Browsing Posts tagged cattle

Rustling costs ranchers millions in poor economy

By JIM SUHR, AP Business Writer

ST. LOUIS (AP) — Even with cattle theft rampant in much of the nation’s midsection, Oklahoma rancher Ryan Payne wasn’t worried about anyone messing with his cows and calves. By his estimation, his pasture is so far off the beaten path “you need a helicopter to see it.”

Branding a cowThat changed last month when Payne, 37, checked on his livestock and found a ghoulish scene: Piles of entrails from two Black angus calves he says thieves gutted “like they were deer.” They made off with the meat and another 400-pound calf in a heist he estimated cost him $1,800.

“Gosh, times are tough, and maybe people are truly starving and just need the meat,” he said. “But it’s shocking. I can’t believe people can stoop that low.”

While the brazenness may be unusual, the theft isn’t. High beef prices have made cattle attractive as a quick score for people struggling in the sluggish economy, and other livestock are being taken too. Six thousand lambs were stolen from a feedlot in Texas, and nearly 1,000 hogs have been stolen in recent weeks from farms in Iowa and Minnesota. The thefts add up to millions of dollars in losses for U.S. ranches.

Authorities say today’s thieves are sophisticated compared to the horseback bandits of the rugged Old West. They pull up livestock trailers in the middle of the night and know how to coax the animals inside. Investigators suspect it’s then a quick trip across state lines to sell the animals at auction barns.

“It almost has to be someone who knows about the business, including just knowing where to take the cattle,” said Carmen Fenton, a spokeswoman for the 15,000-member Texas and Southwestern Cattle Raisers Association, formed in the 1870s specifically to combat cattle rustlers. “It’s crazy to think we’re still in business.”

There’s no clearinghouse that tracks thefts nationally, but statistics among certain states are staggering. In Texas — the nation’s biggest cattle producer — and to a lesser extent Oklahoma, some 4,500 cattle have been reported missing or stolen this year, according to Fenton’s group. The association’s special rangers managed to recover or account for $4.8 million in stolen ranch property each of the previous two years, most of it steers, bulls, cows and calves.

Such thefts also are happening in places once spared. In southwestern Missouri’s Jasper County, not far from a regional stockyard, about 100 of the nearly 180 head of cattle stolen this year were snatched during a recent six-week stretch, sheriff’s Lt. Ron Thomas said.

Branding a cow“Occasionally one or two have gotten stolen (over the years), but not this many in such a short time. They’ve gotten us big time,” he said, figuring the stolen livestock have been whisked off to another state. “These guys are not your typical fly-by-night, let’s-steal-a-cow kinda people. They know exactly what they’re doing. They’re pretty slick, and they’re bold.”

Investigators have found clues to be elusive, partly because thieves often artfully conceal their crimes by replacing pasture fences they’ve cut to get to the animals, Thomas said. Ranchers unaccustomed to counting their cattle each day may not realize any are missing for a week or more, and by then, any tire tracks or other evidence — perhaps even DNA or fingerprints from a soda or beer can discarded by the bandit — may be gone.

The other problem is that while brands are widely used in the West, three states hard hit by livestock thefts — Missouri, Oklahoma and Texas — don’t require them. That’s hampered investigators’ efforts to match recovered cattle to owners or to relay to stockyards markings to watch for when strangers haul in livestock to be sold.

Without brands, “ranchers could tell me their missing cow is brown and white, but goodness gracious, go down the road and you’ll see thousands,” Thomas said.

While a voluntary national livestock identification system exists, few ranchers and farmers participate in it and those who do fear that the rustlers will simply cut off the ID tag in seconds.

“Unfortunately, cattle don’t have a serial number that goes with them or some type of permanent ID” short of branding, said Jim Fraley, an Illinois Farm Bureau livestock specialist. “Thieves look at it as an opportunity and can market the cattle under their name. It’s a fairly easy thing to do.” Hot iron branding is the only proven method of ID that is permanent. Hide brands can not be removed or changed like electronic pens or ear tags.

In Ohio and Pennsylvania a single cattle rustler stole over $400,000 cattle. He was wise in never acquiring a single animal with a hot iron brand. Those stolen with ear marks or tags were quickly removed, therefore leaving no ID for law enforcement to track. The lack of hide brands invites a new breed of cattle rustler.

Owners’ vigilance has paid off in some cases. A Colorado rancher who was hunting prairie dogs spotted one of his branded, missing cows on another man’s property. Deputies swooped in and found 36 cows and 31 calves worth $68,000 and belonging to nine different people.

An Alabama rancher reported a couple of his cattle missing, and then two more were stolen the next night, Chilton County Sheriff Kevin Davis said. Sheriff’s investigators installed cameras on the property but got nothing before pulling them days later.

Not long after, the farmer called because he spotted two men with a pickup truck and what turned out to be a stolen trailer on his land. Deputies arrested the men and found five of the six missing cows — half of them pregnant — at various locations. The sixth animal already had been slaughtered.

