Small Flock Cost of Production ("COP")

The skeptics at BetterFarming wanted my COP (Cost Of Production) info, as they don't believe that Small Flockers can compete (nor should they be allowed to compete) against the SM Chicken Mafia.

I present this data on a break-even basis, so the debate of a "reasonable profit level" is removed.

Here is the data (Data Revised: 2014/05/30 11:07 Hrs.), updated from the previous version,

Figure1:  Comparison of Small Flocker Cost Of Production ("COP")
for various flock sizes

In Figure 1, the blue vertical bars show the break-even cost of the eviscerated chicken meat produced on a $/kg basis by me, a Small Flock farmer.  Break-even means there is no profit margin included in these costs.

If Ontario's millionaire SM Chicken Mafia must be allowed to earn a "reasonable profit", should small flockers be allowed to earn a reasonable profit?

If yes, what should that reasonable profit be?

Note that as the flock size increases, the cost on a $/kg basis drops dramatically.  At 2,000 birds per year, it is almost equal to the April 2014 retail prices of $4.37/kg.

Speaking with some local abattoirs that process chicken in Northern Ontario, I was informed that their small flock farmer customers generally charge $8.25/kg (ie. $3.75 per lb.) for fresh, eviscerated chicken sold at farm gate.

The red horizontal line shows $4.37/kg which is the typical April 2014 retail price for chicken in Ontario.

The green horizontal line shows the typical price for small flock chicken at the farm gate in Northern Ontario ($8.25/kg).

The purple horizontal line is the average US chicken price in Mid-West, as reported by US Bureau of Labor Statistics converted to $CA at the average exchange rate in April 2014 ($CA 0.9099 per $US 1.00) as reported by Bank of Canada.

Most economists will also compare pricing on a "marginal cost" basis.  This is where the producer is already making "X" units per year, but has the opportunity to sell just one additional unit.  What does that one additional unit cost to make?  I have not yet done that analysis.

In Figure 2, the detailed cost breakdown is provided for my operation at the average flock size of 57 birds per year.

Figure 2:   COP Breakdown for flock size of 57 Birds (Average Small Flock size in 2013, per CFO)

Note that due to the small flock size, and the long distance to the nearest abattoir that does custom poultry processing, the slaughter process adds an additional 30.03% to the cost structure.  This is a 378 km round trip for me, adding significant costs of transport, whether I carry 1 bird or 300 birds.

Hopefully this explains why I need the 2,000 bird limit if I want to supply safe, nutritious, affordable, locally produced chicken for my remote community.

Other small flockers have similar challenges, but may have significantly different cost structures.

In Figure 3 is a summary table of the various fresh, whole, retail chicken prices, and a comparison between the different prices:

Figure 3:  Summary table of retail chicken prices, fresh whole chicken, April 2014

Based on these data, will you support our cause to get the increase from 300 to 2,000 birds per year on what CFO permits Small Flockers to raise?

54 Vs. 300 Vs. 2,000 Bird Exemption

Based on a posting I made at Better Farming, I was asked to justify expanding the 300 bird/yr exemption to 2,000 birds per year.  Here is my answer:

You ask for the justification of a 2,000 bird per year exemption for small flockers when the average small flocker raises just 54 birds per year with a 300 bird limit.

With 54 birds per year for the average small flocker, that is using just 18% of the 300 bird/yr exemption.  Why then do we ask for a 2,000 bird per year exemption?

A small flocker who raises 54 birds per year, assuming 2 kg. per bird and 37 kg/person/yr of chicken consumed(Canadian averages), is feeding just 2.9 people.  In other words, the typical small flocker is feeding their own on-farm family.

As I understand it, there are 3 issues that restrict small flock chicken farmers:

1. Profitability;
2. Transport to/from Abattoir; and
3. Advertising.

Profitability
CFO has repeatedly said that the 300 bird limit was set with no thought of it being sufficient to be able to raise chickens in a commercially profitable manner.  I tried raising safe, nutritious, locally grown, and affordable chicken, and know from personal experience, it can't be done under the current regulations.  That is what launched my investigations, and eventually the appeal to the Tribunal.

By setting the 300 quota limit, which is far below the break-even point, CFO guarantees a virtual monopoly for themselves within Ontario.


Transport to/from Abattoir
Not all abattoirs process chickens.  There was a huge collapse of local abattoirs in 2005 when OMAF's new Meat Regulations came into effect, and on-farm slaughter was banned.  For me, I have a 300 km journey to the nearest abattoir that will do custom processing, then have to hire a refrigerated truck to bring the meat back to my farm.  This too, is a significant price and logistical barrier designed to drive Small Flockers into extinction.  I have asked OMAF for the scientific data and risk assessment to justify these oppressive regulations, but they have none, or refuse to supply it.  It appears that CFO and its lobbyists have achieved regulatory capture of OMAF, further strengthening their death grip on Small Flockers throats, and CFO's chicken monopoly in Ontario.


Advertising
Small Flockers are banned from all advertising.  They can only rely upon secret or private communications, and word of mouth.  Most Canadians believe in and enjoy Freedom of Speech, but this is denied to Small Flockers by the millionaire monopolists of CFO.

Small Flock Poultry Farmers of Canada believe in full disclosure and truth in advertising.  On what legal basis is there a total banning of advertising by small flockers?

The CFO system has been well-designed by CFO to make small flock chicken farming an impossibility.  In spite of this, the number of Small Flockers continue to grow as we wait for the end of tyranny and oppression by the CFO minority upon the Small Flock majority.

If the exemption limit is moved from 300 to 2,000 birds per year, and the other barriers are reviewed, justified or relaxed, then the high fixed costs of small flock farming can be spread over a larger base, making it profitable and feasible.

Sick Chickens Go To Market

When a flock gets sick, the fastest and lowest risk solution is to send those birds to slaughter, passing the problem off onto unsuspecting consumers.  Is this standard procedure for the Chicken Mafia, or just the actions of a rogue chicken farmer?

The reading of government records can yield interesting questions and glimpses behind the curtain.  Sometimes CFIA takes actions, and lays charges against a member of the Chicken Mafia.  The member of Chicken Mafia wants to escape censorship and the resulting fine (2 tickets @ $6,000 per ticket= $12,000 total fine), so they often plead and whine, promising anything that will get them off the hook.  In spite of this, sometimes CFIA sticks to their principles, and won't let the issue die.  The Chicken Mafia member then often chooses to appeal the CFIA charges to the Canada Agricultural Review Tribunal ("CART").  That is where the public gets to see behind the Chicken Mafia curtain of secrecy.

