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Livestock gobble up the antibiotics

Melissa Healy. Los Angeles Times
December 14, 2010, 12:35 p.m.

The U.S.-raised animals we eat consumed about 29 million pounds of antibiotics in the last year alone, according to a first-ever Food and Drug Administration accounting of antimicrobial drug use by the American livestock industry.

The release of the figures — in a little-noticed posting on the FDA’s website Friday — came in response to a 2008 law requiring the federal government to collect and disseminate antibiotic use in livestock as part of the Animal Drug User Fee Act. The Union of Concerned Scientists, which authored a 2001 report that was highly critical of the routine practice of feeding antibiotics to livestock, estimated the yearly animal consumption of antibiotics to be eight times as large as the volume of antibiotics produced for human consumption in the U.S.

Mardi Mellon, director of the Union of Concerned Scientists’ Food and Environment program, said the new report corroborates the 2001 findings of the group’s report, titled “Hogging It.”

“Antimicrobial use in U.S. agriculture is way out of proportion” to what is necessary, said Mellon. “That poses dire risk to human health by undermining the effectiveness of these drugs,” she added.

Farmers feed these medications to the animals they raise for market in an effort to prevent disease from spreading among poultry, pork, dairy herds and beef cattle. Some medications also promote faster growth in many animals. The ubiquitous use of these medications is controversial because they are often used to counter the effects of raising animals in poor conditions.

But they represent a major public health concern too: the widespread administration of antibiotics to prevent infections in animals has made those same antibiotics less effective in fighting off disease in animals and in humans. That is because, when under constant bombardment by existing antibiotic medications, the viruses that cause disease evolve at an accelerated rate just to stay alive. The results: new viruses that are resistant to existing antibiotics, and a population that is increasingly vulnerable to them.

The American Medical Assn. this summer called antibiotic resistance “a major public health problem” and called on the Obama administration and Congress to take action to address it.

The Obama administration recognizes the problem, but has not acted to stem antibiotics’ use on animals, said Mellon of the Union of Concerned Scientists. “We hope the FDA will motivate the administration to take concrete steps to protect public health by limiting inappropriate antimicrobial use,” she added.

Food purchased from local farms, or seasonal local producers will be less prone to excessive medication than food produced by large factory farms or imported from distant countries.

Producers used more Tetracyclines (including Chlortetracycline and Oxytetracycline) than any other antibiotics–a total of 4.6 million kilograms of the medication yearly.

No Pelosi

No comments

Years ago when I sometimes used unsavory language, I often used the expression “Bull S***.”

No PelosiAs I grew up a bit and discovered it was not necessary to use such crude language, that expression became “BS.”

What did I really mean when I used those expressions? I meant that something was ridiculous, or idiotic or a half truth or just stupid. It covered any number of negative formats. The dictionary defines it as: nonsense; especially : foolish insolent talk…

I have decided that I no longer will use either of those expressions in the future. When I have a need to express such feelings, I will use the word “Pelosi.”

Let me use it in a sentence. “That’s just a bunch of Pelosi.” I encourage you to do the same. It is such a nasty sounding word, it really packs a punch, we are no longer being vulgar, and it clearly expresses our feelings. If enough of us use it, perhaps the word could be entered into the dictionary.

When on a ranch watch your step and don’t step in the Pelosi. It will get on the bottom of your boot and won’t go away until next election.

What a fitting and descriptive legacy for the Speaker of the House!

PASS IT ON TO AT LEAST 10,000,000 PEOPLE. DO NOT BREAK THIS CHAIN OR YOU WILL GET MORE PELOSI THAN YOU CAN SHAKE A BULL AT.

The Milkweed

Dairy’s best marketing info and insight
P.O. Box 10, Brooklyn, WI 53521 – (608) 455-2400 (c) 2002 – 2008 The Milkweed all rights reserved

by John Bunting

$9,995.00? $9,995.00??? NINE THOUSAND,    NINE HUNDRED, NINETY FIVE DOLLARS?????    On December 28, 2009, critics of USDA’s    goofy plans to mandate radio-frequency identification    devices (RFIDs) in all livestock got just the fodder    they need to set livestock country afire in protest:    the price tag for this absurd government mandate —    the National Animal Identification System (NAIS).    Forget USDA’s “cost-benefit” analysis claiming    that computer-chipped livestock ear tags would    cost about $3 to $5 dollars apiece. The cost of those    ear tags, even when purchased in minimum lots of    100, is peanuts, compared to the accompanying    hardware necessary to use those ear tags.

$9,995.00. That’s the “bundled startup kit” cost offered with a discount of $1,905.36, when compared to the costs of the components in the “startup kit,” if    those items were purchased separately.

$9,995.00 out-of-pocket costs so livestock producers    may comply with USDA’s intended mandate to require all livestock in the U.S. to be monitored with ear tags containing computer chips? In Missouri, for example, a hotbed of anti-NAIS, the average beef cattle operator has 35 head. In these money-losing times for beef ranchers, how can Uncle Sam demand livestock raisers shell out a minimum of $9,995 for a “startup kit” for this foolishness.

The December 28, 2009 press release said:
“Eriginate™ Corporation announced today the    approval of its eTattoo™ tag by the United States    Department of Agriculture (USDA). The approval    marks the first ultra-high radio frequency identification    tag (UHF RFID) and the first non-low frequency    tag (LF) to be approved for use with the ‘840’    Animal Identification Number (AIN).”

This private electronic devise is approved by    the USDA for use in the controversial National Animal Identification System (NAIS) program. USDA has promoted this program as a winning solution for everyone in animal agriculture.

Many persons in animal agriculture have objected for many reasons, including religious objections.

USDA has posted a cost/benefit analysis available at: http://animalid.aphis.usda.gov/nais/naislibrary/
documents/plans_reports/NAIS_overview_report.pdf

In the overview cost/benefit analysis, USDA explains the “Economic benefits in both the    domestic and international marketplace resulting    from enhanced traceability may be greater than the    cost savings realized during animal disease control    and eradication efforts.”

On page 5 of this same document, USDA    states, ” Tags and tagging costs vary among cattle    producers with 50 head from $3.30 to $5.22 per cow,    depending on current identification practices.” Well,    that cost/analysis is not exactly correct because the    eartags are the only low-cost element in the system.    In addition to the tags you need the reader or    scanner.

eTattoo™ conveniently has a “starter” kit.

$9,995!!! That “startup kit costs    $99.95 per animal!!!

This kit would be the basic requirement for a    small family dairy of say 50 milking cows. Replacement tags, and they certainly will be necessary, are a low $395 per hundred.

eTattoo™ claims, “Tags will accommodate    handwritten management numbers.” What exactly    is missing here? Anyone might think these fancy    tags would eliminate the need for “handwritten management    numbers.” What will government bureaucrats    and their anointed corporate beneficiaries conjure    up next?

Get yours while supplies last at:    http://www.etattootag.com

Company contact information:
Mailing address:
eriginate Corporation
PO Box 189
LeRoy, MN 55951-0189

Phone: (785) 694-3468
E-mail: Info@eriginate.com
Web site: www.etattootag.com

Harmful to small & medium farmers

Is USDA intentionally trying to destroy the nation’s small and medium livestock producers? USDA ultimately intends to mandate electronic livestock identification. Few small/medium livestock producers will be able to afford $10,000 for such technology. The margins in livestock have generally been negative. USDA has misrepresented costs for the NAIS program.

As NAIS becomes a less relevant, useless, bad USDA idea, BEEF Magazine, and other smaller circulation media, grope in the dark hunting some simple benefit, or some lack of pain to encourage NAIS implementation. A wheel barrow load of ideas have been falsely exploited wrongly promising virtues of, profitable source verification, export sales expansion, world trade compliance, useful carcass data for breeders, and even (ho ho ho) economy of application.  All of these fail to hold water, as this article reveals, the NAIS proposed data is “FOR PRIVATE USDA EYES ONLY.”  None of the above promises, virtues, claims or assumptions are of any value to US ranchers, nor ever were.  USDA has squeezed the NAIS purpose down to, “nothing more than information from a phone book,” according to USDA’s chief veterinary officer, John Clifford.
Snicker through this December 14, 2006 Iowa Farmer Today article, from their archives, resurrected from the dead, for the December 2009 issue, designed to entice livestock producers to fear not, and try to dance with NAIS one more song.  The thrust — bring in enough attorneys and it can be simplified enough to be palatable?    What!!!
Darol Dickinson, www.naisSTINKS.com

Financial Sense Editorials

NAIS privacy not black and white issue

By Gene Lucht and Jeff DeYoung, Iowa Farmer Today
Thursday, December 14, 2006 8:27 AM CST

Privacy has been a central issue in the debate over whether to make a National Animal Identification System mandatory or voluntary.

“It’s a legitimate concern,” says Doug O’Brien, a staff attorney at the Drake University Agricultural Law Center in Des Moines.

But, O’Brien, who also works at the National Agricultural Law Center at the University of Arkansas, says the issues are not black and white. Instead, they are shades of gray. Many could be addressed in the drafting of legislation that could be written to implement a national system.

“It’s fairly complicated,” O’Brien says of an ID program. “The ground is shifting on this.”

But, in the debate over a mandatory vs. a voluntary plan, privacy has been a driving factor.

John Clifford, USDA’s chief veterinary officer at the Animal and Plant Health Inspection Service (APHIS), agrees privacy has been a central issue.

“Confidentiality is definitely a concern to the private sector,” Clifford says. “We will have the premises identification database, which is nothing more than information from a phone book.

“Federal law will protect the confidential information from disclosure. We will have access to that data in the event of an occurrence.”

O’Brien says that could be addressed in a mandatory system.

There are really two confidentiality issues, he explains. The first is over whether information about animals and their owners could be gotten from the government through a Freedom of Information request. The federal Freedom of Information Act requests would appear to apply to any information gathered by the government about animals.

But, O’Brien says there are nine exemptions to the act that are stipulated in the law, and several could reasonably apply to this situation. For example, there is an exception for confidential business information. Another protects released information that would make it difficult to run a program. These items have been factors in the federal price-reporting law.

Those concerns could be addressed by writing specific statute language that would prohibit such release of information.

The second concern is the potential for government agencies to share the information gathered for a government program.

Again, that could be handled through specific language in a new ID law or it could be part of language to be included in contracts between farmers and the government, O’Brien says.

There are privacy concerns with private ownership of information in a voluntary program.

Farmers might want to make sure federal code or contracts with those private groups would ban the selling of sharing of that information with private groups that might try to use the information for their private gain.

From the Underground Food Movement



Sustainable farms, healthy foods, local foods

NAIS Is A Threat To Small Sustainable Farms and Ranches

NAIS is the National Animal Identification, a government system to track animals by injecting them with a computer chip that is read and reported on by the farmer whenever an animal changes places. It will require small farmers to spend a great deal of money on equipment and inserting the chips and reporting any changes, with terrible fines for computer errors, acts of nature, or non-compliance. Large feedlots are virtually exempted from the process, as they need only one chip number for hundreds of animals.

NAIS is a very important issue to me, as well as to small farmers, who produce our healthiest foods in a sustainable manner. It will not help with food safety, however.

The USDA will be in charge of NAIS, and the government is pushing it, because they are being heavily lobbied by the companies who will make millions off of the tags, reading equipment, and data management. It makes it look like they are doing something to promote food safety, yet NAIS is the antithesis of food safety.

The National Animal Identification System is truly frightening to me. Clearly, the modern American food system is not keeping us safe. Yet NAIS is more dangerous than the status quo. It is Orwellian, it threatens small farms, it runs against my beliefs, and is a threat to my basic needs.

It’s not that we do not need vast improvements in food safety to clear up our health crisis and food contamination dangers. We do! But corporate agribusiness pressure is preventing Congress and the USDA from enacting and enforcing true animal health and food safety measures. NAIS is not an animal health or food safety measure.

The USDA has been hearing overwhelming opposition to this measure, from both consumers and farmers. I will add my voice to the choir. I am a nutritional therapy practitioner, and I represent myself, my family, and my clients who rely upon high quality foods from small farms to regain and maintain their health. We all say that NAIS is not the animal health or food safety solution this country needs.

I am suffering from mercury poisoning caused by having a lot of silver fillings, which were removed with no consideration for the toxicity of mercury, and by consuming a lot of catfish that were contaminated with mercury and DDT. In order to survive and get well, I need to eat a lot of the highest quality milk, meat, eggs, and other animal foods. I am very careful about what I purchase, because I feel the quality of my food immediately in my day-to-day well-being. Most of the foods I buy are from small local farmers.

