:20

113:4 124:22 187:6

188:6 237:2 243:19

second-sized 147:12

Secondly 35:16

Secretary 148:12 186:4

Secretary's 204:2

section 7:17 94:13

98:13 193:8,8 245:14

sector 58:15 247:10

secure 252:13 254:16

255:17

securely 270:10

security 24:19 25:2,10

25:11,15 43:10 253:9

253:14

see 6:2 8:16 9:1 13:21

21:2 31:22 40:4 44:4

48:6 55:5 67:10 80:11

81:2 82:22 86:16,19

86:21 88:1,17 89:2

95:20 97:10 100:13

101:13 104:18 107:2

108:16,21 118:18

119:21 130:2 131:5

134:22 135:6 140:5

142:19 145:5 151:16

164:18 166:11 175:4

176:14 177:1 196:1

203:1 205:8,14 210:2

211:8 229:18 234:10

242:19 249:12,22

253:20 260:5 268:20

272:3 278:16

seed 51:1

seeds 50:22

seeing 27:21 30:3

32:12 42:16 101:16

127:19 228:3 259:3

seeking 253:17

seen 19:6 71:22 154:18

155:6 164:14 182:16

187:18,19 196:22

215:16

select 54:19

selling 237:22

seminars 57:5

Senate 186:3,14

send 54:6 55:11 186:19

262:1

sending 69:13 259:14

senior 20:3

sense 55:18 139:22

140:8 163:17,19

167:17 200:14 224:10

234:14 244:18 245:8

sensitive 164:4

sensitivity 63:21

sent 24:11 32:7 45:19

55:15 225:12

separate 53:10 62:17

72:16 140:14 217:10

218:3

separated 117:11 193:9

separation 215:20

separations 215:14

September 18:19 47:5

55:6 88:9 112:12

203:16,20 207:22

sequence 64:21 65:12

sequences 65:16

sequencing 65:13,14

65:18 66:1

serious 32:17 101:15

serve 10:5 40:16 47:17

70:10

served 19:21 21:8

38:19 42:4

server 53:12

serves 42:9

service 9:19 11:16

14:12 16:14,20 22:5

23:16,18 25:18 35:18

36:1 39:6 41:4 45:9,9

47:12 91:21 94:13

101:7 109:9 110:9

111:13 118:1 131:4

131:17 140:4 154:11

154:12 157:19 158:1

161:4 177:19 181:11

194:3 252:18 253:11

265:14

serviced 230:2

services 52:8 57:6

59:14 69:18,21 70:1,6

86:2,3,8 87:19,19

109:6,11 110:13

111:1 112:8,12,13,19

115:1 116:15 121:10

121:17 122:5 125:11

131:18 132:5 175:7

197:1

servicing 123:22

serving 19:14

sesame 51:1

session 53:19 57:4

81:16 213:20

sessions 54:3

set 23:7 25:21 68:9 92:5

156:12 175:16 184:7

189:18,20 212:5,11

225:13 271:18 272:1

sets 219:14

setting 277:10

settings 94:17

settlement 132:22

seven 98:8 102:10

127:6 128:13 226:12

228:6

Seventy-two 128:22

shaking 168:9

share 12:19 15:22

25:21 35:8 38:7

141:20 145:12 151:8

151:10 155:4,9

201:11,12 207:19

253:16

shared 43:3 196:20,21

200:19 266:7,7

shareholder 255:9

sharing 128:10 148:15

155:10 195:18 273:5

Shay 4:19 170:21

Shayleen 1:17

Sherry 20:16

shift 28:20 29:13

138:12,13

shifts 107:2 112:19

128:14 138:11 145:17

146:2

ship 92:9 112:11,20,22

shipments 49:20 112:9

152:15

shipped 92:10,12 94:3

ships 116:11,18 141:14

shock 236:17

shockwave 176:10

shoes 21:16,17

short 64:6 105:22

267:19,19

shortages 100:19

101:10 104:12

shorter 159:15

shot 236:17

shouldering 146:12

show 96:18 103:10

115:6 127:5 130:8

131:1 189:13

showed 73:17 178:9

showing 173:8

shown 161:7

shows 31:5 43:20 66:21

108:18 118:22 127:8

171:9 231:11

shrunk 155:22

shut 6:9 40:3 208:13

shutdown 39:21 40:1,4

55:4 173:4 174:22

179:14,14

shutting 202:6,7,8

shuttle 5:11 231:15

234:22 235:10 240:8

259:8

shuttles 209:4

