comments re consolidation in agriculture

Dept. of Justice is thinking about may be investigating the situation in the food industry to see if may be there are a few big players there who kinda dominate the field and write the rules for the themselves (no s**t) and asked the public for comments, so below is what I sent them. I'm not happy with it, I think I didn't explain it as clear as I should have but the deadline is today and I really don't have much time on it anyway, so here it is:


Dear Sir/Madam,

We're a small sheep farm in Dade City, Florida and we're limited to selling live animals only by combination of laws and lack of infrastructure for meat processing. If we could sell the meat directly it would be a healthy, natural, low-cost and humane alternative to industrially produced or imported meat but we can't. This is how it works (or, in this case, doesn't work):

Meat for re-sale must be processed by a USDA-inspected meat plant and there are only 15 in the entire state of Florida. Only 8 of them accept animals from the public. Only 5 of those work with sheep. Only one of these 5 is less than a 4-hour drive from us and this one only does slaughter, no cutting or packaging. So, there is no way for us (or any other sheep farm nearby) to sell meat and the big companies who do it here have no competition.

And it gets worse actually - let's say someone is willing to buy an animal but they can't or don't want to do their own butchering (and that probably describes 99% of the population). They can take the animal to a "custom butcher" who is not allowed to process meat for resale but can do it for the owner of the animal. There are more custom butchers than USDA inspected ones but still too few. The closest ones to us are about an hour away and their fee for slaughter and cutting a sheep comes to about $100. The average 100 lbs. animal itself only cost about $200, so 33% increase from a butcher's fee is definitely a big turn off for many people, especially low income people, who are already in big disadvantage when it come to access to healthy natural foods. On the top of that, custom butchers are often do a rather poor job that impacts quality of the meat. The reason they're able to get away with that is because there are so few of them and because they don't have competition from USDA-inspected butchers who are few and far away and mostly don't accept animals from the public.

I'm not suggesting that big food companies somehow created this environment (more likely it was a result of the unwise drive to cheap food at any cost we've experienced in the second half of the 20th century) but they're certainly benefiting from that, as they only have to compete with each other. Whatever the newspapers say about benefits of natural or local meat - an average person not happy enough to live near a farm and USDA-inspected plant, not having extra money and not willing to butcher animals himself has only one source of meat - a big box chain store. Not only it is dangerous (as evidenced by almost weekly recalls of contaminated foods, affecting hundreds of people) but it's in no way a competitive marketplace that was always the real reason behind American success and ingenuity.

Thank you for your attention to this matter,