Published in today’s Federal Register is the official notice and request for comments for NAIS-related documents
National Animal Identification System (NAIS) official identification devices with animal identification number, 4680–4681 [E7–1719] [Text, PDF, Summary]
Note that this is an official comment period. Comment should be made within 30 days - do it ASAP:
Comments regarding these information collections are best assured of having their full effect if received within 30 days of this notification. Copies of the submission(s) may be obtained by calling (202) 720–8958.
:
Comments about any of these documents or other aspects of the NAIS may be submitted to USDA through the NAIS Web site e-mail address: animalidcomments@aphis.usda.gov or by mail to NAIS Program Staff, VS, APHIS, 4700 River Road, Unit 200, Riverdale, MD 20737
Let the circus begin.
Hat tip to Tom
I am totally opposed to the USDA National Animal Identification System. Is this another make-work program, because I can’t see any need for it. Is the USDA going to listen to the voice of the people? I don’t remember voting for this!
Comment Nancy Smoller — February 1, 2007 @ 2:50 pm
I am truly very concerned about NAIS. The big boys and those who sat in on the boards that created this brain child(Monsanto, et al) at first had it going voluntary for the big factory farms who wanted to sell overseas. I say fine, let them go into the NAIS. Then with the RFID and tech company’s input, decided to make it a sweeping mandate for all (homesteaders, granny’s pet chicken, small farmers) for profit, the almighty dollar, not ast all for our health! And they use fear to push this onto a frightened public - fear of animal disease. Well then, my good Lads, test at the slaughter house! Label packages that are NAIS compliant (VOLUNTARILY) and let the FREE market go! Consumers will make their choice. And USDA can’t say ‘well everyone must comply or it won’t work’ because that is ludicrous - what about wild animals, cats and dogs? A cat can kill and eat a sick wild bird and then nuzzle up to an owner’s mouth that evening! They are trying to dupe us Americans! Ben Franklin said “Those who would give up Freedom for a security deserve neither!” Let’s all remember what Germany went thru int he late 30’s and early 40’s: Had to register all livestock, get a permit to slaughter your own pig, etc. Then when hell broke loose, they knew where to find animals, and come in and take over to feed military (which by the way of executive order on the books of the USA can happen here) then killed everything else before they left so the enemy couldn’t have it to eat, even if the family needed the rest of the livestock to survive. NAIS is VERY SCARY!!! This is America, and we need to remind those that serve us as public servants that we will not stand for this. Political left, right or center!!!!
Comment Bonnie Sawyer — February 1, 2007 @ 5:13 pm
Hello and that you for this opportunity. I speak for many of my fellow friends and neighbors.
I am very concerned about this NAIS program and a mandatory implementation. Let the free market decide. Label NAIS compliant meat (VOLUNTARY NAIS) and let the consumer decide. Do not force everyone into this impossible program. The large feedlots want it to keep markets overseas open. Let them go into it. The small farmer, homesteaders, people who like to grown their own food or buy from a local farmer will be severely hurt by this ludicrous program. It will push more small farmers out of business not only because of the costs, but the hassle of reporting every last move – reportable events that will drive everyone crazy trying to maintain. It’s just not feasible. Think about that.
Realistically, what about the livestock that break a fence and run out at night and then are back in the morning. No one will know where that animal was. NAIS will not stop disease and by driving smaller farmers out of business will further decrease the genetic gene pool we vitally need for future viability. Concentrating our food sources into larger and fewer hands is unsustainable, dangerous and downright dumb. If an animal disease is going to hit, it will hit. And if it does, we need a diverse genetic pool to rely on. How will that be possible when small farmers are increasingly being put out of business for reason of greed and money? Wild birds and animals and airborne pathogens can mingle with domestic animals and then come in and nuzzle its owner the next minute – no livestock around. And who wants to jeopardize the 30 billion dollar a year pet industry???
People who buy local farm food won’t need track back – they know where they got their food. Why can’t testing be done at the slaughter house? Why are smaller producers being stopped by the USDA for testing their beef for BSE? Have we all gone mad already? With the likes of NAIS being proposed, it sure seems it. Money and greed reign supreme to be sure, but NAIS is stepping over a greedy line that should not by any means be stepped over.
Please make sure, whoever is reading this and compiling comments, to do your homework on this before passing hasty judgment against my stance. Follow the trail back to who was first involved in creating NAIS (I’m sure it started out being a well meaning way to keep out foreign markets open) and how it grew into a frothy monster with the input of the tech companies drooling over the money they could make on this.
NAIS will not stop disease; it will only trace it back from whence it came (perhaps), as innocent livestock that are healthy are depopulated. Why aren’t we concentrating on where disease starts (overcrowded conditions in same gene animals) and testing at the slaughter house, like Japan does. Are not American citizens as good as Japanese citizens? NAIS is just an idea that had a well meaning start, but by making it mandatory (and I mean mandatory by any means, interim rules of closing off borders to non-consistent states, sneaking it into a farm bill, etc) is entirely unacceptable.
Thank you,
Bonnie Sawyer
Concerned Consumer
Comment Concerned Consumer — February 1, 2007 @ 5:43 pm
Done,I sent them a comment,telling them to scrap the whole NAIS plan!