shy 18:11

side 64:16 146:13 201:1

252:2 254:6 258:20

264:4 273:12,22

side-by-side 152:4

sides 260:2 270:18

signal 7:11

significant 174:13

215:18 216:7 244:13

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
305

246:5

significantly 89:8

127:17 147:18 180:22

218:19

silent 6:10

Silvey 28:4

similar 64:11 99:14

137:9 182:14 188:14

201:3

simple 162:1 207:10

271:4

simplified 68:6 260:18

simply 43:7 157:12

158:7 162:1

SIMS 26:17

simulation 67:17,18

Singapore 56:17

single 67:19 261:14

Sinner 1:16 4:11,11

107:14 116:19 117:13

143:1,4 176:16

sir 73:11 155:11

sit 203:12 230:21 238:5

site 33:4 219:20 220:18

220:20 222:12

sites 220:10 221:4,5,8

222:5 236:9

sitting 146:11 237:9

situation 27:14 32:17

33:3 39:9 152:19,20

158:18 177:4 188:14

201:15 234:5 236:6

268:10

situations 238:16

six 27:22 28:16 53:22

58:18 92:11 99:20

118:3 127:6 138:12

138:12 226:12 228:6

230:8

six- 147:6

six-month 145:14 196:8

six-tier 92:8

six-year 147:2,6

Sixty-four 131:8

size 215:19 246:1,4

sketch 255:19

skilled 27:18

skills 37:8 54:4

skyrocket 184:5

slack 152:19,19 154:16

162:3,4,7 163:18

slide 18:14 30:16,19

36:6 64:10 82:2 91:11

127:5 137:18 171:9

179:22 184:16

slides 32:14 34:16

75:19 127:4 170:19

196:17 206:18

slow 82:2 103:20 195:8

small 17:15 24:13 75:4

125:20 177:9 215:13

216:21 233:7 246:4,4

250:10 268:1,9

smaller 201:6 215:15

221:19 249:22 278:10

smallest 246:1

smile 21:13

smiling 212:9

smooth 205:21

smoothed 206:6,7

socialize 203:1

soft 60:16

software 64:12 260:7,8

260:14 261:3,9,18

sold 217:19,20

solicited 66:6

solutions 274:21

solvent 209:1

somebody 6:18 7:5,12

78:10 125:22 139:19

149:22 150:4 209:4

217:4 232:20 233:19

240:19 269:5,21

270:20 272:8,17

276:13

somebody's 246:19

259:17 260:1

something's 114:8

someway 256:20

somewhat 205:18

229:16

soon 18:11 21:21 34:14

39:3 45:1 48:9 167:4

204:4 207:3

sooner 175:22 230:9

sorghum 48:20 246:7

sorry 3:18 11:12 73:13

77:15 137:17 144:13

155:16 168:6 223:1

246:11

sort 198:16

sorting 17:9

sounds 146:21

source 49:9

south 5:19 55:12 56:17

83:12 111:2

Southeast 56:5

soy 176:22 245:21

246:2,8

soybean 51:10,20

58:19 59:21 60:3 65:9

194:9 229:1

soybeans 5:12 10:10

10:14,21 11:1,3,6,8

12:1 18:6 46:17,19

47:8 51:17 56:14

226:20 227:18 230:17

space 53:12 165:2

169:8 187:1

Spanish 53:5

speak 47:16 54:9,14

159:21 173:13 202:20

speaker 8:11 160:13

speakers 149:11

speaking 42:22 199:8

speaks 37:3

spear 146:12

spearheaded 76:6

spec 216:14

specialist 41:2

specialists 60:1 61:14

specialty 17:1 72:1

specific 63:21 139:7

149:10,21 154:14

183:20 223:10 247:5

257:6 265:16

specifically 51:12

146:15 152:16 153:14

162:3 170:17 214:22

215:9,17 222:15,18

252:1 254:14 256:8

268:11

specifications 52:3

70:8 216:12

specificity 30:17

specifics 256:2

specified 162:5 242:16

specifies 12:16

specs 224:10

spell 8:3 185:14

spend 14:18 15:18

154:13 210:15 267:1

267:16 268:5

spending 15:5 106:3

109:1

SPOC 47:7,10

sponsor 58:12

spot 232:2

spread 111:15 235:19

spring 60:16

stability 183:9

Stacked 64:1

staff 22:13,14 24:22

