Since the stated purpose for allowing cotton to transfer under the CCC loan was to facilitate the flow of cotton into world markets, and since unlimited transfer days will ultimately impede the flow of non-loan shipping orders into world markets, the Cotton Growers Warehouse Association supports a 75-day limit on storage credits for transferred bales. CGWA members will comply with all USDA minimum shipping requirements but assert that non-loan shipping orders should have priority over loan transfer shipping orders.
The Cotton Growers Warehouse Association finds that storage credits are an important component of US cotton’s competitiveness. With this background we strongly encourage USDA to:
– Consider regional costs and practices in setting a maximum credit rate
– Allow any warehouse rate changes up to the maximum credit rate for that region
– Set the forgiveness rate at a minimum 2005 crop’s average.
The Cotton Growers Warehouse Association believes that having a single organization, the National Cotton Council (NCC), which develops and advocates U.S. cotton industry policy, is in the best interests of our domestic industry. The Cotton Growers Warehouse Association therefore urges the NCC to be diligent to assure the current makeup of the seven segments of the cotton industry and policy making procedures of the NCC are in the best interest of its members whose capital and infrastructure are located on U.S. soil.
The Cotton Growers Warehouse Association supports the NCC policy which encourages the industry to establish and utilize techniques and systems which improve the flow of cotton by, among other issues, urging that racking samples not be practiced.
The Cotton Growers Warehouse Association fully supports the National Cotton Council’s Performance and Standards Task Force in its effort to improve the flow of U.S. cotton from farm to mill. Recognizing the warehouse-merchant nexus is critical for efficient cotton flow, we believe that this is best achieved with the proper balance of market forces, incentives and mandates.
CGWA continues to support the protection and integrity of bale quality and condition, and stresses that extensive capital investments have been made to support this endeavor which should be protected to the extent necessary to accommodate significant fluctuations in cotton production.
The Members of Cotton Growers Warehouse Association:
Additionally, the Cotton Growers Warehouse Association contends that the availability of information is beneficial to cotton market participants. The Members of the Cotton Growers Warehouse Association:
The Cotton Growers Warehouse Association continues its opposition to outside storage of cotton bales as a customary practice, realizing unnecessary and prolonged use of outside storage increases the likelihood of country damage which jeopardizes the position of U.S. cotton in foreign markets. CGWA supports the temporary allowance of outside storage of cotton only under extraordinary circumstances. USDA denial of storage credits should be limited to individual bales remaining outside more than 15 days after the warehouseman is notified the bale is in the CCC loan program.
CGWA supports the USDA policy of allowing outside storage only in areas determined to be storage deficit areas.
The Cotton Growers Warehouse Association’s definition of "Delivered or Staged for Scheduled Delivery" is as follows:
Cotton bales that are "delivered or staged for scheduled delivery" means any cotton bales that, with respect to the relevant week of shipment,
The Cotton Growers Warehouse Association opposes any obligation calling for warehousers to print bills-of-lading as any such requirement inherently increases warehouse’s errors and omissions liability without any tangible benefit to the warehouse or improvement on industry services and efficiency.
The Cotton Growers Warehouse Association supports total conversion to electronic receipts and in doing so supports any regulatory revision which, have not yet been made by the USDA to remove references to paper receipts.
The Cotton Growers Warehouse Association supports USDA/APHIS/PPQ efforts to harmonize international rules for import and export phytosanitary requirements for cotton bales; the CGWA also recognizes the efforts the United States has made toward eliminating unnecessary fumigation requirements for exporting domestic cotton by certifying that bales meet commercial ginning requirements and meet minimum compression densities of 22 pounds per cubic foot; and acknowledges that for international harmonization, imported bales meeting the same ginning and compression standards may be permitted without fumigation provided standards for exemption for pests that are non-typical of US cotton meet the same scientific proof of no-pest-risk as US bales prepared for export; supports use of electronic phytosanitary certificates.
The Cotton Growers Warehouse Association supports the industry standard of uniform density bales and in doing so supports any remaining regulatory revision, if any, to remove references to flat bales including bale packaging specifications.
The Cotton Growers Warehouse Association recognizes that worker safety and health are primary concerns for all segments of the cotton industry and request that the National Cotton Council maintain liaison with all agencies and industry segments including warehouse associations; the CGWA also urges its members to have a safety policy in place and perform regular training for all affected employees on safe bale handling and stacking including requirements for pedestrian safety measures.
Urge the USDA, Cotton Incorporated and the Cotton Foundation to allocate funding for systems analysis research that focuses on identifying potential areas of payoff such as cotton flow, transportation, labor saving devices, equipment use and utilization of other physical resources.
Recognizing Permanent Bale Identification is an essential feature of US cotton bales urge the National Cotton Council to review PBI tag requirements in light of emerging technology
Encourage bagging equipment designers, approved bagging manufacturers, gins, warehouses and others work together to improve bale bag closing techniques which: (1) take into account bale stack stability; and (2) prevent lint from being exposed to contaminants.
Encourage pilot programs to investigate the feasibility of innovative methods to increase storage and handling efficiency from the gin to the textile mill such as 4-bale groupings (a nominal short ton) to be merchandized as a single unit
Urge cotton industry implementation of quality control programs to prevent lint contamination from all sources, especially from those originating in the cotton field and cotton gins.