Comment LEE — February 1, 2007 @ 6:44 pm
I’ve written my opinion to the USDA email comments. Here it is, as copied and pasted for you-all’s reading pleasure: I hope it helps…
The NAIS idea is really a bad, bad, bad idea. Small farmers are what made this country so great. Their wisdom in living on the Land with the rhythms of the seasons, the genetic diversity of livestock and poultry are both sacred and of utmost importance. Small farmers are the salt of the earth, and they should be left alone and respected for the unique people they really are. They are to be revered and admired for their indomitible determination to live their lifestyle against great odds. I say, “leave the small farmers alone”, for what they offer is what a lot of people want: Home grown eggs and meat as well as fruits and vegetables. If the federal government cannot protect the public from tainted spinach or green onions, I sure as hell do not want the federal government to charging me for growing my own food!
I urge you to abolish the NAIS, and let the agribusiness giants live with it, since it is THEY that are selling their products to foriegn countries; we small farmers merely sell to neighbors and local counties and mainly feed themselves and their families, and how DARE you (USDA) try to regulate us?! It makes me spit nails! If the agribusiness want to implement NAIS, that is their business, and they have unlimited funds to carry it out amongst themselves. Let them suck on their high salaries and leave us small, family/hobby farmers alone!
So, Canada is implementing NAIS? Great Britian? China? That’s fine, but WE are NOT China, Canada or Great Britain; we are Americans, and we have our own style that works just fine for us through the eartags on our cattle and so forth.
Take the small farmers, hobby farmers and backyard egg producers out of NAIS and leave us alone — I ask that you (USDA) stop trying to make criminals out of hardworking, honest people. Frankly, your efforts to push the NAIS on an unwilling population is infuriating with your total disregard to our Consitutional Rights as well as the Bill of Rights. I suggest that you ALL go to your local library and study the Bill of Rights! You might then appreciate what makes our country so special. Stop that NAIS nonsense and focus on things that are really important! Following the money too closely is a dangerous business, for it corrupts souls and ruins lives.
Thank you for the opportunity to vent about your NAIS idea.
John Sherrer
Comment John Sherrer — February 1, 2007 @ 8:15 pm
Insanity does not even begin to describe NAIS, the filing of Federal Reister Noted above in Main Article because on first page in Summary it talks of the three documents posted, Draft User Gude, Program Standards and Technical Reference Document. However, in the Nov. 6 Users Guide it says these are replaced…but where is the Users Guide in the Federal Registry to make this so? And of course the Cooperative Agreement Application that came out the same day as the new Users Guide claims “the NAIS is voluntary at the federal level”.
Scroll down to page 11. 2nd paragraph from the bottom:
Projects must focus on implementation of premises and animal identification methods according to the standards defined in the NAIS Draft Program Standards.
Then scroll down to page 16:
Outline a Plan of Action
Provide a brief overview of the work to be performed and how the plan builds upon the 2005 or 2006 cooperative agreement plan. Also, explain how this plan will support the timelines for full implementation of NAIS as outlined in the draft strategic plan.
For those who believe this was “accidental”, that the CA was written before the USDA’s change to a voluntary system, remember that Sec of Ag Johanns announced publicly on August 24, 2006 that this program would be voluntary rather than mandatory.
Many of us have been saying since the new NAIS User Guide was released, it is nothing but a smoke screen. They have every intention of imposing a mandatory NAIS at some point in the future. Looks like it will be through confusion and trickery to this poster.
Comment Sue Karber — February 1, 2007 @ 10:08 pm
Can anyone find these documents mentioned below or are they actually the old Documents. I have been all over the site, used search until blue in the face and still no documents to read to comment on…
SUMMARY: We are advising the public that we are making available for
review and comment three documents related to the National Animal
Identification System: A Draft User Guide, a Program Standards and
Technical Reference document, and a technical specification document
for the animal tracking databases.
ADDRESSES: All three documents are available on the Internet at link
Comment Sue Karber — February 1, 2007 @ 10:39 pm
Do you think this might be to harsh???
I am so appalled with the USDA that they would treat the hard working citizens of the United States of America by mandating the NAIS. Apparently the USDA or Congress have no concern what’s so ever that you will be the ones who run people out of there livelihood and there love of animals.
All letters that have been sent in the last year by citizens to their Senators all say the same. Each and every member of Congress and the USDA have no Understanding of the NAIS. We the People have been called factions, we have been called liars, we have been called rumor mongers, we know the NAIS , we have read and studied every document that the USDA has issued. We are not the dumbed down drugged up society you all have been hoping for, but intelligent hard working people that you all want to squash like a bug.
Do any of you realize what you will do to the economy when NAIS is Mandatory in 2009? In the last 100 years the citizens of the United States have done an exceptional job of controlling sickness and disease within there herds. WE are not he problem. Take our money and fix the countries who do have the foreign diseases of concern. If the Big Agriculture companies want NAIS as they import and export let them have it. With NAIS my dream of livestock ownership will come to an END!!!
I have a choice and that will be no more money to any local business dealing in any form of livestock products, no more money will go out of my state to other business’s for livestock equipment . No more money will go out to purchase a livestock trailer, no more money will go to purchase that new Ford truck. NO more money to anyone!!!! I do have a CHOICE and with that choice my dream of livestock ownership will come to an END!!!
The NAIS program reminds me of Stalin’s regime’s move to force collectivization of agriculture. When they say history repeats itself I am now a very firm believer.
The interim rule” of cutting off states who do not comply surely sounds like a “voluntary to mandatory” tactic that Stalin used.