In one case, of which I know nothing except what I read of  the CART decision, a farmer (Peter and Lisa Rombouts, whose farm is located at Bosanquet, ON) was having 80 chickens die per day from some unknown cause.  After suffering these huge losses for a week, the farmer decided to ship his problems off to the abattoir, crystalizing his profits to cash before the whole flock ended up dead.

The farmer called a company (Greidanus Poultry Service Ltd. ) that is in the business of catching birds, loading the chickens into cages, putting them on a truck, and shipping them to the chosen abattoir.

After the first of two trucks were shipped, the farmer disclosed to the trucker that he had had a huge death rate in his flock the week before.  The trucker then examined the farmer's records, and confirmed that this was substantiated.  There is a responsibility that a sick or fragile bird  should not be loaded.

Because this critical info was withheld by the farmer, and/or due diligence by the trucker was delayed or done out of sequence, it is questionable if the birds were properly assessed prior to shipping.

From CRAC's decision, we learn:

"Buttar [an employee of the trucker] told the Tribunal that on that night he did discuss flock health issues with the producer and the producer informed him that there had been a big death loss the week before the loading, up to 80 bird deaths per day during that period, which was verified when Buttar reviewed the producer’s log on the day of the loading."

In cross-examination, Buttar told the Tribunal that the increased mortality at the Rombouts’ farm in the days before the loading was not brought to his attention until the end of the loading process. While this increase was a concern, one of the loaded trucks had already left when this fact was brought to his attention and at any rate he told the Tribunal the decision to send or not to send the truck would be the producer’s or the processor’s. However, Buttar said that as foreman he has an obligation to only load birds that are fit for transport.

Buttar said that the crates into which these large chickens were being loaded that night would hold about nine 4-kg birds, and so, with loading instructions to load only six to seven birds per crate, there would have been room for up to two more birds in each crate.

When asked under cross-examination, Greidanus [the owner/manager of the trucking company] agreed that about 9,600 chickens were loaded by his crew in around two hours and that it was possible for a loader to load a chicken into the crate on its back, particularly with the heavier chickens. Greidanus added that he would not leave a chicken on its back in a crate but that “everyone is human and it is possible to miss [righting] a chicken [back onto its feet]”.

total length of time from beginning of loading to beginning of processing: 15 hours 45 minutes for first trailer and 18 hours 35 minutes for second trailer

Buttar also stated, however, that at the end of the loading he chatted with the producer and noted that there were at least 60 dead birds and 10 smaller, injured or frail live birds in the producer’s barn which were not loaded for transport by his crew.

The evidence is equally clear that on January 20, 2011, when the birds were unloaded for processing, 334 of the 9,599 birds were dead and of these 156 were found dead on their backs.

"Greidanus told the Tribunal that his company had experienced a lot of problems shipping birds to Quebec because of the increased transport distance and the heavy size of birds that are shipped. The birds now grow so rapidly that they are stressed and it takes so little to make them die, he stated. Greidanus testified that he has seen birds dying in a crate and has seen a bird flip over and die in its crate."

Do other possibilities exist for where and how the injury and death of the chickens took place? Yes, the chickens might have been in a fragile state before loading, as indicated by the producer log sheets, showing a higher than normal mortality rate in the days and weeks before the shipment. The chickens might have experienced increased stress due to their heavy weight, the long distance and the long period of time between the farm of origin and the abattoir, which could have resulted in increased mortality while en route.

Greidanus has his theory that the chickens were large stressed birds that travelled a very long distance and died of a heart attack en route, which may or may not be consistent with the rare phenomenon mentioned by Lefebvre [chicken Vet] and Fortin [Chicken Vet], which has been observed in chickens called “flip-over disease”.

From all of this, we learn about the razor edge that has been created by the Chicken Mafia's search for maximum profit.

Birds grow so quickly, they face the daily risk of dying from too rapid of a growth.  About 560 birds died the week before shipment (ie. 80/day * 7 days= 560).  Another 334 were DOA (Dead On Arrival) at the abattoir, and 70 birds were left behind as too sick or too frail to ship, and 9,265 made it to the abattoir alive to reach their ultimate purpose of going to slaughter.

It is unknown how many were approved or condemned at the slaughter stage, but I previously showed that it's typically 1.26% (see Condemned Chicken Blog posting of 2013/03/14), where I show that Ontario has a condemnation rate that is "23.3% worse than Atlantic Canada, and 21.7% worse than BC".  If that holds true in this case, 117 birds were condemned during the slaughter process as unfit for human consumption.  Therefore we have a total death or ill toll of 1,081 birds with 9,148 becoming chickens sold, so a loss rate of 10.57%.  In addition, we would have the losses in the early life stage (ie. day old chicks to 5 weeks of age, which can be equally horrific under the Chicken Mafia's system of pseudo agriculture animal husbandry.

When will be learn that the current system designed and practiced by the Chicken Mafia  has become more and more broken as we go down the wrong road.

This is not right, nor sustainable.

Decision Time

The Tribunal has made its decision on our Appeal.  Now it is time for Small Flockers and their friends to make our decision.

The Tribunal's decision on CFO's Motion to Dismiss our appeal is available here: Tribunal's Decision.

Small Flockers need to decide if we abandon our fight for freedom and affordable food, or continue our fight for truth, justice, and pragmatic solutions.

I just sent an email to all members of Small Flockers, and a few key agriculture media contacts.  That emailed letter is reproduced here.

As requested in this letter, if you have any feedback, I'd like to receive it too. Call, email, or post your comments below, whether pro or con.

* * *
Begin Email Letter

To:    Members of Small Flock Poultry Farmers of Canada
c.c.   Agriculture Media

As a member, supporter, or follower of Small Flocker Poultry Farmers of Canada, you need to know that we are at an important decision point for Small Flockers, and I seek your advice.

Attached, you will find the Tribunal's decision on my appeal, where I was acting as proxy for all other Small Flockers in Ontario, and the rest of Canada.

The Appeals Tribunal has rejected all of our issues raised, except for one:  the 300 birds/yr grow limit imposed on Small Flockers by CFO (Chicken Farmers of Ontario), and our request to have the limit raised to 2,000 birds per year, in line with most other Provinces.

The Tribunal has invited me to file an amended Notice of Appeal on this one issue.  I need to decide if I should give up now, or file the abridged appeal.