Because of my personal experience, I have changed the way I feed my family. My family members and my grandchildren all eat high quality animal foods from local farms, and I can really see the difference in their health and well being, especially compared to other families we know. My husband recovered from osteopoenia within a year of changing our diet to locally purchased meat and milk, and my son also became much healthier. Local animal foods have saved my life during my difficult struggles with chronic mercury toxicity.

I serve a number of clients who also have serious chronic health problems. Like me, they have found that proper nutrition is much more effective than drugs and medical procedures in improving their health and well-being. These people also rely upon animal foods from small local farms to keep them alive and healthy. If NAIS is implemented, I believe we will have NO MORE local small farms to purchase high quality products from. This is a huge quality of life issue for many people, and may even be a life-and-death issue for me, personally.

Corporate industrial farms may want to use NAIS to improve their overseas sales, and I have no objection to them tagging their own animals. Let them. However, because the tags are known to cause cancer, I wouldn’t want to eat the meat they produce, and I don’t think people from other countries will, either, once they know the tags cause cancer. And NAIS is clearly not the answer to animal health or food safety for food we want to consume in our own country.

I have a friend who did a lot of health care work at the VA hospital in Gainesville. She said that the identification tags the veterans had embedded in their necks, which are very similar to the NAIS tags, caused terrible cancers. Research shows that these tags used on pets are causing cancer, also. I do not want to eat food that has been injected with cancer causing tags. Do you?

The REAL sources of food safety problems are huge confined animal feeding operations (CAFOs) that concentrate thousands of animals in one location, as well as unsafe practices at the slaughterhouse and in food processing. NAIS traceability ends at the slaughterhouse, so what’s the point?

NAIS requires small farmers and ranchers to track each animal individually, while allowing CAFOs to track all animals under one blanket Group Identification Number. So it will be infinitely easier for the huge and dangerous CAFO’s to comply with NAIS, and impossible for the small farmers and ranchers. Thus, the USDA is promoting factory farms whose practices encourage disease, while putting small farms out of business and destroying the local food movement with their tag requirements and fees. Whose USDA is this, anyway?

What we actually need is small farms scattered all over, especially around urban areas, where the demand is the greatest and the distance the smallest, for energy efficiency and food security. The huge centralized CAFOs clearly are not good for people, for the environment, for animals, or for food safety. They are not even good for the economy, because, like WalMart, they replace the local small businesses (farms) with low-income low-quality slave labor types of jobs.

We need diversified farms, which are more sustainable, healthy, efficient, productive, and safe. If a local farm grows both animals and plants, their ecology supports one another (fertilizer for the plants, food and bugs for the animals). Small, sustainable farms are a pleasure to live near; CAFO’s are a blight.

We need to improve the viability of our own farming sector by making imports more costly, by increasing inspections of imported animals and agricultural products, and barring the entry of animals from countries with known disease problems.

We need to support our small farms, not try to put them out of business with laws and regulations such as NAIS. Read Joel Salatin’s book, “Everything I Want To Do Is Illegal” if you want to hear a funny but true story of the difficulties of producing really high quality food in this country.

We particularly need to improve enforcement of existing laws and inspections of large slaughterhouses and food processing facilities, including unannounced spot inspections. I heard an interesting story about the USDA slaughterhouse near Gainesville. Apparently they were stealing and switching meat, so that high quality grassfed meat that my friend was selling would be replaced at the slaughterhouse by conventional, low quality meat. My friend tried to talk with the slaughterhouse management, but the unethical practice continued. When my friend asked the USDA to intervene, they said that wasn’t their job!

It appears that the USDA sees its job as protecting the huge industrial farms from competition from small farms that produce exceptionally high quality food that is now in high demand.

Where NAIS has been tried already, it has been found to be a resounding failure for all of its stated goals. NAIS is government control and ineptitude magnified a million-fold. Furthermore, it is reminiscent of the practices of Nazi Germany. NAIS may make a few large corporations wealthy (like the tag and reader manufacturers and database managers), but for all the rest of us, it has no redeeming value, and an unacceptable cost.

Please stop this travesty now.

To sign a petition against HR 2749
http://www.ftcldf.org/petitions/pnum993.php

To sign a petition against NAIS
http://www.ftcldf.org/petitions_new.htm

To submit comments regarding NAIS to the USDA
http://animalid.aphis.usda.gov/nais/feedback

For more information on NAIS and HR 2749
http://www.nonais.org/
http://www.ftcldf.org/press/press-08july2009.htm
http://www.ftcldf.org/news/news-02june2009-5.htm

Gainesville Sun editorial on HR 2749
http://www.gainesville.com/article/20090714/NEWS/907149927/1008/WEATHER?Title=Maria-Minno-This-bill-is-a-threat-to-small-farms

For those of you expecting to see the long-promised interview with USDA Secretary Tom Vilsack, let me set the stage. In early June, I traveled to Jefferson City to attend an NAIS listening session. I was joined by several hundred distinctly angry people who wanted to personally give the Secretary a piece of their mind. I’m using the singular version of the word because they were of a common opinion. Many voices, one mind.

One of the first things I heard was the voice of the Secretary explaining his rationale behind calling these meetings. It was delivered by videotape and a longer variation of his initial comment announcing the sessions: “Today, I am asking farmers and stakeholders to engage with USDA in a more productive dialogue about NAIS. Now is the time to have frank and open conversations.”

At the table behind me was a big fella in well worn jeans and a very large cowboy hat. To make sure his political leanings were perfectly clear, his shirt was emblazoned with a large round “No NAIS” sticker. He stage-whispered to his friend, “The least the S.O.B. could do is show up and listen.”

Such is the way politics break on this issue, especially in Missouri. It’s a black-and-white, friend-or-enemy state. Vilsack and the USDA? They were the enemy.

I mulled over that farmer’s incendiary comment for a few minutes and decided it was a wise decision for Vilsack to stay away. These events were supposed to be “listening sessions” and an on-site appearance by the Ag Secretary would have only served as a lightning rod for people with a confirmed and unfriendly agenda.

After hearing what everyone had to say, I thought Vilsack ought to have an opportunity to be front-and-center with his constituency on the issue. Listening to his thoughts about these one-sided sessions might help cattlemen understand his position. I contacted Caleb Weaver, Vilsack’s press secretary, and asked if he might be willing to answer a few questions.

NO problem. He asked me to send the questions to him and he would get right back to me with the answers. “Good approach,” I thought. “NAIS is such a politically sensitive subject, I don’t want to mis-read or misunderstand an answer. Better that they be well-thought out and precisely worded.”

We missed the first deadline – the questions got lost along the way. I sent them again and thought the new date might be even better since the deadline would fall just after the final listening session in Omaha. With the responses from all 14 sessions in hand, Vilsack’s answers would be even timelier.

It might help level the journalistic playing field, too. After doing back-to-back “Five Minutes with” columns on the NAIS issue and with anti-NAIS activist, Rhonda Perry, a few words from Vilsack should give my coverage of the issue some needed balance.

I waited for his responses last Thursday – until 11:39 PM. Weaver then emailed a note saying he wasn’t going to be able to deliver in time for last Friday’s Five Minutes With column. “How about next Friday (today),” I asked? NO problem, again. Meanwhile, several people from the No NAIS camp were needling me with comments that the interview would never happen.

Then came the word by email at around noon yesterday. Vilsack would be unable to answer but Dr. John Clifford, the USDA’s chief vet, would respond and his answers were attached. Now I know Dr. Clifford to be a learned and honorable man, well respected by his peers, and normally I would be delighted to interview him.

But, on this issue, he’s not Tom Vilsack.

Still, the core of my questions were aimed at finding out what the USDA had learned during these listening sessions and how the Department might use that knowledge to refine their approach to NAIS. I think you’ll understand their position after reading this column.

Note: The questions were written for Tom Vilsack and I’ve left them as they were originally submitted. The answers should be attributed to Dr. John Clifford, however.

Question (Jolley) On April 15, you announced a seven city listening tour to “hear producers’ concerns for the proposed National Animal Identification System (NAIS) as well as to hear producers’ solutions for enhancing animal disease traceability.” A few weeks later you expanded the number of stops on the tour. Why did you add more cities and what have you learned?

Answer (Clifford) We expanded the number of stops on the listening session tour to ensure we heard from a wide variety of affected parties. We wanted to provide additional opportunities for the public, and limited-resource farmers in particular, to voice their concerns about the current NAIS system and offer potential solutions.

Truth (Dickinson) The poor broke farmers are the problem. The “limited-resource” poverty people are not informed well and just need to rant and blow steam. (All farmers are limited resource people—only the government is unlimited.) We added our cheery get-to-gathers to selected sites trying to find any area where there was a positive interest in NAIS. We kept trying and there isn’t such an area. We thought locations where we generously gave “no oversight cooperative agreement funds,” — the universities and “veterinarian stakeholders” would show up in force to support USDA and NAIS, but only a few of the “bought ones” would testify. The whole thing was very discouraging. We have surely mis-guessed the livestock producers. The listening sessions were a worthless PR wreck!

Q. (Jolley) I attended the Jefferson City meeting and the speakers were overwhelmingly against NAIS in any form. From what I’ve heard about the other stops, they had similar results. Do you think the tour has resulted in a fair representation of public opinion or were the anti-NAIS forces better at “getting out the vote” so to speak?

A. (Clifford) The listening sessions were bringing interested parties together to find a solution that works for everyone, not “getting out the vote.” At the 14 listening sessions we held across the country, and online through the Federal Register, we’ve received comments from people from across the spectrum on this issue. At the listening sessions, during the afternoon, we broke into smaller groups to look at some of the common areas of concern, such as cost, confidentiality and liability, and take a hard look at some potential solutions. We’ve heard some good ideas and are looking at what kinds of changes could be made to create a traceability system that producers and other segments of industry can support.

T. (Dickinson) Really, we just didn’t have enough money to get out the vote. The “limited-resource” people just badly out numbered our educated well paid staff on the tour. We heard some good ideas when we broke into groups—-mostly they said, “Shove NAIS where the sun don’t ………….!” That was not what we wanted to hear. Basically they don’t want any kind of traceability ideas that come from USDA. That was the summary.

Q. (Jolley) Sitting the listening tour results aside for now, I know you’ve received a lot of feedback through letters and visits from stakeholders. From both a pro and an anti-NAIS point-of-view, what are they telling you?

A. (Clifford) Many of the comments focused on important issues producers have often raised such as implementation costs, impact on small-scale farmers, privacy, confidentiality, and liability. Some producers have very real concerns about what the program will cost, and how their information will be protected. Others believe that we must have a strong traceability program in place to protect our industries from animal diseases and ensure that U.S. products continue to be marketable, domestically and abroad. All of the comments are available for the public to view on Regulations.gov, and we will also post transcripts from the listening sessions on the NAIS website once they are available.

T. (Dickinson) One thing we were surprised to learn. The land owners don’t like to be called “Stakeholders” Wow, did that make the “limited-resource” people mad! One guy in Omaha from the pig association thought traceability was important. We will build on that comment to extend that thinking. If you are a computer genius you can do a serious search and find selected transcripts from the sessions. We have hidden them in a huge USDA site.

Q. (Jolley) Many have said NAIS is important to maintaining international trade. Do you agree and what can be done if a program isn’t acceptable to a large number of people in animal agriculture?

A. (Clifford) Having an effective traceability program in this country is critical to maintaining both international and domestic trade. An animal disease outbreak can cause international trading partners to reject U.S. products, and we must be able to quickly identify the affected animals and areas in order to reestablish trade. The same goes for interstate trade. The faster we can identify the counties or states affected by a disease outbreak, the faster those farms and ranches that are outside of the outbreak area can resume moving their products and animals interstate.

T. (Dickinson) We have a lot of people in NCBA, Drover Magazine and Beef Magazine convinced that beef exports are life and death to livestock survival. Really, the truth is, the US has not produced enough beef to feed the nation in several dozen years. If there were no beef exports it would not affect US beef sales at all. This is a sales tool for NAIS and getting harder daily to make people believe it.

Q. (Jolley) The biggest knock against NAIS seems to boil down to a feeling by small farmers that it’s a needlessly costly program that only benefits the large packers. Would you address their concerns here?

A. (Clifford) A strong traceability program will benefit all of American agriculture. It is designed to help protect livestock and minimize production losses and disruption after a disease outbreak. It will help us maintain and expand international markets for U.S. animals and products. It raises confidence in domestic and international consumers. Most importantly, it helps ensure that large farms and small farms can more quickly get back to business as usual after a disease outbreak.

T. (Dickinson) Yes, this is true. It will probably put the “limited resource” farmers that have no business farming anyway out of business. But the big guys that have the resources to hire lobbiests and throw some serious money around will turn out just fine.

