Obviously you folks don't realize that this will affect everyone in the country who has farm animals. Every cow , horse chicken duck etc is going to be given a number. Each time an animal is sold, shown in a fair or dies it will have to be reported to the government. What is your opinion?

General info here.

Here is a link that might be useful: About NAIS

I find this idea a bit scary. I'm sure the government means well and views these measures as a way to prevent epidemics... but it stikes me as overkill. Also impossible to enforce. If my rabbit had ten kits and I sell two of them to my neighbour, who would know?

I'll tell you one thing... makes me glad I'm a Canadian. We may have three layers of government and strict gun laws, but I can't imagine our government trying to implement something like this. (Of course, I am tempting fate by posting this!)

Well, I wasn't going to post because I really don't have anything nice to say about the whole thing. I'll give it a whirl.

First, let me explain that I test my animals for many diseases-regulated or not. I do this because I'm starting out with breeding animals & I want to be able to control any diseases while I'm still "small" and can afford to test(scrapies being the exception, of course as that is only testable on a dead animal). I want, and have, a clean herd at this point. The last thing I need is to be quaranteened or have my animals disposed of because I failed to do my homework & bought diseased animals. I look at it like I'm investing in & safeguarding the future of my herd (goats).

I've heard of "reportable" diseases being reported to the state and absolutely NO FOLLOW UP has been performed. Given that, I don't really understand the whole purpose of them being "reportable". I do understand that these diseases could indeed hurt the general public in one way or another-but they're going overboard. There must be a better way.

Question-WHY does my state still require TB & Brucellosis when importing animals (and all but 3 or so states) have been eradicated of the disease? Why not just imports from those 3 states & out of country? (Someone please correct me if I'm wrong here). Bottom line here is the only animals being tested are those legally being transported across state lines. My point is, that by the time a disease gets to the reporting stage, too many farms/animals have been exposed and became possible carriers.

I beleive the whole idea is a scam. A scam to suck more money out of farmers, and try to control them, possibly put out of business. Voluntary and paid for today, once we all sign up, then mandatory and we'll be paying for it out of our pocket. I don't actually make a gosh darn dime on anything I may sell when looking at the whole picture(feed, shots, taxes, labor). Yet I will be supporting even more payrolls through my tax dollars to initiate, monitor, improve, control, and follow through on this program. For what? So they can continue tellimg us we can't sell raw goats milk to my neighbor even though they know the risks, one goat equals a cow in regards to pasture so we're overstocked, we can't have a rooster because he crows, our livestock guardian dog who protects his goats from attack is not protected under the law because goats aren't categoried as livestock, and one ADHD boy cannot keep his goats in his suburban neighborhood.

Scrapies tags (some states require another tag, too), are innappropriate for goats who get into EVERYTHING. Who pays for the damage from the tag being ripped off? If something happens to my $600.00 goats, i'll be lucky to get $100.00/head. We pay for it, of course. Time, labor, stress. It's too much. Tagging a chicken? Absurd.

What about the new law they're trying to pass about sales of animals over $500.00/year? Not sure if that's the proper amount, but it would include rabbits, cats, dogs, goats, horses, chickens-you name it. Why? Control. Money. Greed. I'm not sure where that issue stands right now but it's ludicrious. Sarcasm? You bet.

Thanks for letting me vent. I'll get off my soapbox now.

Darn good question and I'm interested in hearing other's take on this issue.

BrendaSue

I think it is too invasive in our private lives. We should be scared! Our personal rights have been slowly eroding over the years and it needs to stop. I didn't really like the idea of the government telling me I needed a seat belt inside my own vehicle! Did your auto insurance go down? That was a big selling point back then.

I suspect most of the diseases are coming from other countries. Maybe all these animals should be quarantined and tested before allowing them in. I know we already have several animal communicable diseases that the vet has to report if he finds it on a farm. It seems that should be enough.

I personally want Uncle Sam to stay off my farm, out of my car and out of my home! It is bad enough we have to report everything at tax time, enough!

Of course, this will provide jobs......think how many people will have to be employed to do this and we know what a super job government has always done.....................

I am always open to new ideas and I may be wrong about the source of diseases. Please feel free to enlighten me or show me the benefit of all this.

Maggie, not every animal, but all cattle, sheep, goats, swine, bison, and farmed cervids need to be tagged in Canada. You don't have to tag and report animals that remain on your farm, or die there. You do need to tag all animals in the species above with a tag which has been registered to you by a gov't approved agency before they leave your property for any reason.

This law has been in effect for several years, depending on the species.

Thanks, Sharon, for the clarification. So it doesn't apply to poultry? Odd, when you consider the worries about avian flu lately.

BrendaSue, FWIW, your mandatory scrapie (No "s" at the end of the word) ID can be tattooed on a goat. I know it doesn't solve the overall "Big Brother" problem, but it does give you a non-tag option.