27:3,17 28:18 30:1

36:10 37:8 38:5,21

79:6 108:18 110:14

111:10 121:6 122:12

130:14 134:15,16

242:1

staffed 22:10

staffing 19:18 22:9

29:16 41:9 100:16,19

101:3,10,10 104:11

113:21 127:16 130:4

148:20

stagnant 89:15

stakeholder 206:16

stakeholders 79:9

167:11 168:1 198:20

199:19 200:5,8

202:22 207:2,19

255:16

standard 75:4 122:15

123:6 125:2 126:13

215:10 216:9,16

217:8,10,11,12,14,17

218:1,4 220:15,17,20

224:20 245:5 271:8

271:17 273:5 276:11

standardization 62:4

255:15 273:17

standardized 261:2,16

261:18

standards 9:15 57:5

61:15 82:21 84:6

85:12 188:13 193:6

212:6 214:20 215:8

216:19 217:7,10

225:5 226:5 229:13

246:18 248:9 251:9

253:19 270:12

standing 39:5 121:1

standpoint 23:4 166:17

264:16

stands 64:5

start 3:13,16 8:8 15:15

20:12 23:17 24:14

29:17 52:17 85:1

112:4 113:13 150:2,5

150:9,14 176:3

193:13 195:13 200:10

205:16 228:11 231:7

234:15 237:10 269:13

275:15,18 276:21

started 33:1,2 36:10

39:9 89:1 99:18 113:1

154:10 234:22 237:21

239:9,13 269:21

starting 29:8 88:20

94:12 100:2 228:5

238:22 245:16,17

276:19

state 3:14,19,20,21 4:7

8:2,12 99:22 185:13

206:21 217:6,7,11

224:10,11 225:5

241:2

statement 161:17

248:12

states 1:1 24:3 86:4

246:20

stations 222:18 223:7

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
306

statistical 67:12 68:8

249:16

statistically 240:20

statisticians 67:16

statistics 233:8,16

240:18 241:10 243:15

status 22:8 181:6 219:5

219:6 243:10

statute 33:12,13

statutory 177:18

stay 25:17 43:8 89:14

165:16,18 188:4

201:8 202:11 248:20

stays 90:16

steady 89:3 171:2,7

step 66:2,16 162:12

164:17 174:15 210:20

211:10 258:8,9

270:21

stepped 6:15

steps 26:18 125:8

166:22

stick 166:20

stomach 176:9

stood 69:22 71:19

stop 190:3 262:17

stopped 235:12 262:17

262:19

stops 54:15

stowage 31:6 53:9

91:22

stowages 131:19

straight 132:6 144:3

184:22

strand 64:17

strategic 180:6

strategy 16:3 25:13

stream 231:17 272:6

streamline 14:6

streamlined 49:8

streamlining 70:22

streams 88:11 257:6

street 36:14

strengthen 23:22 25:13

strides 28:2

strive 272:2

strongly 248:15 249:8

stuck 125:1 183:13

studies 62:14 73:5

269:9

study 36:7 53:21 62:17

67:1,9,22 73:14,16

stuff 62:20 134:17

190:22 209:22 268:8

276:2

subcategories 31:15

subcommittees 278:5

subject 183:3

subjects 53:7

submission 73:3

submit 19:10 80:18

submitted 82:15 152:4

164:9 191:10

subsequently 39:3

substantially 228:16

substantiated 46:15

subsurface 153:1,17

156:19 157:21 158:7

158:8,11 159:1,3,9

162:5 163:18

success 179:20 272:17

274:1

successes 272:13

successful 24:16 25:4

33:7 74:15

sudden 209:10 253:15

suddenly 141:13,14

suffered 235:16

suggest 183:5

suggested 36:21 52:1

55:15

suggesting 174:17

suggestions 210:6

suite 69:22

sum 229:7

summary 151:18 207:4

summit 16:18 18:1 80:4

274:12 275:6

Sunday 140:10

sunflower 230:17

supervision 14:16

85:14,16 86:3,6,15,20

87:1,5 88:9 94:5,5

105:7,18,22 202:1

supervisor 258:5,6,6

supped 259:2

supplementing 92:16

supplies 110:20

supply 252:11

support 18:9 27:2

61:11,14 66:9 76:3

110:14 194:14 218:4

supported 60:18