Q. (Jolley) Rosa DeLauro, a Democratic member of the United States House of Representatives, representing Connecticut’s 3rd congressional district, acting in her role as chairwoman of the House Agriculture, Rural Development, Food and Drug Administration and Related Agencies Appropriations Subcommittee, marked up the subcommittee’s fiscal year 2010 bill with proposed funding of $20.4 billion – $2 billion above fiscal year 2009 – but it contained a short section that deleted any further funding for NAIS.

According to a press release on her web site, “The bill eliminates funding for the National Animal Identification System (NAIS). After receiving $142 million in funding since fiscal year 2004, APHIS has yet to put into operation an effective system that would provide needed animal health and livestock market benefits. USDA is currently conducting a public listening tour around the country for several months to hear from stakeholders. Until USDA finishes its listening sessions and provides details as to how it will implement an effective ID system, continued investments into the current NAIS are unwarranted.”

Does that sound the death knell for NAIS or is there room to forge ahead and try to craft a compromise?

A. (Clifford) I believe there’s always room for compromise. We are beginning work immediately to gather what we’ve heard– during the listening sessions, through the Federal Register, and in our ongoing conversations with producers and other segments of industry–and craft some changes in the program to ensure it provides the traceability protection we need, but also addresses some of the concerns we’ve heard. I sincerely appreciate those who have provided feedback and ideas for how to move forward with animal traceability and we will keep everyone informed about the future direction of the program.

T. (Dickinson) This DeLauro thing is a joke. She is just moving the chairs around on the Titanic. In
government there is a word called “fungible.” It means we move the money around from one fund to the other wherever bureaucrats decide. We will compromise and do a one to one evaluation—-take one positive NAIS comment and one negative, then decide. We will do what we want to with traceability and address “some of the concerns we’ve heard.” We will move forward and you will know when it hits you what the cost will be. We are in control. You get to rant, and we hold the guillotine. Tough, Sec. Vilsack did not think this interview was important!

Q. (Jolley) And an optional question: Thousands of cattlemen in North America read Cattlenetwork. What would you like to say to them?

A. (Clifford) –No response–

T. (Dickinson) There is nothing he can say!

Bottom Line: After reading this, I would be very interested in your responses to Dr. Clifford’s answers. Please send them to me at CRJolley@msn.com and let me know if I can publish them in a future article or forward them to Tom Vilsack.

Follows is a public record comment from USDA’s request for comments that are being taken until August 8th. If you haven’t submitted your comments yet, I urge you to do so but not until you read this one. This succinctly details all the problems with NAIS, all of the industry pandering, the international entanglements, etc. Once you read this you will be able to put it all together in your mind and, with all hope, you will find you have a renewed fire in your belly to fight along side us. We must get consumers to stand with us as well. If you think the prices of food are high now, just wait until they implement NAIS.

Get a cuppa and read on.

Happy 4th of July. I pray it is not our last one of independence.

APHIS-2009-0027-0469.1[1]

Platt Land and Cattle is a large, family owned/operated cow-calf ranch with owned and leased ranches in Arizona and New Mexico. We oppose NAIS in total.

NAIS is simply an unworkable and highly intrusive bureaucratic boondoggle; it is a regulatory proposal for which a need has never been demonstrated and, more importantly, for which USDA has never provided specific citations of statutory and constitutional authority authorizing such action. NAIS should therefore be terminated in total.

More specific comments are as follows:

*1. _No need for NAIS has ever been demonstrated._*

USDA has failed to demonstrate a need for “48-hour trace back.” It has similarly failed to identify what diseases require the imposition on producers of such a costly, onerous, and intrusive program.

Producers, by their failure to register premises and their overwhelming opposition at the listening sessions, have sent a clear message: there is no need for NAIS. These producers have trillions of dollars at stake in livestock, land, equipment and water rights. Their very lives are bound up in that investment. Many have fine educations with degrees in veterinary science, law, and business.

We are left, however, with the preposterous proposition that government, academia, a few veterinarians, and tag/tech manufacturers with no corresponding stake in livestock, land, equipment and water rights know what is best for producers’ livestock herds.

The concept of “48-hour trace back” is from OIE’s Terrestrial Animal Health Code, Article 4.2.2, Performance Criteria, which suggests, as a measure of effect animal ID, that “all animals can be traced to the establishment of birth within 48 hours of an enquiry.”
http://www.oie.int/eng/normes/mcode/en_chapitre_1.4.2.htm

USDA’s use of the word “premises” also comes from the OIE code. The glossary defines “establishment” as used in connection with 48-hour traceback as “the premises in which animals are kept.”
http://www.oie.int/eng/normes/mcode/en_glossaire.htm#sous-chapitre-2

The purpose of the OIE Code is one of assuring “*the sanitary safety of international trade* in terrestrial animals and their products, (emphasis added) http://www.oie.int/eng/normes/en_mcode.htm?e1d10 and in his May 6, 2009, editorial, OIE’s Director General Bernard Vallat proudly proclaims, “One World, One Health.
http://www.oie.int/eng/edito/en_lastedito.htm

During the gathering of the American Association of Bovine Practitioners in Vancouver in September, 2007, former USDA Under Secretary for Marketing and Regulatory Programs, Bruce Knight, was queried as to why USDA was making such a push for premises registration. His response: “It is quite simple. We want to be in compliance with OIE regulations by 2010.” http://www.r-calfusa.com/news_releases/2009/090507-nais.htm

In short, USDA has been less than transparent and honest with American cattle producers. It has been pushing an animal ID system to benefit industrialized agriculture—those involved in international trade. There can be absolutely no doubt on this point.

On June 11, 2009, Rosa DeLauro, Chairwoman of the House Appropriations Subcommittee on Agriculture issued a press release on the committee’s fiscal year 2010 bill which included the following statement :

*The bill eliminates funding for the National Animal Identification
System (NAIS).* After receiving $142 million in funding since fiscal year 2004, APHIS has yet to put into operation an effective system that would provide needed animal health and *livestock market benefits.* USDA is currently conducting a public listening tour around the country for several months to hear from stakeholders. *Until USDA finishes its listening sessions and provides details as to how it will implement an effective ID system, continued investments into the
current NAIS are unwarranted. *(Emphasis added.)

At the NAIS listening sessions a welcoming video is shown featuring Secretary Vilsack. He asserts that “we will all agree that we need to *protect the livestock markets* and the livelihood of producers” and then continues:

I don’t want us to get to the point where Congress says they will not continue to fund the system. If that were to happen, I would doubt the *reliability of our market* and that’s not where we want to be. (Emphasis added.)

Apart from the fact that his nation is a net importer of beef, what markets are demanding NAIS? If indeed there is such a demand, cannot exporters work privately with producers on an export/ID program? USDA never answers such questions. The fact is that “markets” are not concerned about NAIS. They are concerned about exports which contain Canadian product.

The Korean meat export protocols list as ineligible,

1. Beef and beef products derived from cattle imported from Canada for immediate slaughter ….

2. Beef and beef products derived from cattle imported from Canada that were resident in the U.S. less than 100 days prior to slaughter….

http://www.fsis.usda.gov/Regulations_&_Policies/Republic_of_Korea_Requirements/index.asp

In a June 10, 2003, letter from Toshikazu Ijichi, Japan’s Animal Health Division Director, Dr. Peter Fernandez, Deputy Administrator, Veterinary Services for USDA-APHIS was advised that Japan had “deleted Canada from the list of countries which are eligible to export” beef to Japan “in light of confirmation of a single case of BSE in Canada.”

Dr. Fernandez was further advised that *In order to protect Japan from possible introduction of BSE, I* would like to *ask you again* *not to export beef* and its product which is derived *from* the [sic] cattle born, raised or slaughtered in the
*countries with indigenous BSE cases…to Japan through your country*. Therefore, *I would* like to *ask you again* *to indicate the country of origin *where the cattle from which the exported meat product to Japan was produced were born, raised and slaughtered…. (Emphasis added.)

http://www.r-calfusa.com/Animal_Health/080618Exhibit1-LetterToNewYorkTimes-JapanAnimalHealthLetter.pdf

The notion that export markets are clamoring for the imposition of NAIS is simply not supported by the factual record. Of ironic interest in light of the above letter is USDA’s delay in the implementation—and its frustration of the clear intent—of COOL.

One thing is very clear from the listening sessions: producers, the owners of the animals USDA would ostensibly protect, overwhelmingly reject NAIS and the claimed need therefore. There is a great irony of paternalism—government knows best—vis-à-vis the producer rejection of NAIS in the “listening sessions” and their failure to register their “premises.”

USDA never mentions OIE, its Terrestrial Animal Health Code, and the Codex Alimentarius except by implication when it asserts that NAIS is needed to protect “markets,” a euphemism for trade. It has simply been disingenuous at best, as it panders to industrialized agriculture and ignores its statutory obligation to rural agriculture.

Such pandering has come at great cost to rural producers. Examining USDA
data for the period from 1984 through 2006, farm/ranch share of income
distribution from trade declined by 28% while services’ share doubled
and trade/transportation’s share increased nearly 52%!

Using the period 1982 – 1984 as the base, and adjusting for inflation,
the price of slaughter steers/heifers has declined 57% since 1947 while
the retail beef price index has increased 3%! Today, the United States
is a net importer of beef, some 17% of domestic supply is of foreign
origin. USDA has failed those it was established to serve.

Qui bono? NAIS burdens producers with costs and intrusive regulations to
benefit industrial agriculture and global trade. There are no benefits
for producers in NAIS. Being in the business of accumulating and
wielding power, Government is a beneficiary; the tag and technology
companies will earn increased profits; meat packers will mine data and
industrial agriculture engaged in international trade will likewise
enjoy increased profits.

This is a simple issue of “follow the money.” USDA’s 2005 Strategic Plan
for NAIS states that

In 2002, the National Institute of Animal Agriculture

(NIAA) *initiated meetings that led to* the development of the U.S.

Animal Identification Plan (USAIP). That work provided the

foundation data standards for the National Animal Identification

System (NAIS). (Emphasis added.)
http://wlsb.state.wy.us/brands/Premises/brochure/NAIS_Draft_Strategic_Plan_42505.pdf

An examination of NIAA’s membership list discloses a lengthy list of
tag/tech companies including AgInfoLink, Allflex, Brock’s Cattle-Identi
Company, Cattle-Traq, Destron Fearing, EZ-ID/AVID ID systems, Farnam,
Fort Supply technologies, Meta Farms, Inc., Micro Beef Technologies, and
National Band and Tag, to name a few. The meat packing industry is
represented by Cargill and AMI.
http://animalagriculture.org/aboutNIAA/members/memberdirectory.asp

The head of NIAA’s Animal ID committee is from Allflex.
http://animalagriculture.org/aboutNIAA/committees/AIDIS/animalid.asp

NCBA also appears as a member; however, it entered into a cooperative
agreement with APHIS, taking money to promote premises registration.

http://www.cattlementocattlemen.org/watcPremisesRegistration.aspx

http://www-mirror.aphis.usda.gov/newsroom/speeches/content/2007/02/NatlCattlemen2-1-07.shtml

The producer bears all the costs and derives none of the benefits. That,
simply, is the reason for the overwhelming rejection of NAIS by
producers. The listening sessions, if USDA will listen, make that point
beyond cavil.

The existing combination of hot brands, brand inspection, health papers,
auction back tags, and border interdiction of disease has served this
nation well for 100 years. Brucellosis, TB and other livestock diseases
have been effectively controlled while FMD has been unknown in the
country since 1929.

On its website, USDA/APHIS acknowledges that existing “programs have
achieved significant success over the years in reducing animal disease”
but then asserts that “animal disease remains a reality in the U.S. as
illustrated in the following examples.” The two bovine diseases used to
illustrate USDA’s assertion are BSE and TB.
http://animalid.aphis.usda.gov/nais/why/animal_disease.shtml

This is overreaching at its best. BSE has an extended incubation period.
BSE is spread not animal to animal but rather by the use of contaminated
feed. The United States has not had a domestic case of BSE: the two
reported U.S. cases were both atypical which is characterized by an
absence of the spongiform changes in the brain caused by typical BSE.
(Fact Sheet: Atypical BSE, published by NCBA and the Beef Checkoff.)

USDA, through extended litigation with R-CALF USA, fought to open the
U.S. border to Canadian cattle including those over 30-months of age.
Canada does have a BSE problem. USDA further litigated with Creekstone
Farms to prevent that business from voluntarily testing its cattle for BSE.