The problem I foresee is that you not only need to tag, but to keep records. Not very many people in the general population are good and consistent record-keepers, let alone people who are busy handling livestock. I can foresee some pretty ugly situations if a problem is traced back to a farm whose records are lacking, and the consequences prescribed are harsh because the problem animal's lineage or herd associative information isn't clear.

I'm in Pennsylvania, and haven't heard anything about this. I'll have to tag my two ancient pet hens??

When I purchased my goats from Florida, the farm had no farm ID program in place, so when the vet drew the blood, he had to place a mandatory tag on both animals so I could fly/import them to my state. They didn't give me the option of a tattoo. I'm not sure if that was because they didn't have the tattoo kit, rushed circumstances, simply because the vet said so, or maybe airline regs. I just don't know. They were not yet registered, that may have made a difference, too-but it just didn't fly-(pun intended).

Yes, no "S", I noticed another typo in that post, too. What does FWIW mean?

Records are indeed hard to keep up with sometimes. I keep a pad near the medicine chest so I can transfer the info into my records later. Even so, sometimes I forget & they are not necessarily in date order(manual system). I guess it's better than nothing. Is there somewhere that lists exactly what records should be kept & how long? Or is it just the normal shots, parents, Id,ect? I didn't see one on the Aphis site but I'll look again, or maybe I need a completely different website?

Thanks!

BrendaSue

BrendaSue, FWIW is for what it's worth. (I had to look it up too).

Records that will make a difference if you ever have a Scrapie scare:
If born on your farm, the date of birth and the ID, origin and acquisition dates of the dam and sire, name and address of recorded owners if not you, and name address and sale date of current owners if not you. If purchased, the name and address of the seller, and the purchase date. If you sell it, the name and address of the buyer and the sale date. If it dies, the date of death and probable cause. They aren't going to care if you wormed it. They're going to care what animals were related, and what animals were in physical contact so that trace-forward and trace-back can be accomplished.

Laughing here-rough week already after the holiday. Couldn't figure that one out to save my life.

I found a sample record sheet on my states USDA page. Simple stuff to record. At least it's not a major project on the record keeping end of it....5 year retention!

Pipersville Carol-I don't think you have to as of yet, but yes, if this goes through, you would have to if they left your farm/land, or purchase them with it (I beleive). I'm not up on the bird end of it really. There's a link posted earlier to help bring you up to speed, or visit the USDA website & look for links to APHIS.

i personally believe it`s a total crock of poh, as far as the "safety concerns" part goes. i don`t think they (goverment) cares diddley squat about "our safey", they see it as another way to have more control over us: creeping socialism. i believe they don`t like the independence we farmers have, we are not corporate goons. they would love to replace our small farms with large corporate owned an run factory farms and have all of us work for them, where we could all be under more control. think about it! control the food and you control the people. heads up people, our american independent spirit is waning. i said this 20 years ago and most people thought i was some sort of weirdo, but many of them today agree with me. as i said before, heads up and pay attention to what is going on around you. we don`t need the government to regulate anymore of our daily lives; they already do too much of that. i know the real reason for this animal id program and yes it is corporate motivated.

I plan on getting eggs from out of state to incubate more chickens this spring. I also plan on selling fertile Welsummer and Buff Orpington eggs in the spring. Will I have to put my farm ID on each of the eggs? How will this work? Which comes first the chicken or the egg?

Been reading this with interest and have several comments.

Instead of relying on hearsay, please call your State's Department of Agriculture to find out if there are any regulations relating to any of the livestock you raise/sell. It is my understanding that the USDA will not be ready for this until 2009. IMHO, as a cattle producer, this is ridiculous. There are already great cattle id systems on the market. There is a consensus out there that the reason this is being delayed is due to corporate lobbying. If you will do a google search of cattle animal identification, you will probably find that in general, the corporation (specifically meat packing plants) are against this as it will add their cost of production.

I work for the government. I agree that the potential bureaucracy will probably be mind boggling. On the other hand, as a small cattle farmer (we have 30 cows), I am in favor of an id system. If the US has a BSE cow show up in the US and there has been no traceability, it would devastate the cattle producer in that the markets could hit botton. As a consumer, I would also hope that the government would have the ability to trace where meat comes from.

I think it will very likely never pass or if it does lack of funding, personel, and trying to keep track of everything will kill it. Who is going to go out and tag and track the millions of broiler chickens who live 8 weeks? Or the hundreds of cattle on free range out West? Or the 4000 cow dairys with animals going in and out and dying and being born? I can't even begin to fathom the logistics. Heck, look how slowly and inefficiently other gov. offices run! We can't even keep out or keep track of illegal aliens- how are you going to track down every chicken in 50 states?

clairegrace, that`s my point exactly. if you can`t do it you will be forced out of the business creating a void where the corporate factory farms can and will fill. these people know how difficult it will be, and that`s what they are counting on. when you say " i can`t do this, it`s too much, i`m getting out", they will say "good: another one gone". and as far as the bureaucracy; yeah, you bet. but they would love to have all of us work for them anyway, so they would killing two birds with one stone.creeping socialism!