In my mind, the #1 issue was, and remains, whether CFO  is a power unto themselves.  CFO seems to feel they can do as they please with the government powers delegated & vested in them, to feather their own nest at the expense of everybody else in Ontario.  If we solve this one issue about CFO's role, most or all other issues in chicken supply management will automatically (more or less) solve themselves.  This is why safe, affordable food for all Ontario families is the second most important issue that we hoped to address in this appeal.

Today, Health Canada reports that 7.6% of Canadian families can't afford the food they need to feed themselves.  In our have-not Province of Ontario, food insecurity is 11% worse than the Canadian average.  Will this be an election issue?  Is there any hope of solving or improving this issue if we abandon our appeal at this point in time?

If I file the amended appeal, the Tribunal may have to rule on that central core issue (ie. Does CFO have a duty to do what is in the best interest of the public?), but the Tribunal could also refuse again to address that important issue, deciding the 300 vs. 2,000 bird limit question based on other facts.  I believe we can show on the balance of probabilities that strengthening and expanding small flockers would be in the public's best interest, and would be more fair to small flockers.  CFO has again stated that the 300 bird limit was not set, and has no need to be set at a level that is commercially viable (ie. it is not necessary that a small flocker has a reasonable expectation of making a profit).

I expect that if I go forward, most or all of the cost, time, and effort will likely have to come from me personally.  For that reason, I seek your advice, but reserve the final decision to me alone.  In other words, I reserve the right to accept or reject the advice of the majority of Small Flock members, and each individual.  However, I would greatly appreciate receiving your advice, and more important yet, the REASONS behind your advice.

There is no guarantee that we will win or achieve anything if I do all the work of re-filing a new, revised version of an appeal, and go back to the Tribunal again.

I suggest that CFO would be very glad to sweep all of this under the carpet.  By making this appeal a tough and drawn out process, CFO likely hopes to wear us down, so that all sane people give up before getting anywhere close to the finish line.  In that way, CFO wins by default, and the status quo continues in CFO's advantage.  There is no guarantee that CFO won't file another Motion to Dismiss to my revised Notice of Appeal.

Personally, all or most of my issues have been swept aside; gone, deemed outside of the chosen jurisdiction of Tribunal by this decision.

On the other hand, it is usual for Courts and Tribunals to decide or comment on only the minimum number of issues necessary to make the decision at hand.  The Tribunal was asked to dismiss or contain the issues in the appeal.  That is the decision that they have made.

If we go forward by filing the amended Notice of Appeal, the Tribunal may have to decide on some of these other collateral issues too.  That would be the best possible outcome, where some or all of these other important issues get decided by the Tribunal as collateral benefits that come with the Tribunal's future decision about the 300 vs. 2000 bird limit.  Perhaps we can enter by the back door after having been refused entrance by the front door.

The Tribunal suggest I should ask for a Public Inquiry on all of the issues raised. What's the chances of getting the Fed or Prov. government to hold a public inquiry?  What a joke.  Snowball's chance in Hell, in my opinion.  Perhaps I am wrong on this, but I am not prepared to spend 1 second of effort on that impossible dream.

As for me personally, my barn can only grow 100 meat birds at a time.  At a max. of 6 grow sessions per year (think of the energy bill in -40 deg. C weather), I can do a max of 600 birds per year if I don't build a new barn.  If I restrict my growing to those that I can do economically, I can grow 4 sessions per year @ 100 birds per session= 400 birds per year.  There isn't much difference between 300 (current CFO limit by Ontario Regulation) vs 400 birds per year limit (the physical restraint of my barn).  I can't justify all the effort to fight this David Vs. Goliath battle for 100 more chickens per year that I would grow personally.  CFO's data says that 50% of small flockers have 60 birds or less at present.  It would appear that most Small Flockers in Ontario are similar to me at present.

There is the possibility that after 10 or 20 years with the 2,000 bird limit, more and more Small Flockers will start growing more chicken because it has become economically feasible to do so.  That is the hope, but mostly speculation whether it would actually occur.  Nobody knows for sure.

The current 300 birds/yr. limit allows one farmer to produce enough chicken to feed 5.5 families for a year.

Alternatively, there are about 100 families in my small village.  If I focus on feeding them, that is about 250 people.  Assuming 38 kg of chicken consumed per person per year, that is a total of 9,500 kg per year of chicken required.  At 2 kg per eviscerated chicken, that is 4,750 birds per year.  With a 2,000 bird limit, I would be able to feed about 42% of my remote village for their annual chicken consumption.  That would seem to be reasonable in my particular case.  Perhaps there are many Small Flockers who have a similar duty or opportunity so as to achieve safe, nutritious, locally produced chicken for their community.  Perhaps this is sufficient reason to continue the fight.

On the other hand, this revised grow limit [of] 2,000 birds per year might allow for the creation of mid-sized regional chicken producers, possibly adding a middle tier into the current 2 tier system (ie. currently just quota farmers and small flock farmers).

I'd be doing all the work for a very few individuals who would benefit from being able to become a regional chicken producer.  In the future, will these regional producers align themselves with the small flockers and the consumers, or will they choose to align themselves with the big boys (ie. the millionaire quota chicken farmers and producers) so that they get free crumbs from the master's table?  I am not highly motivated to help splinter and add to the opposition forces (ie. possibly similar to chopping a star fish in half so as to get rid of them, but you end up with twice as many star fishes, as each piece re-grows into a whole star fish). On the positive side, perhaps this new middle tier of chicken producers will help apprentice & ease in new chicken farmers to our industry, rather than the current trans-Atlantic jump that is required from small flock (easy for everybody to do) to full minimum quota size (ie. a multi-million dollar operation).  Therefore a 3-tier system might be good for Ontario in the long run.

If I stop now, I will have failed in my purpose, as Jim Rohnman said yesterday in his Blog   http://agri007.blogspot.ca/2014/05/black-loses-appeal.html 

Perhaps I have poisoned the well, and it is better if I toss the ball into the air, yell "Free Throw", and hope somebody else jumps up, grabs the ball, and runs with it.

I don't like the thought of being a quitter, nor of being a failure, nor admitting to have wasted the huge effort I expended over the last 3 years on these issues.  However, it would be an even greater disaster to ignore this setback, then blunder on to an even greater waste of time and effort, or the further polarization and entrenchment between the CFO and Small Flocker factions.

If I go forward, I have little to no personal skin in the game.  It will be mainly "for the good of all Ontario" and the new regional chicken producers who would gain from my efforts if I choose to proceed.  Perhaps in the long term there might be some advantages to what we have done so far; it's hard to know.

