July 3, 2006

A Matter of Timing

Commentary — walterj 10:10 am

It is interesting to note that the USDA’s comment period on NAIS opens July 1st and closes July 31st, 2006.

The new “Non-Commercial Small Producer Guidance” document came out June 2nd, 2006.

The Vermont Agency of Agriculture is holding its hearings and releasing its rules right now with the comment period ending August 31st, 2006.

We are in the busy season for farmers and homesteaders. We have animals birthing, hay to be cut, planting, weeding, tilling and other real work. If we miss these critical times of the yearly cycle we lose the entire year’s productivity.

At the same time the government is giving us a very short period of time to read and comment on lengthy, complex regulations that could destroy our lives. They are choosing to do this during a period of the year when we don’t have time to take away from real work. Is the government purposefully doing this in order to make it so that farmers and homesteaders do not have the time to read the documents and comment on them? Is this one more way the Govi-Corp subverts democracy? Or is there some other innocent reason relating to how deskjockey’s work?

Suggestion: comment periods on laws and regulations should fit the people being affected. For small farmers and homesteaders, a winter comment period would be far more appropriate than summer time.

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31 Comments »

  1. They are not giving us a convenient time to respond to their rules for the simple reason that they have already made up their minds. They don’t care what we have to say, they intend to do it, anyway. This plan has been at least eleven years in the making, they have had lots of time to think over how to best destroy small homesteads and the American Dream.
    They are not giving us time, because to them, it is a “Done Deal.” We don’t count, let’s face it, America…..

    Comment Diana Flanary-Bray — July 3, 2006 @ 12:16 pm

  2. I’m SURE they’re not trying to subvert democracy! (heavy on the sarcasm) They’re just trying to do what’s best for us. Hmmmm,… yeah, right.

    Keep up the good work Walter. I don’t know how in the world you make time to run this board. Thank you!

    David Hannes (Missouri)

    Comment David Hannes — July 3, 2006 @ 12:18 pm

  3. They must assume we do not take time to read proposed legislation(s) since most of them don’t. They assume wrong.

    Comment Celeste — July 3, 2006 @ 12:20 pm

  4. In Mo. I find Federal represenative totally bought into NAIS. (Joann Emerson) But my State Rep. is very much against NAIS. Every state has to legislate enabling laws for NAIS to become law. Our state is blessed with many rural represenatives that are on our side. I believe that in our state we have a fighting chance to prevent NAIS from becoming Mo. law. Time will tell.

    Comment Tom Benzen — July 3, 2006 @ 1:21 pm

  5. Please be advised also that according to Linda Campbell chair of the Goat ID group, the various species working groups will be submitting their ’somewhat’ final recomendations for ID and movement reporting for animals to the USDA in August. Why she put the ’somewhat’ in her post to the Goat ID Group on Yahoo I don’t know, but that’s what she said.
    I wouldn’t be suprised at all if the comment period was set for this time period on purpose, regarding the work load on us this time of year. The species working groups are by and large made up of people who don’t want to hear from the small holders, period. Various laws say that the USDA has to be open to receiving public comment, it does not say they have to make it easy on us, or even that they have to take us into consideration or listen to us….Your tax dollars at work for you.

    Comment Joanne Rigutto — July 3, 2006 @ 1:32 pm

  6. We all hope and pray that their non-sense of timing for comment (during the busy season), lack of real notification of those it will ultimately hurt or destroy and other big holes in the system will lead to a lawsuit that will take them down.

    Comment SUSAN — July 3, 2006 @ 2:13 pm

  7. Where I live I have to use a ferry to get too and from home to major services. There are no roads to connect us to the mainland. It can take 8 hours or more to get groceries, feed, or fuel and often there are 2 hour waits to get a ferry home. I’m not complaining–I chose to live here.

    What bugs me though is that these ferries only run at certain hours of the day. We have no other means of transportation–sure if you have a boat you can travel, but only if you don’t need to drive somewhere when you get to that point. So why does the local government, including the Ferry Board–who keep raising rates and taking away our freedoms–schedual meetings and hearings in the middle of the day, or at off-hours, where only a few–mostly retired–people can attend?

    It’s the same everywhere. If They don’t want your vote they’ll make it so you can’t. If They want their opinions confirmed, they’ll make sure the majority of attendees are already leaning their way.

    The time is now to use every means possible–internet, blogging, mobile phone and wifi technology to beat them at their game before those things too are limited and regulated “for our own good.”

    http://www.podchef.motime.com

    Comment Podchef — July 3, 2006 @ 5:01 pm

  8. Linda Campbell has a less than savory rep among a number of people I’ve seen make mention of her. Let’s see, she has been the driving force behind what got ADGA in hot water over being proNAIS (amazing how her committee notes to ADGA are rather USDAish for their pablum), pushed into the sheep working group for NAIS (spent an evening reading some interesting comments from sheep owners on that one), is on the goat working group for NAIS, is trying to form an omnibus goat group for all breeds and registries (started 1993, picked up steam in 2003). I seem to remember a few other goodies in the “follow the money” area, but cannot run them down right now.

