The good, bad, and unknown of new FMMO pricing formulas ‘approved’ by producer referendum

Calvin Covington shared that the collective impact of all the FMMO changes on the Northeast Order farms is likely to be neutral to slightly beneficial, while farms in the three Southeast Orders will benefit the most because of bigger Class I differentials and greater Class I utilization. Butterfat and other solids prices will be lowered, and the wild card will be protein because barrel cheese prices moved higher than blocks in 2024, but the barrel price will no longer be used in the protein price formula after June 1st. Photo by Sherry Bunting

By Sherry Bunting, Farmshine, Jan. 31, 2025

SAVANNAH, Ga. and EAST EARL, Pa. — As part of his annual outlook for Southeast milk markets, and also in his look ahead for the milk market nationally and in the Northeast, well-respected retired milk co-op executive Calvin Covington broke down the final USDA Federal Milk Marketing Order (FMMO) formula changes into three categories: The positive, the negative, and the unknown. (Plus, there is also the ‘unvetted.’)

Covington spoke to over 300 attendees from 10 states at the 2025 Georgia Dairy Conference in Savannah on Jan. 20th, just a few days after USDA’s announcement that producers in each of the 11 FMMOs approved the final rule. Then, on January 28th, he was in eastern Lancaster County, Pennsylvania speaking to 250 dairy farmers on this topic at R&J Dairy Consulting’s 18th Annual Dairy Seminar at Shady Maple Smorgasbord.

The FMMO changes will be implemented June 1, 2025, except for the increased milk composition factors, which will be delayed six months due to impacts on “risk management.”

Covington shared collective analysis based on USDA’s backward-looking data (2019-23), showing that all six pricing changes, combined, would have benefited producers by 26 cents per hundredweight across all FMMOs, nationwide, during those years.

“But, like the disclaimer on a financial prospectus, ‘past performance is not an indicator of future results.’ It is all relative,” he said. “The three Orders of the Southeast are by far the biggest beneficiaries, but going forward, there are a lot of things we just don’t know.”

Calvin Covington shared analysis of how the recently approved FMMO milk pricing changes could collectively impact each of the 11 Orders, but warned that analysis based on past performance, may not be an indicator of future results.

Orders with estimated negative net impact at test are: Pacific Northwest (124) -5 cents; Upper Midwest (30) -9 cents; Arizona (131) -11 cents; and California (51) -27 cents.

Orders with estimated positive impacts at test are: Appalachian (5) +$1.90; Southeast (7) +$1.80; Florida (6) +$1.43; Central (32) +52 cents; Mideast (33) +50 cents; Northeast (1) +35 cents; and Southwest (126) +7 cents.

The good

“The Southeast will see the majority of benefit, with the updated Class I differentials,” Covington reported, illustrating how they vary by location for an average increase of $1.42 per cwt across the country – but only for Class I milk. The three Orders of the Southeast will see more of this benefit because they have the largest Class I differential increases and their blend prices are predominantly Class I.

A University of Wisconsin-Madison study had previously looked at where the plants are and where the milk is, in order to think about moving milk from where it more is produced to where it is needed.

The highest differential increase is along the route 85 corridor, beginning near Atlanta, up into West Virginia, where there are plants but no milk. Interestingly, his chart showed that the smallest increases for the region are in Florida locations as well as Valdosta, Georgia, where the new Walmart milk plant is being built.

In the Northeast, Covington said dairy farmers will have to get used to what this looks like on their milk check, and they will also see more incentive to move milk South under these new differentials.

“Each county has a differential assigned to it,” he said, pointing to the area of the R&J Meeting, near New Holland seeing a $1.40 per cwt. increase in Class I differential, but this is a smaller increase compared to the much larger increase put on at Boston, Mass.

“That big increase in Boston is because there’s not any milk around there, and it’s raised to get the milk to move to the people there,” he said. This means that even though the new Class I differential will raise the Class I price in New Holland, “farmers will have to get used to seeing their location differential as a bigger negative on the milk check,” because the increased differential in Boston is so much bigger.

The milk composition factor updates are straightforward, he said, yielding about a 35 cents per cwt benefit to the Class I milk price in all FMMOs, and will raise the standardized skim value of the other classes in the three southeastern Orders that are still priced as fat/skim instead of by multiple component pricing.

The bad

The make allowance increases will lower the price for butterfat and other solids value, he said, “but we don’t know what will happen with the protein price because of the elimination of the barrel cheese prices from the formula.”

This will manifest as lower butterfat and other solids component prices for the Northeast, he said. “We would expect the protein price to be higher, based on history, but that depends upon the block to barrel price spread and its relationship to the butterfat price.

The unknown

Historically, the 500-pound barrel cheese price was lower than 40-pound block price.

Last year, however, barrels have been higher, so we don’t know,” said Covington.

Also in the unknown category is the return to the ‘higher-of’ as USDA’s method for setting the base Class I skim price.

“In the past five years, the average-of method cost dairy farmers millions of dollars, but we don’t know going forward if the skim factors (Class III vs. Class IV) will get back to being closer together, which would lower prices. If the spread stays wide, this change to the higher-of will increase prices,” he explained.

When asked if the Covid pandemic created the loss in Class I value under the average-of vs. higher-of, Covington said the Covid period — while most obvious — only accounts for one year out of five years in which the spreads between Class III and Class IV and between block and barrel cheese were detrimental.

“The thing going forward is, we just don’t know,” he said.

The unvetted

The sixth change is not listed separately in the Jan, 16th USDA notice to trade, and it was not part of any hearing proposal. Covington said he views the extended shelf life (ESL) adjuster as “a new class of milk.”

“The ESL adjuster is only on Class I. You’ll have a Class I mover skim price that will be calculated for conventional milk based on the higher-of III or IV,” he said. “Then you need a big spreadsheet to show what’s going to happen next. They’ll look 36 months previous to 12 months previous at the difference between the higher-of and the average-of, and that will be the adjuster to use for ESL milk that month.”

He estimates the ESL adjuster would have averaged -30 cents in 2024, but for some months it would have been a plus.

“My initial analysis is that it will not make a whole lot of difference in the short term, but we just don’t know going forward if some will try to manipulate this,” he said. “My concern is that it was not proposed at the hearing at all, and there’s no definition for extended shelf life. I know being in this business all these years, if there is a way to work around it for a benefit, they will find a way to do it.”

When asked about the competitive issues between conventional and ESL fluid milk and between out-of-area packaged ESL milk competing with in-area fresh milk, Covington observed potential competitive issues between conventional and ESL milk in the same area.

“You’ll have two different costs at the same location. What has always been the beauty of the Federal Order system is having the same raw product costs at the same location,” he said, adding that new ESL plants are being built and others are expanding.

“As ESL grows… there could be some months with a price advantage,” Covington suggested, pegging that difference historically to be as much as $1.00 per cwt in some months. “That kind of difference can create disparity between conventional and ESL milk.

“The thing is, we just don’t know, going forward, what it’s going to look like.”

Covington urged farmers to pay attention and be involved. Federal Order reforms are a slow process involving a lot of time and compromise. Changes this big only happen about every 25 years, he said.

He noted that Farmshine has kept dairy farmers “well-informed” with effective reporting on the markets and the FMMO process.

He said that as more manufactured products are sold and less fluid milk, compared with 25 years ago, the future could look different if future administrations and lawmakers feel differently about the pricing of milk. If manufacturers perhaps choose not to participate, FMMOs could some day be looked to primarily for handling the payments and test weights.

However the future plays out, Covington urged: “Stay informed and be involved because it is your milk check.”

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Good news may trump bad nutrition policies

Editorial Analysis: Tumultuous 2024 spills over into 2025 – Part One

By Sherry Bunting, Farmshine, January 3, 2025

EAST EARL, Pa. – Year 2024 was tumultuous, and 2025 is shaping up to be equally, if not more so. Spilling over from 2024 into 2025 are these three areas of potential for good news to trump bad nutrition policies that are having negative impacts on dairy farmers and consumers.

Farm bill and whole milk bill

Both the farm bill and the whole milk bill showed promise at the start of 2024. No one championed the two pieces of legislation more than House Ag Committee Chairman Glenn ‘GT’ Thompson (R-15th-Pa.). He even found a way to tie them together — on the House side.

The Whole Milk for Healthy Kids Act made it farther than it ever has in the four legislative sessions in which Thompson introduced it over the past 8 to 10 years. It reached the U.S. House floor for the first time! But even the overwhelming bipartisan House vote to approve it 330 to 99 at the end of 2023 was not enough to seal the deal in 2024.

That’s because over in the U.S. Senate, then Ag Committee Chairwoman Debbie Stabenow (D-Mich.) blocked it from consideration — despite over half her committee signing on as cosponsors.

GT Thompson, found a workaround to include it in the House farm bill, which passed his Ag Committee on a bipartisan vote in May. The language was also part of the Senate Republicans’ draft farm bill under Ranking Member John Boozman (R-Ark.)

It too fell victim to Stabenow dragging her feet in the Senate. By the time the Ag Chairwoman released a full-text version of the Senate Democrats’ farm bill, little more than 30 days remained in the 2023-24 legislative session.

Key sticking points were the House focus on dollars for the farm side of the five-year package. It put the extra USDA-approved Thrifty Food Plan funding into the overall baseline for SNAP dollars and brought Inflation Reduction Act climate-smart funds under the farm bill umbrella while removing the methane mandates to allow states and regions to prioritize other conservation goals, like the popular and oversubscribed EQIP program.

Attempts to broker a farm bill deal failed, and on Dec. 20, another one-year extension of the current 2018 farm bill was passed in the continuing resolution that keeps the government funded into the first part of 2025, without amendments for things like whole milk in schools. However, Congress did manage to provide $110 billion of disaster relief for 2022-24 hurricanes, wildfires, and other events. Of this, roughly $25 billion will go to affected farmers and ranchers, plus another $10 billion in economic disaster relief for agriculture.

Looking ahead, there is good news for the farm bill and whole milk bill in the new 2025-26 legislative session. The House Ag Committee will continue under Rep. GT Thompson’s leadership as Chairman. On the Senate side, whole milk friendly Boozman will chair the Ag Committee. With Stabenow retiring, Sen. Amy Klobuchar (D-Minn.) will serve as Ranking Member, and she previously signed on as a Whole Milk for Healthy Kids Act cosponsor in March 2024.