Mr. Knight and Mr. Johannes constant belittling of the public such as calling us rumor mongers, telling us we are miss representing the truth and spreading miss information is appalling. When in fact these two men should be fired from there job by the taxpayers who pay your salaries. The USDA should be working for the farmers and not for Big Ag. Laws being written to punish us by excessive fines for traveling on public roads , forced searches for proper paper work, permits, health certificates, premises card. News cast after news cast it has portrayed America as unsafe, unsecure and has turned our population into reporting each other. My goodness where do I live? Sounds just like the factual stories my mother told me of Nazi Germany.
Our herds need not fear Disease, the USDA has all the rulings and regulations to come in and depopulate or stamp out our healthy herds. This program has got to stop, it has no benefit to the hobby farmer, it has not benefit to us small people other then milk us dry in fines, back door taxes on personal property. I’m appalled, disheartened that we all looked up to the USDA and now, well we can call it USDA, INC. owned and operated by big Ag and lobbyist. Where do I live again? It will be a cold day in hell when the USDA will ever regain its good name back from “We the people”. Stop this program for once and for all.
Comment Gisela — February 2, 2007 @ 4:03 am
Gisela, I don’t think it’s harsh at all. I remember my Grandparents stories too. They are tales that need to be remembered.
Comment Sue F — February 2, 2007 @ 6:40 am
…Gisela, your mesage was not to harsh.
Right on point, in fact.
I sent a message too, detailing the public’s rejection of NAIS.
My opening line was …”I’m opposed to any type of National Animal I.D. “voluntary, “mandatory” or the currently proposed and very sneaky “voluntary / mandatory”. Naturally I went on a bit more too.
I urge everybody to send in
messages stating your opposition to NAIS. If you aren’t as verbose as some of us, a simple message stating you reject NAIS in any form will do. We must be heard!
Comment Bob Constantine — February 2, 2007 @ 7:07 am
Notice on Sue’s comment #7 link the USDA comes right out and says access to markets.
Comment Sue F — February 2, 2007 @ 8:06 am
I just sent mine out. As follows:
Why do you persist on pushing NAIS, when you know it is not wanted? Why do you feel that you have this need to put the screws to the small farmer and homesteader, and put our food supply in total jeopardy?
NAIS makes absolutely no sense. However, USDA, Inc, has partnered up with Monsanto and the rest of big ag, and couldn’t care less about anything but their own bottom lines. And please don’t insult my intelligence by denying this, as USDA alone owns how many patents? Monsanto wants to take over how much of agriculture world wide?
You all keep saying that, those of us against NAIS are lying, fear mongering, etc. No, we’re not. It is you and you alone who are doing this. Your people are giving the wrong answers. Your people don’t even know half the time what your own bogus program says. You are the people lying to everyone, including the consumer.
You keep harping on the fact that Japan wants trace back? That is BS! All Japan wants is testing of the meats, like what Creekstone wants to do, but YOU, the USDA, will not allow. Yet, you’re getting ready to allow meats and stock from other countries WITH problems to come in.
It is obvious that the USDA is trying to sabotage agriculture to meet its own needs. NAIS is not about disease, it is about tracking, it is about the slow elimination of the small farmer and homesteader. It is about YOU, the USDA being more concerned about big ag than about the people.
If you were REALLY concerned about animal health and food safety, you would close down all the Tysons and Mosantos of the country, as well as the factory farms world wide, and go back to all small farms, local abattoirs and on farm purchases. THAT is animal health and a safe food supply.
Now, who do you people think you are kidding.
If you really were worried about the people, you would listen to the people.
Thank You
Kim Pezza
Marion, NY
Comment Kim P. — February 2, 2007 @ 11:34 am
How about this approach?
Dear USDA Public Servant(s):
I would greatly appreciate it if y’all would kindly tell your bosses to, cease and desist, wasting the American peoples money promoting the National Animal Identification System(NAIS) for the benefit of their special interest friends over at National Institute for Animal Agriculture(NIAA) and elsewhere.
Do you folks realize they are suppose to be working in behalf of the ‘people’ of America, not against our best interests?
Now, I appreciate that you who are reading this don’t make these dumb repressive rules, and you probably love our country too, so don’t take this personal OK?! My beef is with those who develop these rules and your bosses who are trying to make them the law of the land by bribing my state agricultural officials to do what your bosses cannot legally force feed us hicks. Do note this isn’t being adopted through Congress, that this is some sort of bureaucratic end run.
Also, you’d be doing your fellow Americans a real service, if you’d leak as much information as possible about the what your bosses, and their cronies are doing and planning; because I have to tell you, what they’re trying to accomplish with NAIS is but one aspect of endangering the American food supply, which, in the short term, will assuredly lead to higher food costs for everyone(ask the Aussies). And shortly after that, will most certainly lead to shortages due to the limitation and/or complete elimination of local producers. And a great deal of the market is made up of small local producers.
Too, being you work there, you must be aware how insecure digitized information is. Do you really want the information of where every farmer is, in databases, where they can be stolen en masse. Imagine what a terrorist could do with that, let alone the major players of agribusiness, y’know …?
So again, if you could see your way clear, because you love the American way of life, we could use all the leaks you can safely manage. By the way? Do you realize they want to GPS everyone’s property so farmers can be policed by satellite. Or, that some of that is already occurring. And that the Census Bureau has already announced they are going to GPS every Americans front door in 2010(in addition to searching our backyards , garages and sheds?). And finally, that this system will violate the 4th Amendment of our Bill of Rights, among others.