It's a tough decision.  That's why I need your advice.  Please call or email me with your thoughts; pro or con.


Yours truly,

Glenn

--
Glenn Black
President
Small Flock Poultry Farmers of Canada
c/o 576 Firehall Rd. P.O. Box 101
Providence Bay ON   P0P 1T0
Phone (705)-377-4039
cdn.small.flockers@gmail.com
Blog: http://canadiansmallflockers.blogspot.ca/

Small Flock Poultry Farmers of Canada is a not-for-profit organization dedicated to communicate, discuss, and advocate for the civil rights and important role that small flock poultry farmers can play (and should play) in Canadian Society.

* * *
End Email Letter


If you have any feedback, I'd like to receive it too. Call, email, or post your comments below, whether pro or con.

Monopoly Vs. Competition

Yesterday, we Blogged about Does SM create higher prices?
Today, we will look at compare and contrast monopoly vs. competition.  Does a competitive supply system really perform better than a monopoly?

First, I propose and assume that both monopolies and competitive suppliers must operate within a rules-based framework that retrains, guides, and enhances their performance.  Without that framework, the system will be worse for it, and has a high likelihood of spinning out of control, and becoming a disservice to its stakeholders and owners.  For example, selling addictive drugs can be highly profitable, but is not in the long term best interest of society, so it is made illegal, and becomes part of the rules-based framework.  If this was not part of the rules-based framework, short turn optimums can lead to long term dysfunction.

There is a 37 minute video on YouTube called "Sticky Prices Microfoundations in a Supply Chain Agent Based Model", by Ernesto Carrella, Dept. Computational Social Studies, George Mason University, Fairfax VA, USA. which explores the differences between a monopoly and a competitive market.  

Figure 1:  With zero knowledge of the rules, the computer simulation of a Monopoly
is able to discover the maximum profit point (22 units of production and 79
units of price) by adjusting production and price every 20 days.

Figure 2:   With zero knowledge of the rules, the computer simulation of a
competitive market is able to discover each supplier's maximum profit point.
Note that with the same market demand (ie. q= 101-p), the competitive market
with 5 suppliers has an optimum price at 58, instead of the optimum price
in a monopoly of 75. 

From this presentation, we get Figure 1, where we see the output from a computer simulation of one firm with 100% market share (ie. a monopoly) doing price discovery to maximize their profits by adjusting their quantity of production and selling price.  With no prior knowledge of the optimum (22 units of production at 75 units of price), the system is able to seek and discover the optimum (Marginal Benefit vs. Marginal Cost).  To help achieve stability, adjustments in production were assumed to occur every 20 days, allowing time for successfully seeking the optimum without excessive hunting, instability, overshoot, or noise.

In Figure 2, we see a similar computer simulation for a competitive market with 5 suppliers, all who compete for market share against each other by adjusting their prices and their production, each seeking to maximize their individual profits.

The wide, black line, fluctuating above and below the optimum value in Figure 2 is formed by the 5 suppliers continuously jostling for a better position in the market place.  There is never a feast or famine, the market is always well served.  There just needs to be a small amount of inventory in the system to cover this day to day fluctuation in the system.

Even though the competitive market simulation uses the same price-demand function as the monopoly (ie. q= 101-p where q= quantity produced, and p= price market is willing to pay), the optimum price in the competitive market place is 58, which is 29.3% cheaper than the monopoly market optimum price of 75.

This computer simulation, and many others like it, clearly show that monopolies cause or contribute to higher prices in the market place.

What are the reasons that justify the government purposely creating monopolies in supply management goods?  SM Mafia argue that this is a necessary evil so that farmers are protected from the foreign producers in low wage, low cost producing countries, thereby achieving domestic food security.

Unfortunately, this assumes that there is no other alternative than a monopoly.

In fact, that is an assumption that is un-necessary.

For example, the SM system could reward the most productive producers with additional quota, while the least productive are frozen with the quota they have already been given.  In this way, the system gets more and more efficient over time.  There are many other alternatives.  However, to say there is no other solution is false, mis-leading, and self-serving to the SM Mafia's special interest, and against the greater good that the public is owed.

Why, oh why is  this obvious error allowed to continue?

Does SM create higher prices?

In a recent posting on Better Farming, another person repeats the often made claims that Supply Management ("SM") doesn't create higher prices for the commodities that they control.  He provides the case of Australia and New Zealand as proof positive.

I assume he is referring to the removal of SM from their dairy industry in New Zealand.

For those interested, the Globe & Mail provides a good, short history on SM in New Zealand, why New Zealand developed the way it did, and then chose to abandoned SM, starting around the 1980.

I agree that doing away with, or modifying SM in Canada will not necessarily lower the price of previously SM commodities in Canada.  The world is complex, many factors interact to create the outcome.  Not all economists agree why there are "sticky prices" (also called nominal rigidity, market inertia, or market friction).

In 1998, Alan Blinder and others surveyed 100 corporations on how and why they made changes to their prices, so as to compare real-world actions against the 12 prominent theories economists have used to describe price stickiness.  Blinder wrote the book on price stickiness, called "Asking About Prices:   A New Approach to Understanding Price Stickiness", 400 pages, ISBN 978-0-87154-121-5, $34.95,

Alan Blinder is Gordon S. Rentschler Memorial Professor of Economics at Princeton University, where he has taught since 1971. He also founded and directs Princeton’s Center for Economic Policy Studies. He has served as vice chairman of the Board of Governors of the U.S. Federal Reserve System and as a member of the US President’s Council of Economic Advisers.  To me, it sounds like he might know what he is talking about.

Why don't companies change prices more frequently than they do?  The #1 reason provided was:

"It would antagonize or cause difficulties for our customers" which was 20.9% of all responses received (41 responses out of 196 total responses, from 151 firms.

Here is the survey answers received (click on graphs & tables for larger version):

Why don't you change your prices more often?, survey results from Blinder et al, for
151 US firms in various industries, 1998.

The top 6 reasons provided represent 81% of all answers received (ie. Pareto's "Vital Few").

Reasons for not changing prices more frequently.  Source:   Blinder et al.

Organizations tend to care about how customer's feel when they realize that angry or disrespected customers tend to get even by voting with their feet and/or wallets, leaving you for your competitors.  With a monopoly, that can't easily happen, so monopolists tend to be less concerned about what customers think or do.  This would mean that the top two reasons don't apply to monopolists, so they are ready to change prices much more easily, in both frequency and magnitude.

