In its comments, NGFA
points out that both current law and STB regulations constrain railroads' ability to price their services differentially to captive shippers once the carriers have reached revenue adequacy.
According to NGFA
President Kendell Keith, the two NGFA
publications provide information "that can assist grain, feed and processing firms immeasurably in better understanding the kind of recordkeeping information FDA requires, as well as available compliance options.
Third, international commercial arbitration is more like court adjudication than is the NGFA
arbitration studied by Professor Bernstein.
In addition to NGFA
and NAEGA, organizations signing the letter were: American Farm Bureau Federation, American Seed Trade Association, American Soybean Association, Biotechnology Industry Organization, Corn Refiners Association, National Association of Wheat Growers, National Corn Growers Association, National Oilseed Processors Association, U.
in March submitted a statement to EPA opposing the proposed restrictions and suggested safety measures including:
recommends that part of such an emergency response plan should be that, in the event of a Globex outage, "open outcry trading will be suspended until Globex again becomes operational.
and NAEGA also termed "inappropriate" FDA's proposal to hold importers financially and criminally liable for the failure of foreign facilities to properly register with the agency.
45 million tonnes since mid-November, NGFA
said, with the shipments diverted to other buyers that "most assuredly would have negotiated a discount.
is the nation's largest trade association comprising commercial hedgers of grains, oilseeds, feed and feed ingredients, and grain products.
In its recommendations, NGFA
notes that current federal budget pressures "make it imperative to allocate farm program spending in ways that provide sufficient funding for federal crop insurance and conservation programs for working farmlands.
According to David Barrett, counsel for public affairs with the NGFA
, disclosure statements and warranties may be required when a farmer delivers grain to an elevator.
The National Grain and Feed Association is concerned that a wave of construction of on-farm storage facilities could disrupt or economically harm the commercial storage sector which NGFA