I tell ya true, your fellow Americans out here could really use a few heroes down there is DC to help us out with the inside dope. Thanks a bunch and good luck(I suspect , if you’re reading this, you’re not all that high on the USDA food chain).
Did I mention, my family wants NAIS junked? Well we do!
peaceably,
Vermont
“Absolute power is when a man is starving and you are the only one able to give him food.”
- Robert Mugabe, Zimbabwe’s Marxist dictator
Do you really want that power in your bosses, or agri business’ hands?
Comment Mr Dirty Nails — February 2, 2007 @ 2:26 pm
Lost another one to the cyber eater,Gisela,no you were not harsh,truth can be harsh to those who are gettin it spoken to them,but truth is the only thing that will prevail,the govicorp hasn’t seen or heard harsh “yet” as to what they’ll get if they keep this crap up,keep on telling the truth,if it makes them mad,GOOD!
Comment LEE — February 2, 2007 @ 3:22 pm
Kim #12, take no prisoners! Good job on your letter!
Comment Bob Constantine — February 2, 2007 @ 4:57 pm
“Just the facts, Ma’am.”
Just sent my opinion to them. Though I don’t feel that I was derogatory towards them, I let them know that I have this ongoing dream of being an AMERICAN with freedoms and rights to choose what is best for me.
We shall prevail!!
Blaine Hubsmith
Richfield, Idaho
Comment Blaine Hubsmith — February 2, 2007 @ 6:53 pm
WALTER!!! You broke 200000!!!!!
Comment PV — February 2, 2007 @ 7:02 pm
I just sent these comments off:
I am totally opposed to mandatory NAIS and mandatory premise ID registration.
The process that created NAIS excluded the small producers, hobbyists, recreational horse owners, and those who raise food for their own family. NAIS has been expensive – close to 100 million dollars.
No cost/benefit analysis was ever done. We don’t know how much it will cost. We don’t know who will bear the cost of this. We don’t know the financial impact for small producers or for rural communities. Most states have animal id and traceback procedures that have been in place for years. No attempt was made to analyze whether or not these procedures are adequate, or if they could be enhanced. Spending so much money with so little thought brings into question whether or not the USDA is a good steward of our tax dollars.
The groups that the USDA chose for input are not representative of the general livestock owners. For example the American Horse Council is primarily a lobbyist for the race track gambling industry. And it should be no surprise that the AHC’s hand-picked ESWG represented the gambling industry, the microchip/database industry, and those who would benefit monetarily from NAIS. Even though the majority of horse owners are pleasure owners, not one person on the ESWG represented that group. I provided feedback to the ESWG and received acknowledgement from only one member of the group. This process did not leave me with the impression that anyone at the ESWG was even bothering to read my comments. A taxpayer’s communication with the USDA should not require contributions to the correct lobbyist firm, either as a member or for access to their meetings.
The USDA received input from the American Farm Bureau. This is a company that is first and foremost an insurance company. In order to buy insurance from the AFB one must become a member. The AFB has more members than all the farmers in the US. The Farm Bureau is not the voice of the farmers of this country; it is the voice of big business.
We’re all concerned, of course, about the welfare of our animals. In the event of an outbreak of a disease the USDA and the state animal health agencies will need the support of the general livestock owning public. Yet, it appears that the USDA and the states are doing everything possible to alienate those whom they need the most. Calling a program voluntary and then providing money, through cooperative agreements, to the states so that the states can make premise id mandatory and supply the information to the USDA is underhanded. It undermines our trust in the government. USDA policies need to be up-front and transparent. Calling a program voluntary but then restricting access to veterinary care, feed products, sale of livestock, breed registration, and shows to those who have a premise id is coercion, not a voluntary program. The USDA’s acceptance of premise id information, collected by the states through data mining or from non-profit organizations, bribed with CA money, is not a voluntary program – it is an invasion of our privacy. Any program that is truly voluntary has a process for one to opt-out; the USDA has not specified what this process is.
The use of cooperative agreements to the states for mandating premise id has spawned duplication of effort. Each state, each participating tribe, and territory all will have their own system., their own database. Why should the taxpayers being paying for the same program 50+ times? There are no mechanisms to guarantee the safety and privacy of our data.- even with just one database. How can anyone trust that 50+ different programs will keep information secure?
My recommendation is to end NAIS. Work with the states to enhance their traceback process. We currently have food safety regulations; if they are not adequate fix them – don’t create a whole new system. If the export market requires animal id, let producers via the market decide whether or not to participate; don’t subsidize this with taxpayers’ money. If animal movement is a concern, increase the international quarantine time and restrict the importation of livestock from countries with disease problems.
Comment Ann Nelson — February 3, 2007 @ 12:34 pm
Ann,Well said!
Comment LEE — February 3, 2007 @ 4:24 pm
No a thousand times no.
The USDA may be, “Big Brother,” but GOD makes thing grow not ignorance.
NAIS is not going to prevent the spread of disease caused by factory farming.
It is factory farming that needs to be eliminated not independant farmers.
NAIS only legalizes disese trafficking. NAIS is a betrayal of the PUBLIC TRUST
not a protector.
