6/6/01 -- As of 11:35 AM Tuesday, June 5, I evaluated the postings of comments sent to Secretary Ann Veneman regarding the volume regulation proposals.

Overall, the total number of comments was 400. I then subtracted all the comments from non-growers to the best of my ability. This included politicians, economists, employees from Ocean Spray, Makepeace and Decas, unsigned comments, etc., which reduced the number to 291. Names that I did not recognize and that did not identify themselves as growers I still counted as growers. Undoubtedly some were not. To the best of my ability I counted one comment per grower contract.

The number of comments comes out as follows:

     4.7 Marketable Quantity 191

       4.0 Marketable Quantity 41

                              No Order 59

                                            291

This count DOES NOT include any of the over 50 Massachusetts growers who signed a petition against a volume regulation circulated by Charles Johnson and submitted to the USDA during the comment period.

I respect all views on this issue, but given the fact that there are 1,363 grower contracts in the US and only 291 growers responded, it becomes very clear that there is absolutely no mandate or consensus among growers that a volume regulation is the answer to our oversupply problems.

The extraordinary effort in time and money spent by the Cranberry Marketing Committee, Ocean Spray and other volume regulation proponents in an effort to build a consensus was a colossal failure.

Endless grower meetings by handlers, by state grower associations, by the CMC and all of its subcommittees, along with ad hoc groups such as Tee Pee and the Zeadey’s group couldn’t generate more than a token response.

Handlers writing sample letters and sending out envelopes stamped and addressed to the USDA still couldn’t generate a meaningful response.

Endless meetings in Washington, DC by growers, handlers, lawyers and lobbyists had little to no impact on grower attitudes. Even the emotional and endless debate on the Stressline couldn’t get the growers to make themselves heard to the USDA.

There are those who proclaimed in their comments that 9 out of 10 growers favored a volume regulation. This is simply not true, and the Secretary of Agriculture should be aware that it’s not true. One can make a more effective case that 5 out of 6 US growers are not interested enough to publicly proclaim their support of a volume regulation. No response from the vast majority of growers sends a more meaningful message than an Ocean Spray-orchestrated response from only 191 supporters.

I estimate the cost of the volume regulation campaign, including the cost of CMC and CMC subcommittee meetings, legal costs by all parties, USDA administrative costs, lobbyists’ fees, private jets and all the rest, must have been $700,000 or more.

All of this to generate 232 or less comments in favor of a volume regulation out of 1,363 eligible growers.

This represents a huge failure for the proponents of a volume regulation, who have worked hard and long to promote a regulation ever since the harvest of 2000.

The Secretary of Agriculture should not impose a volume regulation on the great majority who either don’t care enough about it, don’t believe it will make a difference, or who simply are not convinced it is the answer to our problems.

This should be followed by an immediate meeting of the six major handlers and the USDA to hammer out a Marketing Agreement that will fairly and effectively eliminate the surplus without giving one handler an advantage over another, while also instilling the necessary discipline upon all handlers to build the market and not the surplus. This, in my opinion, would be the best way to generate grower consensus and support. This option is made available by law, and we should take immediate advantage of it.

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