191:12

supposed 55:17 113:20

155:4 178:17,17

179:5

Supreme 4:16

sure 6:2,9 7:4,11 8:12

11:10,22 15:9,19

23:20 26:1 90:6

125:21 148:9 149:18

167:19 168:2,17

169:14 170:22 174:20

176:12 180:18 185:13

187:21 198:17 202:10

203:9 209:7,8 235:3

236:1,20 238:6 241:3

241:15 242:17 245:5

248:18 258:8 263:1,4

264:13 266:1 267:2

268:10

surface 153:17 157:21

158:6,8,11,16,22

159:3,9 162:4 165:15

165:21 166:3

surplus 101:20,20

102:2 142:8 191:7

205:17

surpluses 205:22

surprise 210:10 211:15

surrounding 39:4

surveys 25:18 194:9

survives 173:16

suspect 80:20 120:11

249:8

suspend 33:9

suspension 38:15,19

39:10

sustainability 28:7

swallow 177:21

Sweden 66:13

swings 124:1 145:16

177:10 181:18

switch 65:5 228:5

230:13 237:16

switching 244:9

symptom 182:3

system 25:16 32:3 60:8

61:8,13,13 62:8 64:18

69:12 72:20 77:10

112:14 115:13,15,16

139:19 140:4 246:19

254:7,12 256:5,11,21

258:7,14 259:18

261:6 262:7,12

264:21 265:17 268:3

268:14 272:16 274:15

275:1

systems 25:4,10,10,15

66:7 252:16 253:6

254:17,18 256:22

257:4 263:10 264:6

269:22 270:1 273:21

T

table 3:15 133:16

151:11 153:2,13,14

154:3,6,14 155:3,7,10

156:6 157:4,12,14

158:15 160:6 162:9

163:16 164:12 165:17

167:8 172:7,17 189:2

190:11 243:8 277:19

tables 133:14 189:8

190:10,12,19

take 6:13 13:19,21

18:13 38:8,16,22

41:16 53:12 54:2

64:10 71:8 76:22 77:1

77:2 81:7 84:12 93:15

104:5 116:14 121:12

126:12 142:21 156:6

162:16 165:5 167:7

172:1 174:15 179:1

185:12 204:6 209:4,5

210:19 212:14 222:8

227:6 230:1 243:4,5,5

251:14,14 258:6

272:16

takes 125:14 126:10,11

190:12 209:22

talk 7:6 48:10 52:7

55:12 56:19 59:2,10

59:11 90:21 93:8,21

94:1 113:18 127:22

148:20 149:16 171:15

176:11 196:14 197:14

213:8,20 255:1

264:20 270:17 277:11

278:1

talked 18:4 56:13 77:5

79:17 94:17 117:8,8

134:1 162:13 171:14

176:7 193:21 195:7

200:16 209:7 247:12

251:22 277:5

talking 6:18 25:1 57:18

75:16 122:20 130:3

174:9 184:2 185:22

187:10 194:5 197:21

203:14 211:16 214:16

223:2 228:15,17

234:6,15 255:10

256:22 259:12 272:21

274:20

talks 126:18 197:9

tanks 162:4

tap 257:13 271:13,13

tapes 32:3

target 64:13,15,17 65:3

145:13,14,15,22

156:22 178:18 196:9

targeted 269:17,18,19

taskforce 248:9

tax 50:13

taxing 266:19,19

team 121:5 134:9 151:3

152:2 275:4

teams 53:2 78:14

teary-eyed 21:7

Tech 16:18

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
307

technical 57:16 58:7

63:8 85:8 169:9

technician 228:17

239:3

technique 65:15

techniques 63:4,6

technologies 74:18

80:8 254:20 255:1

technology 1:13 2:8 3:9

3:18 4:4,5 16:1,3,4,6

16:9 17:4 18:5,9

24:22 25:18 40:21

45:22 55:20 59:7,12

61:6,11 63:11 64:8,11

65:12 66:5 71:14,19

72:18 75:15,17 77:5

79:13,18,20,21 80:4

149:3,4,5 194:2,5

209:19 237:6,14,17

237:22 238:4,7

251:22 252:4 257:13

274:9,12 278:9

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(202) 234-4433 Washington DC www.nealrgross.com
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(202) 234-4433 Washington DC www.nealrgross.com
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82:16 83:2,3 84:14