People already keep track of their animals. I do it for productivity reasons. I can tell you the parentage, birth, death or sales information on every sheep and lamb that has been on our farm in the past 25 years. I know when a ewe who as had multiples for a few years suddenly doesn't lamb or has a single, or when the lambs grow poorly. It may be time to get rid of her. I know which ram lines have daughters with good productivity.

I also know which animals have been eliminated to remove disease from our flock.

I know which ewes and rams are good producers and which aren't. In the past 10 years we have only brought one ram onto the our farm. This is to stop disease transmission. The ram we just bought was from a farmer whom we have known for many years and who is even more picky than we are about health issues.

Dairy producers who don't keep scrupulous records would soon be out of business. The cattle producers that I know buy from known sources with good records.

Good records are a matter of good business. Even if your farm is a hobby, timely record keeping will mean that your hobby loses you less money that it would otherwise.

Very well said Sharon. Curious, do you use any kind of computer program? When you buy your rams, are you now watching for Scrapie DNA testing?

I use EweByte.

I was the main programmer/designer of this software developed jointly by the University of Guelph and the Ontario Ministry of Agriculture. It is now used internationally. All the profits go back into improving the program or supporting sheep research.

The only ram we have bought in the past 10 years was genotyped for scrapie.

Here is a link that might be useful: EweByte

I was wondering how this would affect some small farms like I have. I don't buy or sell any goats, just raise them for meat and milk. They never leave here, except for feed, mine is pretty well self contained.
Is there going to be a number limit, like if you have ten or more of any animal, or if you even have one.
I think the whole idea is pretty petty.

Forwarded from another list. Mary is with Farm for Life in NY & assists small farmers producing their own food. It is long but please read through:

MARY-LOUISE ZANONI
P.O. Box 501
Canton, New York 13617
315-386-3199

Docket No. 05-015-1
Regulatory Analysis and Development
PPD
APHIS
Station 3C71
4700 River Road, Unit 118
Riverdale, MD 20737-1238

Re: Agency Docket Number: 05-015-1

Docket ID: APHIS-2005-0044

Comments on NAIS "Draft Program Standards" and "Draft Strategic Plan"

June 29, 2005

Introduction

I practice law in St. Lawrence County, a leading dairy-producing region of
New York State. I am also the Executive Director of Farm for Life, a
nonprofit group supporting small-scale and sustainable farmers, and
citizens who raise livestock and crops for their own food. (We refer to
this last category as "home farmers.")

I have carefully examined the Draft Program Standards (Standards) and Draft
Strategic Plan (Plan) issued by the USDA (the Department) on April 25,
2005, in furtherance of the Department's proposed National Animal
Identification System (NAIS). Many aspects of the Standards and Plan appear
to create insurmountable legal, fiscal, and logistical problems. The
comments below address five categories of problems: (1) constitutional
infirmities of the proposed program; (2) an enormous economic cost to
animal owners, the States, the Department, and, ultimately, to American
taxpayers and consumers for a program likely to be ineffectual; (3)
weaknesses in the stated rationales for the program; (4) a lack of
consideration of alternative, far cheaper and more easily administered
measures which would more effectively protect animal health and food
security; and (5) a lack of notice and an opportunity to be heard for
medium-scale, small-scale, and home farmers, and for other citizens owning
livestock solely for their own use or pleasure, in the Department's process
thus far.

1. The Standards and Plan Violate Many Provisions of the Constitution.

First Amendment Violations. Many Christians (as well as persons of other
religious beliefs) cannot comply with the Department's proposed program
because it violates their First Amendment right to free exercise. For
example, the Old Order Amish believe they are prohibited from registering
their farms or animals in the proposed program due to, inter alia,
Scriptural prohibitions. The way of life of these devout Christians
requires them to use horses for transportation, support themselves by
simple methods of dairy farming (most ship milk to cheese producers, since
their faith prohibits the use of the technologies required for modern fluid
milk production), and raise animals for the family's own food. The proposed
NAIS would place the Amish and other people of faith in an untenable
position of violating one or another requirement of their most important
beliefs. Further, it is not unlikely that enactment of the NAIS as
presently proposed would force the Amish and other devout people to seek
migration to another nation. It would greatly injure the status of our
country among the community of nations if the Department's actions were to
result in the forced migration of such simple, devout, and peaceful people.