Blinder also provides data on the 4 major driving forces on those who change prices, and how long before a price change occurs after that exogenous event (ie. outside forces cause a change, then firm decides to change their prices in response):

How long after an exogenous trigger event does the firm change their prices?
Time lag in months.  As expected, it can be as fast as the same day for a firm
suffering cost increases (Mean - 3 Std. Deviations or zero, whichever is greater),
to as long as 15 months for a firm experiencing a decrease in their costs before
they pass those savings on to their customers (Mean + 3 Std. Deviations).
Source: Table 4.3, Blinder et al.

The firms were asked why they tend to avoid raising prices before their competitors do.  An overwhelming majority said,

"If we raised our prices first, we would lose too much business to low price competitors."

Obviously, not a concern when you're running a monopoly with 99.96% market share.  Guess why Canada's SM Mafia love raising prices on a consistent basis, like clock work?

Canada's Chicken Mafia are obviously not troubled by "Sticky Prices",
they make absolutely sure to raise prices almost continuously, rain or shine,
for the last 17 years and counting, 3.54%/yr price increase on average.
Graph from SFPFC's Blog posting on Feb. 28, 2013
Chicken Price Parity Will It Ever Come?

Flexible pricing is the opposite of sticky prices.  The most flexible pricing occurs when every trading opportunity is priced on a 1-off basis, without regard to any previous trades made.


Sticky prices serve a useful purpose in the marketplace.  In one simple model used to investigate sticky prices,

As I understand it, to get price reductions, there has to be:

1. a free market,
2. effective price discovery,
3. no or minimal collusion by the major players
4. a competitive marketplace, and
5. adequate slope on the price-volume supply curve
6. low or insignificant barriers or thresholds to the entry of new players
7. natural consequences (ie. bankruptcy, consumer shunning, etc.) for poor suppliers.

Without all of these and more factors, prices tend not to change for the better.
One of the biggest drivers of price changes are competitors.  If a competitor raises or lowers prices, other suppliers tend to follow the lead, or at least, it prompts them to reconsider their current strategy, and decide if they want to join, stand pat, or go in the opposite direction.  Witness the wave of retail gas price changes that often occur once one gas station bites the bullet, and changes their price.

The second biggest factor is the slope of a supplier's price-volume curve.  This means that there must be a significant difference to the total profits of the supplier if they are to go to the work and hassle of optimizing their price vs. volume factors (usually means low overhead cost suppliers are more motivated to change first in a competitive market).

There also must be low thresholds for new people to enter the marketplace.  Without this, the veterans often get sloppy and complacent over time, become less and less efficient over time, and don't take care of their customer's best interests.

When suppliers are saved from the natural consequences of poor service (ie. government grants, favors to "friends", regulatory entrapment and changing the rules in favor of status quo, etc.), the pain in the marketplace is allowed to continue a little longer, and to a greater degree.

Economists have found that price changes can occur second by second (ie. Chicago Board of Trade commodities), to as long as a 4 year cycle, but the median is around 1 year between price changes.  For more info, see Sticky Price Manifesto and Nominal Rigidity

To reach equilibrium, it usually takes between 3 to 7 time constants to get over 90% of the resulting price adjustment effect to have occurred.

We must therefore hold off in jumping to conclusions about price effects until 3 to 7 years have passed.

For example, someone who understands how the world works won't check the status every day on an acorn that they planted by digging it up to check for root development, then giving up in just seven days because nothing seems to have occurred as assumed.

It takes longer, you must have patience.

When SM is removed, either by government changing the laws, or by consumers bypassing the laws and SM's monopoly, we need to ensure that the new system meets the 7 requirements listed above, and we will soon enjoy the more affordable commodities Canadians deserve, and will enjoy more and more.

Tribunal Hearing: CFO's Motion To Dismiss my Appeal

CFO's Motion to Dismiss hearing has been completed.  The Tribunal will take the next 30 days to decide whether our appeal will be allowed to proceed, or killed so as to maintain the chicken supply management status quo.

As Blogged previously (see SFPFC's Ball is in Tribunal's Court), I filed an appeal with the Ministry of Agriculture Appeals Tribunal of the actions, inactions, and decisions of Chicken Farmers of Ontario ("CFO") and Ontario Farm Products Marketing Commission ("OFPMC").

Shortly after receiving my Notice of Appeal, CFO notified the Tribunalthat they didn't want to discuss these issues raised, and would be filing a Motion to Dismiss my appeal.  The appeal was held in Guelph ON on May 14, 2014, from 9:30 AM to about 4:00 PM.

There were 3 lawyers who were assigned to the Tribunal.  These were lawyers who work in private practice, and have been appointed to hear the cases assigned to them for the Appeals Tribunal.  There were 2 lawyers (articling law students?) from London ON, a staff member from CFO, 2 Tribunal staff members, a staff member from OFPMC, and Jim Rohman, a Blogger and agriculturee reporter who was kind enough to come from Kitchener ON to cover this trial, then Blog on his perceptions (see link above).

The Tribunal Hearing was all very professional, cordial, and respectful.  I felt that our arguments were listened to by all members on the Tribunal Panel.

CFO went first, as it was their Motion To Dismiss.  The lawyer for CFO, Mr. Spurr, took about 1.5 hrs to present his arguments in favor of CFO's motion.

Since OFPMC was so closely aligned with CFO, Ms Michelle Ireland, lawyer for OFPMC, was allowed to go next.  She confirmed that OFPMC was in full agreement with everything that CFO said.

Finally it was my turn. The Tribunal offered to do an early lunch, and I start after lunch, or I start before lunch, and resume to finish after lunch. Calculating the importance of getting immediacy to respond to CFO's case before lunch could solidify these opposing views without the balance provided by my alternative views, I decided it best to do my prepared presentation before lunch, then argue against what CFO had presented.  I accepted the Tribunal's offer to get started on my arguments immediately, then call lunch, and finish my presentation after lunch. 

My viva voce [Latin for "live voice"] arguments are available as Appellant's Viva Voce Arguments.  The case law and other documents referred to in the foot notes are indexed and available in the Submissions Brief (see below) using the Footnote # sequence.