The whole milk bill will have to start over again in the Education and Workforce Committee with another vote on the House floor. It was enthusiastically supported by prior Education Committee Chairwoman Virginia Foxx (R-5th-N.C.). Her years of chairing this committee have expired, but the good news is Rep. Tim Walberg (R-5th-Mich.) will step in, and he was an early cosponsor of the Whole Milk for Healthy Kids Act in the 2021-22 and 2023-24 legislative sessions.

New Dietary Guidelines

The 2025-30 Dietary Guidelines Advisory Committee (DGAC) submitted its ‘Scientific Report’ to the outgoing USDA and HHS Secretaries on Dec. 19, 2024 — just 40 days before they head out the door to be replaced by incoming Trump appointees.

The Report is the guidance of the so-called ‘expert committee’ that reviews evidence and makes recommendations for the Secretaries of USDA and HHS to formalize into the 2025-30 Dietary Guidelines for Americans (DGAs). This process occurs every five years.

The DGAs are used in all USDA feeding programs, including school lunch, childhood daycare, and eldercare institutional feeding, as well as military mess halls. They also inform food offerings in many other controlled settings. 

The bad news is the Report has gone from being increasingly pro-plants over the past nine cycles to being outright anti-animal in this 10th cycle.

The good news is that dairy keeps its special spot on the so-called ‘My Plate.’ The bad news is that despite acknowledging evidence about the benefits of milkfat in nutrient dense milk and dairy foods, the DGAC rated the evidence as ‘limited’ – largely because USDA screened much of it out of the review process.

In the section on under-consumed nutrients of public health concern, especially for children and elders, the DGAC noted that whole and 2% milk were top sources of three of the four: Vit. D, calcium and potassium. Even this was not enough to persuade them to loosen the anti-fat grip that governs milk in schools, daycares and eldercare.

The DGAC states in its Report that their ‘limited access’ to research showing positive relationships between higher fat dairy and health outcomes was “too limited to change the Guidelines.”

They even doubled-down on the beverage category by recommending against flavor-sweetened fat-free and low-fat milk and that water be pushed as the primary beverage. 

In the Report, the DGAC also doubled-down on saturated fat with recommendations to “reduce butter, processed and unprocessed red meat, and dairy for replacement with a wide range of plant-based food sources, including plant-based protein foods, whole grains, vegetables, vegetable (seed) oils and spreads.”

This opens the door for more non-dairy substitutes beyond soy-milk, which is already allowed in the dairy category. In fact, the Report looks ahead to future cycles changing the name of the dairy category to broaden what qualifies as makers of new dairy alternatives improve their nutrition profiles via ultra-processing. At the same time, the DGAC punted the ball on the question they were given about “ultraprocessed” foods and beverages, stating they didn’t have access to enough evidence on health outcomes to answer that question. (The next HHS Secretary might have something to say about that.)

Other animal-based foods such as meat and eggs took a big hit this cycle. The 2025-30 Report uses stronger methods for discouraging consumption. They recommend moving peas, beans and lentils out of the vegetable category and into the protein category and listing them FIRST, followed by nuts and seeds, followed by seafood, then eggs, and lastly meat.

Once again ‘red meat’ is mentioned throughout the report as being lumped in with ‘processed meat’ even though not one stitch of research about negative health relationships with processed meats included any unprocessed red meat in the studies! Clearly, consumption of whole, healthy foods from cattle is in the crosshairs. This 10th edition of the Scientific Report just continues the trend. 

As in past cycles, a whole core of research on the neutral to beneficial relationships between consumption of saturated fat in high-protein, nutrient-dense foods was screened out of the DGAC’s review process by current Ag Secretary Vilsack’s USDA.

This Report essentially sets the stage for ultra-processed plant-based and bioengineered alternative proteins to play a larger role in the institutional meal preps of American schools, daycares, eldercare, and military.

But here’s the good news! The DGAC was late in finishing its 2025-30 Scientific Report!

The law requires a 60-day public comment period before USDA and HHS formulate the actual Guidelines for 2025-30. This mandatory comment period ends Feb. 10, 2025. Comments can be made at the Federal Register link at https://www.regulations.gov/document/HHS-OASH-2024-0017-0001

By the time the comment period ends, Vilsack and company will have left town. Let’s hope Senators confirm Trump appointees before the public comment period ends on Feb. 10 so their eyes are on this before the bureaucracy finishes the job.

This is a golden opportunity for the dairy and livestock sectors, along with health and nutrition professionals and health-conscious citizens to weigh-in. (Look for ways to participate in a future Farmshine.)

Meanwhile, commenters can remind the incoming Secretaries of how flawed the DGA process has become; how Americans, especially children, have become increasingly obese with increasing rates of chronic illness and underconsumption of key fat-soluble nutrients during the decades of the DGA’s increasingly restrictive anti-fat, anti-animal dogma.

Commenters should point out the fact that the Committee was not provided with all of the evidence on saturated fat. This is a message that is likely to land well with USDA Secretary designate Brooke Rollins and HHS Secretary designate Robert F. Kennedy Jr. In fact, RFK Jr. is on record opposing the low-fat dictates and has said nutrition will be among his first priorities, if he is confirmed by the Senate for the HHS post.

FDA’s final rule on ‘healthy’ labeling

In the mad rush at the end of 2024, the FDA released its final rule about using the term “healthy” on the label of foods and beverages.

This process was outlined in the White House National Strategy on Hunger, Nutrition and Health. FDA’s preliminary ‘healthy’ labeling rule was released on Sept. 28, 2022, on the first day of the first White House Nutrition Conference since the 1980s.

At that Conference, Ag Secretary Vilsack said: “The National Strategy’s approach is a whole of government approach that involves the entire federal family.” And President Biden said: “We have to give families a tool to keep them healthy. People need to know what they should be eating, and the FDA is using its authority around healthy labeling so you know what to eat.”

In short, the FDA’s role here is to restrict healthy label claims to foods and beverages that meet its criteria and allow them to also use a new FDA ‘healthy’ symbol that is still under development.

“Nutrient-dense foods that are encouraged by the Dietary Guidelines – vegetables, fruits, whole grains, fat-free and low-fat dairy, lean game meat, seafood, eggs, beans, peas, lentils, nuts, and seeds – with no added ingredients except for water, automatically qualify for the ‘healthy’ claim because of their nutrient profile and positive contribution to an overall healthy diet,” the FDA final rule states.

No surprise that whole milk (3.25% fat) will not qualify, nor will real full fat cheeses, yogurts, and other dairy foods that are not fat-free or low-fat (1%). Natural, unprocessed beef, pork and poultry are off the ‘healthy’ list too.

Specifically, the FDA’s final rule states: “To meet the updated criteria for the ‘healthy’ claim, a food product must: 1) contain a certain amount of food from at least one of the food groups or subgroups (such as fruit, vegetables, grains, fat-free and low-fat dairy and protein foods) as recommended by the Dietary Guidelines for Americans, and 2) meet specific limits for added sugars, saturated fat, and sodium. 

The fat and sodium criteria are a double-whammy against most real dairy cheeses. A single 1-oz slice of American, Swiss, or Cheddar won’t make the cut on saturated fat or sodium; even part-skim Mozzarella is slightly over the limit. Furthermore, low-fat, high-protein cottage cheese barely makes the cut on saturated fat, but far exceeds the new limit on sodium. Likewise, a typical yogurt cup only qualifies if it is low-fat or non-fat, and fruited yogurts must steer clear of added sugars.

Dairy can’t win in this labeling scheme unless products are made with virtually no saturated fat and far less sodium. To sell flavorless cardboard and chalk water that fails to deliver key fat-soluble nutrients, products will undergo more ultra-processing, and Americans will consume more artificial sweeteners.

Under dairy products, FDA’s final rule for ‘healthy’ label claims states: 1) Must contain a minimum of 2/3 cup food group equivalent of dairy, which includes soy; and 2) Each serving must have under 2.5 g of added sugar, under 230 mg sodium, and under 2 g saturated fat.

This means even a serving size of exactly 2/3 cup (6 oz) of 2% milk might barely squeak by, and a full cup (8 oz) of 1% or fat-free milk would be – you guessed it – ‘healthy’. Flavoring the fat-free and low-fat milk will not qualify, except by using artificial sweeteners to stay within added sugar limits.

Under protein foods, the FDA is even more restrictive. The only protein foods listed in the ‘healthy’ labeling final rule are: game meat, seafood, eggs, beans, peas, lentils, seeds, nuts, and soy products. Furthermore, these options must meet the criteria of less than 1 g added sugars, less than 230 mg sodium and less than 1 to 2 g saturated fat.

But here’s the good news! This FDA final rule (21 CFR Part 101, RIN 0910-AI13) falls under the Department of Health and Human Services (HHS). It’s not likely to sit well with HHS Secretary designate RFK Jr. The rule becomes effective Feb. 25, 2025. The compliance date is three years later, so there is hope of requesting HHS initiate a new rulemaking process under new HHS leadership.

Bottom line is all three of these bad nutrition policies impact consumer health and dairy farm economic health and are rooted in the flawed Dietary Guidelines process.

There is good news on that front in Congress as well. House Ag Committee Chairman GT Thompson included DGA reform and oversight in the farm bill that had passed his Committee in the 2023-24 legislative session. It is critical that this issue be part of the new farm bill that moves forward in the 2025-26 legislative session.

Part II in a future Farmshine will look at the tumultuous 2024 dairy markets and margins spilling over into 2025.

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Christmas with cows shared with the public at milking time

‘It’s not about us, it’s about the cows’

By Sherry Bunting, Farmshine, December 20, 2024

RONKS, Pa. – What better place to be on a chilly evening 12 days before Christmas than in a stable with cows as a family goes about their evening milking and feeding? How fitting to remind the public not just about where their milk comes from, but also the way the Lord Jesus entered this world as a baby, wrapped in a manger, in a stable, with cattle lowing His lullaby.

The second annual Christmas with the Cows at the Melvin Stoltzfoos farm was a big hit, drawing double the attendance of 380 people from six states to the 50-cow dairy in Ronks, Pennsylvania.

While many visitors came from all around Lancaster and nearby counties, many also came from other parts of the state as well as New Jersey; Long Island, New York; a few from Delaware and Maine; and an over-the-road trucker brought his family from Houston, Texas after seeing the signs.

Local attendees like Bridgette Zell of Nottingham said they saw the event posted on Facebook. She brought her two young boys to see what it was all about. Bridgette had the quote of the night as she stopped by the 97 Milk table, where GN Hursh of Ephrata and Nelson Martin of Robesonia were the volunteers handing out stickers, 6×6 cards, small magnets, and other informative goodies.