Fourth Amendment Violations. The Department proposes surveillance of every
property where even a single animal of any livestock species is kept; and
to require, at a minimum, the radio-frequency identification tagging of
every animal. (Standards, pp. 3-4, 6, 17-
18.) Perhaps the Department had in mind as its model large commercial
facilities where thousands, or in many cases tens of thousands, of animals
are housed or processed. However, aside from large livestock businesses,
there are also tens of millions of individual American citizens who own a
pet horse, keep a half-dozen laying hens, or raise one steer, pig, or lamb
for their own food. In these instances, the "premises" that the Department
plans to subject to GPS satellite surveillance (Standards, p. 10) and
distance radio-frequency reading (Standards, p. 27) are the homes of these
tens of millions of citizens. The government is not permitted to use
sense-enhancing technologies to invade the privacy of citizens' homes.
Kyllo v. United States, 533 U.S. 27 (2001). The sanctity of the home is
entitled to privacy protection in circumstances where an industrial complex
is not. See Dow Chemical v. United States, 476 U.S. 227, 238 (1986).
Therefore, the Department should abandon its present proposals, insofar as
they entail enormously intrusive surveillance against unsuspecting innocent
citizens who have done nothing more than to own an animal (a common form of
personal property under the American system of law).

Fifth and Fourteenth Amendment Violations. The proposed NAIS is the first
attempt by the federal government at forced registration in a huge,
permanent federal database of individual citizens' real property (the homes
and farms where animals are kept) and personal property (the animals
themselves). (Standards, pp. 8-13; Plan, pp. 8, 12-13.) Indeed, the only
general systems of permanent registration of personal property in the
United States are systems administered by the individual states for two
items that are highly dangerous if misused: motor vehicles and guns. It is
difficult to imagine any acceptable basis for the Department to subject the
owner of a chicken to more intrusive surveillance than the owner of a gun.
For example, whereas the owner of a long gun generally can take the gun and
go hunting beyond the confines of his or her own property without notifying
the government, the Department proposes that the chicken owner, under pain
of unspecified "enforcement," must report within 24 hours any instance of a
chicken leaving or returning to the registered property. (Standards, pp.
13, 18-19, 21; Plan, p. 17.)

Even more important than the trammeling of basic property rights under the
program is the insult to fundamental human rights which must remain free
from government interference. See Lawrence v. Texas, 539 U.S. 558, 565
(2003). These fundamental human rights include decisions about nutrition
and bodily integrity. Cruzan v. Director, Missouri Dept. of Health, 497
U.S. 261 (1990); Rochin v. California, 342 U.S. 165 (1952). Surely it is
overreaching for the Department to propose, as it has, the constant
surveillance of one's home and animals when the citizen is only attempting
to raise food for the household or for a limited local area, and there is
no intention of distributing the food on a wider scale.

The foregoing numerous constitutional infirmities are bound to enmesh the
Department and state governments in extremely costly litigation for years
to come. Therefore, please reconsider the Department's plans to institute a
program so at odds with fundamental American values.

2. Practical and Cost Impediments to Enforcement.

As discussed more fully below (see no. 5, Lack of Notice), most owners of a
small number of livestock are not even aware of the USDA's proposals at
present (see, e.g., "Helping to Head Off A Livestock I.D. Crisis,"
Lancaster Farming, May 28, 2005, p. A38, discussing difficulties of
informing all farmers of the NAIS requirements). The Department does not
plan to issue "alerts" to inform livestock owners of the requirements until
April 2007, only eight months prior to the date when it will be mandatory
to submit the GPS coordinates of one's home and the RFID of one's animal to
the USDA database. The final rule governing mandatory home and animal
surveillance will not be published until "fall 2007" (Plan, p. 10), leaving
only a couple of months, at best, for notification and compliance before
January 2008. The citizens apt to own small numbers of livestock are rural
dwellers who have chosen their way of life partly as a means of escaping
excessive corporate and government bureaucracy. These factors suggest the
likelihood of a noncompliance problem of heroic proportions. In addition,
the proposals call for an animal owner to report, within 24 hours, any
missing animal, any missing tag, the sale of an animal, the death of an
animal, the slaughter of an animal, the purchase of an animal, the movement
of an animal off the farm or homestead, the movement of an animal onto the
farm or homestead. (Standards, pp. 13, 18-19, 21.) The Department plans to
demand the following actions by all animal owners according to the stated
timeline: "January 2008: All premises registered with enforcement
(regardless of livestock movements). . . . January 2008: Animal
identification required with enforcement. . . . January 2009: Enforcement
for the reporting of animal movements." (Plan, p. 17; emphasis added.)
Moreover, the NAIS will "prohibit any person" from removing an I.D. device,
causing the removal of an I.D. device, applying a second I.D. device,
altering an I.D. device to change its number, altering an I.D. device to
make its number unreadable, selling or providing an unauthorized I.D.
device, and "manufacturing, selling, or providing an identification device
that so closely resembles an approved device that it is likely to be
mistaken for official identification." (Standards, p. 7.)

Thousands of enforcement agents would have to be employed to find the
potentially tens of millions of unregistered premises and violations of the
animal identification and animal tracking requirements. Indeed, beyond the
expense, the spectre of these government agents entering onto citizens'
property to find possible unregistered homes and animals brings to mind the
actions of a frightening police state, not the actions of a government
agency whose mission should be to assist rural people, not to hunt them
down.