Canada’s Food Inspection Agency has acknowledged that feed cohorts from
known BSE animals were exported to this country for slaughter. For
example, the CFIA announced that five cohorts of the November, 2008, BSE
Holstein dairy cow were “exported for slaughter.” According to CFIA,
“investigation showed” the feed cohorts “consumed the same potentially
contaminated feed.”
http://www.inspection.gc.ca/english/anima/heasan/disemala/bseesb/bccb2008/15investe.shtml

Given USDA’s i) laissez-faire attitude toward the importation of BSE
from Canada, ii) its asserted position that its risk assessments and the
removal of SRMs result in a de minimis risk to consumers, and iii) its
insistence that U.S. producers cannot voluntarily test for BSE, the
contention that BSE is a disease that must now be managed with NAIS is
simply disingenuous.

BSE cannot be managed or prevented by NAIS following its importation.
BSE should never be imported period. Dr. Stanley Prusiner, Nobel Prize
winner for his work in the discovery of prions, the cause of BSE states:

Regardless of whether the tonsils and distal ileum have been removed
from cattle – and in the case of cattle 30 months of age and older, the
brain, eyes, spinal cord, and trigeminal ganglia as well – these
measures are unlikely to be sufficient to ensure the safety of the meat
we consume. *The only reliable way to minimize the risk of humans
developing vCJD from BSE-infected cattle is to eliminate BSE-infected
cattle from the food chain. *(Emphasis added.)

http://www.r-calfusa.com/BSE/081117-Exhibit%207,%20Prusiner%20Declaration.pdf

NAIS will do nothing to eliminate BSE from the food chain. USDA
continues to allow the importation cattle from Canada which undeniably
has a BSE problem. Dr. Prusiner further states that “active testing in
the EU has shown that BSE-infected cattle may display no signs even
though they harbor substantial numbers of prions that can be identified
using a rapid test for BSE.” _Id_.

There is no rapid testing done in the United States and, as previously
mentioned, USDA employed litigation to prevent Creekstone farms from
voluntarily testing cattle. To assert that NAIS is now needed to manage
BSE is an absurdity at best: either USDA with its risk assessments
coupled with the removal of SRMs is correct and there is no BSE risk;
or, Dr. Prusiner is correct and BSE should never be introduced into the
food chain via imported cattle. In either case, NAIS is of no value.

With regard to TB , Audit Report, Animal and Plant Health Inspection
Service’s Control Over the Bovine Tuberculosis Program, U.S. Department
of Agriculture, Report No. 50601-0009-Ch, September, 2006. Section 2,
page 19, states:

*Between FYs 2001 and 2005, 75 percent (205 of 272) of the TB cases
detected through slaughter surveillance were determined by APHIS to have
originated from Mexico*. In response, *APHIS has worked with Mexico *to
improve their TB eradication program; *however, these efforts are
undermined by the disease’s 3 to 12 month incubation period. Cattle may
test negative for the disease prior to export, but develop TB and infect
U.S. cattle after import. *Although the majority of TB-infected cattle

found by slaughter surveillance in the United States are from Mexico,
*APHIS has not developed controls to restrict the movement of cattle, or
require additional testing to compensate for the disease’s incubation
period. Until additional controls are added, APHIS cannot reasonably
expect to achieve its goal and *

*eradicate TB when it is being imported into the United States each
year.* */ /*(Emphasis added.)

Page 19 of the Report further noted that Mexico annually “exports 1
million cattle to the United States”; that Mexico has “a higher
prevalence of the disease” such that Mexican cattle “are more likely to
be infected with TB”; that *Mexico has “no accredited-free states” and
in 2004 “reported over 2,000 TB-infected herds…compared to just 10
positive herds reported by the United States”; and that “99 percent of
the cattle imported from Mexico spend time on U.S. premises prior to
slaughter” with such time generally ranging from “5 to 14 months.”
*(Emphasis added.)

Page 20 of the Report states that “despite the higher prevalence of
TB-infected cattle in Mexico, APHIS has not established additional
import controls or requirements to test or restrict the movement of
Mexican cattle after importation to the United States” and that the
cattle so imported “simply become part of the U.S. herds.” The lack of
controls over Mexican cattle “has resulted in infected cattle being
detected in 12 states over the last 5 years.” A chart on page 20 of the
Report shows the states and numbers of TB cases traced to Mexico for FYs
2001-2005. That chart shows 2 in New Mexico and 5 in Arizona.

Page 22 of the Report set forth the conclusion that “*APHIS was under
utilizing…high risk herds” as a tool to “target testing to questionable
areas.” *(Emphasis added.)

In short, USDA’s contention that TB must be managed by NAIS while we
continue to import the disease from Mexico is, like its similar BSE
argument, most disingenuous.

Foot and mouth is another disease which Homeland Security and USDA have
used as a scare tactic. Given USDA’s efforts to regionalize Argentina
and the announced relocation of the Plum Island facility to Kansas,
America’s heartland, the assertion that producers must now embrace NAIS
to combat a potential FMD outbreak is untenable.

There may well be an outbreak of FMD. Unfortunately, it will likely be a
direct result of government action: a leak from the new Kansas facility,
similar to the recent breach at the Surrey facility in England; or, it
will come across our border which USDA refuses to secure and in fact
works to make more porous. NAIS will neither prevent nor mitigate the
damage that will occur under either scenario.

The Canadian Veterinarian Journal, Vol. 50, January, 2009, contained a
60-page report on the containment of England’s 2001 FMD outbreak.
England has long had an animal ID system; however, that system and
“traceback” was not the key to FMD containment in 2001.

The 2001 FMD outbreak was handled by throwing up perimeters and then,
with locals, working in from the perimeter. Similarly, states have
existing plans for handling emergencies which would include a FMD
outbreak. Such an outbreak would be handled as it was in England: a
perimeter would be established with no movement inside the perimeter as
the necessary epidemiology work would then be done from the perimeter
inward.

Animal ID was not utilized to contain the 2001 FMD outbreak nor would it
be of any meaningful benefit were this nation to suffer an outbreak.
Further, it would not identify vehicles and individuals who have been in
contact with contaminated herds; hence, the establishment of a perimeter
with work then directed inward.

Even with TB, a perimeter is established and work is then done inward.
USDA’s handling of the current TB situation in Nebraska well illustrates
this point. NAIS would not alter the course of the investigation.

USDA claims that NAIS is vital in the case of TB as some investigations
have taken up to 160 days. Again, the current Nebraska situation is
instructive. A perimeter is established and herds are investigated
within that perimeter.

What have been possible contacts with the infected herd and what has
happened in the last 12 – 24 months with neighboring herds and cohorts?
USDA postures that the livestock industry has no records, no idea of
where calves may have been sold or cull cows sent.

USDA adduces no evidence to support that assertion beyond its claim of
an investigation of up to 160 days in length. USDA never details what it
did in that 160 period and how much investigative time was on issues for
which NAIS would have been of no benefit.

Producers have records and so do states. Arizona is a brand state. It
has a record of every animal that has left our ranch, where it went, and
who the trucker was. We have similar records. USDA is simply
misrepresenting the state of the livestock industry.

Border interdiction of disease and running a closed herd—which we do in
our operation—are the two best defenses against the introduction of
disease. NAIS is of no benefit to us as producers.

*2. _USDA has neither statutory nor constitutional authority for the
imposition of NAIS; indeed, NAIS represents the implementation of the
OIE Terrestrial Animal Health Code and the Codex Alimentarius, the
adaptation of which is a treaty action never ratified by the Senate as
required by Article II, Section 2 of the U.S. Constitution._*

USDA has received repeated requests from multiple organizations for a
specific citation of authority for NAIS. It has never responded, beyond
a generic reference to the Animal Health Protection Act of 2002 coupled
with a broad assertion of authority to “carry out operations and
measures to protect the health of American Agriculture.”

That assertion is apparently from 7 USC 8308 and has been taken
completely out of context. That section authorizes USDA to “*carry out*
operations and measures to *detect, control, or eradicate* any pest or
disease of livestock (*including the drawing of blood and diagnostic
testing* of animals), including animals at a slaughterhouse, stockyard,
or other

point of concentration.” (Emphasis added.)

The statutory examples of “operations and measures” are of _overt action
by USDA _ such as drawing of blood and diagnostic testing, all directly
intended to “detect, control, or eradicate” pests or diseases. The
statutory construction doctrines of ejusdem generis and noscitur a
sociis require the general terms “operations and measures” to be
construed in light of the specific terms “drawing of blood and
diagnostic testing.”

The language most certainly does not confer broad authority to mandate
_overt action by producers_ in the form of an animal ID system designed
to track livestock movement; that does not directly and actively
“detect, control, or eradicate” pests or diseases; and which certainly
is not a measure such as “drawing of blood and diagnostic testing.”

Any fair reading of the Act does not permit the assertion of authority
by USDA for NAIS. Further, USDA’s assertion of broad authority cannot be
countenanced under any fair reading of the United States Constitution.
The powers of Congress are not implied, plenary, and inherent, but
rather express, limited and enumerated. USDA’s assertion that Congress
has delegated and granted it broad powers which are implied, plenary and
inherent flies in the face of the clear intent of Article 1, Section 8,
of the U.S. Constitution.

USDA is an administrative agency under the Executive branch of the
federal government and enjoys no powers beyond those expressly granted
it by Congress, acting in turn under the express, limited, and
enumerated powers granted under Article 1, Section 8.

As noted above, USDA is essentially seeking to implement OIE’s
Terrestrial Animal Health Code and the Codex Alimentarius by
administrative fiat. Both Codes are a complex web of international
agreements and actions by numerous countries.
http://www.oie.int/eng/OIE/en_histoire.htm?e1d1;
http://www.oie.int/eng/OIE/organisation/en_structure.htm?e1d1;
http://www.oie.int/eng/OIE/actes/en_accords.htm

The net effect of an implementation of NAIS by administrative fiat would
be the enforcement upon American producers of international standards
agreed to by various countries. Those standards are, in essence,
treaties much like the free trade agreements which required the consent
of the Senate. That body has never considered the agreements comprising
the two codes.

The very fact of disagreement between producers and USDA over the
necessity of NAIS underscores the need for transparent debate,
deliberation, and consideration by the Senate.

Even if the two codes are not construed as treaties, they are most
certainly a regulation of commerce with foreign nations, a power
reserved to Congress, not to USDA as an administrative agency under the
executive branch of government. USDA simply has no power, statutorily or
constitutionally, to mandate NAIS.

*3. _The regulatory and enforcement provisions of NAIS are unknown and
its underlying premise is suspect._*

Inherent in NAIS is the assumption of an errorless system; i.e., that i)
no cattle will ever lose ear tags, ii) that the tags will always
function and not succumb to the effects of weather and sun, iii) that
all dead and missing cattle can be accounted for, iv) that all movements
of cattle can and will be accurately scanned, v) that the data so
scanned will always be properly registered, vi) that the data so
uploaded will always be properly received vii) that the data so received
will be always be properly recorded and viii) that the data will always
be retrievable.

USDA has no concept of the conditions under which cattle producers
operate, how cattle are handled, what facilities will actually be
required to read and scan tags, of weather—heat, cold, wet, dry,
dust—under which NAIS would function. It has no concept of a lack of
internet access to upload information. The errorless system envisioned
by USDA is simply not a real world scenario.

There is no duplication or redundancy as is the case in our present
system. The concept of 48-hour trace back, while beguiling, is actually
inferior to the present system due to the duplication and redundancy in
the existing system.

England has experienced problems with its ID program with a cow herd
that is substantially smaller than the U.S. herd. According to a
November, 2003, House of Commons Report, the entire population of
cattle, sheep and pigs in England was a mere 25 million. In contrast,
there are nearly 100 million cattle in the United States.

The livestock industry in England is on a much smaller scale than in the
U.S.; yet, according to the October 12, 2008, issue of the /Telegraph/,

In a situation described as udder chaos, officials at the Department for
Environment, Food and Rural Affairs (Defra) admitted in Parliamentary
questions that 20,979 of the animals had been mislaid.

The livestock should have been logged on Defra’s Cattle Tracing System,
devised to protect public and animal health after the BSE and foot and
mouth epidemics.

However the cattle have disappeared from the system, while another 1039
are believed to have been loaded onto cattle trucks and never heard of
again, according to the Daily Star.

http://www.telegraph.co.uk/news/newstopics/howaboutthat/3182720/Defra-admits-losing-20000-cows-in-Britain.html

The same article noted that Britain’s Ministry of Defence had lost a
computer hard drive containing the private details of 100,000 members of
the Armed Forces and that the Home Office had lost a memory stick
containing data on 84,000 prisoners in England and Wales.

Such experiences are not unique to England. USDA itself has had similar
incidents.

