NAIS Alert!

February 2, 2009

Animal owners, consumers and taxpayers:

NAIS ALERT!

Protect your right to farm and the food supply!

The USDA has proposed a rule to mandate premises registration under the
National Animal Identification System (NAIS) for existing disease control
programs. The draft rule covers programs for cattle, sheep, goats, and swine
but it sets the stage for the entire NAIS program to be mandated for
everyone.
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 anyone who owns even one livestock animal (including a single
chicken or a horse), as well as consumers who care about local and
sustainable foods, taxpayers who object to wasteful government programs, and
advocates for a safer food system.
STEP 1: Submit comments to USDA online or by mail. The comments must be
received by USDA by March 16, 2009.
You can submit comments online by clicking here. Click on the yellow balloon
under “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.
(Sample comments are 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 by clicking
here
Background
The U.S. Department of Agriculture (USDA) has been working for over five
years to force a National Animal Identification System (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:
Usurp states’ existing, well-functioning disease response and brand
inspection programs;
Impose high costs and government surveillance on every farmer and animal
owner for no significant benefits.
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 regional 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. This
draft rule would mandate the first step – premises registration – for
anyone who is involved in a federal disease control program. That includes
tuberculosis, brucellosis, scrapie, Johne’s and more. The NAIS Premises
Identification Number (PIN) will become the only form of premises
identification acceptable for official USDA 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, and click on the yellow balloon under
“add comments.” Be sure to 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!
Sample Comments
Docket No. APHIS-2007-0096
Regulatory Analysis and Development PPD, APHIS
Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238
Mail two copies to the address above, or submit comments online by clicking
here.
Date: __________
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 - farmer, consumer, animal 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 official USDA 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:
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 capacity of existing programs to
meet this purpose, nor how the proposed rule actually improves on the
current ability to identify locations.

Ignores the costs and burdens. The proposed rule would substantially
increase costs, and add intrusive governmental burdens, to the industry and
the taxpayer. The costs include the development and maintenance of a massive
database; the purchase of 840-numbered tags by animal owners; state agencies
having to implement changes to existing programs; and increased federal
government intrusion into the lives and daily activities of farmers and
other animal owners.

Violation of individuals’ religious beliefs. Amish, Mennonite, and some
other individuals have religious objections to the universal numbering
system under NAIS.

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 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.

Adds to the confusion. This rule is the latest in a series of ambiguous and
often contradictory documents that the USDA has issued on NAIS. This has
created enormous confusion over the intent of the USDA and problems for both
animal owners and state agencies.

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 objectionsto the entire
NAIS propgram:

No significant benefits: USDA’s assertions that NAIS will provide benefits
for animal health are not supported, and actually contradict basic
scientific principles.

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.

Impracticality: The databases to register the properties, identify each
animal, and record billions of “events” will dwarf any system currently
in existence.

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.

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.

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 food. Programs such as
NAIS that burden small, sustainable farmers will hurt efforts to develop
safer, decentralized local food systems.

Discourages involvement in farming or animal husbandry: Because of the 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: __________________________
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