Ms. Campos and Mr. Nissen:

I appreciate the opportunity to comment on the United States Department of Agriculture’s (USDA) proposed rule, “Onions Grown in South Texas and Imported Onions: Termination of Marketing Order 959 and Change in Import Requirements.”

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Summary
Terminating Marketing Order 959 on South Texas onions would be appropriate given that the referendum to support continuation failed. The Order does not provide useful information for consumers and gives domestic growers the opportunity to collude to create regulations that give preference to their varieties and growing conditions.

Many retailers have standards that exceed those set out in Marketing Orders, thus the additional inspection processes required to meet the standards of the Orders are redundant. Further, as retailers maintain such standards, a market for high-quality produce would remain with the termination of Marketing Order 959. Additionally, termination of the Order would increase market access for other varieties produced elsewhere, providing consumers with more choice.