88:6 94:16 100:11

103:5,21,22 104:4,6

104:12,12,14,15

109:15 113:19 128:1

129:3,6,11,14 138:10

141:4 149:1 154:9

155:6 156:8 162:2,2

174:15,20 181:4

183:14 187:10,18,19

192:20 193:14 195:17

197:17,21,22 198:6

198:13,14 201:20,21

201:21,21 203:7

213:15,15 238:3

239:17 245:18 255:10

263:4 264:14 266:8

267:4 277:5

webinar 19:3 34:21,22

website 34:22 43:5,12

50:18 104:22 155:6

Wednesday 1:4

week 20:9 43:21 54:12

54:20 58:8 114:19

128:13 156:13 214:7

245:13 250:20

weeks 20:2 40:6 56:1

112:6 116:17

weigh 168:8,21 242:19

weighed 83:19

weighers 257:16

weighing 5:5 61:8

85:13,21 88:17 91:18

131:19 196:7 197:1

215:13 218:3 225:22

weight 219:14 239:3

254:7 259:15

weighted 121:18

weights 207:12 217:16

217:17,22 219:5

232:10 234:20 240:2

240:4 242:10 243:21

244:3,8,10 256:7,9

257:19 260:22

welcome 3:6,11 276:20

well-received 61:4

went 33:8 39:1 43:16

45:2,7 53:20 56:9

81:15 84:2 92:12 93:1

93:2,13 147:10

150:12 157:7 179:13

184:8 239:11 241:19

251:20 278:22

weren't 92:15 128:10

177:11 183:7 243:1

256:9

wet 54:9

Whalen 1:11 2:5 26:6,9

38:14 39:18,22 42:14

whatever's 133:15

whatnot 254:15

wheat 4:15 18:6 54:21

55:5,9,11,15 56:14

57:4 58:21,22 59:21

60:3,10,14,16 63:16

71:12,15 194:10

215:16,17,21 216:21

222:1 226:17,20

227:6,18,20 228:7,12

228:13,22 230:14,17

233:6,21 234:6 235:1

236:3 246:7

white 60:16

wholly 191:12

wide 54:13 124:1

145:16 185:7 227:4

widely 63:19

widespread 237:3

Williams 1:19 5:6,6

20:16 91:3,12 127:3

127:12 212:3 220:4

249:3

willing 162:14

window 218:10 244:22

windows 154:5

winter 60:16

wish 22:5 128:10

wondered 75:4

wonderful 42:12

wondering 115:18

word 167:6 237:2

wording 247:4

words 84:1

work 5:17 16:4 18:10

25:2,8 27:8,10 40:7

70:14 84:16 119:8,12

119:15 128:13,20

129:2 139:2 156:8

169:9 188:1 190:21

221:10 240:1 253:1

254:13 259:20 260:18

263:6,7,9,12 264:6

266:21 271:19 273:4

worked 10:17 29:5

32:17 38:21 39:2,4

45:8 46:20 52:6 53:14

83:17 139:21 205:12

workforce 210:14

working 11:15 13:12,14

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
311

20:2,20 24:21 25:12

31:19 36:20 50:3,6

54:22 55:7 128:9

138:10 139:9,10,10

139:15,20 174:19

182:16 202:9 242:22

253:10 264:11,12,20

264:21 266:12 270:21

273:21 274:5

workings 253:8

works 12:14 28:14 35:3

64:11 138:12 202:15

258:1 265:3 271:8

workshops 57:6

world 160:10 238:12

worried 176:19

worry 52:2 139:9

worth 264:17

wouldn't 23:7 98:8

128:12 130:2 135:13

139:8 204:2,4 218:3

221:3 229:3 238:8

239:14

Wrap-Up 2:11

write 149:14 223:22

write-up 217:4 252:7

255:4

write-ups 277:20

written 123:9 164:8

217:3

wrong 237:12 242:2,10

X

Y

Y 67:5

yeah 75:19 79:15 84:7

90:13,13 91:10

103:18 110:1,1,2

111:17 124:11,19,21

140:7 143:10 144:5

145:10 146:6 151:15

152:7 155:18,19

166:20 167:9 168:11