In 2007, USDA inadvertently published the social security numbers of
63,000 people on the internet.
http://www.technewsworld.com/story/security/57029.html?wlc=1243391840

Also in 2007, USDA had computers stolen containing sensitive information
about farmers. http://seclists.org/isn/2007/Mar/0060.html

In 2006, USDA’s office of Inspector General, in its annual audit,
concluded that the “Agriculture Department continues to suffer from
inadequate management and monitoring of IT security controls, both at
the department-level and in its agencies.”
http://gcn.com/articles/2006/10/20/usda-security-improvements-still-not-effective-ig.aspx

Indeed, USDA has been given the lowest possible marks for 5 straight
years on federal computer report card grades by the House Government
Reform Committee. http://www.internetnews.com/security/article.php/3615831

John Carter, former chairman of the Australian Beef Association and
whose family holds the oldest registered brand in that country, reports
that 20% of the cattle in the NLIS data base are missing; that a
personal audit of his NLIS data base shows that less than 50% of the
animals he has sold are so reflected in the data base; than a “trace
back trial” of 300 head of cattle could track only 75% and that the
remaining 25% could be tracked only through Australia’s traditional
“paper trail.”* * Carter states that NLIS has “produced a shambles.”

The notion that NAIS is a technologically feasible means of tracing 100
million head of cattle is not supported by existing evidence. USDA’s own
record with computers, theft, hacking and other security breaches
coupled with animal ID experiences in England and Australia well
demonstrate that it is a system that should be rejected.

What will happen when cattle movements are not accurately scanned,
registered, transmitted, or received? There will be discrepancies and
irregularities in data. How heavy handed will USDA be in such instances?
Most producers have experience with federal agencies and in many cases,
it is not favorable.

In our own experience, dealing with TB in New Mexico, we have found the
agency and its rules to be heavy handed with demands which, by its own
admission, have no rational basis.

USDA has given no indication to producers of how NAIS will be enforced
and discrepancies/irregularities handled. If England is any indication,
producers can expect heavy-handed enforcement.

According to London’s /Telegraph/, Cheshire dairyman David Dobbins had
567 head of dairy cattle destroyed by DEFRA as a consequence of ID
paperwork “irregularities” notwithstanding that DEFRA “failed to explain
how many or what these were.” Prior to the destruction of the animals.
Mr. Dobbins records were seized by DEFRA, negating his ability to even
respond to DEFRA’s noncompliance assertions.
http://www.telegraph.co.uk/news/uknews/1545862/Christopher-Bookers-notebook.html

One fears that NAIS will bring similar events upon the heads of this
nation’s cattle producers

*4. _USDA has spent well in excess of $140 million promoting premises
registration and NAIS. This expenditure is most irresponsible at a time
when this nation is—in essence—bankrupt. This nation simply cannot
afford any more such frivolous expenditures._*

In the face of the hundreds of billions and indeed trillions of dollars
which the Federal Government has thrown about the last several months,
USDA’s NAIS expenditures are minuscule. Nevertheless, it is an
expenditure of money which the federal government simply does not have.

The May 30, 2009, issue of /USA Today/ reported numbers previously
discussed in various sources by David Walker, former U.S. Comptroller
General who resigned in disgust following Congressional inaction on his
annual report to Congress. The total unfunded liabilities of the Federal
Government now total a record $63.8 trillion, a sum equal to $546,668
for every U.S. household!

Estimates are that only around 1% of U.S. households have a net worth
sufficient to pay their proportionate share of the $63.8 trillion in
debt. In short, this nation is bankrupt.

Continued spending on NAIS, a program for which, as discussed above, no
need has ever been demonstrated is simply irresponsible given this
nation’s financial condition.

NAIS should immediately be terminated and not a single additional dollar
spent thereon.

* *

*5. _USDA has no credibility with producers and there is no on the
ground support for NAIS, without which it simply cannot succeed._*

At all of the listening sessions—through Albuquerque on June 16—two
salient facts emerged: there is widespread mistrust of USDA among
producers and there is virtually no producer support for NAIS. A chasm,
a gulf exists between USDA and producers.

NAIS was never intended to be voluntary. Several comments in the 2005
Strategic Plan underscore this:

– NAIS must be implemented/ /(USDA Secretary Mike Johanns)

– We have been working on an animal identification plan here at

USDA…over a number of years now, and our goal

has remained consistent—to be able to track animals within a 48-

hour period. We are prepared to roll up our sleeves and get this

implemented…. NAIS is a top USDA priority. (William “Bill”

Hawks Under Secretary for Marketing and Regulatory Programs)

– [W]e move forward to implement NAIS. (John R. Clifford, Deputy

Administrator Veterinary Services)

(Page 2, Strategic Plan)
http://wlsb.state.wy.us/brands/Premises/brochure/NAIS_Draft_Strategic_Plan_42505.pdf

The Plan claimed that “stakeholders provide broad support for national
animal identification” and in its timeline listed January, 2009, as the
target date by which “Reporting of defined animal movements [will be]
required; [and the] entire program [becomes] mandatory.”

USDA pulled out all stops. In Colorado, 4-H children were prohibited
from showing livestock at the state fair unless their parents had
registered their “premises.” Money was given to FFA in the hope of
cajoling parents.

The Plan was changed to become “voluntary” and NAIS morphed from an
animal health plan to a marketing tool; then it became a means of
assuring consumers that their beef is wholesome—a food safety issue;
finally, the trump card of bio-terrorism was played.

Four years later, and following some $140 million to register
“premises”—much of it bribe money handed out to “partners” in an effort
to enlist their support—only some 30% of “premises” have been registered.

In many states, however, when dairies, feeding, hog and poultry
operations, are excluded, less than 10% of cattle producers have
registered. Missouri is such an example.

Having played all its cards of crisis, USDA’s plan had nevertheless run
amuck. There was no “stakeholder” support. USDA, fond of the term
“stakeholder” had forgotten that the only real “stakeholders” were those
producers on the ground who actually owned the cattle that were to be
the subject of NAIS.

USDA apparently assumed that producers were red-necked bumpkins who
could be coached into compliance by smooth talking bureaucrats in Brooks
Brothers suits singing the soothing song of the voluntary nature of NAIS.

USDA’s next target for bamboozlement was Congress. At the March 11 NAIS
hearing earlier this year before the House Agricultural Subcommittee on
Livestock, Dairy and Poultry, USDA stacked the deck. The first “panel”
consisted of but a single individual: APHIS’ Dr. John Clifford who was
given over one hour to advocate for NAIS.

There was but a single independent cattle producer invited to give
testimony, R-CALF’s Dr. Max Thornsberry, who was afforded a mere five
minutes of time.

All other panel members were* *representatives of government (Dr.
Williams and Mr. St. Cry); were representatives of groups who were had
taken, directly or indirectly, bribe money from USDA to promote NAIS*
*under the euphemism of “co-operative agreements” (Mr. Nutt, Dr. Jordan,
and Mr. Butler); or were former USDA/APHIS employees (Dr. Ron DeHaven.)

Chairman Scott, during a brief discussion on foot and mouth, seized on a
reference to the highly contagious nature of bovine FMD and a mention of
potential airborne contamination to try and connect human health with
bovine FMD. Specifically, Chairman Scott suggested that NAIS was
necessary to protect humans from contracting bovine FMD. USDA’s Dr.
Clifford did nothing to correct Chairman Scott’s misapprehension.

There is a human form of FMD which is “a common viral illness of infants
and children” but it is “*not related*” to the bovine disease. (See the
website for the Center for Disease Control and its discussion of the
human form http://www.cdc.gov/ncidod/dvrd/revb/enterovirus/hfhf.htm

)Misconception manifested itself again when Representative Conaway asked
Dr. Clifford about the triggering event for a 48-hour traceback under
NAIS. Representative Conaway’s question was in the context of a boy in
Philadelphia who becomes ill after he has eaten a hamburger.

Traceback of live animals has nothing to do with traceback of E. coli,
which was underlying Representative Conaway’s question. There is
presently no traceback system from the consumption of meat to the
processing facility or meat packing plant which would be the source of
contamination. NAIS does nothing to change this: traceability would stop
at the processing plant door.

As he had done with Chairman Scott and the misconception on FMD and a
perceived risk to human health, Dr. Clifford did nothing to correct
Representative Conaway’s erroneous conception that NAIS had something to
do with tracing of E. coli in contaminated meat. In short, Dr. Clifford
allowed the erroneous conception that NAIS was a human health and food
safety issue to go unchallenged.

Having engaged in such misleading conduct, USDA initiated listening
sessions, handing out materials including a May 7 “Dear Participant”
letter under the signature of John Clifford. There are interesting
phrases in that letter:

n We need to work *collaboratively* to resolve concerns *and move
forward with animal tracebility*

n NAIS is a *cooperative effort*

n Much more work is needed to *fully implement NAIS*

n *Together* we can develop a system that we an all support.

Inherent in those phrases is a determination on the part of USDA to
proceed with NAIS, notwithstanding total producer opposition thereto.
Producers will be spun as rejecting the reasonable overtures of a wise
USDA. The platitude of wanting to listen and hear producer input is a
velvet glove masking an iron fist.

Several states have statutes prohibiting a mandatory NAIS. How will that
be handled? In a system of federalism, does USDA really have ultimate
authority over livestock? Does Article 1, Section 8, of the federal
Constitution in fact negative much of the Animal Health Protection Act
relied on by USDA? At the Albuquerque listening session, one Navajo
speaker suggested that the tribes may not accept a mandatory NAIS. How
will the issue of tribal sovereignty be resolved? Does USDA really wish
to force a constitutional confrontation on these points?

USDA may mandate NAIS but in the process will further alienate
producers. The existing gulf will become an unbridgeable chasm.
Enforcement will make criminals of law abiding citizens as producers are
jailed and their property subjected to confiscatory fines to coerce
compliance. Is this what USDA truly desires?

In our operation, we will simply not comply with NAIS, even if it is
made mandatory. We are weary of an intrusive government and the fights
associated therewith. Rather than continuing to submit to intrusive,
heavy-handed regulation, we would choose to exit the business. There is
no joy in serfdom on one’s own land and with one’s own animals.

We respectfully urge Secretary Vilsack to close down shop with NAIS and
to began a new dawn of rebuilding bridges with producers, working with
us rather than with industrialized agriculture, to fulfill USDA’s
express statutory mandate and be about the business of improving “the
quality of life for people living in the rural and nonmetropolitan
regions of the nation.” 7 USC 2204 (a).

That mandate is a true cooperative effort, one that can be achieved
without the expenditure of vast sums of money, without onerous
regulations but rather by simply working to rehabilitate commodity
markets, restoring them as true markets where prices reflect supply and
demand and not the oligopsonistic bargaining power and market
manipulation by industrialized agriculture coupled with speculation by
hedge funds and individuals who have never and will never own a cow.

As producers, our livelihood is more dependent on fixing broken domestic
markets than it is on expanding foreign markets and implementing an ID
system that provides a false sense of security for herd health.

Stop NAIS now and actually help producers do what they do best: produce.
Currently, USDA’s policies would castrate and bid the gelding be fruitful.

greedHR 2749, the “Food Safety Enhancement Act of 2009“ is the latest in a series of misguided ”food safety” legislation that  utilizes a failed “one-size-fits-all regulatory scheme”. The legislation is completely absent effective regulation for US food imports and corporate agribusiness behemoths such as Monsanto, ADM, Con Agra and Cargill (primary causes of food safety failures).  HR 2749 clearly favors the increased greed of the corporate industrial food complex while shifting the cost to small, local farmers, local food producers. It must be stopped at once.
There’s more.
According to Farm to Consumer.org, a non-profit organization protecting the constitutional rights of  small family farms and consumers, “this bill would be an “absolute disaster for small farms and artisan food production”.
Here is the skinny on the HR 2749:
HR 2749 gives FDA tremendous power while significantly diminishing existing judicial restraints on actions taken by the agency. Power to Quarantine a Geographic Area; the FDA can also Halt All Movement of All Food in a geographic area.
  • Random Warrantless Searches of Business Records
  • Establishing a Tracing System for Food
  • Severe Criminal and Civil Penalties.
  • Annual Registration Fee of $500
  • Regulation of How Crops Are Raised and Harvested

HR 2749 does not address underlying causes of food safety problems such as industrial agriculture practices and the consolidation of our food supply. The industrial food system and food imports are badly in need of effective regulation, but the HR 2749 does not specifically direct regulation or resources to these areas.