NO to NAIS
James D. Basinski
Comment James — February 3, 2007 @ 8:05 pm
If you want to be really effective you should send your comments to these guys, too.
John.Clifford@usda.gov
Ron.DeHaven@usda.gov
Bruce.Knight@usda.gov
John.F.Wiemers@usda.gov
Sharon…always stirring the pot.
Comment Henwhisperer — February 4, 2007 @ 8:39 am
I just responded to this article to opinion@capitalpress.com
link
I responded only to the voluntary part. Here is what I wrote to help out my fellow state of Washington:
Cookson Beecher wrote “the USDA has made the controversial National Animal Identification System voluntary, the agency is still aiming at 100 percent participation by 2009.” I would like to dispel this miss-information to the readers of Capital Press.
I have read all the documents on the National Animal Identification System and the USDA will not stop until it is MANDATORY as per this Cooperative Agreement.
link
on page 11 in the CA
Projects must focus on implementation of premises and animal identification methods according to the standards defined in the NAIS Draft Program Standards
on page 16 in the CA
“Provide a brief overview of the work to be performed and how the plan builds upon the 2005 or 2006 cooperative agreement plan. Also, explain how this plan will support the timelines for full implementation of NAIS as outlined in the draft strategic plan.
This means the USDA has all intentions of following the Draft Strategic plan.
On the cover of the NAIS User Guide it States, link “The November 2006 Guide is the most current plan for NAIS and replaces all previously published program documents, including the 2005 Draft Strategic Plan and Draft Program Standards and the 2006 Implementation Strategies. I think with the small amount of information that I wrote above clearly demonstrates that the USDA and the State Vet are miss-informing the public again.
Further more, another document is recommending that any state that does not support NAIS will not be able to ship across state lines.
link
Two recommendations were considered by the Committee. The following recommendation was approved by the Committee.
That USDA-APHIS-VS with input from the National Assembly of State Animal Health Officials (NASAHO), promulgate an interim rule that establishes a list of Consistent States for Cattle Identification. The rule would provide for restriction of interstate movements other than direct to slaughter from non-consistent states. The rule would specify that consistent states have established by law, rule, order, or other means requirements that all breeding age cattle be officially identified by means of official tag or registration brand or tattoo at each change of ownership, other than movements direct to slaughter, or movements through one approved market and then direct to slaughter. Further, that consistent states have import requirements that all such cattle be officially identified prior to import or at first point of concentration. Consistent states may grant waivers for such requirements for interstate movements which are part of normal operating business with no change of ownership and for seasonal grazing/feeding as agreed to by the state and federal animal health officials of the states involved. Further, that this interim rule be promulgated prior to July 1, 2007. In addition, the Committee recommends that a follow-up rule be promulgated prior to July 1, 2008, that establishes consistent states as those that have in place similar requirements for breeding aged cattle upon change of ownership for feeding or grazing.
-Report Of The Committee On Livestock Identification
The Committee has recommended that, prior to July 1, 2007, the USDA should promulgate an “interim rule†that would prohibit interstate movement of cattle from any state that fails to REQUIRE THAT ALL BREEDING AGE CATTLE BE OFFICIALLY IDENTIFIED at each change of ownership. Such an “interim rule†would make it impossible for any state to resist, because it would become economically isolated. Also note that an “interim rule†can be promulgated WITH NO PRIOR OPPORTUNITY FOR PUBLIC COMMENT.
Is the USDA planning to follow this Committee recommendation and force NAIS upon the entire nation by means of a dictatorial “interim rule� It is bad enough that the USDA has been killing off American agriculture for decades; don’t let them kill off democracy.
If the Committee of the USAHA can recommend this for cattle, will pigs, chickens, goats, equines, and the other listed livestock under the “Draft Strategic Draft Plan” be included?
People need to realize that the NAIS will be under FEDERAL RULES and REGULATIONS. Its a legal binding contract where you can not opt out once you sign up “VOLUNTARILY” and they need your signature to do so.
Every “State” who implements the National Identification System will have to be Stripped of the United States of America’s Constitution and the Bill of Rights in order to comply with this “Voluntary to Mandatory” Program in Jan 2009 per the timeline in the USDA DRAFT STRATEGIC DRAFT PLAN!
Comment Gisela — February 4, 2007 @ 5:56 pm
Just sent comments… took several weeks to think it over and decide what to write. I took the I’d-prefer-it-if-you-scrap-the-entire-thing-but-if-you’re-going-to-keep-it-you-need-to-overhaul-the-entire-plan-and-here’s-where-you-start angle. I don’t think that they will ever do it, but I think that if they do, it will go a long way toward protecting the individual against the bad parts (I know, I know, it’s much easier to point out what isn’t bad - nothing! but even so). The letter was three pages long in 10pt Times New Roman. Here’s some of the points I brought up:
- I explained specifically what I found utterly intolerable about the NAIS program. I explained my utter lack of faith in the USDA and its related agencies to do its job in any measure or to be in any way uncorrupt. I explained why I feel this way. Then I explained how they could fix it, starting with putting all kinds of policies in place to ensure that the NAIS remains 100% voluntary.
- I explained that they need an independent oversight committee in Congress to ensure that the USDA does not bribe states with federal funds to make NAIS mandatory in any state (I know, I know… I can hear your objections from here).
