This morning at 10 am I participated in a discussion with USDA Secretary Tom Vilsack about the USDA proposed National Animal Identification System (NAIS). As I publish this the meeting is continuing. Below is what I presented to the Secretary. My understanding is that a complete transcript of the meeting will be made available to the public. There were a few big producer organizations who were strongly pro-Mandatory NAIS but there were more organizations that were hesitant and opposing mandatory NAIS. It will be interesting to read the full transcript of the session and see what comes out of this.
Update 20090426: The transcript is now available.
Hello, I am Walter Jeffries from Sugar Mountain Farm in Vermont where our small family farm raises pastured pigs. You know me from NoNAIS.org I am a voice in the wilderness, in rural America. I hear from a great many other small farmers and homesteaders who are upset about NAIS for a great number of reasons. We need honesty, transparency and a totally voluntary privately created, managed and funded NAIS system. Government should have nothing to do with NAIS. NAIS must not be mandatory. Small farmers must not be burdened by NAIS.
NAIS does not prevent disease. Even USDA memos state this. Everything about NAIS is after the fact and may not be noticed until months have past. NAIS is not even particularly good at tracking disease. Prevention is the better solution. Don’t feed cows to cows and you don’t get BSE. Don’t abuse antibiotics and you don’t get MRSA. Don’t import animals without quarantine and testing and you don’t bring in FMD or other exotic diseases into our country. Prevention is the solution. NAIS is just an expensive boondoggle that makes more jobs for government, tagging companies and crushes small farmers with paperwork and costs.
NAIS is not about food safety or disease prevention. NAIS is about meeting global standards for trade. It is the Big Agricultural producers that do virtually all the exporting and benefit from NAIS. Realize that virtually all food born illness comes from big producers and almost all of that happens at the processors after the animals leave the farm. Big Ag wants trace-back for exports and as a marketing tool so that they can crack into niches of consumers now looking to connect with their food. It is Big Ag that should be privately creating their own truly voluntary trace-back and tracking system at their own cost. Government should have nothing to do with this.
Virtually all small farmers sell locally, do not export, do not import and do not benefit from NAIS. We already have 100% trace-back for our animals. Our customers know where their meat comes from - they can drive by and see it in our fields. We don’t need the cost or wasted time dealing with NAIS. A fundamental problem with NAIS is that while it benefits Big Ag it burdens small farmers and homesteaders.
Depopulation threats scare people into noncompliance. For Big Ag depopulation is not a problem - they just reorder new animals from the catalog. They are not raising unique genetics. They have insurance. The government reimbursements are sufficient for them. But for small producers and homesteaders with unique genetics the threat of depopulation is overwhelming to the point of pushing them to revolt and non-compliance. Depopulation is unnecessary because simple quarantine and testing is highly effective. A big fear of many people is that errors in the system, or malicious acts, will create depopulations or enforcements to retaliate against individual farms. There needs to be a system of checks and balances just like in our Constitution that prevents this. There is no need to rush in and kill off livestock. Use quarantine. Do open source testing. Share the lab results. Do not be secretive.
100% compliance with a complicated system like NAIS is impossible. Don’t make that a goal because you’ll never achieve it. Forcing NAIS will just create a lot of ill-will.
The Individual Animal ID vs Group ID is a major sore point with small producers. This allows Big Ag to get the benefits they want with little cost or effort while small producers are heavily burdened at high cost of tagging and tracking every animal and movement. This becomes one more subsidy for Big Ag that further exaggerates their unfair advantage in the market. Place the full burden of NAIS on Big Producers. The solution is simple - If NAIS is going to be mandatory in any form then it must require tagging and tracing of every single animal in Big Ag’s big herds. Everyone should be treated equally.
RFID tags have been demonstrated as unreliable in Australia and other countries where they are costing producers money both up front and in lost sales. RFID is a trigger point for many independently minded people who make up a very large portion of the small farms and homesteads creating resistance to NAIS. Drop RFID as any part of the specification of NAIS.
Don’t exaggerate the registration numbers. The published numbers include tens of thousands of false, non-voluntary registrations that were made against people’s will. The numbers also include non-producers although it is stated that they are numbers of farms. Adding up the numbers of horses, sheep, pigs, chickens, cows and other farm animals suggests that the total number of Premises are really on the order of 10 million. Don’t falsify the numbers to make participation look better than it really is. Be honest, be transparent.
Don’t play with words. “Voluntary at the federal level” and then pushing for mandatory at the state level loses the public’s trust. Write in clear, concise, accurate English. Mean what you say.
Threats of fines just increase the resistance to the system. Classic negative feedback loop on resistant population. Try herding pigs and you’ll understand - as soon as they know you’re up to no good they resist harder, even if you mean well and want to take them to a better place. If you want cooperation, ask politely and offer positive benefits. If you say voluntary then you should mean it. Don’t turn around and make it mandatory through underhanded methods. I have worked with our local university extension program and state department of agriculture many times, sharing information about our farm truly voluntarily. But I’ll fight tooth and claw against coercion and threats of mandatory. That is how 92% of the 7.5 million small farmers and homesteaders feel. In other words, government needs to learn to politely ask “Please” and not “Please or else!”
We need honest and transparency. If Big Ag wants trace-back then let them create, operate and fund a truly voluntary NAIS system. Those producers who see benefit can then choose to participate. Those who do not want to participate must not be coerced. That is how a democracy works.
Had NAIS been truly honest and voluntary from the start, I would have participated. The question you must ask yourself is can you make it voluntary and convince me, and thus other small independent farmers and homesteaders like me, that you’re being honest and transparent? We must know you have our best interests at heart and are not simply in the pockets of Big Ag.
Thank you, Secretary Vilsack for this opportunity to comment on NAIS.
Hat tip to Sharon for a copy of the Agenda shown at top.