TRACEABILITY OF FOOD OR A BACKDOOR PATH TO THE NAIS

Section 107 of the proposed legislation outlines the use of ”a unique identifier for each facility owned and operated”. I find this section of HR 2749 rather curious if not sneaky, specifically given the overwhelming opposition to the USDA’s, National Animal Identification System (NAIS) and the privacy issues associated. Consider that, HR 2749 requires a person, farm or facility to register, pay annual registration fees and an ID is issued for compliance and traceability. Isn’t this NAIS?

Go here to learn more or sign the petition to end this legislation.

We have a lot to lose:

While corporate agribusiness stresses institutionalized organization, hierarchical decision making, volume, speed, standardization of the food supply and extracting as much production from the land as quickly and impersonally as possible, family farmers and peasants strive through order, labor, pride in the quality of their work, and a certain strength of character and sense of community to take from the land only what it is willing to give so as not to damage its dependability or diminish its sustainability.

But the so-called “conventional wisdom” in agriculture historically has been that through the continual substituting of capital for efficiency and technology for labor “inefficient” farm operators are eliminated by “market forces” while those who survive manage to thrive.

Such “wisdom” also perpetuates the myth that the world’s agricultural system is still dominated by independent family-operated farms and with the ever-increasing elimination of “inefficient producers” — “excess human resources” — we will witness a never-ending expansion of production to feed the world.

Nowhere has this “conventional wisdom” been more apparent and become the driving force of a nation’s agricultural and food policy than in the United States. Today, such policies derived from such “wisdom” are being exported globally by the U.S. by way of corporate agribusiness and its merchants of greed’s self-serving trade policies. Thus, it is imperative that farm and food policy makers, family farmers, peasants, workers and consumers world wide understand the implications and dire consequences of such “conventional wisdom,” for to ignore or dismiss corporate agribusiness’s inefficiencies as merely anti-capitalist rhetoric is to do so at their own future peril.

AMEN

The excerpt above is from The Merchants of Greed.

By Robert Pore
robert.pore@theindependent.com
Published: Sunday, June 28, 2009 12:16 AM CDT

People are not happy about NAIS

People are not happy about NAIS

Dwindling support for a National Animal Identification System (NAIS) has one Nebraska livestock organization calling on state livestock producers to reject the idea of making the program mandatory.

State producers will have an opportunity on Tuesday to speak their minds about the future of a National Animal Identification System as the U.S. Department of Agriculture has added Nebraska as one of its stops on a national listening tour gathering information on the pros and cons on NAIS.

According to Dave Wright, president of the Independent Cattlemen of Nebraska, his organization is urging ranchers and farmers from across the state to attending the Nebraska NAIS meeting.

Wright said that after five years of voluntary compliance, support for NAIS is very low.

“ICON wants the USDA to see no thread of hope in the cattle country of Nebraska,” he said.

Wright said if the current voluntary system becomes mandatory, the program would fail because the cost of the electronic equipment needed for the tracking system would be “detrimental to the small producer, especially in recent years when profit margins have been almost nonexistent.”

He said both ICON and R-CALF USA question the reliability of the equipment. ICON is an affiliate of R-CALF USA.

“It could be affected or corrupted by any number of processes — loss of electricity, inaccurate information, computer viruses and even capability of producers to operate the delicate equipment in remote areas,” Wright said. “Members also question who can access this information.”

Another flaw, he said, that should “greatly concern cattlemen” is the lack of state jurisdiction.

“All livestock would be treated as one big herd,” Wright said. “The movement of cattle from one location to another is also questionable when one considers a broken fence and herds mixing together.”

He said the program wold be easy for a confined feedlot but would be difficult to implement for cow-calf herds and ranchers.

“How it will deal with livestock lost because of predators, theft or hunters is another question ranchers have,” Wright said.

A great concern, he said, is just how far NAIS can go.

“There is no law to give boundaries to the program,” Wright said. “Livestock owners are very worried about their Fourth Amendment right, which guards against unlawful searches and seizures.”

What concerns Wright is whether U.S. cattle producers will eventually be dictated to by a “global organization” and whether the new program will be a tool for disease eradication or disease and management and control.

Current Nebraska livestock officials are concerned about an outbreak of bovine tuberculosis in Nebraska.

The state’s congressional delegation is asking the USDA, in behalf of the state of Nebraska, for additional assistance to address the TB problem.

What is at stake, the delegation said in a letter recently sent to Agriculture Secretary Tom Vilsack, is the impact of the TB outbreak on the economic viability of the state’s billion-dollar cattle industry.

According to Nebraska’s congressional delegtation, 15,000 head of cattle have been quarantined for testing with the TB exposure risk across Nebraska, Colorado and South Dakota.

“This is not just a Nebraska issue or a Midwest issue,” the delegation said in its letter to Vilsack. “Considering the significant amount of beef produced in the Midwest, this problem could affect the beef industry nationwide. The scope and seriousness of this problem demand a federal response.”

Under the proposed National Animal Identification System, its goal is to protect “the health of U.S. livestock and poultry and the economic well-being of those industries by being able to quickly and effectively trace an animal disease to its source.”

According to the USDA, when a disease outbreak occurs, animal health officials need to know:

— Which animals are involved in a disease outbreak

— Where the infected animals are currently located

— What other animals might have been exposed to the disease

Wright said R-CALF and ICON officials are offering “a practical solution for disease management and control.”

He said they want to see disease prevented by limiting foreign sources of beef to our country.

“If imported, the cattle must be tagged or branded with a distinguishable mark, meet health codes and feed standards already required in this country,” Wright said. “Require TB testing – especially on cattle from Mexico. Test imported feed and bone meal.”

He said cattlemen have been very pleased with the current program for disease control within the United States.

They are asking the USDA to follow the directive of the current program and “leave the power of control with each state and tribal livestock office, which have been very successful over the years, but also ask for federal support of these programs with financing.”

“All cattlemen would like to see an increased surveillance of BSE and a tracking system set up for tracking interstate movement of cattle which originate in countries which have a BSE problem,” Wright said. “A disease program should be created for wildlife, which can contaminate a domestic herd of cattle.”

Editors note: This is the most complete and detailed evaluation of the NAIS plan. If you want to read just one document to understand NAIS in every crease and corner of it’s flawed design, this is the read. Attorney, Judith McGeary puts her brilliant legal touch on NAIS impossible, to a common sense workable solution at the end.

Review of the National Animal Identification System


Statement of the Farm and Ranch Freedom Alliance
to the U.S. Department of Agriculture on May 20, 2009

The Farm and Ranch Freedom Alliance (FARFA) requests that USDA halt implementation of the National Animal Identification System (NAIS). Contrary to its stated purposes, NAIS will not address animal disease or food safety problems. Instead, NAIS imposes crippling costs and paperwork burdens on family farmers, which may lead to loss of these farms, increased consolidation of agriculture, and more reliance on foreign imports. This will ultimately lead to greater disease problems and reduced food security. This Statement will discuss some of the many problems with NAIS, and then suggest alternatives for improvements in animal health, food safety, and food security.

I. The design of NAIS is not scientifically sound

NAIS is based on the premise that we need 48-hour traceback of all animal movements for disease control. FARFA has submitted two Freedom of Information Act requests, the first in November 2006, asking for any scientific studies or analyses supporting the design of NAIS as a disease control program. USDA has failed to provide any scientific basis for the program.

The attempt to track every movement of every animal violates epidemiological and risk-based principles. The susceptibility of animals to disease and the likelihood of transmission differ greatly depending on the species of animal, the disease, and the conditions under which the animals are kept.1 Some diseases spread in a matter of hours, while others take years. NAIS fails to address the realities of disease or the varying risk levels.

From an animal disease control perspective, pasture-based livestock operations are not the problem. While confinement operations present the ideal conditions for the spread of disease, pastured operations, in which animals are kept in natural conditions on rotating pastures, have a far lower risk of developing or spreading diseases.2 For example, in the 2004 outbreak of avian flu in Texas, the disease was found in a 6,600-bird commercial poultry operation; but no infected birds were found in any of the 350 nearby non-commercial flocks that were tested.3

Despite the clear, scientifically documented differences between production systems, NAIS treats small-scale livestock owners as if they were large commercial producers. The backyard poultry owner with 10 chickens free-ranging is considered as much of a threat to animal health as a commercial operation with 10,000 chickens living in a crowded building. The farmer raising sheep or cattle on healthy pastures is treated the same as the feedlot with hundreds of animals crowded into small pens. Indeed, the small-scale producers face even heavier burdens than the large commercial operations because of economies of scale and the way the USDA has defined group or lot numbers. This program is precisely the opposite of what is needed to prevent and control disease.

Increasing tracking of animals cannot improve our ability to address animal disease because tracking is not the weak link in the chain of our animal health system. In 2005, the GAO analyzed the government’s provisions for preventing agroterrorism, assessing livestock diseases

Page 1

in particular. The GAO did not identify any deficiencies in current livestock tracking, or recommend that resources be allocated to programs such as NAIS. Rather, the GAO identified multiple deficiencies in other aspects of animal disease programs, including the lack of training for veterinarians in foreign animal diseases, USDA’s failure to use rapid diagnostic tools to test animals at the site of an outbreak, USDA’s complex decision making process for deploying vaccines, and the decline in agricultural inspections at ports of entry. 4 The federal government should allocate its resources to these deficiencies.

II. NAIS is cost-prohibitive for small farmers and individuals with a few animals

The costs of complying with NAIS will be unreasonably burdensome for small farmers. A 2006 Kansas State University report found that costs of an RFID-based system are significantly higher for people with smaller herds due to the expense of the electronic infrastructure.5 The costs of NAIS go far beyond the tag itself, and include:

a) premises registration database creation and updates;

b) tags and related equipment, such as readers, computers, and software;

c) 24-hour reporting requirements, imposing extensive paperwork burdens;

d) labor for every stage of the program;

e) stress on the animals;

f) qualitative costs, from loss of religious freedoms, privacy, and trust in government; and

g) enforcement.

NAIS-required tagging and reporting will disproportionately burden sustainable livestock operations and others that manage animals on pasture. Tag losses due to animals getting their tags caught on brush or fences will be higher than in confinement operations. Most small farmers will not qualify for a group identification number because their herds and flocks are comprised of animals from different sources.6 If 100 laying hens are pastured in a movable shelter, or 200 sheep are grazed together, and the farmer finds the partial remains of an animal from predator attack, the farmer faces the nearly impossible task of individually identifying all of the remaining chickens or sheep in order to identify and report the one that was lost, as would be required to be compliant with NAIS. 7

The USDA’s recently released cost-benefit analysis contains numerous gaps, false assumptions, and misleading tactics that severely underestimate the costs of NAIS to small farmers, individuals with a few animals, and taxpayers. The study also improperly compares the benefits that will accrue to a small handful of corporations to the costs that will be borne by millions of individuals.

The study manipulates the categorizations to disguise the costs to small farmers, homesteader, and other individuals with a few animals.

For example, in estimating the costs for beef cattle, the study uses six categories, based on the number of cattle on the farm, and estimates the costs for producers in each category.8 The first category includes operations that have anywhere from 1 to 49 head of cattle, and encompasses 585,050 operations, or 77% of the total number of operations. There is no valid statistical reason to create a single category with that many operations, while dividing the

Page 2

remaining 23% of operations among six different categories. Moreover, this approach is not consistent with the USDA Census, which separately counts operations with 1-9 head, operations with 10-19 head, and operations with 20-49 head. In other words, the research team had the data available to estimate costs for smaller categories and simply chose not to.

Similarly, the study used four categories for swine, and the first category included all operations with less than 500 head. Based on the USDA 2007 Census, this single category includes 54,885 operations, or 73% of the total number of operations. The Census separately counted operations with 1-24 head, operations with 25-49 head, operations with 50-99 head, operations with 100-199 head, and operations with 200-499 head. So, again, the research team had the data available to estimate costs for smaller categories and chose not to.

The study used four categories for sheep, and the first category included all operations with less than 100 head, encompassing 64,202 operations, or more than 90% of the total number of operations. In contrast, the Census divided operations into those 1-24 head and 25-99 head.

Given the USDA’s own finding that costs increase as herd size decreases,9 the study’s choice of categories obscures the real costs to small operations.

2. The study incorrectly discounts costs for technological infrastructure. The study acknowledges that NAIS will require extensive technological infrastructure by individuals, including computers, software, and internet access. The study also acknowledges that many small farms do not own computers or have internet access.10 Yet the study then assumes that the hundreds of thousands of people who will be forced to buy additional technology would have “other uses” for those computers, software, and internet access, and therefore only counts 50% of those costs! While many farms and individuals may have use for such technology, that is obviously not true for everyone, and the entire computerization costs should be allocated to NAIS. Moreover, the study assumed that only 10% of equine premises would need a reader and did not account for the costs of computers, software, or internet for the other 90% of the estimated number of equine premises.11

3. The study makes assumptions about the use of group identification for sheep and poultry that contradict both the USDA documents and the working group reports. The study states that poultry operations “would utilize exclusively lot identification systems,”12 and assumed that lambs moving direct to slaughter would be identified as group/lots.”13 As a result, the study did not even attempt to quantify the costs for individual identification of poultry or feeder sheep.