- I told them they need a Livestock Owners’ Bill of Rights which will guarantee all livestock owners of their civil rights and protect them from federal and state employees, providing a system for redress of grievance, whether there is an “emergency” or not. It must specify in specific terms what an emergency is and is not. And it must be ratified by at least 3/4 of all livestock owners/businesses whether they are signed up with the NAIS or not… One vote per individual or entity so that Big-Agro can’t throw their weight around. (I kind of like this idea… although I’m sure that there are all kinds of problems with it… it’s democratic, and damn it, I like democracy!)
- I emphasized that there must not be any penalties of any kind for not participating in the NAIS, and there must not be any coercion by any agency or entity to participate.
- I also said that all livestock owners must be reimbursed by the federal government for any loss of property during an emergency and must not be held finacially or legally responsible for any emergency situation not wholly of their *intentional* making, which must be proven in court at the government’s expense.
- I said that livestock owners must be notified verbally and in writing of the emergency when it occurs and of their rights any time they are visited by a USDA, other agency or state employee.
- I said that reimbursement to NAIS participants must be made for any financial burden beyond published USDA estimates.
- I said that there must be an easy and clear way to un-register from the program at any time for any reason and there must be no coercion to register or re-register.
- I said that buying an animal from someone signed up in the NAIS must not register the purchaser and they must be permitted to remove the NAIS ID device with or without notifying the NAIS of its removal.
- I said there should be a means by which people or entities can legally transport livestock across state lines without requiring participation in NAIS or any similar program.
- I said that the security must be improved to Fort Knox like proportions to safeguard the personal information of those enrolled in NAIS.
- I said that the USDA should require and personally review safety testing of all devices used to ID animals at the expense of the company developing/selling the device before approving or recommending its use to the public because I have read that microchips have been found to cause cancer.
In closing I said, “Ensuring the privacy, the civil rights and the unalienable rights of livestock owners should be the USDA’s number one priority in any attempt to implement the NAIS program. I do not believe that this is the case at this time. I do not believe that the USDA has any concern with ensuring the civil rights of American citizens. I believe that at the moment the USDA is implementing a program designed to limit the rights of US citizens in unconstitutional ways, to strengthen big-agro businesses at the expense of small businesses and individual citizens who own livestock, and to bow to unreasonable pressure from the World Trade Organization. The USDA is responsible to the American farmer first and foremost. The USDA’s responsibility is not to help big business stomp on the little guy or to help international organizations dictate policy inside the United States. As Abraham Lincoln said, it is to be the people’s department. The USDA and all of its employees and related agencies would do well to remember this and to use it as their guiding principle.”
Comment Rachael — February 6, 2007 @ 11:13 pm
Very good, Rachael!
Comment Goatman — February 7, 2007 @ 1:36 pm
Thank you, Goatman! ;D I do try…
Comment Rachael — February 7, 2007 @ 8:52 pm
Oh, and thanks for the additional contacts, Sharon! I sent a copy of my letter to them too… I can’t wait for the response!
Comment Rachael — February 7, 2007 @ 9:14 pm
My hubby says I’m on a rant, but here’s what I sent:
Comments on the NAIS program as proposed.
Our position: My husband and I own horses, sheep and poultry. We are a private, non-commercial small farm and use the animals for their meat, eggs, fleece and for entertainment. We do periodically buy animals, both in-state and inter-state, and may have goats or cattle in the future. We intend to raise / breed / sell a small number of heirloom livestock in the future, probably including cattle and sheep.
We are opposed to the implementation of NAIS in general. We are absolutely opposed to its application to small farmers, small producers, homesteaders, and private individuals. We are absolutely opposed to any mandatory implementation, and any voluntary implementation that could be made mandatory by state legislation, or implemented as a de-facto-mandatory by duress through economic pressure or restriction of access to services.
Incidentally, we are not *nuts* or rumormongers, and object to the characterization of NAIS-objectors as such by Mr. Knight and Mr. Johannes, et al.
Our specific objections (detailed reasons follow below):
1: We objection to allowing or inviting government control, regulation, and oversight into areas it does not belong in, including our backyard.
2: NAIS is not as voluntary as it is promoted to be.
3: Regulating our animals does not improve public safety or reduce the risk of the spread of disease.
4: NAIS interferes with the right to conduct commerce.
5: NAIS costs *our* money and takes *our* time.
6: NAIS does not provide much in the way of prevention.
7: The government already uses heavy-handed and open-ended tactics in dealing with producers, more opportunity to do so is frightening.
8: We have a visceral objection to chipping our animals.
9: NAIS does not provide any real protection against the theoretical introduction of disease as a terrorist act.
10: Regulation and registration of horses and other non-food animals is wholly unnecessary.
11: NAIS is redundant to existing and already functioning programs.
12: Application of NAIS to llamas and alpacas is not necessary.
Point 1: Our first objection is to allowing or inviting government control, regulation, and oversight into areas it does not belong in, including our backyard.
We have had several first-hand and more second-hand experiences with government regulation that brought home this point: Individuals within the government sometimes use or misuse the rules to suit their own purposes. We have absolutely NO confidence that the rules will be applied in the spirit that they were written, as we have personal experience that often they are not. The letter of the law is what matters, and people’s assurances about how and when it will be applied are meaningless. Further, we’ve seen the letter of the law turned to suit an agenda… so not only is the letter of the law important, but every possible interpretation of it needs to be considered… If it could possibly be interpreted or applied in a particular manner, sooner or later, it will be.
