Jim Sutter - Comment on FR Doc # 2011-17994

Since the advent of shipping bulk loaded US soy in containers, the US soy industry has implemented programs and activities promoting the growth of this logistics channel. US soybean producers chose to invest both national soybean check-off resources as well as US Department of Agriculture export development funds to promote container logistics based upon the positive benefits that importers identified when purchasing US soy in containers. Specifically, these benefits are: 1. Soybeans delivered in containers originate very close to the source of production which allows the US soybean industry to offer importers a differentiated soybean in the global market place at or near the prevailing delivered commodity soybean cost. 2. Increased flexibility in terms of purchasing volumes and delivery schedules of US soy. USSEC is membership organization that implements international market development activities on behalf of US soybean producers and exporters. With this role and mission, USSEC’s members contend all advantages to differentiate US soy in the global market need to be maintained and sustained. Bulk loading and delivery of US soy in containers is a clear example of an advantage that differentiates US soy in the global market place and to that end USSEC questions regulations that would detrimentally impact the competitiveness of this logistics channel.