“I get so tired of people saying milk is not for humans,” she said. “When I was growing up, if any of us didn’t feel well or had something wrong, my mother would tell us: ‘Drink a glass of milk see how you feel!’”

One of her boys, Dylan, was thrilled to pet his first cow. He quickly learned the Jerseys were more curious to bring their noses right up to his hand. “This one must give chocolate milk!” he said about the brown cows, flashing a great big smile.

“Well, they are more curious than their black and white herd mates,” I responded while capturing his photo, “and their milk is richer in fat and protein, but we still have to add the chocolate.”

The whole event is a leisurely walk around the barn during chore time, culminating at a table with whole milk, chocolate milk and homemade Christmas cookies.

This was not a fancy event, but rather a time to simply take in the serenity while the Stoltzfoos family — from the littles on up — shared the blessing of their stable routines with the public.

“People ask me what do we get out of it? It’s really just seeing people have fun. Seeing people have fun with the cows is what we get out of it. Everyone I talked to was happy and in a good mood. People were tickled to have the opportunity to just be in a barn,” says Melvin.

And along the way, they learn something too. Upon entering, visitors are given a paper with fun facts about Agriculture and the nutrition of delicious whole milk, along with a welcome note with facts about the farm — names of the draft horses, facts about Holsteins and Jerseys in the herd, fun facts about cows and what they eat. Visitors also receive a thank you card with the Christmas story as told in Luke 2:11-16 and the Reason for the season as told in John 3:16-17.

Melvin and his family truly love doing this. They are already thinking about next year’s Christmas with the Cows, marked on the calendar for Dec. 12, 2025.

The host family’s youngest daughter is pleased to have the calf feeding responsibility.

Feeling blessed to be dairying, Melvin and his family want to share this gift with others — the quiet rhythms of milkers pulsating and cows munching, the soft sounds of their lowing, the nickers from the horse stalls, the rustling of calves at feeding time, the sight of clean, contented, cows in their stalls, placidly chewing their cuds as the family moves the milkers down the row, amid casual conversations answering any questions the visitors may have.

“It’s not about us,” says Melvin. “It’s about the cows. It’s about people having the opportunity to see the cows.”

The largest crowd came early, lined up right at the start of the evening milking at 4:30 p.m. Visitors continued to flow in steadily right up until the advertised ending time of 7:30 p.m. The family rented portable toilets and tower lights, placed outside. They cleaned and emptied the loafing pen to make way for the 97 Milk table and refreshments.

Half a dozen people from Sensenig’s Feed Mill in New Holland volunteered their time too. Nancy Sensenig manned the registration table, drawing people in with her ready smile and outgoing nature, while dairy nutritionists Kyle Sensenig, Steve Morris and Justin Brenneman answered questions about dairy cows and what they eat.

Other volunteers guided traffic to parking, and Mike Sensenig was encourager in chief – walking around all smiles throughout the evening, talking with visitors.

“Melvin does a really good job here, and we support this because it’s grassroots,” says Kyle. “We like to get behind grassroots efforts that are an outreach to our community and consumers.”

He observed a few repeat families who came out last year, but mostly, he shares: “We saw a lot of new faces tonight.”

When asked what tough questions he may have encountered, he says it was really a relaxed evening, people were here out of genuine curiosity to experience something new that dairy farmers see and do every day.

He did get questions about grass-fed dairies and took the opportunity to broaden that discussion to recognize not all feeding systems are the same. He shared that these cows were getting grasses in their feedstuffs, and that cows are superheroes, able to utilize a wide variety of feedstuffs to make nutrient dense milk.

“The important thing is we want to have healthy and content cows, and that’s really what drives every dairy farmer,” he relates.

As I walked through with a group of visitors from southern Lancaster and Chester counties, the conversation turned to A2 milk. Melvin talked about his own progress toward a herd now 75% A2 through the bulls he selects for breeding. In his quiet manner, he demonstrated the reassuring message about how dairy farmers are always looking to improve and put their best quality forward.

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How these dairies manage with innovation, diversity

By Sherry Bunting, Farmshine, November 15, 2024

HARRISBURG, Pa. – Innovation on the dairy farm isn’t just the big investments that come to mind, but a mix of changes and a mindset to improve. Three distinctly different Pennsylvania dairy farms were showcased in a producer panel during the 2024 Dairy Financial and Risk Management Conference hosted by the Center for Dairy Excellence recently.

The audience of mainly ag lenders and industry representatives along with some fellow dairy farmers, had the opportunity to see how producers think through the challenges, progress, and investments, and how they manage their risk in areas such as herd health, feed and nutrition, as well as adversities they can’t control like weather, markets, and labor.

Automation at Oakleigh

For Matt Brake of Oakleigh Farm, Mercersburg, the five-year plan was accelerated in a different direction after a barn fire in December of 2019 forced the family to ask the question whether they would even continue in dairy. No animals were lost, and the 1950s parlor was saved, but they had big decisions to make about the future without a facility.

“We did a lot of praying and had a lot of difficult conversations,” he recalls.

By July 2020, they were milking 120 registered Holsteins with two Lely robots, automated feeding, automated bedding, and retained their preference for a bedded pack barn rebuilt within the existing footprint.

“We really appreciate the cow comfort we get from a bedded pack, and the longevity, which is something we are really seeing now, more than ever,” Brake explains.

They didn’t know — at first – that they would go robotic, but they did know the Lely Vector feeding system would be used for feeding in place of buying a new tractor and mixer and firing it up twice a day.

“It’s amazing to see how all these different pieces of technology play together,” says Brake.

The curtains and fans are all automated and integrated. All data points for the herd are displayed on every single milking. The system ranks cows from zero to 100 on percentage chance of illness, and the automatic sorting for individual attention is based on things like activity, rumination, production, and intakes.

“Everything just plays together in real time, without guessing. We’re still involved as managers, but the data and automation are the tools we didn’t have before. We saw an increase in production, but farming is still farming,” Brake relates, giving examples of ration changes that had to be made with a forage quality issue, and how data systems helped with early detection.

Overall, the animals are doing better in this system, and they are treating fewer cows because they are getting to them earlier.

“It’s really true that an ounce of protection is better than a pound of cure. The quicker we can give those cows the attention, the less likely they are to really nosedive on us,” he says.

Brake sees how automation saves labor in some respects, but it’s more accurate to say that, “With automation, we are better utilizing our skills. We’re able to spend our time better with the cows or focusing on priorities – like chopping corn or getting the alfalfa harvested at the right time.

“We don’t have to stop those activities two times a day or worry about if we have enough help in the parlor, and do we trust that person to stand in the parlor. The robot might ‘call in sick’ temporarily here and there, but in general, compared with some of the employees we’ve had, it’s reliable.”

Moving from just the paper DHIA to incorporating this into the electronic records, changes how they manage culling to be more voluntary than involuntary.

“We can look at space and overcrowding and begin to evaluate cows not just on milk but how efficient they are in the robots looking at deviation from the average with rankings on everything from performance in the robot to reproductive performance and past treatments and other metrics,” he explains.

Better management of the culling decisions also gives them the ability to plan how many heifers to raise. “One of the things we are doing is using more beef semen and using the system to decide who to use it on,” he says.

Renovation at Mount Rock

For Alan Waybright, innovation was the focus when he purchased Mount Rock Dairy from the Mains five years ago near Newville.

A building project was in order to update the over 30-year-old milking systems. About a year ago, they began milking in a 50-stall rotary, which changed the milking time on 2.5 times a day with each milking in a double-12 taking 9 hours, to now milking 4 times a day with each milking taking 3 hours and 45 minutes.

Waybright has been expanding from the 650 cows and 150 bred heifers he brought to Mount Rock from his prior home farm involvement at Mason Dixon, to milking 940 cows today with a 92-pound average, 4.2F and 3.3P.

Automation features were part of the rotary to reduce labor, and the calf barns include the wet barn to get them started before grouping for automatic feeders where they receive four to five feedings a day, resulting in healthier, better growing calves.

With the automated pre- and post-dipper, Waybright says the milking procedure in the DeLaval 50-stall rotary is very consistent, requiring just two employees, the first to wipe and forestrip and the second to dry and attach.

“This is a labor savings, yes, but there have been other benefits for udder health too,” Waybright reports. “When we went from the double-12 where we were hand dipping to the sprayer, a 50-gallon drum used to last seven days, now it’s three days.”

One of the innovative things he has worked on is the use of manure solids for bedding while keeping somatic cell counts low. His system uses two screw-presses dropping manure into the drum, leaving about two days’ worth of bedding at the other end with moisture levels around 50%.

They bed stalls every day during the week to use the solids as they come right out of the separator drum, adding acidifying ag lime to control mastitis.

Diversity key at Slate Ridge

“For us the secret weapon is diversity,” says Ben Peckman of Slate Ridge Dairy, Thomasville. He and his wife and high-school aged children milk 150 cows and raise 100 heifers, also feeding out all bull calves as steers.

He says there’s not one multi-million-dollar investment here, just the things that altogether add up to make a large impact.

At the dairy, he looks for ways to streamline, like ovsynch for repro. “It’s the little pieces here and there, he says, mentioning the machine with a smart phone app he purchased to do daily dry matter analysis on feedstuffs before mixing.

“Instead of always looking at the past for those adjustments, I can go out and see what the DM is right now,” says Peckman.

He fills the small sampler with three samples to get an average. “I have feed charts on my phone, pop in that number, and it changes out what I put in the mixer to get the same DM pounds,” he explains.

With feed stored in drive over piles, this is even more important to get the accurate measures each day, according to Peckman, who sees how it changes daily, firsthand.

“On a rainy day, it goes up, and on a dry, hot day, it goes down,” he says. “When changes happen day to day, testing every two weeks is not enough. My spreadsheet smooths out the changes by using the average of the past three days. When we started doing this we saw better production and components.”

A robotic feed pusher is another feed technology that’s made a difference. “We see higher intakes, fresher feed, labor savings and the ability to do this when I’m not there,” Peckman relates.

Bankers asked what ‘calculus’ goes into making such investments. For Peckman, the answer was blunt. “It’s something that improves how my herd performs but the robotic pusher does something I’m not willing to do. I’m not getting out of bed at 2:30 a.m. to push up feed.”

Other barn updates include ventilation controls and ceiling fans above bed pack areas. It’s better for cow comfort but there’s also a cost savings. “We use half as much straw and bedding with the new fans drying the air.”