This assumption does not reflect reality. Hundreds of thousands of poultry and sheep owners would not be able to use group identification for their animals. The USDA documents state that group or lot identification is available where groups of animals are managed together from birth to death and not commingled with other animals.14 In practice, this only occurs in the vertically integrated confinement operations, not on small

Page 3

farms. Indeed, the Poultry Working Group has stated that group/lot identification is “mainly for commercial poultry” and has provided a list of potential methods for individual identification for poultry that do not qualify for group ID.15 The Sheep Working Group recommends group or lot identification only for feeder sheep in groups of “10 or more animals,”16 not for all feeder sheep.

According to the USDA Census, there were 135,843 farms with less than 100 laying hens in 2007. These are not vertically integrated confinement operations and would not qualify for group identification. They represent 93% of the farms with laying hens accounted for in the 2007 census. Further, according to the census, there are 54,889 farms with fewer than 25 head of sheep, and another 21,070 operations with between 25 and 99 head, constituting 91% of the farms with sheep. Many of these farms would not have 10 head going to slaughter at the same time, and thus would not qualify for group identification. Yet the USDA cost benefit analysis completely ignored these small farms with a few head of poultry or sheep.

4. The study makes unsupported assumptions about many of the costs that will be imposed, and even contradicts itself.

a. The study recognizes that the cost of RFID readers will not be economical for small producers, so it advances the premise that a new business will spring up, to do custom reading.17 They then assume that there will be custom tag reader businesses within 25 miles of each small farm, even though ranches in the West and Southwest may encompass more than 25 miles of territory each. They also assume that the cost of RFID reading will be comparable to the cost of brand inspections, even though brand inspections do not require expensive equipment, unlike RFID tagging and reading. Based on those fundamentally flawed assumptions, they claim that someone with five head of cattle would pay only $9.35 ($1.87/head) to have someone drive out to their farm and electronically read the tags.

b. The study also makes unfounded assumptions about the charges for database entries. The study acknowledges that they were not able to get any information on such charges from private companies — the very entities who will be setting the prices that individuals will have to pay under NAIS. The study estimated that database charges would be only 8.5 cents, based solely on data from the Michigan Department of Agriculture, which has received hundreds of thousands of dollars from USDA to require electronic tagging by Michigan farmers.18 As just one comparison, the Canadian Livestock Records Corporation recently published that its fee is $5.05 for each electronic registration;19 that is the fee to the associations, which is turn may charge even higher fees to individuals.

c. In the section on costs to horse owners, the study used an informal survey of just ten vets to determine the costs associated with microchipping horses.20 That very limited survey resulted in an average travel cost was $41.96 plus fuel charges.21 Ythe study then estimates the cost of vet travel at $29.36, with no fuel charge.22 Not only is the study internally inconsistent, but the survey was wholly inadequate. It is

Page 4

not uncommon for veterinarians to charge $100 or more per farm call, depending on the nature of their practice and the geographic location

5. The study does not address the massive underestimates of the number of “premises” affected by NAIS, and as a result significantly underestimates the total costs of the program. All of the cost estimates are based on data from the USDA Census. Yet the USDA Census, by definition, covers only those operations that have $1,000 or more of agricultural product for sale in the census year. Not only do many people fail to respond to the Census, but hundreds of thousands of hobby animal owners, homesteaders, and micro-farmers are not covered. Yet these people would be covered by NAIS. The USDA’s own premises registration statistics reveal the severe undercounting of affected people. While the Census lists only 3,555 “premises” in Massachusetts, the USDA has registered 8,066 premises in that state — 227% of the estimate!23 And since the cost-benefit analysis relies on the Census estimates, the estimates of the total costs of NAIS — to both individuals and the government — are fundamentally flawed.

6. The study improperly justifies the costs that will be imposed on millions of people by looking to the benefits to a handful of companies. The study weighs the costs of NAIS against the alleged benefits to the export market. Indeed, in identifying the “three key points” from the study, USDA lists the value to the export market and the global marketplace as the key benefits.24 Not only are the alleged benefits based on speculation rather than fact, but this approach is entirely improper. The majority of the costs of NAIS will be borne by individual animal owners, ranging from pet owners to large ranchers. But the export market benefits will accrue almost entirely to a handful of large companies who participate in the export market. In essence, individual rural Americans’ Main Street will be taxed for the benefit of Big Ag’s version of Wall Street.

III. NAIS does not increase food safety

In considering food safety and traceability, it is critical to distinguish between tracking live animals and tracking meat from the slaughterhouse to the consumer. Most food-borne illnesses are from bacteria such as salmonella, e. coli, and campylobacter, or a specific group of viruses called the Norwalk viruses.25 These organisms contaminate food due to poor practices at slaughterhouses or in food handling. NAIS will not prevent these problems. And since NAIS tracking ends at slaughter, it will not improve the tracing of contaminated meats in the food chain.

Neither will tagging cattle prevent BSE from occurring or from entering the food supply. In last year’s Hallmark/Westland beef recall, the packing plant’s violation of existing regulations and USDA’s failure to properly inspect the plant, allowed “downer” cows to be slaughtered. In the video from the Humane Society, every time there was a clear shot of a cow’s left ear, one can see a tag.26 Changing the type of tag to a NAIS electronic tag would do nothing to avoid similar problems in the future.

An immediate feed ban, that closes loopholes allowing things such as poultry litter in cattle feed, is the best way to prevent BSE from occurring in the first place. To address the human health risk, we should test cattle entering the food supply, as is done in Japan and Europe.

Page 5

IV. NAIS will decrease homeland security

A. Increased consolidation threatens food security.

Under the USDA’s plans for NAIS, the default requirement is individual identification of each animal. Group identification would be allowed for “animals that typically move through the production chain as a group of animals of the same species … This practice is most common in the poultry and pork industries.”27 In practice, this means that companies who maintain ownership of the animals throughout their lives — as is done in vertically integrated confinement operations — will be relieved of most of the costs and paperwork burdens of NAIS. NAIS therefore creates significant incentives to further consolidate agricultural production.

Increased consolidation of our food supply creates greater risk. The 2005 GAO report on agriculture and terrorism noted that the concentration of our food supply makes it vulnerable to attack: “the highly concentrated breeding and rearing practices of our livestock industry make it a vulnerable target for terrorists because diseases could spread rapidly and be very difficult to contain.”28

Moreover, by discriminating against small-scale food production for local consumption and promoting large-scale industrial food production that is intended to be shipped hundreds or thousands of miles, NAIS further increases our dependence on foreign oil.

B. The use of electronic technology and databases create vulnerabilities.

RFID technology is subject to problems that do not exist with traditional identification methods such as branding or tattoos. Depending on the security of the technology used, the microchips can be cloned or infected with computer viruses (which can then be passed to other chips through the scanner).29 In fact, the specific type of RFID to be used in NAIS, the ISO 11784/11785 chip, is designed to be programmed in the field before is applied to animals or even reprogrammed after application. This problem with the ISO standard is well known in the technology community and has been debated for years.30 It is impossible to reliably trace an animal if someone can change its identity at any time. Also, the databases will be vulnerable to accidental release of the information as well as hackers.

C. NAIS is not effective in addressing avian or swine flu.

Avian influenza, in particular the highly pathogenic H5N1 virus, is frequently raised as a homeland security issue that weighs in favor of implementing NAIS. The threat, however, comes from large commercial operations, because the density of the birds and the conditions they are kept under provide ideal conditions for the rapid spread and mutation of viruses.

An NGO report indicates that the spread of avian flu, including H5N1, is due to conditions in confinement poultry operations.31 A later report states: “Studies indicate that highly pathogenic strains of bird flu evolve when low pathogenic strains of the virus, which circulate harmlessly among wild bird populations, are introduced into high-density poultry flocks. Once bird flu

Page 6

takes hold in a factory farm, the virus amplifies and spreads beyond the farm through a multitude of channels: trade in birds and eggs, people coming in and out, the elimination of waste, the use of litter in feed, etc.”32 For a domestic example, in the 2002 outbreak of avian influenza in Virginia, “farm equipment, vehicles and personnel” moved among commercial facilities caused transmission of the virus.33 Even a USDA report found that, out of 45 outbreaks of H5N1 in the country of Laos, 42 of the outbreaks occurred in commercial operations.34

The recent mutation of the H1N1 swine flu virus to a form that is transmissible human-to-human has dominated the headlines. Genetic analysis indicates that the current virus has two ancestors, one of which is a swine virus found in factory farms in North Carolina in the US in 1998.35 Scientists postulate that a human flu virus may have starting circulating in U.S. pig farms as early as 1995, but “by mutation or simply by obtaining a critical density, caused disease in pigs and began to spread rapidly through swine herds in North America.”36 The mutated virus emerged in North Carolina, the home of the nation’s largest pig production operation, with some of the densest pig populations in the continent.37 A veterinary pathologist from the University of Minnesota stated the obvious in Science: “With a group of 5,000 animals, if a novel virus shows up it will have more opportunity to replicate and potentially spread than in a group of 100 pigs on a small farm.”38

A study published in 2008 in the journal Zoonoses and Public Health investigated the relationship between farm size and risk of Eurasian lineage swine flu infection. The researchers concluded that pigs from farms with more than 5,000 “standing pig population” were anywhere from two to nine times as likely to have swine influenza than pigs originating from small farms.39 A recent study of pig farms in North America similarly concluded that “increasing the number of finishers [fattening pigs] by 1000 increased by 4.4 the adjusted odds of a finisher herd being positive” for classic H1N1 swine flu.40

As with all of the disease issues, a one-size-fits-all approach of tracking every chicken or pig in the country will not address avian and swine flu. The agency should focus its efforts on the high-risk commercial factory farms and practices that can spread disease, such as feeding poultry litter.

D. NAIS will result in a black market in livestock, leading to greater problems.

The premise that 100% participation is necessary to address disease issues founders on the reality that there will never be full participation. If NAIS is adopted, it is inevitable that some livestock owners — whether for religious or economic reasons, or unwillingness to allow the government intrusion — will not comply. Since they will be acting illegally, they will be far less likely to seek a veterinarian’s help should a disease problem arise. This black market will create disease problems, as evidenced by the outbreak of Exotic Newcastle Disease that occurred in Los Angeles in 2002. The outbreak was started and spread by cockfighting flocks that had been smuggled from Mexico because cockfighting is illegal in California.41 NAIS will increase the probability of disease outbreaks by undermining the first line of defense: the actions of private individuals and their veterinarians in quickly diagnosing and containing diseases.

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V. NAIS cannot succeed because of the many practical barriers to implementation.

NAIS is fundamentally impractical to implement. USDA’s plans call for multiple public and private databases, capturing all of the reportable “events” for every animal, with the USDA creating a metadata portal to use for its purposes.42 Establishing these databases will be a monumental task. There are almost a hundred million cattle in the U.S., and millions more horses, chickens, sheep, goats, pigs, deer, elk, bison, and other livestock animals. These animals are taken to shows, sold in auction houses, sold in private transactions between individuals, slaughtered, and otherwise moved for myriad reasons. The NAIS reporting and tracking system has myriad potential failure points. Moreover, integrating databases is far from simple. Indeed, despite the emphasis on interagency cooperation since 9/11, the GAO’s 2005 report on agriculture and terrorism noted that the federal government still had not integrated its own databases.43

The plans for NAIS assume that all people covered by the NAIS will have computers and web access to report within 24 hours after a reportable event. Based on 2007 Census, however, almost half of farmers do not have internet access. Aside from the costs, some individuals have religious objections to the technology or simply lack the knowledge to use it. Thus, state agriculture departments will have to accept written reports mailed to their agencies or telephone reports that will be transcribed. This creates two more failure points: human error in data input and the untimely recordation of events.

The massive databases themselves pose a barrier to successful traceback. Colorado researchers developed a mock data set and algorithms for using a NAIS-type database for tracing animal movements and the cohorts of diseased animals.44 Although the research indicated that traceback of a diseased animal was quite rapid, the tracing of the cohorts (the animals that had come into contact with the diseased animal and then with other animals) took vastly longer, especially if the data was kept in more than one database. Their simulation of 100 million animals with the data held in multiple databases indicated that it could take more than 39 years to trace the cohorts.