 I was required to submit copies of all the case law and other documents to which i referred and relied upon during my viva voce arguments that I presented at the Tribunal Hearing.  A copy of all these documents has been submitted to the Tribunal as the Appellant's Viva Voce Arguments Submissions Brief (Version A01) which you can download and review (Caution:  it's a 29.16 MByte Adobe Acrobat pdf, with 1,623 pages, so dialup Internet users will be a lifetime getting it downloaded).  In Adobe Reader, bookmarks are activated by clicking on a blue ribbon symbol near the top of the left margin of the Reader window.  The references are bookmarked in this file using the format:   XX_TitleDescription where XX is the Footnote # in the Appellant's Viva Voce Arguments, and TitleDescription is a short description of the document starting at that bookmark.

In this preliminary version of the submission's brief, I have been unable to obtain the following cases and reference documents:

• Footnote #4:   United Nations Committee on Economic, Social and Cultural Rights, Responses to the Supplementary Questions to Canada’s Third Report on the International Covenant on Economic, Social and Cultural Rights, 1998, UN Doc HR/CESCR/NONE/98/8       I have a request in to Heritage Canada to supply me this document.
• Footnote #19:   Lorne Sossin, Boundaries of Judicial Review: The Law of Justiciability in Canada, 2nd ed., ISBN: 978-0-7798-4933-8 (Toronto:Thomson Reuters, 2012) at pg. 244.   I have an inter-library loan request for a copy of page 244 of this textbook submitted to Osgoode Law Library at York University.  In the interim, I have included a Book Review on the text, and the Table of Contents showing the item referenced on pg. 244.

Now we wait for the Tribunal's decision.

Canadian Chicken At Risk?

They signed my petition, but added that they support having Canadian chicken to feed Canadians.  They were afraid that my actions threatened to open the flood gates of foreign chicken into Canada, sweeping away Canadian farmers.

Good question.

Legitimate fear?

Is there any substance to this potential risk?

I have previously explained that under WTO (World Trade Organization) Treaties, Canada is required to allow 7.5% of the previous year's domestically produced kilograms of chicken  to enter Canada at a reduced import tariff, which is called TRQ (Tariff Rate Quota).

I have also previously Blogged about IREP chicken that is imported for the alleged purpose of processing that chicken in Canada, then re-exporting it out of Canada as a value-added product.  I say alleged, because many tonnes of that chicken gets "misplaced", mysteriously disappearing inside Canada, and is never exported.  This is cheap, US chicken (or other cheap chicken) that disappears; chicken that's 300% cheaper than domestic chicken.  The oppression and abuse of monopoly-priced chicken enforced by the Chicken Mafia ensures there is a white hot market for cheap US chicken in Canada, just like smuggled cigarettes.

Cheap chicken is the same as cash, a fungible asset. It's almost as good as cash, and easily disappeared for quick, un-traceable cash, if you know the right people.

When you add up all the imported chicken, we consume about 75% domestic chicken, and about 25% imported chicken.

As chicken prices drop with the Federal government's lowering of the non-TRQ import tariff, consumption of chicken will increase.  If the price of chicken in Canada falls, perhaps the chicken farmers, or the producers no longer want to participate to the same degree as they previously did (ie. it's no longer worth their while to produce chicken). This may mean that the amount of domestic chicken produced will drop, and the resulting shortage in chicken available will stabilize prices.  In the short term, this may increase chicken prices more than before the non-TRQ tariff reduction occurred.

In the alternative, the Chicken Mafia may have a change in heart, and support the non-TRQ tariff drop.  As market prices of chicken drops, they make it up on quantity sold.

If the government doesn't get scared and stop, but continues to lower the tariff on a steady basis, eventually it will become of greater and greater interest to Canada's chicken farmers to produce more chicken to feed the lowers prices and the greater demand.  If Canada's Chicken Mafia refuse to step up and serve the need, eventually the import tariff will attract foreign chicken to come to Canada and serve the domestic need.

I would prefer that Canada's Chicken Mafia choose to continue in their full participation, but it's a free country.  They're big boys.  They can make up their own mind.

If Canada's Chicken Mafia attempt a "work to rule" approach to frustrate the dropping non-TRQ tariff rate, eventually foreign chicken suppliers will be able to significantly with increased imports into Canada.  As a foreign brand, they need to gain consumer confidence and market share.  The incumbent brands have the advantage, so foreign brands will likely drop their price below the current market price.  Chicken price wars have just started.

Let's take a monopolistic price gouging example

Soon after Dupont invented nylon in  Feb. 1935 it soon became the most profitable product in the history of the company, totally changing the company's focus.  Dupont tightly controlled the market for nylon, and the market price.  Many felt Dupont was price gouging its customers.  For the next 15 years of the patent, Dupont gained between 33% to 50% of its profits from just one product:  nylon.  When the patent ran out, competitors started manufacturing nylon substitutes, and the price dropped sharply.  Realizing that all of DuPont's competitors had built their own nylon manufacturing plant in preparation for the ending of the patent, DuPont finally dropped the market price for nylon in the last few months before the patent ended.  By that time, it was too late.  The competitor's plants were built and ready to go, no matter what DuPont did to fiddle with the price at the last second.  Most customers were upset at having been gouged for 15 years, and defected in drove's to DuPont's competitors.  DuPont's monopoly and unlimited power on the nylon market came to an end within hours after the patent expired.

Perhaps the Chicken Mafia can learn a lesson from DuPont.  Price gouging of consumers creates many long memories, ready for revenge when the chance comes.

End of the Empire?

My facts were challenged in a posting I made on the Better Farming website about the failure of the Pullet Growers to join Supply Management.  That posting was copied, enhanced, and posted on this Blog as Pullets Pooched.


The BF comments suggest some people think Supply Management was a great idea 50 years ago when Bill C-176 was passed in Dec. 1971.  Some of those think Supply Management is still a good idea.  They question how it could still be around 50 years later if it was a bad idea.  They assume my facts are all screwed up when I suggest that the end of this bad idea may soon be here.  I acknowledge that those people exist, and have the right to their opinion.


My response to them was as follows:

I want to be sure I have accurate facts.  I appreciate you taking the time and effort to correct or clarify dubious facts.  You state there are errors.  Exactly where?  Please be specific.

Complex systems are affected by many factors.  Neither I, nor anybody else I know can predict the future.  If a system is complex, non-responsive to its stakeholders, and contrary to the best interest of its stakeholders, then I define that as a "bad idea".

Back in 1965 when Chicken Farmers of Ontario was formed, farmers were trapped and abused by the powerful upstream feed producers, and the downstream processors and distributors.  The consumers were being abused by the system too.  In Dec. 1971, a badly flawed Bill C-176 was again before Parliament, was passed and created Supply Management in Canada, so as to help the farmers.