169:1 171:21 172:22

184:16 185:10 199:12

202:12 207:8 210:9

218:16 220:8 235:4

236:1 241:13,14

242:1 245:12 257:7

257:20 258:17 262:18

266:4 270:22 272:4

273:10 274:2 275:20

year 9:1 10:12 13:7

14:8 16:7 19:3 20:17

22:10 23:14 27:16

29:12,18 32:16,17

38:7 44:7 47:1 50:15

52:6 53:1,14 54:17

56:3,3,7,8,9,15 58:18

59:13,18 60:9 62:6

65:21 66:6,10 69:18

70:12,15,16 71:4

72:17 73:10 81:20

87:20 88:14 89:1,11

89:14 90:3,4,5,14

93:11 94:12,14,18

95:1 96:14 97:1,2,5

101:9,18 102:1

103:15 104:18 106:8

106:14,15 107:9,10

107:10,12,13 112:19

112:21,22 113:1,2

118:21 121:4 123:2

125:1,9,14,15 128:2

129:17 130:5 135:21

142:11 145:14 146:14

147:7 149:2 163:4

173:6,17 177:5,8,9

179:6 185:8 186:16

187:14 191:3 193:2

196:13,15 204:3,7

206:3 208:6,6 237:2

237:20 244:22 258:12

258:22 272:2 277:15

year's 11:11 28:1 44:8

129:22 141:5,17

193:2

yearend 204:1

years 4:3 10:12 21:9

26:12 28:6 30:6,18,22

31:19 36:9,13 41:3

48:7,7,12 57:2 63:7

63:17 73:12,13 76:13

81:20 87:17 90:6

95:15,16,21 96:2

97:11,17 99:14,17,21

106:18 107:5,7 123:1

127:7 128:1 130:11

142:21 143:19 144:1

147:10 155:21 171:2

174:3,11 175:2,22

178:5,6 179:12 180:3

182:8 189:1,8,10,15

190:5,6,14 195:18

197:14 205:18 206:4

208:12 211:21 239:1

244:22 267:8

yellow 11:2 86:16

Yep 140:17 258:18

yesterday 21:4 35:3,4

108:9 277:12 278:2

Z

Zen-Noh 4:9 146:7

zero 67:5 178:10,11

0

0.33 184:20

0.58 184:22

01 75:2 225:14

03 216:3

1

1 95:1 98:18 129:14,16

131:14 132:8 135:12

135:17 140:22 142:10

174:7 215:20

1.1 87:3 98:18

1.2 87:13

1.4 129:15,15

1.6 88:3

1.7 68:2,13 88:3

1.98 105:10

1/10 214:18 215:4

218:14

1/100 214:18 215:5,7

10 11:7

10,000 220:7 221:15,16

249:9

10:05 81:12

100 37:2 46:13 67:19

215:14 228:11

100s 189:19

100th 31:17

10383 1:7

105 106:19

107 106:21 107:8

10th 31:17

11 31:12

11.9 98:3

110 107:8 191:3

114 107:1

12 128:13 138:11

152:17 153:19 158:15

120 134:22

122 106:20

125 246:2 249:21

129 107:1

13 53:2,2 113:9

13.7 135:19

130 63:1

135 106:22

14 54:5 88:18

15 62:7 81:10 86:18

88:18

15- 251:15

15-minute 251:17

15,000 49:18

15th 112:15

16 31:9 41:3 62:6 70:2

83:4 86:18 88:19

100:6 119:21 120:1,4

134:7 136:12 139:2,9

16- 138:11

16-hour 128:14

17 83:4 86:22 88:19

100:6 102:1 106:20

108:16

17.45 82:20 83:9

17025 70:16 71:6

177 48:11,14 49:1 50:2

18 36:19 86:22 88:1

100:7 102:11 106:22

129:15 154:2 205:14

18-day 165:17

19 86:22 88:1 100:7

102:12 107:4 129:15

205:14

1992 63:1

1996 91:17 92:7

1st 12:22 34:19 47:5

86:11 91:17 92:6,6

93:3,10,12 97:7 102:5

106:13 113:11,13,21

119:19,22 120:20

133:14 136:2,13

196:16 203:2

2

2 97:1 98:16 99:8

102:14 134:22 185:3

237:8

2,000 61:6 221:14

227:13

2.2 102:20 129:17

2.471 100:14

2.6 129:16

2.8 135:16

2.9 142:13 144:20 145:8

2/10 216:5