His wife’s mobile milk pasteurizer is another innovation. They always fed whole milk and had a few problems when they fed it unpasteurized.

With the mobile pasteurizer, it’s two-fold: “the milk is better, but also the temperature is much better. It keeps the milk warmer, and we have healthier, better growing calves.”

Peckman really enjoys the cropping side, farming 1100 acres of diversified crops to feed the cowherd and take advantage of other markets.

“Diversity is how I mitigate risk. It’s my key technology. Diversity can’t be bought, but it pays. It helps me combat weather, combat markets, and combat other adversities in general,” he says, adding that it’s “not rocket science,” just looking at things other farmers are doing and adapting.

He does use GPS guidance for his tractors for planting and spraying, which saves seed and inputs and work off field monitoring with yield maps.

In addition to traditional corn for grain and silage and alfalfa haylage, they grows high oleic soybeans at Slate Ridge Dairy. “We saw a drastic increase in butterfat percentage,” Peckman reports.  

On his silage ground, small grains are grown — triticale, wheat, and barley. The barley he harvests after it gets the head, two weeks before it would be a grain harvest, as silage for feeding heifers.

One “big new innovation” he’s excited about is male sterile forage sorghum.

“It puts a head on without developing grain in the head,” Peckman explains. “This allows the plant to concentrate on putting energy into a plant that is a high sugar crop not a high starch crop. It’s very comparable to corn silage. I take a pound of corn silage out of the ration and put a pound of this stuff right in.”

He has replaced up to 40% of his corn silage with this particular sorghum silage and would like to get to 50% because “it’s a very economical feed to grow, the seed is cheap and inputs are less. It’s working well for me, but you have to have a way to harvest it as the BMR forage sorghums don’t ‘stand’ all the way to harvest.

“We started feeding this two years ago, and our components are up.”

Another newer crop in Peckman’s diversified portfolio is milo, or grain sorghum. He says it’s economical to grow and drought resistant, and they have a market for bird seed.

The wheat is grown as a cash crop but it has been fed too. The barley he harvests is a supplement for dry corn, depending on the year. He likes to grow these crops because they make good straw to bed the cows.

Peckman is a big believer in keeping his soil covered at all times, so some of the decisions and rotations are tweaked with weather and calendar. Over the past couple years, he has added a few acres of sunflowers to the crop rotations.

“We can double crop sunflowers after wheat, and there is a viable bird seed market for those,” he says.

“Mainly, they are beautiful, and I see people enjoying them. Nobody is paying me for that part of it, but it warms my heart to see neighbors stopping with the families, taking pictures and looking at my flowers. With everything going on in the world today, if I can see someone go out and smile a little, it’s worth it.”

Awareness, appreciation, and praise don’t pay the bills

97 Milk is a 501(c)3 non-profit. Donations are tax deductible.

By Sherry Bunting, Farmshine, November 22, 2024

EPHRATA, Pa. – Farmshine readers are no-doubt aware of the work of the volunteers operating the 97 MILK education efforts. But awareness and thank you’s don’t pay the bills.

First of all, 97 MILK is a 501c3 non profit, meaning donations are tax deductible.

Secondly, 97 MILK is managed and operated by volunteers. Not a single person doing any of this great work is paid a dime or a nickel (not even a penny) for their time and only in some cases are personal expenses for projects reimbursed

97 MILK has made huge strides on literally a shoestring budget. 

However, even the frugal cannot survive without donations because printers have to be paid for printing materials like the popular and eye-opening 6×6 cards.

Website hosts and programmers have to be paid to keep the platform up and running.

When whole milk isn’t donated for an event, it has to be purchased.

When dieticians or other experts are interviewed for a Q&A at the website or on social media platforms, they expect their expert time to be paid.

Boosting the best and most informative ad posts on facebook also comes at a cost. 

The list goes on, and it doesn’t even cover the things 97 MILK wants to do that are expensive, like BILLBOARDS.

There’s a reason Nelson Troutman started this movement by painting a wrapped round bale, or BALEBOARD — because the billboards were too expensive, but wouldn’t it be nice to amplify the good work of 97 MILK with a few larger than life billboards?

These are tangible costs that surround the small but strong and dedicated army of 97 MILK volunteers.

When it comes to the content created, the daily social media posts, the educational printed materials, the interactions with followers to answer their questions on social media, the constant monitoring of social media conversations, along with the answering of emailed questions at the website question desk, the compiling of new information for the website designer to keep it refreshed, the staffing of booths at consumer-facing events, the painting of bales, the miles driven, time spent talking to consumers, time spent designing eye catching ads to show consumers, time spent actually communicating with consumers – that is all done by volunteers who take time away from their paid livelihoods to voluntarily promote whole milk education, often not even being reimbursed their personal costs for supplies.

We are in the season of Thanksgiving. A great way to show some gratitude to the hardworking 97 MILK volunteers is to help keep the boat afloat with a donation. Apart from a few regular givers, donations have not come into this volunteer effort for a long time, and the shoestring is baring thread, despite the important advances this educational effort has made for dairy farmers and the many agribusinesses that serve and depend on them.

A recent Dairy Foods Magazine website panel discussed the State of the Dairy Industry in 2024. One panelist observed that their monitoring data show a 30% increase in social media conversations about milk and dairy products. We can chalk some of that gain up to 97 MILK, posting six days a week and reaching hundreds of thousands of consumers every quarter, with many reacting and having conversations with 97 MILK volunteers — engaging directly.

The website, alone, is averaging 200 users per day, most of them new users. That’s a big number.

Total page views at 97milk.com were 11,000 over the past 30 days – another big number.

Facebook reached tens of thousands of people last week, without any paid ads, but reaches tens of thousands more with boosting. Of these numbers, the nationwide reach is broad. Nope, they don’t all come from Pennsylvania. The places with the highest views register as California and Texas, along with states all in between East to West and North to South.

Of the website interactions, the No. 1 draw is the Milk Facts section. Visitors to the website spend an average of 2 minutes and 40 seconds there. In today’s fast-paced digital world, that’s a long visit! 

97 MILK is doing things right.

And guess what? Have you read the Oct. 16, 2024 Farmshine story about fluid milk trends? Do you read Market Moos keeping you up to date on the monthly estimated packaged fluid milk report by USDA?

Fluid milk sales are UP year-to-date over year ago, and have been trending this way since partway through last year. In fact, the long-term fluid milk sales downturn was slowed and flattened ever since 97 MILK was formed in February 2019. But in the past 18 months, it’s turning slightly higher. There is momentum now — enough that industry trade organizations and other farm publications are beginning to take notice.

This is spurred by the big increases in whole milk sales as one of the main categories turning the trend around when looking at the volume, not just the percentage of increase on a smaller volume category. Whole milk sales are up 21% since 2019 when 97 MILK was formed.

Consumers want to eat and drink more healthfully. They want to know about milk!

97 MILK has caught their attention, piqued their curiosity to learn more, and helped reveal the details about the nutrition in a glass of whole milk. Not to mention, the Whole Milk for Healthy Kids Act that passed the House of Representatives 330 to 99 last December got this far because of one thing: Whole Milk Education.

Whole milk bill champion, Representative G.T. Thompson, Chair of the House Ag Committee, said it best during a 97 MILK meeting attended by farmers in 2021, and he’s repeated similar statements at other meetings and panels where the subject of whole milk in schools comes up: 

“Keep doing what you are doing with the well-designed combination of influencing, marketing and providing factual information. Keep up the education. It’s working,” said G.T.

I personally want to thank each and every person who has donated funds and / or donated their time to help keep this whole milk education movement going. Thank you 97 MILK for all you’ve done for America’s dairy farmers and consumers – and above all for America’s children!

So, what are you waiting for? Want 97 MILK to continue and do more? If so, go to https://www.97milk.com/donate/ and prove it, or mail your donation to 97 MILK, PO Box 87, Bird In Hand, PA 17505.

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USDA to complete producer vote before new administration comes to town

Final FMMO rule adds more to make allowances, shortens delay on composition updates, restores higher-of, keeps controversial ESL adjuster.

By Sherry Bunting, Farmshine, Nov. 15, 2024

WASHINGTON, D.C. – The USDA released on Nov. 12 the Secretary’s nearly 400-page final decision on the Federal Milk Marketing Order (FMMO) price formula changes, with a few changes from the July ruling.

USDA rejected comments seeking to forestall the make allowance increases or to reduce their size. All make allowances are further raised in the final rule vs. preliminary rule by a fraction of a penny for marketing costs. Also, USDA has added more than a penny per pound to its earlier decision on the nonfat dry milk make allowance. These are milk check deductions that are embedded in the class and component formulas.

USDA also plans to stick with its earlier decision to introduce a rolling adjuster for extended shelf life (ESL) milk, which creates essentially two-movers for Class I that was not part of the hearing scope. The Department further defined ESL milk by processing method to be all milk using ultra-pasteurization, not just relying on the shelf life designation of 60 days or more.

The broad range of changes in the proposed final rule are the result of the national hearing and rulemaking process that began in 2023. It will be made final for implementation after dairy producers vote to approve these changes in the Order-by-Order referendum that will be completed before the new administration takes office on January 20th.

USDA AMS will mail voting ballots to eligible producers and qualified cooperative associations — which may bloc-vote on behalf of their eligible members — after the final rule is published soon in the Federal Register. Ballots must be returned with a postmark of December 31, 2024 or earlier and be received by the Department by January 15, 2025 in order to be counted.

Not all producers in a Federal Order will be eligible to vote. Only producers with milk pooled on a Federal Order in the month of January 2024 are eligible to vote in that Federal Order.

A ‘yes’ vote accepts all parts of the final rule. A ‘no’ vote rejects the changes but also rejects the continuation of that Order. Any of the 11 Federal Orders that does not meet the two-thirds majority requirement for acceptance of these changes will be terminated. The two-thirds majority is calculated among eligible producers in the Order who return a ballot.

USDA AMS will host three public webinars to further inform stakeholders of the changes and referendum process on Nov. 19 and Nov. 25 at 11:00 a.m. ET and Nov. 21 at 3:00 p.m. ET. A link to access the webinars will be provided at the AMS hearing website along with supplementary educational documents. 

Using its backward-looking analysis of applying the changes to actual 2019-23 pool test data, the combined net benefit for all 11 Federal Orders of all the changes in the final rule is estimated at +$0.26 per hundredweight. However, an average does not tell the full story, and it does not include the positive orderly marketing impact of restoring the higher-of method for calculating the Class I base price mover.