This is especially important to consider when we have limited resources to defend our position and our property, and the government has essentially unlimited resources. More concerning still is that the government has the power to take control of or destroy our property and our animals and detain or arrest us before a court would even hear a case. We are aware of a number of cases where animals have been destroyed before their owners have had a hearing before a judge. We personally know people who have been arrested on what we know *for a fact* to be false pretences and lies. Once the damage is done, it is done. Dead animals cannot be restored if the government is later determined to be in error.
Point 2: NAIS is not as voluntary as it is promoted to be. Often, things said to be “voluntary” are not so in practice. Pressures can be applied to force the issue. For instance, the “interim rule” to prevent the movement of animals from noncompliant states would pressure these states to comply or lose the economic opportunities of buying or selling outside their own territory. It could prevent us buying livestock from out of state, or even moving the livestock we already own. That is an outrageous invasion of our rights as property owners.
In addition, any voluntary program that is promoted as expecting 100% compliance within 2 years does not meet the requirements for “voluntary”.
Point 3: Regulating our animals does not improve public safety or reduce the risk of the spread of disease. Regulating our animals provides no public good or personal advantage, and introduces additional costs and government intrusion.
The government has no place in our back yard or in regulating our livestock. We are not a large commercial producer. We have a few sheep, horses, chickens, ducks, and geese. We do not keep our animals in a high-density environment where diseases are likely to spread. We do not buy and sell and have transient animals that might introduce or contract a disease and then be moved before it became evident. In theory, we might give or sell come eggs to a neighbor, or sell a lamb to be slaughtered or bred, but we will know our buyer and they know us. They know precisely where the animal came from; most likely have been on our property. They know what conditions the animal has lived in and how it has been cared for. If they have questions about our husbandry, they can check it out first hand before buying. If there were to be a problem, there is only one place to go, no mystery to be solved, and no risk to the general public’s health. If an animal we sold were to turn up ill - unlikely since it has only lived on our farm and is not exposed to other animals - the problem would still be contained… our farm and theirs. Simple good husbandry practices like quarantine of new animals reduces the already minimal risks.
Point 4: Interference with the right to conduct commerce. It seems to us that the opportunity to engage in commerce is one of the most basic of human rights. If we choose to buy or sell an animal or animal products from a neighbor, or to a friend, how is it the business of the government to be notified of that? If we raise half a dozen calves on contract for individuals that want lovingly raised, home-grown beef, how is it the government’s business to regulate that? Since doing so does not pose a general public health risk, there is no need to be involved for that reason. Perhaps, then, it is for reasons of tracking commerce? Since it is the current practice that those transactions may be taxable, it is our obligation to report income or expenses as part of our already existing tax obligation, and under already existing tax laws. There is no need for additional regulation or government invasiveness to cover commerce.
In addition, for the small farm, homestead, or landowner, NAIS does not protect access to markets. While we know that large commercial producers may like the tracking-factor because it makes them appealing to foreign markets, we are never going to be selling a steer to Japan. Our potential market is protected by the fact that we are a small grower with an attention to the welfare of our animals, and our customer’s product needs, because it is our way of doing business. Because it is our way-of-being in the world. If our customer wants what NAIS provides, they can buy beef at the market. If they want what we would provide, it has nothing to do with NAIS.
Point 5: It costs money. Regardless of if we pay directly for the tracking devices and services, or they are paid for through tax-generated “government” funds, it is still our money. Regardless if it is ten cents or a thousand dollars, it is still *our* money. The government already takes plenty of our money for use in things we may or may not approve of, not to mention obscene amounts of waste. We see no reason for the government to take more of it, directly or indirectly, for a program that, as it applies to us, provides no benefits. Why should we have to give them any amount of our money so we can have and use our horses, sheep, chickens and ducks?
Besides that, it takes time. Tagging, reporting, tracking all take time. For a program that provides us no benefit, why should the government be able to require we spend that time? Or punish us if we don’t?
Point 6: It is not clear to us that this program provides much in the way of prevention… rather it allows tracking of the perpetrators in case of a problem that has already occurred. It seems to us that in most cases this is already rather well accomplished by the existing systems. Cases of contaminated meat are relatively quickly tracked back to the source and the government already jumps in with quarantines and testing. The product is removed quickly and *further* illness is averted. I say *further* because the initial outbreak is NOT prevented, and we see no way in which the NAIS program would provide prevention. It is not clear to us how this program would provide significantly faster tracking back to the source that the existing systems. I don’t recall where I read it, but we think the numbers I saw were significant… current system tracks to source in 72 hours, where it is proposed (not proven or guaranteed) that NAIS would track to source in 48 hours. We are greatly opposed to giving the government huge new rights and accesses for that theoretical 24-hour gain.
Point 7: The government already uses some heavy-handed and open-ended tactics in dealing with producers; we find it scary that we would voluntarily offer more ways to do that. It was recently all over the news that some children had gotten sick with e-coli in raw milk. The producer was shut down, without a resolution date. Testing was done and *no* contamination was found. More testing was done and *still* no contamination was found. The dairymen have been throwing out their products for months, unreasonable economic harm has been done to both the producer and the dairy cow owners, but the government takes its time and the restrictions are not lifted. Recourse through the courts is slow, and certainly there has been no public vindication of the dairy or its products. In this case, the government found a likely looking villain and never mind that there is no proof. Those people have been irreparably damaged and are unlikely to be compensated. They are guilty until proven innocent and that is wrong, not to mention un-American. It is examples like this that make us wholly unwilling to yield our options and freedoms and offer more rights to the government.