The proposed NAIS makes clear that animal owners will have to pay the costs
of registration and surveillance of their homes, farms, and livestock.
("[T]here will be costs to producers," Plan, p. 11; "private funding will
be required. . . . Producers will identify their animals and provide
necessary records to the databases. . . . All groups will need to provide
labor . . .", Plan, p. 14.) In fact, the financial and labor requirements
for animal owners would be huge. Livestock owners, even the owner of one
pet horse who takes rides off the property, would have to invest in RFID
reading devices and software to report information. The Standards and Plan
do not enlighten us about the amount of these costs. Many rural people do
not have (and do not want) computers at home and even those who have them
often cannot get high-speed connections. Even if some system of written or
manual reporting were allowed as an alternative, this would only greatly
increase the labor required for citizens who elected it. Indeed, with or
without access to technology, the labor requirement would be huge.

Consider a small-to-moderate size dairy, milking 160 head. A total of about
150 cattle (75 bull calves, 50 cull cows, and 25 excess heifers) would
leave such a farm each year. The farmer would be required to report each
tagging of an animal and each event of an animal shipped off the farm (300
reportable events). Plus let's assume that the farmer has 50 growing
heifers outside during pasture season, and, as heifers are prone to do,
they breach the fence and go off into the neighbor's fields twice during
the season, and the farmer has to herd them back. This results in an
additional 250 reportable events 50 instances of heifers having to be
tagged (strictly speaking, the rules would require tagging before they
leave the farm -- Plan, p. 8 -- one hopes the enforcement agents might
overlook the technical violation of the farmer perhaps not being able to
tag them until they are herded back), plus 100 instances of individual
heifers leaving the farm, and 100 instances of individual heifers returning
to the farm. The farmer now has at least 550 total reportable events, or an
average of over 1.5 times per day, 365 days per year, that the farmer must
interrupt his or her other work and submit data on premises identification,
animal identification, and an event code to the USDA's database. Further,
the animals shipped from this farm would generate at least an additional
600 reportable events per year for other stakeholders (i.e., 75 bull calves
into and out of the auction house, then onto a veal farm, off the veal
farm, and to a slaughter facility (375 events); 50 cull cows into and out
of the auction house, then to a slaughter facility (150 events); and 25
heifers into and out of the auction house, then onto new farms (75 events).
Thus, only one modest-sized farm would generate well over a thousand events
per year requiring recordkeeping and reporting.

Indeed, the only economic advantage of the NAIS is an advantage to the
corporations that manufacture high-tech tags, ID equipment, and the vast
amount of hardware and software required for the system. This "advantage"
is totally outweighed by the economic costs to both large and small
segments of the livestock industry and the social and civil-rights costs to
small producers, home farmers, and non-farming animal owners. The
Department's mission should be to protect and foster agriculture, not to
protect and foster manufacturers of tagging and computing equipment.

3. Infirmities in Supposed Justifications.

The primary justifications given by the Department for the NAIS are animal
health issues, specifically, foot-and-mouth disease (FMD) and bovine
spongiform encephalopathy (BSE). (Plan, p. 1.)

There has been no FMD in the United States for over 70 years and the
possibility of its reintroduction is speculative. Of course, FMD is a viral
disease exclusively of cloven-hoofed animals and does not infect humans.
Moreover, FMD is primarily an economic disease. Animals may become
temporarily lame or refuse to eat because of the lesions caused by the
virus, but nearly all animals recover within a few weeks. Thus, the primary
effects are a setback in weight gain for animals produced for meat, reduced
lactation in dairy animals, and restrictions on exports for countries where
FMD is present. NAIS proponents need to carefully consider whether a
disease of no risk to humans, not present in the United States, and only of
temporary effect to animals, can possibly justify a gravely flawed system
such as the proposed NAIS.

There have been only two known cases of BSE in the United States. There
have been no cases of humans contracting, while within the United States,
the related condition of variant Creutzfeldt-Jakob disease. The Department
has put into place all necessary safeguards and assures that the American
beef supply is safe and that transmission of BSE prions to humans cannot
now occur in the United States. After the banning of meat and bone meal
from ruminant feeds in 1997, any possible instances of BSE would now occur
only in relatively old cattle. Obviously, the number of such cattle
diminishes yearly and even assuming the longest potential lifespan of
cattle, any slight possibility of BSE in the U.S. cattle herd will
disappear in about 12 to 15 years. Thus, BSE is a very low-incidence,
self-limiting, rapidly disappearing disease in the United States. BSE has
not resulted in transmission of a single case of human disease in the
United States. BSE is, rather than a health threat, primarily an economic
problem affecting exports and imports of cattle and beef. It is apparent
that the Department's position that sufficient controls are in place is
correct. Thus, as with FMD, BSE cannot justify the creation of a huge,
permanent, expensive, and intrusive NAIS.