USDA’s Table 5 above is the backward-looking static analysis of the weighted Statistical Uniform Price (SUP) – at actual pool component test – showing net benefits for the following Orders: Appalachian +$1.90 per hundredweight, Southeast +$1.80, Florida +$1.43, Central U.S. +$0.52, Mideast +$0.50, Northeast +$0.35, Southwest +$0.07. 

Table 5 shows net-negative impact for California -$0.27, Upper Midwest -$0.13, Arizona -$0.11, and Pacific Northwest -$0.05.

However, this analysis does not factor-in the positive impact of restoring the higher-of method for calculating Class I. The Orders showing net negative impacts above have more liberal policies for jumping in and out of FMMO pools. Since USDA did not quantify the benefit of its restoration of the higher-of method for the Class I mover, it’s important to note that this can soften the blow. 

According to experts consulted by Farmshine on this matter, the potential average benefit for the same 2019-23 period of orderly marketing under the higher-of method in a low-Class-I FMMO like the Upper Midwest is 7 to 10 cents per hundredweight.

More importantly, the orderly marketing restored by this part of the final rule has a protective effect on the month-to-month hits taken by pooled producers from opportunistic depooling and negative PPDs. Why? Because the higher-of method — used for two decades, before the legislative change in 2019 — encourages functional class price relationships that promote orderly marketing.

In short, producers should realize that the restoration of the higher-of reduces the prevalence of very large negative PPDs that can disrupt performance of their risk management tools and treat pooled producers inequitably during black swan events and times of major market imbalances — like have been experienced over the past five years under the average-of method. This is a benefit that is difficult to quantify, but is contained in this decision nonetheless.

On the positive side for dairy farmers, the USDA will also shorten the delay from 12 months to six months for implementing the updated skim milk composition factors. These updates are shown above, which witnesses testified would raise Class I prices in all Federal Orders by an estimated 70 cents per hundredweight (based on 2022 data), while also increasing the manufacturing class prices in the four fat/skim Orders.

Raising the skim component standards helps bring the Class I, III, and IV in alignment, reduces the frequency of negative PPDs, and reduces the incentives for depooling that undermine orderly marketing.

The manufacturing class prices in the other seven Orders that use multiple component pricing are already paid on actual components, not by standardized levels.

Standardized butterfat composition at 3.5% will not be updated in this decision because this is a paper number that does not affect how producers are actually paid. Each pooled producer’s individual minimum price in all Federal Orders is already based on their actual butterfat test for pounds shipped.

The updates to county-by-county Class I location differentials were also tweaked in places, compared with the July preliminary decision, and the base differential for all counties at $1.60 per hundredweight remains in place.

Butterfat recovery within class and component formulas will be updated from 90% to 91%. Several proposals had requested a larger increase.

The Secretary’s final decision on the Class I base price mover remains unchanged from July.

USDA will restore the higher-of formula, which had been changed to an average-of formula in the 2018 farm bill. USDA is also sticking with the ESL adjuster, creating what is essentially a two-mover system for fluid milk.

Processors will separately report sales of conventionally processed (HTST) and ultra-pasteurized (ESL) fluid milk product sales each month. The higher-of method will set the base price mover, and USDA will apply the new ESL adjuster to the sales of ultra-pasteurized milk to determine their final pool obligation.

The ESL adjuster represents the difference between the higher-of vs. the average-of the Class III and IV advance pricing factors over a 24-month period with a 12-month lag. USDA states that it sees this adjuster “stabilizing” the difference between HTST and ESL over time.

USDA also rejected comments that had raised competitive concerns, stating: “The record does not contain evidence to support the implication that manufacturers of dairy products, the majority of which do not manufacture ESL products, would make business decisions to gain an advantage in the fluid market where they do compete.”

On the negative side for dairy farmers, the large increases in processor make allowance credits were made a bit larger, not reduced, after the 60-day public comment period.

USDA relied on the voluntary surveys of processor costs that were presented at the hearing as customary data sources from past make allowance adjustments. While USDA did not fully meet the requests of International Dairy Foods Association (IDFA) and Wisconsin Cheesemakers Association (WCMA), it does recommend much larger make allowances than what National Milk Producers Federation (NMPF) had proposed.

Make allowances represent the costs of converting raw milk into the four manufactured dairy products surveyed by USDA. They are embedded in the pricing formulas, not line items on a milk check, and they aggregate to an impact of 75 cents to $1.00 per hundredweight — depending on product mix and Class utilization.

USDA responded to processor comments about marketing costs, adding $0.0015/lb to its previously proposed processor make allowance credits for cheese, butter, nonfat dry milk, and dry whey. USDA also responded favorably to the processors’ request to adjust the nonfat dry milk make allowance to be more than a penny per pound higher than previously proposed.

The final decision will raise the make allowances on the four products used in class and component pricing – per pound — as follows:

Cheddar cheese will be increased from the current make allowance of $0.2003 to $0.2519 per pound; dry whey from $0.1991 to $0.2668; butter from $0.1715 to $0.2272, and nonfat dry milk from $0.1678 to $0.2393.

In its rationale, USDA stated that NMPF member-cooperative-processors supported the NMPF proposal as “a more balanced approach” to consider impacts on producers and processors. However, they also testified that the smaller increases proposed by NMPF “did not cover their costs.”

This put USDA in the position of having to rely only on the cost data provided by IDFA and WCMA because NMPF offered no cost data to support their smaller proposal. USDA said it rejected consideration of the impact on dairy farmers because the Agricultural Marketing Agreement Act does not include producer profitability as a factor for the Secretary’s consideration on this matter.

USDA chose not to wait for the mandatory and audited cost of processing survey that Congress is expected to authorize and require USDA to utilize in the future. This language is included in all versions of the new farm bill and is reportedly supported by NMPF, IDFA and American Farm Bureau Federation (AFBF).

The final rule also removes 500-pound barrel cheese prices from the protein and Class III formulas, meaning only 40-pound block Cheddar price surveys will be used going forward. USDA rejected proposals that sought to add 640-pound block Cheddar, bulk mozzarella cheese, and unsalted butter to the pricing survey.

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‘Stop feeding us lies’ say protesters as Dietary Guidelines Committee unbelievably doubles down against animal fat, protein

Dietary Guidelines have most negatively impacted children and youth.

Dietary Guidelines Advisory Committee holds final meeting. Draft recommendations include: Reductions in total protein; Less protein from animals, more from plants; Dairy emphasis still low-fat, non-fat; Implementation recommendations include food supply leverage

By Sherry Bunting, Farmshine, October 25, 2024

WASHINGTON, D.C. – This week is National School Lunch Week, and on Oct. 22 while USDA Secretary Tom Vilsack kicked off the so-called “largest federal-led summit in support of healthy school meals” in Las Vegas, the 2025-30 Dietary Guidelines Advisory Committee (DGAC) met publicly by zoom to gamble away the nutrients children need for the development of their brains, bodies and long-term health.

This was the seventh and final meeting of the DGAC after 22 months of subcommittee meetings and periodic full committee meetings, yielding a draft “scientific report” that is increasingly vegetarian.

Its recommendations to USDA and HHS are to develop 2025-30 Guidelines that significantly decrease the role of nutrient dense animal foods, even though they spent the first hour of the 12-hour, two-day virtual meeting puzzling over how to solve the nutrient deficiencies in their analysis.

The recommendations merge the three current DGA patterns (Vegetarian, Mediterranean and Healthy U.S.) into one dietary pattern with a draft name of “Healthy Flex U.S. Diet.” The flexibility part, according to the DGAC discussion, is the ‘how much’ and ‘how to’, which relies on ‘food pattern modeling’ and more specific strategies on how to replace animal based foods with plant based foods. 

The DGAC aims to improve its poor performance on the under-consumed nutrients by “including more nutrient-dense plant-based meal and dietary recommendation options” in its advice for 2025-30 Dietary Guidelines. 

The draft advice aims to continue to “emphasize consumption of low-fat or non-fat dairy and unsaturated fats; limit consumption of red or processed meats and foods high in saturated fat; and limit foods like sweetened beverages.”

Some committee members raised the concern that further addressing one problem (fat, salt, and sugar) leads to other problems in other areas (under-consumption of key nutrients, over-consumption of carbohydrates, and impacts on metabolic health). 

In fact, a week before the DGAC met, the first ever Change the Dietary Guidelines protest drew hundreds of people to the nation’s capitol — with Nina Teicholz, author of Big Fat Surprise, as emcee. It was organized by Metabolic Revolution with the mission of asking the Administration to “STOP FEEDING US LIES.”

Nutrition Coalition photo

Meanwhile, in the DGAC meeting, at least one member at the end of the first day noted how animal foods, specifically mentioning dairy, have all of these essential nutrients and that the bioavailability of the nutrients is important.

This didn’t make much difference. On the question of saturated fat restrictions, the 2025-30 DGAC doubled-down. These restrictions began with the first edition in 1980, and the quantitative recommendation of “limit saturated fat intake to less than 10% of calories per day starting at age 2 and replacing it with unsaturated fat, particularly poly-unsaturated” began in 2005.

The Committee’s biggest justification was that, “This has been confirmed by several previous DGACs based on the relationship between saturated fat intake and cardiovascular disease risk.” Basically saying it has been previously decided, and “we’re sticking with it.” Essentially, all evidence to the contrary was again ignored.

The Committee stated that only 1 in 5 Americans implement this limitation; so, food replacement strategies, cultural diet pathways, and diet simulations were recommended to show how to get more nutrient density from plant sources. Pre-packaged and pre-portioned implementation strategies and plated combinations of plant-based meals are suggested as ways to ensure nutrients without the fat.

This high-level academic exercise means very little to everyday Americans making choices about food, but it could fundamentally change what is available to choose from — if the “systems science, implementation science, and behavioral science” the DGAC is also recommending pushes diets even more toward highly processed, pre-packaged, pre-portioned options designed by global food giants.

Bottomline: the DGAC will recommend to the USDA and HHS to further reduce animal-based protein consumption and to further increase plant-sourced consumption in the 2025-30 Guidelines, while continuing to limit dairy to non-fat and low-fat options.

For dairy, the DGAC is also recommending that USDA update nutrition composition and dairy reference guides to reflect what they say are ‘improved’ plant-milks, and to use ‘diet simulators’ to show Americans how to be more ‘flexible’ in replacing animal foods with plant foods.

The DGAC also changed the wording of its 2025-30 mission to “reduce the focus on chronic disease risk reduction, to instead focus more on promoting growth and development and improving the healthspan.”