Davis credited luck and the rancher’s “heightened alert” for snaring the two suspects.

“The boldness is the thing — for them to come back three different times to the same pasture,” he said. “Obviously, they didn’t feel very threatened about being caught. But I’ve never given criminals credit for having high intelligence.”

And they’re not finicky. An Ohio woman has been charged with taking $110,000 worth of frozen bull semen — which can valuable to breeders in even small amounts — from a liquid-nitrogen tank at a Moorefield Township genetics company where she once worked.

Nor are all the thefts big. Someone recently made off with two horses — ages 16 and 7 — from a home near Hanover in northeastern Illinois’ Jo Daviess County.

Back in Oklahoma, Payne replaced old wire gates on his ranch near Chelsea, with “big, old heavy-duty steel ones,” hoping to safeguard his other cows.

“That’s about all I can do,” he said. “Like everyone says, it never happens to me. I guess that’s wrong.”

R-CALF United Stockgrowers of America

 

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

 

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

December 22, 2011                                                                                          Phone: 406-252-2516; r-calfusa@r-calfusa.com

 

8 Days (Now 10) of Opposition to USDA’s Proposed Mandatory Animal Identification Rule:  Part IX of X-Part Series

Billings, Mont. – To minimize the size of the last scheduled news release in R-CALF USA’s 8-day series, R-CALF USA extended the series for two additional days. Each daily news release provides a detailed explanation of the reasons our members vehemently oppose the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service’s (APHIS’) proposed mandatory animal identification rule titled, Traceability for Livestock Moving Interstate (proposed rule).

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

Part IX:  The Agency’s Disdain for Brands, Inclusion of Feeder Cattle, and Failure to Disclose Documented Reasons for Untimely Disease Tracebacks Demonstrate APHIS’ Insincerity 

  1. APHIS’ Proposed Rule Discriminates Against States that Require Brand Inspections and Brand Inspection Certificates as a Condition for Leaving a Brand Inspection Area and Discriminates Against Cattle Producers Within Those States that Pay for and Rely on Brands and Brand Certificates to Identify Their Cattle
  1. APHIS’ inexplicable failure to include hot-iron brands accompanied by a certificate from a recognized brand inspection authority as a group/lot identifier is unscientific.

APHIS has failed to recognize brands as an official means of providing group/lot identification, under any circumstance. This is more than just alarming because of the obvious fact that each animal in a group of branded cattle is traceable even in the event the group/lot identification number is lost or destroyed, or in the event the group of animals, or any member of the group of animals, is inadvertently separated. APHIS cannot make this claim for any other group/lot identification device it is proposing.

The ability to identify each individual member of the group as a member of the group is scientifically and practicably superior to any of the group/lot identification devices proposed by APHIS in the proposed rule. It is unconscionable that APHIS would reject the single most effective means of group/lot identification, and the only means that would enable a trace back of a group/lot that inadvertently becomes separated or for which the paperwork is lost or destroyed.

APHIS must universally recognize the hot-iron brand accompanied by a certificate from a recognized brand authority as an officially approved group/lot identification method. Further, U.S. cattle producers that move in interstate commerce a group/lot of branded cattle accompanied by a certificate from a recognized brand authority should have no further obligation to place any other type of animal identification on their cattle. When the group lot arrives at its destination, which may be another brand state wherein the cattle likely will be rebranded, the buyer or buyers of those cattle should be responsible for applying any type of identification that may be required by the receiving state if the group is to be separated. I! f the group is not separated, e.g., if the entire group is sold to a feedlot for finishing, than the owner or manager of those cattle in the receiving state should have no obligation to apply any other form of identification.

  1. Under no circumstances should APHIS include feeder cattle in any mandatory animal identification rule.

The U.S. all but eradicated diseases such as bovine TB and brucellosis by focusing on the identification of breeding cattle only. The principal culprits that have caused the resurgence of those diseases are imported cattle (primarily from Mexico, see supra) and wildlife reservoirs. APHIS has the authority, recourses and means to fully prevent the continual reintroduction of disease that are spread by imported cattle as well as to minimize disease reservoirs in wildlife, but it refuses to implement stricter import standards and effective wildlife mitigations. Instead, USDA wants to burden the owners! of our nation’s 31.4 million beef mother cows with its onerous, overreaching rule that effectively forces U.S. cattle producers to pay costs associated with other country’s disease problems and site-specific wildlife problems. This proposed rule is anything but a scientific, risk-based proposal.

APHIS has failed to explain how past disease programs were so “tremendously successful” without ever imposing mandatory identification on feeder cattle and why, suddenly, APHIS deems it necessary.

As stated above, the cost of ear tagging the 2010 calf crop, again using APHIS’ estimate that 3.1 million calves already bear official identification, would be between $554 million and $880 million. This cost would be expected to be incurred year after year if feeder cattle were subjected to the proposed rule. Even using APHIS’ grossly understated cost of $4.68 per head, the proposed rule would cost U.S. cattle producers $152.6 million annually.