VI. NAIS poses ethical concerns and conflicts of interest.

The USDA’s working groups for the design of NAIS were initially drawn from the working groups established by the National Institute for Animal Agriculture (NIAA). The NIAA is an industry trade organization, and the members of the working groups included many companies who stood to profit directly from the implementation of NAIS, such as tag manufacturers and database management companies. These conflicts of interest permeate the plan and have never been addressed.

Additionally, the use of private databases creates more conflicts of interest and leaves farmers and ranchers vulnerable to the misuse of their confidential information. The recent court decision finding that the NAIS premises registration information is exempt from FOIA does not address the potential for misuse of that information by private database managers or by those who obtain the information through illegal means such as hacking the databases.

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While NAIS has been promoted by entities that stand to profit from the program, it has been opposed by the majority of small farmers and animal owners who would be subject to its burdens. Together with these comments, FARFA is submitting approximately 2,000 pages of petition signatures of individuals who are opposed to NAIS. These petitions were gathered by individuals all over the country, by placing petitions at feed store counters, in vet clinics, and at county fairs. No one was paid to collect signatures, and these petitions represent a true grassroots response to NAIS.

VII. The invasion of privacy caused by NAIS is not curable.

USDA has asked how it can address privacy and confidentiality concerns with NAIS, but there is no solution to this issue. Requiring individuals to provide information about their land, animals, and daily activities to the government creates an unprecedented level of government intrusion into people’s lives. Moreover, once that data is submitted to a database, it is vulnerable. Federal agencies have a track record of both accidental releases of information and vulnerability to hackers.

Requiring individuals to submit information to private companies is not a solution to the problem. Regardless of the laws or regulations, individuals would be vulnerable to the sale and misuse of their information. How could an individual even prove that such misuse had happened, much less be properly compensated? Once collected, people’s information will be vulnerable. The only solution is to not collect the information in the first place, or to only collect it on a voluntary basis so that individuals can choose whether or not they wish to take these risks.

Alternatives to NAIS

The Farm and Ranch Freedom Alliance strongly urges USDA to stop implementation of the NAIS and focus efforts on these alternatives:

Encourage decentralization of the livestock industry to reduce its vulnerability to disease outbreaks.

45 Improve training for veterinarians in recognizing foreign and emerging animal diseases.

46 Increase inspections of animals and agricultural products entering the U.S. or crossing state borders and refuse admittance of animals from countries with known disease problems such as BSE or Foot and Mouth disease.

Address problems in the existing disease control programs, including ineffective oversight, improper classifications, and bureaucratic barriers to rapid disease response.

Identify high-risk situations and quantify critical factors for livestock diseases of concern, such as the level of contagion, the means of transmission, and the severity of the diseases of concern. Based on the analysis of these factors and of existing programs, develop improvements to existing programs. Limit any such programs to non-electronic means of identification when the animal enters the stream of commerce.

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Improve enforcement and inspections of large slaughterhouses and food processing facilities, including unannounced spot inspections.

Address traceability of meat from the slaughterhouse to the consumer.

Increase testing for BSE, or Mad Cow Disease.

We thank you for your consideration.

Sincerely

Judith McGeary
Executive Director
Farm and Ranch Freedom Alliance
8308 Sassman Road
Austin, TX 78747
Phone: 512-243-9404
Cell: 512-484-8821

Notes

1 The health problems caused by confinement or industrial management systems have been well documented in the scientific literature. See, e.g., Cravener, T.L., W.B. Roush, and M.M Mashaly, Broiler Production Under Varying Population Densities, POULT. SCI. 71(3):427-33 (1992); D. Herenda and O. Jakel, Poultry Abbatoir Survey of Carcass Condemnation for Standard, Vegetarian, and Free Range Chickens, CAN. VET. J. 35(5):293-6 (1994); T.G. Nagaraja and M.M. Chengappa, Liver Abscesses in Feedlot Cattle: A Review, J. ANIM. SCI. 76(1):287-98 (1998); T.G. Nagaraja, M.L. Galyean, and N.A. Cole, Nutrition and Disease, VET. CLIN. N. AM. FOOD ANIM. PRAC. 14(2):257-77 (1998); D.H. Tokarnia, J. Dobereiner, P.V. Peixoto, and S.S. Moraes, Outbreak of Copper Poisoning in Cattle Fed Poultry Litter, VET. HUM. TOXICOL. 42(2):92-5 (2000)

2 See Exotic Newcastle Disease, Information from the Texas Animal Health Commission (Apr. 2004) (“In close confinement, such as commercial operations, the disease can spread like wildfire. … However, the virus is destroyed rapidly by dehydration and by the ultraviolet rays in sunlight.”) (emphasis added).

3 News Release, Texas Animal Health Commission (Apr. 1, 2004).

4 United States Government Accountability Office, GAO-05-214, Homeland Security: Much is being done to protect agriculture from a terrorist attack, but important challenges remain (Mar. 2005) (hereinafter “GAO Report on Agriculture”) at p.6-7.

5 RFID Cost.xls — A spreadsheet to estimate the economic costs of a radio frequency identification (RFID) system, K.C. Dhuyvetter and D. Blasi, Version 7.6.06.

6 See User Guide (Dec. 2007) at p.24 (Group/Lot identification may be sued for animals that “move through the production chain as a group”).

7 See Program Standards and Technical Reference (Feb. 2008) at p.7 (listing an animal event code for reporting “animal missing”).

8 Benefit-Cost Analysis of the National Animal Identification System, NAIS Benefit-Cost Research Team (Jan. 14, 2009) (hereinafter “Cost-Benefit Analysis”) at Table 4.2 & 4.3, page 30.

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9 Cost-Benefit Analysis, pages 28-29.

10 Cost-Benefit Analysis, pages 24-27.

11 Cost-Benefit Analysis, p. 257 (estimating number of premises) and p.330 (discussing reader costs).

12 Cost-Benefit Analysis, pages vi, 8, & 123-124.

13 Cost-Benefit Analysis, page 102

14User Guide at 30. See also Draft Program Standards, United States Department of Agriculture, Animal and Plant Health Inspection Service (published Apr. 25, 2005) (hereinafter “Draft Program Standards”) at 5-6.

15 Bird Industry Identification Working Group, Update and Recommendations (Aug. 2006) (presentation at the NIAA Animal ID-Info EXPO).

16 Sheep Working Group Report, Executive Summary (Sept. 6, 2006) at page 3.

17 Cost-Benefit Analysis, page 23.

18 Cost-Benefit Analysis, page 26 (discussing the lack of data on database charges) and page 173 (listing Michigan as receiving $689,825 in cooperative agreement funds).

19 See http://www.clrc.ca/index.shtml (“(December 8, 2008) The CLRC Board of Directors met in Ottawa on October 20, 2008 to approve the budget for 2009. On behalf of Chairman Bob Airth and the entire Board, we are pleased to advise you that the unit cost will remain unchanged at $5.05 for 2009. In these turbulent times, the Directors felt that it was very important to maintain the costs at current levels and thus provide a measure of stability for the associations in this area.”)

20 Cost-Benefit Analysis at p. 280.

21 Cost-Benefit Analysis at page 280.

22 Cost-Benefit Analysis at page 326.

23 Cost-Benefit Analysis at pages 169 & 171.

24 USDA-APHIS FactSheet, National Animal Identification System Benefit-Cost Analysis: Three Key Points (Apr. 2009) (“Three Key Points from the Benefit-Cost Analysis:1. A traceability system like NAIS is essential to timely recovery of export markets after a disease outbreak. 2. Traceability is becoming increasingly important, even necessary, for successful participation in the global marketplace. 3. For the major livestock industries, the costs of NAIS vary depending on the industry’s production practices, which in turn determine the type of traceability methods used.”).

25 See Centers for Disease Control and Prevention, http://www.cdc.gov/ncidod/dbmd/diseaseinfo/ foodborneinfections_g.htm#mostcommon.

26 http://www.youtube.com/watch?v=kaM7Hpu47FY

27 User Guide at p.24.

28 GAO Report on Agriculture at p.1.

29 See Annalee Newitz, The RFID hacking underground, WIRED, www.wired.com/wired/archive/14.05/rfid_pr.html; John Markoff, Study says chips in ID Tags are vulnerable to viruses, NEW YORK TIMES (Mar. 15, 2006); Rieback, M.R., B. Crispo and A. Tanenbaum, Is your cat infected with a computer virus?, Vrije Universiteit Amsterdam, Computer Systems Group.

30 In 1998, ISO received a formal petition calling for revisions or suspension of the standards, and identifying multiple flaws in the ISO 11784/85 standard, including the lack of unique ID codes. See letter from Gosstandrat of Russia, Committee of Russian Federation for Standardization, Metrology and Certification, to Rudolf Zens, Secrteary, SC 19 (Mar. 2, 1998) at http://www.rfidnews.com/images/3-2-98.gif. See also The Controversial ISO 11784/85 Standard, ISO 11784/85: A Short Discussion, at www.rfidnews.com/iso_11784short.html

31 Genetic Resources Action International (“GRAIN”), Fowl Play: The Poultry Industry’s Central Role in the Bird Flu Crisis (Feb. 2006) (hereinafter “GRAIN Report”).

32 Bird Flu Crisis: Small farms are the solution, not the problem, in Seedling, GRAIN (July 2006) at p,26 (citing multiple scientific studies from around the world). Although pastured poultry are exposed to wild birds, extensive testing of wild birds has only rarely found bird flu in a highly pathogenic form. “Furthermore, the geographic spread of the disease does not correlate with migratory routes and seasons. The pattern of outbreaks follows major roads and rail routes, not flyways.” Avian influenza goes global, but don’t blame the birds, THE LANCET Vol. 6: 185 (Apr. 2006).

33 E-Digest Volume 2, Number 11, Issues Faced in the 2002 VA AI Outbreak; paper presented by Dr. Bill Pierson, at the 2002 Poultry Health Conference sponsored by the Ontario Poultry Industry Council.

34 GRAIN Report (quoting USDA, Laos: Poultry and Products—Avian Influenza, U.S. Department of Agriculture (Mar. 16, 2005)). Page 12

35 V Trifonov et al, 2009. The origin of the recent swine influenza A (H1N1) virus infecting humans, EuroSurveillance 14(17) http://www.eurosurveillance.org/ViewArticle.aspx?ArticleId=19193;Wuethrich B. 2003. Chasing the fickle swine flu. Science 299:1502-5 http://birdflubook.org/resources/WUETHRICH1502.pdf; Zhou NN, Senne DA, Landgraf JS, et al. 1999. Genetic reassortment of avian, swine, and human influenza A viruses in American pigs. Journal of Virology 73:8851-6. http://birdflubook.org/resources/ZHOU8851.pdf.

36 Webby RJ, Swenson SL, Krauss SL, Gerrish PJ, Goyal SM, and Webster RG. 2000. Evolution of swine H3N2 influenza viruses in the United States. Journal of Virology 74:8243-51.

37 Environmental Defense. 2000. Factory hog farming: the big picture. November. http://www.edf.org/documents/2563_FactoryHogFarmingBigPicture.pdf.

38 Wuethrich B. 2003. Chasing the fickle swine flu. Science 299:1502-5. http://BirdFluBook.org/resources/WUETHRICH1502.pdf.

39 Suriya R, et al. 2008. Seroprevalence and risk factors for influenza A viruses in pigs in Peninsular Malaysia. Zoonoses Public Health. 2008 55(7):342-51.

40 Poljak Z, et al. 2008. Prevalence of and risk factors for influenza in southern Ontario swine herds in 2001 and 2003. Can J Vet Res. 2008 72(1):7-17.

41 See R. Scott Nolen, Exotic Newcastle Disease Strikes Game Birds in California, JOURNAL OF THE AMERICAN VETERINARY MEDICAL ASSOCIATION NEWS (Nov. 15, 2002); News Release, Texas Animal Health Commission (Jan. 1, 2003) (“END likely was initially introduced into Southern California through illegal importation of infected birds.”); Congressman Elton Gallegly, Smuggling Cockfighting Roosters a Conduit to Bird Flu, SANTA BARBARA NEWS-PRESS (Dec. 11, 2005).

42 USDA, Integration of Private and State Animal Tracking Databases with the NAIS (released Apr. 6, 2006).

43 GAO Report on Agriculture at p.7-9.

44 J.A. Scanga et al, Development of computational models for he purpose of conducting individual livestock and premises traceback investigations utilizing National Animal Identification System-compliant data, J ANIM SCI 2007.85:503-211.

45 See GAO Report on Agriculture at p.1.

46 GAO Report on Agriculture at p.6

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