These are key takeaways despite the Committee spending the first hour of the first day stupefied by the analysis showing — uniformly across all socio-economic and cultural demographics — children ages 5-19 had the nutritionally poorest diets in terms of under-consuming key nutrients at this most critical lifestage.

Even when they picked up their Health Equity Lens to look at the data, it was uniformly bad.

The DGAC could not understand why the healthy eating index showed such uniformly poor performance in the under-consumption of key nutrients, especially among children ages 5 to 19 across all populations. (Simple. It’s because the anti-fat DGAs are enforced at school meals twice a day, five days a week, most of the year for this life stage. Kids do not get to choose; adults do.) Oct. 21 screenshot DGAC meeting 

Their interpretation? I will paraphrase: Parents need help understanding how to feed their children.

My interpretation? The Dietary Guidelines are, themselves, the problem because they are used rigidly to formulate the meals that the age 5 to 19 lifestage (kids) are presented with twice a day, five days a week, nine to 12 months of the year – at school! The body will keep snacking until it gets the nutrients it seeks. 

“Obesity is a major public health issue, impacting 36% of children ages 2 through 19 years and 41% of adults ages 20 and older,” according to the DGAC.

However, by the end of the two days, the DGAC showed it would stay on the anti-fat path and give USDA and HHS the “expert” advice to double-down on saturated fat restrictions that have prevailed over the years while Americans become less healthy, more obese, with more chronic disease, at ever younger ages. Do they not wonder why this was not the situation pre-Guidelines? So much valuable research on saturated fat and health was again left off the table.

One of many draft advice slides for 2025-30 Dietary Guidelines emphasizing non-fat and low-fat dairy and unsaturated fats; addressing nutrient density by increasing plant-based meal options and decreasing animal-based. Oct. 21 DGAC meeting 

Impacts of the DGAC draft report on Dairy:

1) Dairy’s ‘place’ in the diet remains somewhat intact, but the committee advises things like not referring to soy milk as an “alternative” because it is part of the dairy grouping. They also are questioning if ‘Dairy’ is the right term for the Dairy group. The DGAC also will advise USDA to update nutrient composition and daily reference amounts to reflect the current state of nutrition art in “plant-milks” and to use diet simulations to show Americans how to be more flexible in replacing animal-based with plant-based.

2) Nonfat and low-fat dairy will continue to be the recommendation (3 milk cup equivalents), although they mentioned that there was not enough evidence to make this a strong conclusion for ages 2 through 5. Perhaps this leaves a door open for daycares and WIC to expand to 2% and whole fat milk up to age 5 instead of the current age 2, but schoolchildren are still out of luck. Dairy fat and butter were mentioned as being consumed mostly in processed foods.

3) The Protein category has been flipped on its lid. The DGAC moved beans, peas and lentils from the vegetable category to the protein category and increased the daily quantities for beans, peas, lentils, seeds, soy, nuts, and fish, while reducing the allowance for meat, poultry and eggs. In fact, they will represent this visually by listing first in the protein category the plant sources, followed by fish, then eggs, then poultry, and lastly, red meat. The DGAC pointed to the dairy group as a source of protein that is not in the protein group, so protein level importance in plant-based comparisons can be reduced. (Several Committee members indicated their belief that Americans consume too much protein, so they wanted to show these crossovers differently.)

4) The additional considerations chapter is of particular concern for the future, advising USDA and HHS to: a) Encourage shifts to nutrient-dense plant-based meals; b) Put stricter limits on foods and beverages high in added sugars, sodium, and saturated fat; c) Use sugar limitations to exclude foods from the dietary pattern (with implications for flavored milk and dairy products); d) Make sodium reduction targets mandatory not voluntary (may impact the cheesemaking process for schools and other institutional feeding); e) Avoid referring to soy milk as “alternative”; Research name change for Protein group and determine if ‘Dairy’ is the right term for the Dairy group.

This draft report ends the DGAC’s work. In the coming days, it will be edited to reflect the discussion for submission as final recommendations to USDA and HHS.

A joint team of staff from both Departments will prepare this DGAC Scientific Report for posting at DietaryGuidelines.gov, along with data analysis, food pattern modeling and other supplemental documents. 

USDA and HHS will then open a new public comment period.

In 2025, the Secretaries of USDA and HHS (whoever they end up being), along with their joint team, will review the DGAC scientific report and the public comments to develop the actual 2025-30 Dietary Guidelines for Americans.

Expect these DGAs to continue most negatively impacting America’s schoolchildren and elderly in senior centers where meals must follow them.

However, it will have some impact on all of us if the Departments use the DGAC recommendation to implement food system science at the food supply level. We can already see what happens to choices for consumers and markets for farmers when the middlemen decide what can be put on grocery store shelves or in the dairy or meat case.

Not only did we not see a serious effort to address the need for more nutrient dense foods in the dietary pattern, the new pattern will double-down against saturated fat, along with salt and added sugar, and erode protein levels, while continuing to search for the missing nutrition profile of its increasingly vegetarian recommendations. 

None of this passes the smell test, and likely not the taste test. Kids eat food not data. Nutrients must pass the tongue to reach the belly. Look for more on that in terms of action next week from the Grassroots Pennsylvania Dairy Advisory Committee and 97 Milk.

***

Additional information:

In its report, The Nutrition Coalition notes: “The collective shift toward emphasizing more plant-based foods has lowered the quality and quantity of protein in our diets. It is time to pause and question whether these changes are endangering health in the U.S., especially among children and the elderly. Still, with plant-based advocates dominating the public comments, plant-based industries and interests lobbying the USDA, and plant-based proponents on the expert committee itself, we may see further reductions of this important macronutrient in the 2025 Dietary Guidelines.”

Nina Teicholz, Ph.D. explains that these draft recommendations “fly in the face of our knowledge that plant proteins are of lower quality than animal proteins. With the exception of soy, all plant proteins lack all the necessary amino acids to make muscle tissue (as well as perform other critical functions in the human body). Reducing the total amount of protein and replacing animal proteins with plant proteins are both harmful changes. These alterations will mean that anyone receiving USDA-funded meals, such as kids consuming school lunches, the women and infant children on the WIC program, and the elderly will receive fewer complete proteins. Also, reductions in meat, dairy and eggs are sure to exacerbate nutritional deficiencies in the guidelines, which currently fail to meet basic targets iron, vitamin D, vitamin E, choline, and folate. The Dietary Guidelines are already deficient in complete proteins. The erosion of protein in the guidelines has been happening for decades, as we wrote about in this post.”

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There is NO basis for two Class I movers in FMMO recommended decision!

AUTHOR’S NOTE: Who’s the wizard behind the curtain on USDA’s last-minute milk pricing surprise, the splitting of the Class I baby to favor ESL? Vilsack, of course, with a little help from his checkoff cronies at Midwest Dairy and DMI — masquerading as ‘dairy farmers.’

By Sherry Bunting

USDA’s recommended decision on Federal Milk Marketing Order Class I (fluid milk) formulas brought a big surprise getting very little attention. That surprise: “splitting the Class I baby” and adding what constitutes a “fifth Class” of milk — TWO Class I movers announced each month.

ZERO proposals to divide Class I into a two-mover system were aired at the national hearing. Even USDA’s analysis shows the two movers would differ by as much as $1 apart — or more — in any given month.

The hearing record is woefully inadequate, indeed completely void of testimony for a second Class I mover. No proposal. No evidence. No testimony. No analysis. No parameters. No definition.

What does this surprise two-mover decision mean? 

Fresh, conventionally processed (HTST) milk would go back to being priced by the prior method, using the higher of the Class III or IV advance pricing factors to determine the Class I skim milk base price portion of the mover. 

On the other hand, milk used to make extended shelf life (ESL) fluid milk products, defined only as “good for 60 days or more,” would continue to be priced using the average of these two pricing factors, plus-or-minus a rolling adjuster of the difference between the higher-of and average-of for 24 months, with a 12-month lag.

Confused yet? 

The industry is calling this surprise two-mover twist ‘innovative’ and ‘creative’, even ‘brilliant.’ But let’s hold the horses a moment. 

With two movers, fluid milk costs could be different for plants in the same location based on shelf life. Could processors change the label to move between the movers and pay whichever mover was lower? Who knows? There is no clear definition for the new class, and the parameters to qualify are non-existent.

ESL processors will know the rolling adjuster 12 months in advance, due to the “lag.” They will know the two advance-priced movers a month in advance. They will have it charted in an algorithm no doubt, and make decisions accordingly.

Dairy farmers, on the other hand, will find out how their milk was used and priced two weeks after all their milk for the month was trucked off the farm. If the two-price Class I system becomes law, dairy producers’ milk checks will be even less transparent than they are now!

Not only does the USDA hearing record and decision fail to clearly define ESL, the industry doesn’t even have an exact and generally-accepted definition or standard for ESL.

ESL is both a loose and specific term.

Generally speaking, ESL is a term covering a broad range of products — ranging from UHT (ultra high temperature) or ultra pasteurization, aseptic packaging, to the inclusion of a process that combines microfiltration, skim separation, and indirect heating (in stages). These processes yield what is more specifically referred to as ESL fresh milk with a longer shelf life in refrigeration, but is not shelf-stable.

What’s at the root here?

Dairy checkoff personnel have openly identified ESL — especially shelf stable aseptically packaged milk — as its “new milk beverage platform.” Dairy farmers’ promotion funds are being used to research and promote ESL milk, as well as studying and showing how consumers can be “taught” to accept it.

For the past few years, the four research centers supported by the checkoff have been drilling into milk’s elements to sift, sort, and test different combinations to reinvent milk as new beverages.

In 2023, North Carolina State researcher Dr. MaryAnne Drake —speaking at the 2023 Georgia Dairy Conference — talked about this “new milk beverage platform. We are after a shelf-stable milk that tastes great and meets our consumer’s sensory needs and our industry’s sustainability needs,” she said.

Bingo. Dairy checkoff funds for ESL are being driven by the net-zero sustainability targets. And now USDA’s federal milk order changes are proposing to lower dairy farmers’ Class I income and/or competitively favor, and in a way subsidize, ESL processors over fresh HTST fluid milk processors. Follow the money.

Dr. Michael Dykes of IDFA, at the Georgia Dairy Conference in January 2024, told dairy producers that “this is the direction we (processors) are moving… to get to some economies of scale and bring margin back to the business.” He said the planned new fluid milk processing capacity investments are largely ultra-filtered, aseptic, and ESL — 10 of the 11 new fluid plants on the IDFA map he displayed are ESL. Some will also make ultrafiltered milk and plant-based beverages too.

