“Wo rk i n g for N eb ras k a b ee f pro du cers – pas t u re t o pl at e .” 

• 4611 Cattl e Drive • Lincol n, NE 68508 -2833

(402) 475- 2333 • Fax (402) 475 -0822 • nc@ necattlemen.org • www. nebraskacattl emen.org

April 27, 2022 

Mr. Bruce Summers, Administrator 

Agricultural Marketing Service 

U.S. Department of Agriculture 

1400 Independence Ave SW 

Washington, DC 20250 

Responding to a Notice to Trade dated April 11, 2022, entitled “USDA to Host Listening Session on Cattle 

Contracts Library Pilot Program Development” Submitted to: Wash.LPGMN@usda.gov 

RE: Nebraska Cattlemen Stakeholder Feedback on Cattle Contracts Library Pilot Program 

Dear Administrator Summers: 

Nebraska Cattlemen is a grassroots membership organization representing farmers and ranchers from every 

sector and scope of Nebraska’s beef cattle industry. Our members appreciate the opportunity to provide 

stakeholder feedback regarding the UDSA Agricultural Marketing Service’s (AMS) development of a Cattle 

Contracts Library Pilot program pursuant to Division A, Title VII, Section 779 of the Consolidated 

Appropriations Act of 2022 (Pub.L. 117-103). 

Nebraska Cattlemen believes that a Cattle Contract Library is an acceptable and necessary tool to increase 

market transparency, providing beef cattle producers with information about possible and/or available 

marketing methods that may increase opportunities to capture previously unrealized value. Our members 

strongly believe that the library should contain easy-to-read summaries of the types of contracts offered by 

meatpackers to cattle producers to procure fed cattle. However, the Cattle Contract Library should only 

report a summary of the information contained in the contracts. No individual contract data that may contain 

confidential business information should not be released to the public, and this is to avoid giving a competitive 

advantage to meatpackers.

Our members believe that appropriate information to include in the Cattle Contract Library Pilot should 

include any information financial in nature, including but not limited to freight costs associated with 

transporting cattle (e.g., “F.O.B.” or “delivered”), premiums and discounts, base price and how it was 

established, and final price. Additionally, contracts that are no longer offered by a meatpacker to a cattle 

producer should remain available for review but must be clearly labeled as “inactive.” Contract types included 

in the library should be aggregates of individual contracts with similar terms. Further, contracts that cover an 

unspecified volume of cattle or allow for a nonspecific delivery time within a broad period (i.e., “open 

contracts”) should be reported and maintained separately. 

To further emphasize our members’ desire for confidentiality, we firmly believe that in establishing and 

maintaining the Cattle Contract Library Pilot program, USDA-AMS must adhere to relevant statutory and 

regulatory requirements and longstanding USDA-AMS guidance related to confidentiality. In the event an 

individual contract is reported to the Agency but cannot be reasonably summarized with similar contract 
“Wo rk i n g for N eb ras k a b ee f pro du cers – pas t u re t o pl at e .” 

• 4611 Cattl e Drive • Lincol n, NE 68508 -2833

(402) 475- 2333 • Fax (402) 475 -0822 • nc@ necattlemen.org • www. nebraskacattl emen.org

types, the contract should be deemed noncompliant with USDA-AMS’s confidentiality rules and not be 

reported to the public or maintained in the Cattle Contract Library.

To further advance the effectiveness of the Cattle Contract Library Pilot, USDA-AMS should provide 

educational outreach to cattle producers to disseminate the library's contents and how to utilize the 

information provided in the program most effectively. For efficiency purposes, USDA-AMS should utilize 

existing programs, such as the Cattle and Carcass Training program, or develop new modules to teach 

producers how to navigate the library. USDA-AMS should also consider expanding existing strategic 

partnerships with land-grant universities, cooperative extension, or other entities to disseminate pertinent 

information regarding the Cattle Contract Library Pilot program.

Thank you for the opportunity to submit feedback on behalf of Nebraska Cattlemen members. We look 

forward to expanding the tools available to our members to increase market transparency.

Best,

Ashley Kohls

Vice President of Government Affairs

Nebraska Cattlemen

CC: 

Jennifer Porter, Deputy Administrator, USDA-AMS 

Taylor Cox, Associate Deputy Administrator, USDA-AMS 

Michael Sheats, Director, LPGMN Division, USDA-AMS