Point 8: We have a visceral objection to chipping our animals. We would never permit ourselves to be chipped, and have no intention of allowing our animals to be chipped either. Aside from the issues of the right to control of property and person, this is an invasion we find completely unacceptable. It is our belief that we have the incontrovertible right to control our bodies, what goes into them, what is done to them. We believe that right extends to the living creatures whose lives we have accepted responsibility for.
Point 9: We don’t see that this program provides any real protection against the theoretical introduction of disease as a terrorist act. As we understand the proposal, not allowing un-tagged animals into the system would in theory protect us from terrorist acts. Somehow, it would seem the terrorists would find it easier to introduce a germ rather than a whole steer. Somehow, the distribution of an aerosol virus or a powder into a feedlot, feed manufacturing, or water supply (like what was done in DC with the Anthrax incident) seems much more likely and much more practical than the introduction of a whole animal. NAIS would do nothing to protect against that. We think this is a boogeyman being used to generate fear… a common tactic when convincing folks to give up freedoms and relinquish personal responsibilities for a theoretical “guarantee” of protection.
Point 10: Regulation and registration of horses, llamas, and other non-food animals is wholly unnecessary. We totally do not understand the need for applying the NAIS to horses. In more cases than not, the diseases of livestock do not affect horses, and vice versa. Horses are not part of the human food chain in the US, and are not carriers for diseases that could, through consumption of meat, eggs, or dairy products, affect humans. There are already laws in place requiring health testing for potentially contagious horse diseases when transporting inter-state. Facilities such as racetracks and show grounds are already attuned to identifying and quarantining animals that show signs of illness, and many already have their own regulations. We don’t see that the NAIS program is going to provide any disease prevention, while it imposes new requirements and opportunities for government interference in people’s lives and businesses.
Point 11: The NAIS is redundant to existing and already functioning programs. We are not convinced that the NAIS program would serve better than the programs such as the lucid and well-articulated plan by the Minnesota Department of Agriculture.
Under the MDA program, infected animal movement would be controlled, infected animals would be destroyed, and quarantines would be put in place. Their program provides for testing, vaccination, and decontamination. Their excellent state plan provides a clear and solid guide for how to manage an outbreak of FMD, or any other highly contagious livestock disease, for that matter. It clearly states who is responsible for what, and what actions should be taken in the various possible eventualities. It has the advantage of state and local control, which is bound to make it more responsive to the conditions, needs and knowledge of the local population.
When states already have such programs in place, the NAIS program is not needed and is, in fact, unwanted, redundant, and expensive overhead.
Point 12: Application of NAIS to llamas and alpacas is not necessary. How is the public health protected by tagging and tracking the movement and sales of llamas? This we totally don’t get. They are not part of the US food chain, they cannot pass diseases to humans, and while they might carry diseases that could be transmitted to sheep or cattle, there are already extensive state programs in place for identifying and controlling things like FMD.
Conclusion: We are not large commercial producers, and don’t know enough about that to have an opinion about the advisability or usefulness of a NAIS program in that arena. But we are categorically opposed to the application of NAIS to small producers, small farms, homesteads, and the average rural landowner. Beyond that, we don’t see that this program would actually do much of what it is being pitched on. We have enough government overhead already and can’t see the value in having more big government oversight to achieve what we think will be a very small result. Especially not when it empowers the government to invade our privacy, regulate our activities, and oblige us to fees and efforts and potentially penalties in a program that brings us no benefit whatsoever.
Comment megan — February 7, 2007 @ 10:06 pm
Well said, megan! I don’t think you were ranting.
God Bless
Comment Goatman — February 8, 2007 @ 12:31 pm
Way to go, megan! I’d send that to Knight and the rest of them too, while you’re at it. It is very well put!
Comment Rachael — February 8, 2007 @ 3:29 pm
I simply said I am against the NAIS/NIAA/Monsanto/Digital Angel/Cargill meats/ I do NOT want this. From what we learned in Montpelier, they summarize all the letters and hand the reps a short how many want it and how many don’t. At least send a simple ‘ I am against or I do not want the NAIS.
Comment karenTaylor — February 27, 2007 @ 8:22 am
Here is what I sent yesterday:
I am totally opposed to the National Animal Identification system. I read a large part of your current User Guide draft and found no good reason for this invasion of privacy. It would be completely non-sense for the registration in this system to become mandatory. Our country is one of freedom. Have you think about the Amish people living of their farm? This system would be against their religious values. They cannot use any technology.
Let the United States remain free.
Some method for disease control would be far more effective and, even, less expensive. A basic example is the ground beef. Don’t mix meat from hundredths of cows all together!!! Europe and Japan have already taken such measure. It is not because the USA is independent that it cannot follow good examples from other countries.
In your User Guide draft of November 2006, it is stated “Time is money”. Whose first concern is money? Not the small farmers. It is probably your first concern and the concern of big food and meat industry. The concern of small farmer is to eat healthy and produce top quality product, fresh from the farm. Not to produce big quantity of meat, completely safe thanks to irradiation and preservatives.
I am deeply and completely opposed to this system.
Are animals the guinea pigs before you try this system on human?
Aude
Comment Aude — February 28, 2007 @ 10:40 am