The linchpin to regional dairy systems and markets for milk from farms that fit USDA’s description of small businesses is the processing of fresh, conventionally pasteurized (HTST) fluid milk.

Meanwhile, dairy checkoff overseers, in cahoots with processors, are making big bets that consumers will embrace the obvious conversion underway to the consolidating shelf stable ESL milk, emboldened by the average-of pricing that has failed farmers miserably over the past five years and is now part of the proposed two-price Class I system mysteriously added to the USDA recommended decision when a two-price Class I system was never noticed as part of the hearing scope.

In the recommended decision, USDA notes that ESL currently represents 8 to 10% of total fluid milk sales but does not present the full picture of how the industry began aggressively converting to ESL since 2019 when Class I average-of was implemented. More of these accelerated investments will become operational in 2024-26.

Before we know it, the industry will have converted to ESL, and dairy farmers will once again experience disorderly marketing, depooling, and the basis risk of the mysterious average-of mover.

Dairy farmers have seen this movie before. 

In 2018, the average-of method — which changed how the Class I base was calculated — was portrayed by National Milk and the IDFA as “revenue neutral.” But at the recent national milk order hearing, testimony revealed that farmers experienced Class I revenue losses totaling nearly $1.25 billion from May 2019 through July 2024… and other impacts. 

Disorderly markets via the ‘average-of’ continue to result in losses and disrupt performance of risk management tools that fail to protect farmers against the intervals of extreme basis risk.

Proponents say the proposed rolling 36-to-13-month ESL adjuster on the second mover in USDA’s decision provides compensation to farmers for the difference between average-of and higher-of. However, that occurs gradually — over time — with a lagged interval. If tight milk supplies boost commodity prices and drive up all classes of milk, then dairy farmers’ incomes will at least partially lag years behind real-time markets!

ESL processors like Nestle and fairlife testified that the average-of method over the past five years allowed them to use Class III and IV hedges on the CME to offer flat 9- to-12-month pricing to wholesale customers and increase their sales. Nice to know the big corporations made money on that inequitable Class I pricing system.

Would a two-mover system ultimately reduce farmers’ access to milk markets in some regions and diminish the food security of those consumers? Watch the impact of a new, unregulated ESL plant now being built in Idaho!

Many legitimate questions lack answers

Milk is commonly prized as the freshest, least processed, most regionally local food at the supermarket. Will the USDA recommended decision accelerate consolidation and a reduction in fresh fluid milk availability for consumers?

Has USDA considered the purpose of the FMMO system is to promote orderly marketing and the adequate supply of fresh fluid milk? Will consumers accept the taste of the not-so-fresh ESL, or migrate faster to other beverages if fresh fluid milk is less available to them?

How will the two-mover system impact dairy farms located outside of the industry’s very specific identified growth centers? 

Will this perpetuate the wide divergence between Classes III and IV that has been an issue since 2019, further punishing dairy farmers with disorderly marketing and opportunistic depooling?

Who knows? The hearing failed to define, examine, or obtain evidence on any such questions… or any other questions that the hearing process is meant to be open to because this decision falls outside of the hearing scope!

Vilsack strikes again?

This proposal — a price break favoring ESL milk — fits the climate and export goals set forth by Ag-Secretary-then-DMI-executive-then-Secretary-again, Tom Vilsack. The pathway to rapidly consolidate the dairy industry to meet those goals is to tilt the table against fresh fluid milk. This is something Vilsack already put a big dent in by removing whole milk from schools.

It’s like one well respected veterinarian in the industry observed recently in conversation: “Someone decided: Thou shalt drink low-fat milk and like it.”

That “someone” is apparently equally convinced that the industry shall move to ESL and aseptic milk processing… while using dairy farmers’ checkoff funds to figure out how to get consumers to like that too.

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‘Make allowance’ among hot topics ahead of producer vote on USDA’s proposed milk pricing changes

35 dairy farmers, industry representatives, and farm media attended “Winners and Losers: a discussion about USDA’s proposed milk pricing reforms,” hosted by the American Dairy Coalition during the 57th World Dairy Expo in Madison, Wisconsin October 3rd.

By Sherry Bunting, Farmshine, October 11, 2024

MADISON, Wis. – “I’m in Wisconsin, and on the graph (below) it looks like producers in Order 30 are having to decide between less money with an Order or even less money without an Order. Am I wrong and is there a silver lining?”

That was the crux of the question one dairywoman asked during the American Dairy Coalition’s (ADC) ‘Winners and Losers’ seminar and press conference Oct. 3 at World Dairy Expo. Over 35 farmers, industry representatives, and media professionals gathered to hear insights about USDA’s recommended decision on changes to Federal Milk Marketing Order (FMMO) price formulas.

American Farm Bureau economist Danny Munch was the invited presenter, followed by time for questions, moderated by Kim Bremmer of Ag Inspirations, and opportunities for networking and farmer-to-media connections during the remainder of the two hours.

Dairy farmers attending ADC’s press conference gave interviews after the discussion on USDA’s proposed milk pricing changes.

At issue was the impact on FMMOs with more cheese and less fluid milk, that would experience the negative impacts of a proposed hike in processor make allowances without the positive buffer of higher Class I location differentials.

Bremmer said over 126 individuals and organizations provided comments to USDA. The comment period ended Sept. 13. 

During his visit to Expo on Oct. 4, Ag Secretary Tom Vilsack said USDA would issue a final decision in mid-November. Also on Oct. 4, USDA held a webinar explaining the producer referendum expected in January. (Look for more specifics in a future Farmshine, and check out the Farm Bureau recap here)

The short answers to the above question appear to be yes, yes, and yes. With an Order, producers in some regions will see lower FMMO blend prices. Without an Order, they would lose minimum prices altogether and other important FMMO functions.

The silver lining? Munch pointed to better competition currently for milk, and he sees opportunity for milk in the future as consumers focus on protein.

New to the discussion was make allowance data compiled by AFBF for its official comment at the Federal Register showing the average plant size of processors participating voluntarily in the Stephenson Survey relative to the average plant size of processors reporting to the NASS Dairy Product Manufacturing Survey (below)

The average size and volume of the plants in the voluntary cost of processing survey is 5 to 20 times smaller than the size and volume of plants reporting to USDA on price and production. This is further evidence that mandatory surveys are the only fair way to examine and set make allowance levels.

ADC reports that farmers have called with questions and concerns about the FMMO changes they will vote on. Part of ADC’s mission is to inform dairy farmers and help them understand factors like this that affect their businesses, said Bremmer.

For example, it’s helpful for farmers to realize that current make allowances equate to $2.17 to $3.17 per hundredweight in deductions already in the pricing formulas to cover the cost of converting milk to butter, cheddar cheese, nonfat dry milk, and dry whey. 

The proposed new make allowances add 70 cents to $1.00, depending on class utilization, bringing the total deduction to about $2.89 to $4.07 per hundredweight, maybe more.

The splitting of Class I into a two-mover pricing system is also causing discontent and concern. On the one hand, USDA would restore the ‘higher-of’ method for conventionally pasteurized fluid milk but use an ‘average-of’ method with a rolling and delayed adjuster for the extended shelf life (ESL) fluid milk products. This new milk class was not vetted nor defined during the hearing.

Also of concern is the delay in implementing positive updates to milk composition standards that have not been updated since Order Reform in 2000.

USDA’s recommended decision applies to all 11 FMMOs nationally but will be voted on by eligible (pooled) producers in each Order, individually.

A two-thirds ‘yes’ vote within each individual Order continues that Order with the changes. If the two-thirds threshold is not met by either producer numbers or volume in an Order, then the result is termination of that Order. 

Producers do not have the option of voting separately on the five pieces of the USDA decision, nor do they have the option of voting to keep the FMMO pricing formulas as they are currently.

Economists with National Milk Producers Federation have stated previously that 65 to 70% of the U.S. milk supply is marketed through cooperatives that tend to bloc vote for their producers, but this percentage can vary on an individual Order basis.

USDA determines voting eligibility, based on whether milk was pooled in the reference period selected by each Market Administrator. 

“When we get down the road to the vote, and if we vote ‘no,’ that will dissolve the Order, right?” asked one dairy farmer. “What opportunity does any geography have to reorganize a new Order to fit what works for them?”

Munch said producers could start a process to create a new Order, but it would still be required to use the same price formula rules because these will apply to ALL Orders uniformly. In contrast, he noted that USDA leaves pooling and depooling rules to be decided individually by each Order.

One member of the media pressed Munch to speculate on what happens if a western Order votes no, but an eastern Order votes yes?

“People always want me to speculate on what happens if California or the Upper Midwest vote out their Order(s). What we’ve seen in the past in unregulated areas, or areas with state orders — they still base a lot of their pricing on the nearby Federal Order system,” he responded.

“If we remove more milk out of the Federal Order system, does that system then play less of a role in pricing milk, and does that unregulated market start to dictate and suck milk out of the regulated areas, if you’ve taken out some of the large milk production states? That’s just some speculation, something to think about in the long term,” he said.

On a more immediate basis, Munch said that if an Order is terminated by this vote, “farmers lose protections like timely payments and component verifications, and the minimum prices. You could end up with a patchwork.”

He pointed out that USDA did not raise make allowances by the full amount requested by processors, but also did not go with the more modest increases requested by the cooperatives.

In their post-hearing comments, processors voiced great unhappiness with the decision, he said, because they didn’t get the multi-year increases to even higher levels.

“We don’t blame USDA for trying to come up with a middle ground… we just don’t have the data. The way hearing processes work is they collect this data brought by stakeholders and try to come up with a compromise that works for everybody,” Munch explained. “Our argument is that the data may not reflect market conditions, and we want to make sure that it does. We can’t get that assurance until there’s an audited, mandatory survey.”

As a standalone piece, AFBF estimates that USDA’s proposed increase in make allowances would remove an additional $1.25 billion annually from producer pool revenue, nationwide, based on past pooling data. However, USDA proposes a one-year delay in implementing the milk composition updates that would contribute $200 million annually in producer pool revenue nationwide.

Munch sees the 12-month delay in implementing the milk composition standards and the splitting of the Class I mover with an ESL adjuster as two things that appear to be “thrown in there,” with a lot of groups voicing discontent and confusion.

When asked by a reporter if the add-ons to Class I will create consumer resistance to what could be a 25-cents-per-gallon increase in retail fluid milk prices, Munch cited the hearing record where economists testified to the relative inelasticity of fluid milk demand.