    Comment Kamatu — July 3, 2006 @ 5:18 pm

  9. I cannot seem to find anywhere on the USDA website to leave a comment regarding NAIS, or the new “non-commercial small producers guideline”. I have left comments to the USDA in the past, and they claim the comment period is expired. Are you sure the comment period wasn’t suppossed to be before they published the document and anyone knew about it?
    Has anyone been able to comment yet?
    Thanks,
    Eileen

    [Eileen, in the Technical Documents section of the right hand sidebar is a link to all the USDA and other related tech docs like the one about Guide to Small Non-Commercial Producers. In the right sidebar under Contacts is the link of where to submit comments (animalidcomments@aphis.usda.gov) up until now. There is supposed to be a new official comment period opening now with the release of the new proposed finalized regulations but I have not seen those rules yet nor a new link. Until then, send comments to that link mentioned above. I would suggest keeping copies of your comments and resubmitting them once a comment period gets officially announced for the final regulations. Keep an eye on the right sidebar sections as that is where I put this sort of thing for easy access for both you and I. Cheers, -WJ]

    Comment eileen — July 3, 2006 @ 5:24 pm

  10. I just spent a mind-numbing 20 minutes on the USDA Web site hunting for the document in question and the URL for submitting comments.

    The URL for the document “A Guide for Small-Scale or Non-Commercial Producers”:
    animalid.aphis.usda.gov/ nais/downloads/print/ Guide_Smal_NonCommercial_6_2_06.pdf

    The email address for leaving comments:
    animalidcomments @aphis.usda.gov.

    Good luck, y’all!

    Comment Susan Maricle — July 3, 2006 @ 7:37 pm

  11. Walter:
    Do you have the docket and/or ID number for the latest comment period on NAIS? I have been all over regulations.gov and do not find an open comment period for NAIS anywhere under any category.
    Karen

    [I have not seen the USDA release this yet. They had previously indicated that July would see the release of finalized rules and the opening of the public comment period. My guess is it will be after the holiday. -WJ]

    Comment Karen — July 3, 2006 @ 9:14 pm

  12. I goggled comment period for National Animal Identification Period and got zip for this comment period. I will keep looking but cannot find the correct address to refer others to. I went to the official site link and got zip. So exactly how is one to comment again? Or will this comment period be like the others where I get a personal email address returned instead of an official USDA email address. In other words is the fix in and this is a farce too?

    Comment Sue Karber — July 4, 2006 @ 2:43 am

  13. Hearings and comment periods are tools designed to ID opposition and marginalize it. The hearings are carefully controlled by facilitators who use the Delphi technique to silence opposition. Anyone attending these hearings should research and recognize this method and how to respond to it.

    [Here is info on the Delphi Technique, and more and techniques for disrupting it. -WJ]

    Comment K. — July 4, 2006 @ 6:35 am

  14. There is a thread giving instructions on finding the docket and leaving comments. HERE
    The ID is: APHIS-2006-0066-0001

    Happy 4th!

    Comment #1 Son — July 4, 2006 @ 10:21 am

  15. I too hate the thought of the government knowing every single aspect of my life. I haven’t had very much time to read the details of the chip paperwork marathon, but I am wondering if there is a physical address to snail mail our comments to (maybe certified)? If they were flooded with actual envelopes, the officials would have to acknowledge that the public has commented. Emails vanish all the time. They need to be snowed with our paperwork before we have to do theirs. Who knows, maybe the volume of mail might make make them
    re-think their outrageous proposal.

    Comment Shirley — July 4, 2006 @ 12:17 pm

  16. Thank you for that most useful link. I will pass that one on.

    Now all we need is a way to be sure opposition IS heard on these issues - which was a problem with the PAWS

    Comment Lynn — July 4, 2006 @ 12:48 pm

  17. Since comment # 8 piqued my interest I did a google for Linda Campbell NAIS and the first link was this:
    link
    It explains her position on NAIS. I’ll let you all read it and digest it yourselves.

    Comment Mary Beth — July 4, 2006 @ 5:34 pm

  18. Just received my latest (and last)issue of “Horse Illustrated” magazine. They FINALLY commented on NAIS. It consisted of a couple of paragraphs promoting the American Horse Council’s new brochure dispelling “myths” about NAIS. Looks like some members of the media are complicent in this whole scheme . I urge everyone to cancel their subscriptions to any publication that has not taken an anti-NAIS stance. If they aren’t with us by now, they’re probably on the other side or at the very least , not doing their jobs by warning animal owners about NAIS.

