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Animal Owners and Taxpayers NAIS Alert!
Protect your right to farm and the food supply!
The USDA has proposed a rule to require all farms where animals are raised
to be registered in a federal database under the National Animal Identification
System (NAIS) for existing disease control programs. The draft rule covers
programs for cattle, sheep, goats, and swine. It also sets the stage for
the entire NAIS program to be mandated for everyone, including anyone
who owns even one livestock animal, for example, a single chicken or a
horse.
It is CRITICAL that the USDA and Congress hear from the hundreds of
thousands of people who will be adversely affected by the NAIS program.
This includes not only animal owners, but also consumers who care about
local and sustainable foods, taxpayers who object to wasteful government
programs, and advocates for a safer local food system.
STEP 1: Submit comments to USDA online or by mail. The comments must
be received by USDA by March 16, 2009.
Submit comments online at:
http://www.regulations.gov/fdmspublic/component
/main?main=DocumentDetail&o=090000648081c664
Click on the yellow balloon next to "add comments."
Or mail two copies of your comments to USDA: Docket No. APHIS-2007-0096,
Regulatory Analysis and Development, PPD, APHIS, Station 3A-03.8, 4700
River Road Unit 118, Riverdale, MD 20737-1238. Clearly state that your
comments refer to Docket No. APHIS-2007-0096.
You can download sample comments at
www.farmandranchfreedom.org/content/files/090202_sample_comments.doc
or see the sample comments at the end of this alert
STEP 2: Send a copy of your comments to your Congressman and Senators.
You can find who represents you, and their contact information, at www.congress.org
Organic Consumers Association has set up an automated system for folks
to submit comments on the proposed USDA NAIS rule
http://salsa.democracyinaction.org/o/642/campaign.jsp?campaign_KEY=26665
STEP 3: Spread the word! Forward this alert to your friends, neighbors,
and any agriculture or food-related mail lists you are on. You can also
download a flyer and the sample comments at http://farmandranchfreedom.org/content/take-action
to put out at local farmers markets, riding stables, feed stores, etc.
BACKGROUND
The USDA has been working for over five years to force NAIS onto American
animal owners. NAIS is designed to identify and track each and every
individual livestock and poultry animal owned by family farmers, hobby
farmers, homesteaders, and pet owners across the country. USDA claims
that NAIS is a disease tracking program, but has refused to provide
any support for its claims. In reality, NAIS will impose high costs
and government surveillance on every farmer and animal owner for no
significant benefits, and will likely force many small producers out
of business.
NAIS does nothing to improve food safety for consumers or prevent animal
diseases. This program is a one-size-fits-all program developed by and
for big Agribusiness. NAIS will increase consolidation of our food supply
in the hands of a few large companies and put the brakes on the growing
movement toward local food systems.
Despite promises to the contrary, the USDA's new proposed rule would
make portions of the NAIS mandatory for thousands of people in every
state. Anyone who participates in federal disease control program for
cattle, sheep, goats or swine will have their premises registered. The
NAIS Premises Identification Number (PIN) will become the only form
of premises identification acceptable for USDA
animal health purposes, with no opt-out provision.
The proposed rule would also limit official Animal Identification Numbers
to the NAIS-compliant 840-numbering system, laying the groundwork for
future regulations that would limit people's options on the types of
tags they could use.
The proposed rule is not final yet. You can help stop it by visiting
the Federal Registry and making a comment. Go to http://www.regulations.gov/fdmspublic/component
/main?main=DocketDetail&d=APHIS-2007-0096
and click on the yellow balloon under "add comments." And
send a copy of your comments to your elected officials, letting them
know how you feel about NAIS.
The grassroots movement has already successfully stalled USDA's plans
for NAIS, which originally called for the entire program - premises
registration, animal identification, and tracking - to be mandatory
by January 2009. The proposed rule is an opportunity to get thousands
of objections in the formal record, and have an even greater impact.
It is imperative that people speak up to protect our right to farm and
our food supply!
FOR MORE INFORMATION
Go to www.FarmAndRanchFreedom.org
or contact Judith McGeary, 512-243-9404 or
SAMPLE COMMENTS
[Mail two copies to the address below. Or submit comments online at:
http://www.regulations.gov/fdmspublic/component
/main?main=DocumentDetail&o=090000648081c664]
Date: ____________________
Docket No. APHIS-2007-0096
Regulatory Analysis and Development PPD, APHIS
Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238
Re: Docket No. APHIS-2007-0096
I urge the USDA to withdraw its proposed rule to implement portions
of the National Animal Identification System (NAIS), Docket No. APHIS-2007-0096.