He also sees great opportunity for milk: “When I go to the gym, I used to see no one drinking milk. Now I see tons of people drinking milk, protein shakes, and other things, and it’s not plant-based products. I think milk can take advantage of marketing the protein benefits that people in my generation are looking for and are willing to pay for.”

Munch was asked if AFBF will recommend how its dairy members should vote.

“We will not make that recommendation. We take positions based on our policy, which includes opposing any make allowance updates until we have mandatory cost of processing surveys, and other aspects related to our policy book,” he replied. “It’s up to our members to make those voting decisions, and there is a regionality to this, so we don’t get involved at that level.”

Florida producers, for example, “will be okay with the new rules” because the over 80% Class I utilization brings with it higher location differentials. The Upper Midwest, on the other hand, has been at roughly 5% Class I and 93% Class III, so there is very little benefit from the Class I changes, but those producers are subjected to the highest make allowance deductions for Class III products, which is 95% of their blend price.

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Concerning surprises in FMMO proposed rule; Comments due Sept. 13th

By Sherry Bunting, Farmshine, Sept. 6, 2024

EAST EARL, Pa. – “Those who don’t learn from history are doomed to repeat it.” That was the theme of the American Dairy Coalition’s webinar on the USDA’s proposed Federal Milk Marketing Order (FMMO) pricing changes, which I participated in last Thursday, August 29th.

Over 125 people participated, including state dairy and state farm bureau organization leaders and individual producers. American Farm Bureau economist Danny Munch helped producers understand the proposed changes and walked through the areas of mutual concern. Other panelists offered information, and participants’ questions were addressed.

“This webinar was a grassroots dairy producer undertaking,” said moderator Kim Bremmer of Wisconsin-based Ag Inspirations. “ADC planned it to make sure dairy farmers have a way to ask questions before the public comment period closes on Sept. 13th. We know the last update to milk pricing occurred in that 2018 farm bill, and that was without your input, and it cost dairy producers over a billion dollars across the country. It is really important that your voices are heard.”

Four primary areas of concern were discussed: the processor make allowance increase, the size of the whey make allowance relative to the price, delayed timing of beneficial updates to milk composition, and the surprising 2-mover system for Class I, effectively adding a 5th class of milk to the FMMO pricing scheme.

A 2-mover system was not vetted during the very lengthy USDA hearing. It appears to be “thrown in” as a last-minute compromise to appease processors investing in extended shelf life (ESL) fluid milk capacity.

Nestle and Fairlife had testified to sales volume growth when they offered 9 to 12-month flat-pricing after the average-of was implemented in May 2019. They said they must have average-of pricing to manage their risk so they can offer long-term pricing to grow sales.

Make allowance increases quite large

USDA proposes to raise processor make allowance credits by 29 to 33% above the current level. That equates to a 75-cents to $1.00 per hundredweight new deduction from milk checks, embedded in the pricing formulas, depending on how the milk was utilized.

Munch said make allowances are part of the formulas that start with surveying market prices for the four base commodities – 40-lb cheddar cheese blocks, butter, nonfat dry milk, and dry whey. USDA works backwards from the surveyed price to derive a value for the raw milk.

He used a cartoon imagining of “little Zippy selling cheese at his cheese stand.” (a light-hearted reference to AFBF president Zippy Duvall, a former dairyman).

“USDA is surveying the volume and value that he is selling it at — out in the marketplace — and then is using that price to derive a raw milk price,” Munch said, explaining that, “working backward, there has to be a part of the formula that accounts for the cost for Little Zippy to convert the raw milk into the cheese. He uses non-dairy ingredients like cultures and salts. It’s his own labor as well as overhead and equipment that he uses to convert raw milk into cheese. In the FMMO system, that deduction that accounts for his costs is called the make allowance,” he continued.

But today, the Little Zippys of the dairy industry are not so little, and they report much less on the USDA price survey, and they make so much more of the products that are NOT price-surveyed. These other products — such as mozzarella cheese, pizza cheese, other non-cheddar cheeses or cheddar cheeses in other bulk package sizes, whey protein concentrate, skim milk powder, whole milk powder, unsalted butter, and on and on — are not part of the formula and do not contribute value to the farmer’s milk check. Class I and II products are not price-surveyed either.

“When we look at the surveys, so many things are made out of the wonderful perfect nutrition of milk made on our farms, so what is the percent of products that are actually represented in the surveys?” asked Indiana dairy producer Sam Schwoeppe, who moderated the webinar Q&A

Survey volume quite small

Munch said the volume captured is “quite small and declining” to 14.8% in 2022 after being a high of 26.4% in 2002. “But those are just the products that are actually surveyed. There’s a lot of products that are not even surveyed, and that means the percent is even less.”

American Farm Bureau, American Dairy Coalition, and others pushed for some other bulk products to be added, but those proposals were rejected in this USDA decision.

So, how can current make allowance levels be too low when processors are spending billions to expand? Or, are dairy farmers expected to pay this debt service? 

Dr. Michael Dykes, the CEO of the International Dairy Foods Association (IDFA), representing processors, told dairy farmers at the Georgia Dairy Conference in January 2024 that, “7 billion in new processing investments (below) will be coming online in the next two to three years. There’s a lot of cheese in those plans. These are going to be efficient plants. You’re going to see consolidation.”

The proposed make allowance increases of 5 to nearly 7 cents per pound across the four commodities equate to a new embedded milk check deduction of nearly $1.00 per hundredweight for Class III and around 75 cents for Class IV – over and above the current make allowances that already equate to $2.20 to $3.40 per hundredweight. Class I would see this embedded in advance skim and fat pricing factors that are used to set the base price mover.

Collectively, the make allowance increases could remove $1.25 billion annually from FMMO pools, Munch showed in a 5-year static analysis based on prior pool composition, (See chart at top). Other aspects of USDA’s full proposal will defray some or all of the loss, mainly in the FMMOs with more Class I utilization. USDA’s proposal includes increases in location differentials for Class I fluid milk.

What happened in 2008-09?

Learn from the past or be doomed to repeat it? The last time make allowances were increased in 2008, a dairy market crash followed. As a webinar panelist and ag journalist, I pointed out that the dry whey price fell below the dry whey make allowance for the first seven months of that implementation from October 2008 through April 2009, resulting in penalties deducted from milk checks on every pound of other solids in the milk.

This time, the proposed dry whey make allowance is the largest of all – up 33.2% from $0.1991/lb now to $0.2653/lb. If in effect a year ago, dairy farmers would have again seen negative other solids penalties on their milk checks in July and August 2023 when milk prices were at their lowest. Meanwhile, processors made less dry whey, instead making more value-added products that are not price-surveyed.

Munch noted that only 66% of the plants on the price survey actually participated in the voluntary cost survey used by USDA to set the proposed new make allowances. AFBF, ADC and other organizations have been on record opposing make allowance increases until mandatory, audited surveys are conducted by USDA.

Conversion from fresh milk to ESL?

Learn from the past or be doomed to repeat it? On the Class I side, the 2018 farm bill changed the base price calculation. Farmers were told this would be revenue neutral, but the change cost them – at minimum — $1.25 billion over the past five years.

USDA now proposes to restore the higher-of calculation, but only for conventionally pasteurized HTST (or fresh) milk. Extended shelf life (or ESL) fluid milk products — labeled good for 60 days or more — would be priced using a new average-of method with a rolling adjuster.

Shouldn’t ESL have been defined in the hearing, and the economic impacts studied? This idea of two different Class I movers was not vetted in the hearing.

With two movers, fluid milk costs could be different from the same location based on shelf life. Webinar comments questioned USDA’s loose definition of ESL; Could processors change the label to move between the movers and pay whichever mover was lower?

The USDA’s one-year static analysis showed the ESL Class I mover would have ranged from being $1.18 per hundredweight over to 95 cents under the HTST Class I mover in various months of 2023. That’s a big spread.

What’s at the root here? The dairy checkoff has openly identified ESL milk as the new milk beverage platform, using dairy farmer funds to research and promote it and to show consumers can be ‘taught’ to accept it.

Dr. Dykes of IDFA, at the Georgia meeting in January 2024, also told dairy producers that “this is the direction we (processors) are moving… to get to some economies of scale and bring margin back to the business.” He said the planned new fluid milk processing capacity investments are largely ultra-filtered, aseptic, and ESL. (10 of the 11 fluid milk plants on the IDFA map above are ESL and/or aseptic fluid milk plants. Some will also make ultrafiltered milk, and some will make plant-based beverages at the same location.)

Has USDA considered the purpose of the FMMO system is to promote orderly marketing and the adequate supply of FRESH FLUID MILK? Will consumers accept the taste of the not-so-fresh ESL and aseptic milk, or migrate faster to other beverages if fresh fluid milk is less available to them?

Would a 2-mover system ultimately reduce farmers’ access to milk markets in some regions and diminish the food security of those consumers? Prized as the freshest, least processed, most regionally local food at the supermarket, will the USDA decision reduce fresh fluid milk availability down the road?

How will the 2-mover system impact dairy farms located outside of the industry’s very specific identified growth centers? And will this perpetuate the wide divergence between Classes III and IV that has been an issue since 2019, further punishing dairy farmers with disorderly marketing and opportunistic depooling?

Webinar participants asked: “Will commenting even matter? Or is the USDA Secretary’s mind made up? How important is individual farmer input?”

“It’s extremely important for farmers to get involved. Even with talking points, really tell your own story with it,” said Munch. “They like hearing from you, and the stories of the impacts to your balance sheet, to your future revenue or the stability of your local community. They want to know the impact on small businesses. That’s one of the driving points.”

Not much time

With a short time remaining to comment at the Federal Register Docket AMS-DA-23-0031-0002.

American Dairy Coalition has prepared an official comment, so other like-minded organizations and individuals can sign on before the filing deadline, which is 11:59 p.m. Friday evening, Sept. 13, 2024.

Comment directly to the Federal Register docket at https://www.federalregister.gov/documents/2024/07/15/2024-14769/milk-in-the-northeast-and-other-marketing-areas-proposed-amendments-to-marketing-agreements-and

Click here to read the ADC’s comment that will be filed before the deadline Friday evening at Sept. 13 at 11:59 p.m. Dairy farmers and organizations wanting to associate themselves with the comment can click here.

Click here to view ADC’s Aug. 29 webinar.

Click here to read Danny Munch’s at Farm Bureau Market Intel.