    [If you can send me a copy of this I can write up a deconstruction of it like TAHC Brochure Lies and Govi-Double Speak which I did earlier. If possible, send me a a link to the article on their site. That is idea. -WJ]

    Comment Jane B. — July 4, 2006 @ 11:04 pm

  19. Khimaira_Farm_Goat_Export
    Seems Linda is in the export business after all and genetics. It also seems she has an official quaritine set up authorized by USDA. follow the money.

    Comment Sue Karber — July 5, 2006 @ 12:38 am

  20. Mary Beth, I never checked her farm website. I find reading that, somewhat, ummm, interesting. Is Linda Campbell doing propaganda for NAIS or is she a useful idiot who doesn’t have a clue? By her rather benign version of NAIS, it just becomes the scrapie program with a new name and voluntary movement tracking.

    The most amusing part, where she says: “Before forming your opinion about this program, I encourage you to find and consider the facts. “, after providing several links, none of which happen to go to any of the actual USDA NAIS documents.

    Comment Kamatu — July 5, 2006 @ 5:48 am

  21. In response to #13:

    Please check out Dean Gotcher and his document:

    The Dialectic & Praxis: Diaprax and the End of the Ages

    This is the Delphi Technique and it is awesome explanation.

    You must understand the techniques employed by the opponent before entering these meetings. The facilitator’s are trained to pick you out, chew you up and spit you out!

    Comment LuAnn — July 5, 2006 @ 8:18 am

  22. link

    Hit the link to website access from April 4 - April 10.

    Lots of USDA hits but little reference to NAIS hits.

    Comment donna — July 5, 2006 @ 10:47 am

  23. I have repeatedly contacted federal and state officials regarding NAIS and can’t seem to make them see the problems that it will cause. How do we open thier minds without drilling a hole to pour the information in.

    Comment Lindaruth Horton — July 5, 2006 @ 11:51 am

  24. Send some informative letters to key players by certified mail. You will get their attention.

    Comment george — July 5, 2006 @ 1:49 pm

  25. link

    Follow linked instructions from comment 14 above to submit your views on Federal regulations.

    My link is to already submitted comments from the above mentioned APHIS-2006-0066-0001.

    Apparently each comment is public.

    We are in big trouble if those are the only comments submitted to the feds on this issue.

    Comment period ends on July 11.

    Comment Donna — July 5, 2006 @ 2:11 pm

  26. Sorry about the above link. The main site for Government Regulations Public Commentary seems to be static.

    Once there, select Animal and Plant Health Inspection at the top of the scroll. Hit SUBMIT.

    There are two or three regulations described in that docket which relate to NAIS & animal monitoring.

    On the right under views you find a few comments already submitted. Not sure if those represent the total number of comments. If they are, it sure doesn’t appear to be a dam burst of public outrage.

    We need to get busy.

    Comment Donna — July 5, 2006 @ 2:31 pm

  27. Just received my latest (and last)issue of “Horse Illustrated” magazine. They FINALLY commented on NAIS. It consisted of a couple of paragraphs promoting the American Horse Council’s new brochure dispelling “myths” about NAIS.

    Which issue? I looked thru the entire July issue and found nothing on this topic.

    Comment Barbara — July 5, 2006 @ 5:07 pm

  28. Horse Illustrated August issue page 8.

    Comment Jane B. — July 6, 2006 @ 4:08 am

  29. Inocent, I don’t believe it! Its all part of the gov’s evil plan

    Comment Nina Swain — July 7, 2006 @ 6:59 am

  30. As a free service, and as my part in our fight against NAIS-nonsense, I will represent any of you who cannot attend meetings on this subject. Just email me ( wires@yellville.net ) or phone (870-449-5810) and give me your message to them. I will print your messages and hand deliver them to whomever they are addressed, along with my own comments. Use pseudonyms, “handles”, etc., if you are shy. Try to keep messages down to a half page or less and be sure to tell me where the meeting is and how to get there. I probably want to go to the meeting anyway if I know about it. At today’s gas prices, I think a 100 mile radius from Yellville, AR would be a practical limit; and for as long as my ‘88 car holds up. I will take notes and report back to you by email (or snail mail if you don’t have email access) How do you like this idea? Any takers? Don Hartley

    Comment Don Hartley — July 9, 2006 @ 6:22 am

  31. Our version of NAIS, the NLIS, has been a total disaster already and it is not very old yet. I fear the worst is to come. Fight it in your country as hard as you can!

    Comment Dale Mcgreeley — August 9, 2006 @ 1:11 pm

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