Today, how much control, pressure, and influence do the feed mills, AOCP, and the downstream chicken distributors have on the farmers and the overall system?

To me, it seems that these large corporations have as much or more control and power as back in 1965.  Did Supply Management fix anything?

It appears that it increased the powers of the chicken farmers, and they have slowly joined forces with the upstream feed dealers, and the downstream processors and distributors, and started changing the system to the advantage of their special interests; growing in wealth, power, and prestige.  Statistics Canada reports in 2010 that chicken and egg farmers are the best paid farmers in Canada, with a median income of $90,250 per year, 21% higher than the median income of all farmers.  Do chicken & egg farmers work 21% harder than grain farmers?

The lowly consumer pays for all the benefits and excesses that everybody else takes for themselves.  If Supply Management was installed back in 1971 to help the farmers, when will this legislation be fixed so as to help the chicken consumers?

That date is unknown to me.  Governments work in mysterious ways.  If you have a crystal ball and want to take a guess, please do so.

All I am able to say is that the longer the abuse and oppression of consumers and small flockers continues, the higher the probability that change will eventually occur.  I believe that time will soon be here.

I have filed an Appeal with the Ministry of Agriculture Appeals Tribunal to expose all the issues I have researched in the last 3 years, and the relief I seek for consumers and small flockers. CFO has filed a Motion to Dismiss my appeal, wanting to continue the secrecy and continue the abuse and oppression.  CFO's Motion to Dismiss will be heard at the Appeals Tribunal in Guelph on May 14th at 9:30 AM.

Perhaps the end of this bad system and its abuse and oppression will end sooner than anybody thought possible.

Glenn Black
Small Flock Poultry Farmers of Canada

Pullets Pooched

Better Farming broke the story that the Pullet Growers application to join the millionaire's club of Supply Management has been denied.

I can imagine that Andy DeWeerd and his team are quite disappointed with the news.  The Egg Farmers chipped in huge piles of cash to fund this application.  Unless Andy and an army of paid lobbyists can change the Minister's mind, it will be money thrown away, added to the bill that egg consumers will be eventually billed through higher egg prices.

Small Flock Poultry Farmers of Canada raised a number of important issues, see our Blog postings:

• Pullet Parasite: $11 million/yr Screwing of Canadians
  
  
• Questions for FPCC and PGC

Small Flockers also made a submission to the government hearings, but our comments were too late to be entered on the record (at least officially).

Perhaps Andy (or his successor) will re-work their application by fixing the many fatal flaws that we and others identified in the Pullet Marketing Board application, and re-submit their application. 

Maybe they will give up.

From this vantage point, it appears that the tide has turned on Supply Management in Canada.  It's all down hill from here.

No imperial system lasts forever; most are 200 years or less (see Empires with Expiration Dates). The longest surviving empire was the Roman Empire in the East, active from death of the Emperor Theodosius in 395 AD, till the sack of Byzantium by the Ottoman Turks in 1453 AD, a total of 1,058 years.  One of the shortest was Canada's Joe Clark, who ruled the Canadian Parliament for just 65 days (sworn in on June 4, 1979, but Parliament only started sitting on  Oct. 9th, and a non-confidence vote ended his reign on Dec. 13, 1979 for a total of 65 days in power).

The really bad ideas, like Supply Management, will burn out far sooner, perhaps around the 50 year point which they recently celebrated (or soon will).

If it's Contaminated, Is It Food?

Why no answers from CFIA or Health Canada about contaminated chicken being sold as food, contrary to Canada's Food & Drug Act?

I asked the following 4 questions of Health Canada on 2013-09-03 13:38 PM (see below).

The Web support team of Health Canada quickly acknowledged receipt of my questions, then forwarded the questions to Health Canada's Food‐Aliment <Food‐Aliment@hc‐sc.gc.ca>  Department on 2013‐09‐03 2:04 PM saying:

For appropriate action, please and thank you!
Food Directorate
Health Products and Food Branch
Health Canada

So far, I have received nothing back from them.  I have now requested the answer again, and an answer on why the delay, with copies to the Minister of Agriculture & Agri-Foods, and the Minister of Health (who share responsibilities for CFIA).

Here are my questions, still without answers:

Unanswered Questions from CFIA and Health Canada

I understand that Canada's Food and Drugs Act, Article 4 states:

No person shall sell an article of food that:
(a) has in or on it any poisonous or harmful substance;
(b) is unfit for human consumption;
(c) consists in whole or in part any filthy, putrid, disgusting rotten, decomposed or diseased animal or vegetable substance;
(d) is adulterated; or
(e) was manufactured, prepared, preserved, packaged or stored under
unsanitary conditions.

I also understand from http://www.hc‐sc.gc.ca/fn‐an/legislation/acts‐lois/act‐loi_reg‐eng.php
that:

"All health and safety standards under the Food and Drug Regulations are enforced by the Canadian Food Inspection Agency. The Agency is also responsible for the administration of non‐health and safety regulations concerning food packaging, labelling and advertising."

I also understand from http://www.ncbi.nlm.nih.gov/pubmed/22221353

J Food Prot. 2012 Jan;75(1):34‐40. doi: 10.4315/0362‐028X.JFP‐11‐206.
Campylobacter, Salmonella, Listeria monocytogenes, verotoxigenic Escherichia coli, and Escherichia coli prevalence, enumeration, and subtypes on retail chicken breasts with and without skin; Cook A, Odumeru J, Lee S, Pollari F. Source: Laboratory for Foodborne Zoonoses, Public Health Agency of Canada, 255 Woodlawn Road West, Unit 120, Guelph, Ontario, Canada N1H 8J1.   angela.cook@phac‐aspc.gc.ca

and other similar studies that between 30% to 80% of all raw chicken meat sold in Canada is contaminated with E. Coli, Salmonella, Campylobacter, and/or other human pathogen.

I therefore have the following questions:

1. Are E. Coli, Salmonella, Campylobacter, and/or other human pathogen considered by CFIA to meet the definitions of one or more prohibited substances or processes as defined by Article 4 of Canada's Food & Drug Act? If yes, which ones? If no, please fully describe and justify CFIA's position.

2. Is there strict liability for Article 4? In other words, if someone takes "reasonable precautions" to avoid all of these prohibited conditions or processes, is that good enough to avoid prosecution and conviction, even if somebody dies from resulting food poisoning? Is mens rea required to be proved in CFIA's opinion?  If someone knew, or ought to have known that an article of food for sale (or sold) was contaminated, is that sufficient to prosecute and obtain conviction in CFIA's opinion?