A further asserted justification is the risk of "an intentional
introduction of an animal disease." (Plan, p. 7.) Far from preventing
deliberate interference with the livestock industry or food supply, the
proposed plan creates numerous new opportunities for mayhem. The
Department's own proposals suggest that the counterfeiting and theft of
tags will quickly become a problem. (Standards, p. 7.) Application of
counterfeit tags could easily mask the introduction of a sick animal into a
facility containing thousands or tens of thousands of other animals.
Consider also the scenario in which someone brings a sick animal to a
slaughter facility and falsely reports its farm of origin as a large
operation with tens of thousands of animals in production. The resulting
baseless scare has the potential to create a huge disruption of food
supplies and the profitability of animal agriculture, regardless of whether
the hoax might ultimately be discovered.

4. Lack of Consideration of Alternate Methods.

As discussed above, the NAIS is a violation of civil rights, extremely
expensive and burdensome, likely to be ineffective, and not justified by
human health, animal health, or food safety considerations. Given these
numerous and probably insurmountable flaws, the Department should carefully
consider alternative methods that would be much more successful in
accomplishing the stated objectives.

The security of America's food supply and the resilience of livestock in
the face of diseases are best served by the decentralization and dispersal
of food production and processing, and of the breeding and maintaining of
livestock. If more citizens could depend on food raised and processed
within, say, 100 miles of their homes, the danger of large-scale
disruptions would be minimized, the costs of transport would be less
affected by volatile fuel prices, and any food-borne diseases that might
occur would be contained by the natural geographic limits of the system.
Similarly, if animals, such as cattle, for example, are kept in small herds
of, say, ten to a hundred animals, infectious diseases will have much more
difficulty in spreading beyond a discrete geographical area. In this
regard, the NAIS would actually be counterproductive, since it would tend
to drive more small producers and small processors out of business. Thus,
the Department should consider an approach and programs to support and
promote smaller, local herds and local food processing.

Smaller herds would also entail the possibility of many more closed herds
than our agricultural model supports at present. Especially in dairy
operations, where artificial insemination is the norm, only modest
government incentives would be necessary to encourage small and medium
sized producers to maintain closed herds. In the case of beef cattle, and
of other species not commonly using AI, a state-
level program requiring vet checks and recordkeeping for new animals
introduced to herds would be obviously far simpler, as well as more
effective, than the proposed NAIS.

Another contribution the Department could make to food safety and animal
health at low cost would be the encouragement of integrated
producer/processor operations. Despite economic and marketing forces that
are stacked against them, many small producers throughout the United States
still process and market their own dairy products, or raise meat that is
processed on site or at small local slaughterhouses and distributed
directly to consumers or to local retail outlets. Consumers love not only
the high quality of such products, but also the assurance that comes from
actually knowing the farmers who, for example, finish their steers on grass
and have the butchering done at a local small business. Very modest
programs of financial incentives and encouragements to the streamlining of
federal and state permitting procedures would help this hopeful segment of
our nation's agriculture to flourish.

Many recent developments in the agricultural sciences have demonstrated
time and again that the least-cost and least intrusive method is the most
effective and protective of health. For example, leading-edge research now
rejects the routine deworming of all cattle and sheep, in favor of
eliminating parasite-susceptible individuals as breeding stock. The
once-heralded approach of routine deworming, it turns out, only resulted in
resistant super-parasites and perpetuation in the gene pool of animal
families naturally subject to the largest infestations. Similarly, in
recent years our thinking has done an about-face on the subject of routine
use of antibiotics in the feed of beef steers and dairy heifers, and in
udder infusions for dry dairy cows who exhibit no clinical mastitis. Once
heralded as a means of increasing weight gain and providing extra insurance
against fresh-cow mastitis, those routine uses of antibiotics in healthy
animals are now rejected because they are known to produce resistant
super-bacteria that may cause not only animal infections, but human
infections. Unfortunately, it takes years for knowledge gained in the
latest research to reach the farmer, and the inappropriate overuse of
anthelmintics and antibiotics is still very common. Thus, another low-
cost and simple initiative the Department could undertake would be an
intensive educational initiative to end the inappropriate use of drugs in
animal agriculture.

The foregoing are just a few of the many possible more effective
animal-health and food-safety initiatives to which the Department could
devote its finite resources. It is appropriate for the Department to study
fully these alternatives before concluding that a bloated NAIS bureaucracy
is our only alternative.