20 21:8 63:17 82:18

83:3,8 87:1 88:1

99:18 102:16 104:7

129:15 152:18 153:19

158:15,22 192:21

193:17

20,000 227:15

2001 190:9

2002 56:6 239:5,9

2003 190:11

2004 92:7,13

2013 184:3

2014 86:17

2015 88:21 113:15

118:7 129:13 176:2

180:1 190:2 191:11

196:4 197:3

2016 41:1 93:1 101:20

106:18 118:6 120:16

176:2 183:5 191:10

201:7

2017 86:21 88:22 93:3

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
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129:14

2019 12:9 13:2 201:5

2020 83:2 93:9 193:5,19

262:19 267:12

2021 68:16 93:11 94:12

128:22 193:13

2022 9:14 91:5 101:1

132:2

2023 1:4 87:12 95:14

97:19

2025 193:13

21 88:3 90:9,14 100:14

107:11,12 129:16

21.9 127:14

2100b 237:8

21st 33:19

22 66:6 88:5 95:22

97:21 100:7 102:21

106:16 107:13 129:17

131:6

22nd 18:19

23 43:11 59:18 65:21

70:12 82:22 96:1

100:8 106:12 120:5

120:16 134:8 135:14

171:5 184:19 192:19

192:21 193:4,12,18

23.5 192:17

24 23:14 43:14 60:11

71:4 140:21 171:6

173:20 186:16 187:15

248 48:17 49:1 50:2

25 171:7 172:2 187:16

252 2:11

26 2:5 172:2 174:1,2

276 2:10

28 132:11

3

3 2:2,3 98:22 135:12,17

140:21 142:9 151:11

153:2,13 154:15

155:3,7,10 160:6

163:16 167:8 215:22

216:1

3.3 97:7 136:14

3.4 102:17

3/10 216:6

3:15 251:17

30 1:4 19:5 37:18 75:19

81:20 227:19

30-day 277:17

30th 105:4 112:12

113:6

31st 11:12 113:6

33 127:9 147:19

33.6 108:17

360 17:8

37 4:3

39 108:16,16

390,000 88:5

3D 77:1

4

4 217:16,22 244:10

4.1 129:18,19

4.4 135:20

4.7 173:3

4.8 89:8

40 2:6 36:12 37:18 67:6

138:17

44 247:5

45 158:11 159:11

161:14 166:20

47 48:7

48 2:7 48:8

5

5 96:10 97:2,3,4,5 98:4

98:21 99:2,4,5,8,10

102:1,9,12,18,20,22

103:3 114:11 118:13

118:14,16,18 129:18

130:2 136:15 143:20

143:21 144:8,10

177:13,14 183:3

184:20 185:3 197:12

197:12,13

5.2 130:1 142:4 145:7,8

5.5 142:15 145:6

5.7 101:22

5:16 278:22

50 36:12 50:10 77:19

228:10 229:5

55 14:18 82:12 186:11

59 2:8

6

6 99:4 132:2 138:6,6,12

138:13

6.6 102:11

60 15:9 22:19 36:22

82:16 84:3 134:22

159:17 186:12 187:5

215:19 249:20

64 131:7

64153 1:7

65 131:15

7

75 27:16

8

8 2:4

8:30 1:4 3:2,3 278:20

8:40 276:19 277:2

80 68:16,17 184:4,7

188:19 189:6,17,18

189:20 191:1

80s 169:4

81 2:9

85 22:9 67:3

85,000 87:14

88 87:12

88,000 87:13

8th 16:16 18:18

9

9 135:16

90,000 88:6

944s 31:8

95 67:3,3,13,22 68:15

68:18

9th 16:17

Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com
313

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: 08-30-23

Place: Kansas City, MO

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate complete record of the 

proceedings. 

-----------------------

Court Reporter 

(202) 234-4433 

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1716 14th ST., N.W., STE. 200

WASHINGTON, D.C., 20009-7831 www.nealrgross.com