3. Is CFIA directly (or indirectly through contractors or delegated authority/responsibility to others) doing any surveillance of raw chicken at chicken producers (ie. farms), slaughter plants, further processing plants, wholesale distribution channels, or at retail stores for contamination of raw chicken with E. Coli, Salmonella, Campylobacter, and/or other human pathogen? If yes, please describe CFIA's sampling inspection plan (including but not limited to sampling frequency, sample size, sampling stratification, sample randomization, sample selection protocols, sample testing), and % of samples found to be contaminated (ie. non‐compliant to Article 4) for the past 5 years. What traceability system for samples does CFIA use so as to determine the source, brand, lot code, meat plant's CFIA or provincial registration number, distribution chain, and sampling point that is associated with samples subsequently found to be contaminated? When contaminated raw chicken has been identified, what subsequent action(s) has CFIA taken to quarantine, condemn, and/or lay charges under Article 4 or other Acts & Regulations (please provide % frequency of each outcome taken by CFIA)? If CFIA has not laid charges in all cases of contaminated raw chicken, please describe why not?

4. I understand that CFIA has recently developed meat plant procedures that will allow unlimited line speeds for the slaughtering of chicken. See MPIP (Modernized Poultry Inspection Program) Inspection ‐ No cap on the line speed. It is unlimited speed as long as process is under control. Some establishments run at >200/minute http://www.inspection.gc.ca/english/fssa/meavia/man/ch19/19‐6‐2e.shtml   Does CFIA consider that the risk of contamination to significantly increase with rising line speeds on some proportional, linear, or exponential function relationship? If a CFIA Inspector suspects or determines that chicken carcass contamination has occurred at some point on the production line in a chicken slaughter plant, what is CFIA's
policy (ie. automatically declared contaminated until proven otherwise, assumed to be OK, or some other designation) concerning all the chicken on the slaughter line that is: a) between the last known good point on the line and the moment that the Inspector first suspects or knows a carcass contamination occurs; b) between the first carcass that the Inspector suspects or knows is contaminated and the first carcass subsequently processed that is again known to have been restored to acceptable quality, all while the line is operating in a stable and statistically predictable manner for an adequate period of time;

Thanking you in advance for your prompt and comprehensive answers to these three questions, I remain,

Yours truly,

Glenn Black
Small Flock Poultry Farmers of Canada

Response to CFO's Motion to Dismiss

CFO filed a Motion to Dismiss our appeaL (see BlogPosting CFO's Motion to Dismiss Small Flocker's Appeal ), and we have now filed a response.  Our hearing on May 14th in Guelph will discuss this Motion and decide if our appeal will live another day, or die stillborn.

You can find our appeal in our Blog Posting  Tribunal Time  This is a guaranteed solution for all with insomnia or Sleep Apnea, or your money cheerfully refunded.

Here are the documents so you can read them, even before the CFO legal sharks get their fingers on them:

• Notice of Constitutional Question which was filed with the Deputy Attorney Generals for Canada and Ontario, alerting them of the constitutional questions that will be argued in the hearing.
• Our Response to Motion to Dismiss where we give the reasons to keep our appeal alive.  CFO threw every possible reason at us to shut us down, except they left out the alleged fact that my Mother wears army boot.  Perhaps I will be on the receiving end of that one during the oral arguments on May 14th.
• Our Submissions Brief is where copies of the applicable statutes, regulations, and case law is presented to all parties, so everybody concerned has the same starting point in the hearing.
• OFPMC's Response to Motion to Dismiss is just 2 pages long, agreeing with most of what CFO stated, offering a few clarifications.  It appears that CFO and OFPMC have a gentlemen's agreement that CFO will take the lead and do all the heavy lifting, and OFPMC stays out of the fray.  If that is true, that is consistent with OFPMC's prior actions:  let CFO do as it pleases.  No wonder Ontario is in the mess that we are today.
• Courier Receipts   You can watch and trace the progress of these critical courier pouches as they wind their way around the Great Lakes to arrive at their destination.  I received a major shock on pricing.  Apparently, Purolator Courier has recently designated us as a "remote region", understandable with how they are forced to use a dog sled in winter and ox cart in summer for their courier pickups.  (whoop! I forgot, we have an international audience who may not understand I was being sarcastic).  The standard envelope Puroletter is $49.69 multiplied by 2 packets, which has destroyed our budget.  We are out of money again, and I had to cash in a bunch of pop, beer, and wine bottle to afford the printing and courier bill.
• Petition Form   This is a handy form to collect signatures from your family, friends, neighbours, farm animal hoof prints, whatever, to support our cause at the Tribunal.  If you read the Response noted above, you will see that I included 7 letters/emails that support our cause.  We will have to get special permission from the Tribunal to enter on the record those that we receive between now and May 14th.  It's the best that we can do, so it will have to do.

While we wait for May 14th to arrive, we have much work to do, as follows:

1. Donations   Guess what, not only are we out of money, we are overdrawn by more than $50.00 from my personal piggy bank.
   
   I will have to drive 611 km x2 (ie. both ways)= 1,212 km. round trip, so I need gas money.  So that I'm not a bleary eyed Zombie at the hearing after getting up at 1:00 AM and driving for 6 hours, I need to come down the day before and stay overnight.  If none of you offer your tent in your backyard for a needy chicken farmer coming to Guelph, I will need to get a hotel room.
   
   Now's your chance to feel good, and help a good cause.  If you wish, I will post your name and amount of donation so all the world will know about your kind and cunning investment, or you can remain anonymous; your choice.
2. Petition Signatures   We need signatures on our petition.  Download (see above), print, and post the petition everywhere.  Take it to work, go door to door.  When filled, scan it and email it to me at cdn.small.flockers@gmail.com  I will print it off and bring them to the hearing on May 14th.
   
   Better yet, you can come running into the hearing room, out of breath, yelling,
   
   "Wait!   Wait!  I have a signed petition supporting our cause!
   I will have to disavow any knowledge of you and your dramatic yet silly stunt, but go for it if you dare.  Just leave peacefully once they handcuff you.

Thank-you for patiently checking back many times to see if I had posted something more.  I apologize for your frustration when another day went by without your Small Flocker fix.  Addiction is everywhere!  Unfortunately, I have been so busy researching and writing the response to CFO's zany motion, there was no time left to do postings.