5. Lack of Notice and an Opportunity to be Heard for Small Farmers and
Animal Owners.

The original impetus for a nationwide animal I.D. program came from a
private membership group, the National Institute for Animal Agriculture
(NIAA). (Plan, pp. 1, 4.) The members of the NIAA include such well-known
industry entities as Cargill Meat Solutions, Monsanto Company,
Schering-Plough, and the National Pork Producers Council. Further, of those
NIAA members listed as "National Associations and Commercial
Organizations," nearly 25% appear to be manufacturers and marketers of
identification technology systems. (animalagriculture.org/aboutNIAA/members/

memberdirectory.asp). In April 2002, the NIAA "initiated meetings that led
to the development of" the NAIS. (Plan, p. 1.) The NIAA "established a task
force to provide leadership in creating an animal identification plan."
(Plan, p. 4.) The NIAA already had been promoting animal I.D. for months
before the Department, through APHIS, became involved in the effort.
Moreover, the Department says that "[t]he development of [the Draft Program
Standards] was facilitated by significant industry feedback." (Standards,
p. 1.) Essentially, a private group has dominated animal I.D. thinking and
has dictated the NAIS plan now being proposed by the Department.

Moreover, the Department asserts a "broad support for NAIS" (Plan, p. 1)
when there is no such support. The Department says that it conducted
"listening sessions" for six months (June-November 2004) on NAIS. However,
only 60 comments were apparently made during these six months of sessions.
If the Department had made a truly widespread attempt to determine
citizens' views on animal I.D., surely it would have received far more than
60 comments on an issue that affects tens of millions of Americans.

The Department relies upon the NIAA's survey of itself as supposed evidence
of public support. (Plan, p. 7.) The Department quotes responses from the
survey and cites animalagriculture.org/survey/NAIS.htm as its source. (Id.)
However, when one visits that page, one finds a statement by the NIAA that
the survey is not scientific, that the survey's results are intended for
use by NIAA members only, and that any reproduction of the survey is
prohibited. Thus, the Department is presenting as "evidence" a private,
unscientific report that the public is forbidden to quote in opposition. To
correct this gross violation of normal agency procedure, the Department
must immediately publish this entire NIAA survey in the docket and issue a
press release specifying that the public is permitted to use the survey
freely in studying the relationship of the NIAA to the genesis of the NAIS.
This is not only a spurious example of "public support" but an
affirmatively misleading rationale for a mandatory NAIS. It tells us
nothing about truly public support to say that the NIAA, an organization of
the largest livestock businesses and manufacturers of identification
equipment, considers mandatory I.D. to be good for its own private
interests.

One further troubling instance of the failure to consider the needs of the
larger public deserves mention. The NIAA lists as public institutional
members some state departments of agriculture and animal health
commissions. These include representatives of several states with
significant populations of members of plain faiths, e.g., Pennsylvania, New
York, Ohio, Indiana, Michigan, Wisconsin, Missouri, Iowa. Yet it appears no
consideration whatsoever was given to the fact that the NAIS as proposed
would violate the right of these citizens to practice their religion
without government hindrance. Thus, the NAIS is not the result of any true
consensus or concern for the welfare of the citizenry as a whole. Rather,
the NAIS is the predictable result of allowing a small coterie of
financially-
interested "stakeholders" to create the agenda for animal identification.

Conclusion

The NAIS proposals as embodied in the Standards and Plan are unworkable
because of economic costs, the huge burdens of reporting, and enormous and
needless complexity. Their justifications based on animal diseases and food
safety would not be served but in fact would be harmed by the NAIS. The
Department has failed to consider numerous alternative methods that might
actually further animal health and food security without the vast problems
of the proposed NAIS. The Department has limited any input on the NAIS
chiefly to a small group of parties with a preexisting bias toward
mandatory animal ID; the Department did not make its plans known to small
farming interest groups and did not seek any input from such groups. Last,
and first, the most fatal flaw of the proposed NAIS is its disregard for
fundamental human rights enshrined in our Constitution: the right to
religious freedom, the right of property ownership, the right of privacy.

Not since Prohibition has any government agency attempted to enshrine in
law a system which so thoroughly stigmatizes and burdens common, everyday
behavior and is so certain to meet with huge resistance from the citizens
it unjustly targets. Therefore, the Department should: (1) withdraw the
present Standards and Plan as failing to embody a fair or workable system;
(2) reconsider whether, particularly in light of the present effective
measures against BSE, any animal I.D. scheme is warranted at present; (3)
consider implementing the low cost and easily undertaken measures that
would more effectively protect animal health, human health, and the food
supply; (4) review its procedures for development of programs such as NAIS
to correct the limitation of input to self-selected groups and the failure
to notify the vast majority of affected parties; and (5) institute
procedures to assure that, in the future, proposed programs will not be
permitted to threaten the constitutional rights of citizens.

Very truly yours,

Mary-Louise Zanoni

Hi. I have read through all of the comments here on the subject of NAIS and I thought I would add a bit more. First, it does not matter whether the livestock animal is meant for the food supply or not, it will have to be ID'd. Second, many states have already began their version of NAIS after being lured by fed. grants totaling 14.3 million. Wisconsin is one example. Indiana (my state)will require 'premise' registration by Sept. 2006. Many more are going to follow. I am going to leave some helpful links below and one of them will be to the USDA website. There you will find a box to check your own state or tribe. I am also leaving you a link to a 'real-life' experience of a hobby farmer who has been living with a type of NAIS in her state. It is really scary.

