July 16, 2024

R-CALF United Stockgrowers of America


“Fighting for the U.S. ! Cattle Producer”


For Immediate Release                                                                         Contact: R-CALF USA CEO Bill Bullard

December 17, 2011                                                                                          Phone: 406-252-2516; r-calfusa@r-calfusa.com


8 Days of Opposition to USDA’s Proposed Mandatory Animal Identification Rule:  Part IV of VIII-Part Series

Billings, Mont. – As promised, R-CALF USA has launched an 8-day series of news releases to explain in detail many of the reasons our members vehemently oppose the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service’s (APHIS’) proposed mandatory animal identification rule titled, Traceability for Livestock Moving Interstate (proposed rule).

With this effort, R-CALF USA hopes to bring to light many of the dangerous aspects associated with the proposed rule that R-CALF USA described in its voluminous comments submitted to APHIS on Dec. 9, 2011. Click here to view the entire 41-page comment submitted by R-CALF USA, which includes all of the group’s citations to specific references that are removed from this news release to save space.

Part IV:  APHIS’ Cost Estimate for the Proposed Rule Robs Peter and Pays Paul


C. APHIS Grossly Understates the Economic Cost of the Proposed Rule that Will be Borne by U.S. Cattle Producers 


  1. 2.      APHIS likely relied on misinformation when it calculated its grossly understated cost estimate for the proposed rule.


APHIS commissioned a study in 2009 titled “Benefit-Cost Analysis of the National Animal Identification System” (EXHIBIT 13) (APHIS ID Study), which study APHIS heavily relied on to arrive at its grossly understated cost estimate for the proposed rule. The assumptions used in APHIS’ ID Study are erroneous and do not reflect actual costs by U.S. cattle producers for tagging cattle. For e! xample, the APHIS ID Study estimated the cost of working (i.e., tagging) cattle based on a 2005 NDSU Article by Dr. Ringwall and assumed it took only 66 seconds to work an animal in a squeeze chute that took 15 minutes to set up; and the chute cost per head was $1.00 (EXHIBIT 13, p. 16).  However, the article referenced by the APHIS ID Study that was used to calculate an artificially low cost to the cattle industry for tagging cattle explained that the cost estimates were based on the use of a state-of-the-art mobile cattle working system that likely is not availab! le to many, if not most, U.S. cattle producers:

The team utilized the For-Most portable hydraulic double alley with a 750 chute. The system, as described by For-Most, has a 14-foot adjustable double alley, adjustable overhead grill and a 4- foot funnel section to a 9-foot single alley behind the model 750 squeeze chute and scale.

Cattle were fed into the For-Most system through a portable Wilson Wheel Corral, a series of hinged panels that unfold from the travel position to a complete corral for 140 head of calves (600 pound) and can be set up by one person in seven minutes (as described by Wilson). The team found setup time was quick and easy, utilizing available hydraulics and skill and experience with fifth-wheel driving (EXHIBIT 14).

In addition, the setup and teardown time for the state-of-the-art equipment that enabled Dr. Ringwall’s team to work each animal in only 66 seconds actually took 56 minutes and 34 minutes, respectively (EXHIBIT 14), which is much longer than the 15-minute setup time used in the APHIS ID Study, and that APHIS used in its supporting document.


Further, while the APHIS ID Study estimated that the cost to beef cow operators for a bookend-type identification system, as manifested in the proposed rule, was only $3.919 per head (EXHIBIT 13, p. vii), and APHIS’ upper-end cost estimate was only $0.76 per head more, the articles by Dr. Ringwall actually relied on by the APHIS ID Study estimated the actual cost of working the cattle, excluding the cost of ear tags, using the state-of-the-art cattle working system wa! s a total of $7.27 per head, provided that 10,000 head of cattle were worked through the cattle working system on an annual basis (EXHIBIT 15).


This is but one glaring example of how the authors of the APHIS ID Study deceived the public and APHIS by misusing legitimate data for the purpose of generating an inaccurate and fictitious low estimate for the cost that typical U.S. cattle producers would incur under a bookend-type animal ID system, as is contemplated in the proposed rule. This example alone reveals that the APHIS ID Study manipulated data to underestimate the basic cost of working cattle by $3.35 per head, even when worked in a state-of-the-art cattle handling facility that is beyond the reach of many, if not most, U.S. cattle producers.


Another glaring example of data manipulation in the APHIS ID Study is its treatment of shrink.  For the cow/calf industry, the APHIS ID Study included only 25 percent of the expected shrink as a cost to the cow/calf producer (EXHIBIT 13, p. 18). The APHIS Study rationalized this deceptive ploy on the basis that the buyer of the shrunken cattle would realize a compensatory gain when ! the cattle were sold and subsequently afforded an opportunity to eat and drink (EXHIBIT 13, p.18). The practical effect of this misuse of data, of course, is that the true cost of shrink borne by U.S. cow/calf producers for tagging their cattle was understated by 75 percent. Based on the fact that APHIS used the APHIS ID Study’s shrink estimate, it too reduced the true cost of shrink that cow calf producers will realize when tagging cull cows and calves by 75 percent.


APHIS is dead wrong to assume that “the cattle industry” would realize only a 25 percent net loss because the buyer would benefit from a compensatory gain. This is because the cattle industry is a distinct and separate industry from the meatpacking industry and when a cattle industry participant sells cull cows to a meatpacking industry participant and APHIS assigns only 25 percent of the cattle industry participant’s cost to the cattle industry, then APHIS has affectively robbed 75 percent of the cost actually realized by the cattle industry and gifted the monetary value of that cost directly to the meatpacking industry. By slight-of-hand, APHIS silently attempted to rob Peter to pay Paul in its effort to artificially lower the true cost of its ridiculously expensive mandatory animal identification scheme.


It must be noted that despite APHIS’ intimation that that the U.S. cattle herd, as it measured by dividing the total cattle and calf inventory by the total number of U.S. cattle operations, “is now nearly 100 head” (see supporting document, at 12), the average size of the U.S. beef cow herd remains at less than 42 mother cows per herd (as measured by dividing the total number of beef cows by the total number of beef cow operations). It is those cow/calf producers, which collectively have an average herd size of less than 42 head, who will be directly burdened and financially disadvantaged by the proposed rule. And, many, if not most, of those cow/calf producers do not have access to the state-of-the-art cattle working system used in Dr. Ringwall’s study. Therefore, the actual costs borne by ! U.S. cow/calf producers would be expected to be higher than Dr. Ringwall projected.

For the foregoing reasons, APHIS’ reliance on the 2009 APHIS ID Study to estimate the cost of the proposed rule on U.S. cattle producers is unjustified, erroneous, and deceitful. As a result of APHIS’ direct reliance on the APHIS ID Study, APHIS’ cost estimates likewise are unjustified, erroneous and deceitful. Based on the realistic cost estimates generated by Dr. Ringwall’s study, the proposed rule’s start-up costs and annual costs, which would range from a low of $554 million to a high of $1.9 billion, are unfeasible. APHIS’ proposed rule is a financially unworkable albatross that will economically harm U.S. cow/calf producers who will not be afforded any opportunit! y to recoup their costs in the marketplace.


R-CALF USA encourages readers to share this information with their neighbors, state animal health officials, and their members of Congress. 


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R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is a national, nonprofit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. For more information, visit www.r-calfusa.com  or, call 406-252-2516.

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