I am a ____________________________________________________________
__________________________________________________________________
[State who you are - for instance, are you a farmer, consumer, or horse
owner -- and why this issue matters to you]
The proposed rule mandates the NAIS Premises Identification Number
(PIN) as the sole means of identifying properties for USDA animal health
purposes. The proposed rule also mandates the use of the NAIS numbering
system (i.e. the "840 numbering system") for eartags using
official animal identification numbers. Tags using other numbering systems
would be required to be linked to a NAIS PIN.
The draft rule is seriously flawed for multiple reasons:
1) Does not substantiate the alleged benefits to animal health. USDA
makes general claims about the benefits of identifying locations where
animals are kept, but the agency does not address the ability of existing
programs to meet this purpose, nor how the proposed rule would improve
the capability to identify locations.
2) Ignores the costs and burdens. The proposed rule would substantially
increase costs for livestock owners and taxpayers. Costs include the
development and maintenance of a massive database; purchase of 840-numbered
tags by animal owners; changes by state agencies to make existing programs
consistent with the rule; and increased federal government intrusion
into the lives and daily activities of farmers and other animal owners.
3) Violates individuals' religious beliefs. Amish, Mennonite, and some
other individuals have religious objections to the universal numbering
system under NAIS.
4) Creates disincentives for people to seek veterinary care for their
animals and participate in existing disease control programs. The proposed
rule lists four animal disease programs-tuberculosis , brucellosis,
scrapie, and Johne's - and will also impact others. These programs include
provisions for veterinary care through vaccinations and testing. Animal
owners who object to NAIS may avoid participating in these programs,
thereby increasing health risks to the public and farm
operations.
The proposed rule is a significant step towards implementing the entire
NAIS program. Thus, the agency should address the fundamental question
of whether it should be implementing NAIS at all. In addition to the
problems with the draft rule listed above, there are many additional
objections to the entire NAIS program:
1) No significant benefits: USDA's assertions that NAIS will provide
benefits for animal health are not supported, and actually contradict
basic scientific principles.
2) High costs for animal owners and taxpayers: These costs include:
(1) the development, maintenance, and update of massive databases; (2)
the costs of tags, most of which will contain microchips; (3) the labor
burdens for tagging every animal; (4) the paperwork burdens of reporting
routine movements; and (5) the costs of enforcement on millions of individuals.
3) Impracticality: The databases to register the properties, identify
each animal, and record billions of "events" will dwarf any
system currently in existence.
4) Waste of money: The USDA has already spent over $130 million on
NAIS implementation, but has yet to develop a workable plan for the
program.
5) Diverts resources from more critical needs such as disease testing,
disease prevention through vaccination and improved animal husbandry
practices, and disease detection in currently uninspected livestock
imports.
6) Damage to food safety efforts: NAIS will not prevent foodborne illnesses,
such as e. coli or salmonella contamination, because the tracking ends
at the time of slaughter. Food safety is better served by focusing on
programs such as increased testing for bovine spongiform encephalopathy
(BSE or Mad Cow), improved oversight of slaughterhouses and food processing
facilities, and increased inspections of imported foods. Programs such
as NAIS that burden small, sustainable farmers will hurt efforts to
develop safer, decentralized local food systems
7) Discourages involvement in farming or animal husbandry: Because
of costs and government intrusion, some people will choose not to stay
in farming or go into farming. This will result in less competition,
greater reliance in foreign imports and poor quality at higher prices.
I urge the USDA to withdraw the proposed rule to implement portions
of the National Animal Identification System, Docket No. APHIS-2007-0096.
Sincerely,
Name: ___________________________________
Address: __________________________________
City, State Zip: _____________________________
Additional Comments:
HAVING TROUBLE SUBMITTING COMMENTS?
Some people have reported problems with the online Federal Register
comment process.
If you don't see your comments posted on the website within a few hours,
think
about these issues:
1) Make sure you clicked on the yellow balloon under "add comments"
next to the very first listed document (the proposed rule). You can
also use this link:
http://www.regulations.gov/fdmspublic/component
/main?main=DocumentDetail&o=090000648081c664
2) Be sure to fill out all of the required fields, marked with a red
star
3) Submitting attachments with other comments can sometimes cause a
problem. If you wish to submit a word or pdf document, submit it separately
from comments typed into the "general comments" field
4) If you don't get a page showing a confirmation number, go back through
each step.
5) Ultimately, you can always submit using the regular mail as an alternative.
Send
TWO copies to:
Docket No. APHIS-2007-0096
Regulatory Analysis and Development, PPD, APHIS
Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238
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