Time is running out to stop this thing. We all need to understand that it is going to happen and it already is happening. Please sign the petition against it.

Another inportant hting to note here is that the only ones who have to reg. their premises and each individual animal are small or home farmers. Big industry farms only will register their facilities (address and GPS units) and not their homes like the rest of us. Also, they can register their livestock as a 'herd', whereas each individual animal on our small farms will need its own number. The 'law' is not fair anyway you look at it.

Of course, this is no surprise considering it is big industry farms and animal ID businesses that are supporting, drafting, and funding this in collaboration with USDA. Check out the strategic draft plan on the USDA link.

Please spread the word about NAIS and help us stop it before our way of life, rights & privacy are gone! Thanks!

http://www.homeschoolblogger.com/SDBookMom/

'Real-life' experience under law. Check out her link to Homesteading Today for an excellent letter written by a lawyer and executive director for Farming for Life.

http://animalid.aphis.usda.gov/nais/newsroom/news_2005-6-21.shtml

One of several 'news' items on USDA site

http://animalid.aphis.usda.gov/nais/index.shtml

NAIS home

http://www.in.gov/boah/new/IDruleSummary.htm

Indianas version-comment at end of summery.

www.stopanimalid.org

More info here

http://www.thepetitionsite.com/takeaction/369063795

The petition to sign against it; I dont have a lot of faith in petitions, but perhaps to will help a little.

It seems reasonable that the very large producers, especially fowl, will not tag individuals but be tagged as a herd/flock as that is how they move. The smaller producer/exhibitor is prone to move individuals.
It also seems prudent to have some kind of system to stem animal disease? This system in present form is not a fair nor viable way of doing much more than create headaches, for all concerned. I think it would be better to not totally reject/attack the NAIS, or at least the underlying principles,but try to come up with a more fair and legitimate means of helping to stem proliferation of diseases which many times is due to poor animal husbandry. My animals are valuable, I'd like to be aware of a herd/flock several miles away which may have a deleterious effect on my investments. I really think this fight is going in the wrong direction. We need to work with oficials to protect our ways of life and our national herd/flock and the animal industry. We are individuals but we do have a national interest.

Google search Americans_Against_NAIS. The Y group is growing.

As a outsider listening in, my first question would be.Did the goverment tag all it's animals? lol and they have us to support the expense to do it.....
Unfortuately someone will be prosicuated to the fullest extend of the law to set an example for the rest....and then the law will fall into the other 13 million on the books that are NOT enforced, but still on reccord, to be dug up by some tin horn overpaid lawyer....Wake up Amercia !!!!

I have been tracking the animal tagging issue on http://NoNAIS.org

Print this to pass out: http://nonais.org/sampleflyers/NoNAISHandout.pdf

Print this to hang up: http://NoNAIS.org/sampleflyers/NoNAISPoster.pdf

-Walter
Sugar Mtn Farm

I have signed the petition against the ID thing, and also found out the the US isnt' the only place doing this. Darry Brownfield was saying that it is also happening in Australia, somewhere in Asia, and Europe too.
He also said that the government has had meetings to see if farmers are against it, and nobody stood up against it. HOWEVER, the meeting was not anounced, and it was during such an awkward time that only like ten people were there, and they were all government!!
The cattle/beef association helped to get a plan in place to help control disease, but didn't think it would do this.
Also the USDA has enough official power that they can do what ever the h*** they want to. So they think. All they have to do is put it across that they are "protecting the food source for the American people" and everyone who doesn't have any animals will flock to support it.
We really need to spread the information to those around us that this may not have reached, and increase the stand against it.
My pastor is a farmer and has many animals, he knew nothing of this new law, Once I told him of it, he got on the phone to everyone in our church and neighbors around, telling them to sign the petition and take a stand.

I have to agree with giventake. The government beauracracy can pass these unenforceable laws to pull out and selectively prosecute people whenever they need a reason.

Look at the IRS. No trial by jury. Guilty until proven innocent. They can confiscate your property without a trial.

Another example is the EPA. Laws written by someone not in congress and not subject to debate or approval by congress.

Look at the SSA, originally voluntary. Now mandatory and you could go to jail if you decide you don't want to participate.

There are many other ugly examples where our federal government is growing and violating the constitution. This is a wonderful country and we need to let our voices be heard by our representatives.

By the time tainted meat is found, it is usually already mixed and in stores. I'm not sure any problems we have had yet would have been helped by this system. If I am not mistaken, the problems have usually been from the processing plants.

It's such an Orwellian thing that most people here can't believe it.

Scream folks! Scream loud and direct those screams!

They were talking about this on Coast to Coast am last night 03.15.06. I'm listening to the replay right now. If you can get ahold of a copy of this show you should check it out.