For comparison purposes, APHIS estimates the annual cost to states and the federal government for bovine TB testing is $2.6 million. However, this cost does not come close to justifying the mandatory imposition of hundreds of millions of dollars in additional costs on U.S. cow/calf producers.

  1. APHIS has failed to disclose the full nature of the problem the proposed rule is intended to address or to explain how the proposed rule would be expected to correct the serious problems APHIS failed to disclose.

APHIS has failed to disclose significant problems that have been identified in its disease traceback operations and has failed to explain how the proposed rule would be expected to correct those problems. For example, APHIS attempts to justify its proposed rule on the basis that some bovine TB investigations exceed 150 days.  See supporting document, at 8.  APHIS, along with other proponents of the proposed rule’s precursor – NAIS – alleged that because of what they call an “outdated system of tracking outbreaks of animal diseases to their sources (EXHIBIT 26, p. 5);” and a “lack of any official identification” with which to determine the “specific origin of the subject animal . . .[and] without movement data (EXHIBIT 7, p. 3),”  disease traceback investigations have taken too long to conduct.  Both the American Veterinar! y Medical Association (AVMA) and APHIS cited the same statistics to su pport their allegations:  AVMA stated, “Investigators spent an average of 199 days tracing the sources of animals infected with bovine tuberculosis between October 2005 and August 2007 (EXHIBIT 26, p. 5).” APHIS stated, “The average time spent conducting a traceback involving 27 recent bovine tuberculosis investigations was 199 days (EXHIBIT 7, p. 4).”

However, the Office of Inspector General (OIG) conducted an audit of APHIS’ control over its bovine TB eradication program in September 2006. According to the audit, the OIG found that a lack of identification on individual animals was not the sole source of APHIS’ problem in conducting its bovine TB investigations. In fact, the OIG found that over half of the investigations that were closed with an outcome of “untraceable” were animals that were identified with eartags, but the eartags either were not collected at the time of slaughter, had been removed by the feedlot prior to slaughter, or were unable to be traced because there was no requirement to maintain records (EXHIBIT 27, p. 38).  Equally important, the OIG found that APHIS’ disease eradication efforts were hampered because the agency was not using its oversight tools in a timely manner, i.e., not timely reviewing and responding to the annual and monthly summaries of program results submitted by States nor was it properly reviewing States for program compliance (EXHIBIT 27, p. 5-9). The OIG also found that APHIS was not following Federal regulations for declaring affected bovine TB herds, which weakened the agency’s ability to contain and eradicate the disease and resulted in no additional controls being put in place for the majority of bovine TB cases detected in the past 5 years (EXHIBIT 27, p. 11-14). The agency was also cited for not timely downgrading the TB status of States after the agency knew that the disease was not isolated in one herd (EXHIBIT 27, p. 16-17); not having adequate controls to restrict the introduction of bovine TB in Mexican cattle (EXHIBIT 27, p. 19-21); not requiring slaughtering facilities to conduct surveillance at the recommended rate (EXHIBIT 27, p. ! 22-24); not monitoring high-risk herds and the corresponding on-farm testing that is required (EXHIBIT 27, p. 28-29); and not providing sufficient training to investigators so investigations could be completed in a timely manner (EXHIBIT 27, p. 22, 25, 28).

APHIS has failed to provide the livestock industry with sufficient data to identify all significant problems associated with current animal disease traceability systems and provide documentation to show how any new animal disease traceability system would be expected to resolve any such specific problems. The systemic problems described above are internal management problems that impede disease control and eradication as well as disease investigations and would not be solved by implementing the proposed rule.

Because the proposed rule fails to address how APHIS intends to address the systemic problems disclosed and discussed above, it is as likely as not that APHIS’ internal management problems would continually hamstring disease investigations and no measurable improvement would be made to the timeliness of the Agency’s disease investigation simply by imposing an outrageously expensive identification requirement on U.S. cattle producers.

 

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

R-CALF United Stockgrowers of America

 

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

 

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

December 21, 2011                                                                                          Phone: 406-252-2516; r-calfusa@r-calfusa.com

 

8 Days (Now 10) of Opposition to USDA’s Proposed Mandatory Animal Identification Rule:  Part VIII of X-Part Series

Billings, Mont. – To minimize the size of the last scheduled news release in R-CALF USA’s 8-day series, R-CALF USA is extending the series for two more days. Each daily news release provides a detailed explanation of the reasons our members vehemently oppose the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service’s (APHIS’) proposed mandatory animal identification rule titled, Traceability for Livestock Moving Interstate (proposed rule).

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

Part VIII:  APHIS’ Proposed Rule Is an Affront to the Cattle Industry’s Centuries-old Brand

 

  1. APHIS’ Proposed Rule Discriminates Against States that Require Brand Inspections and Brand Inspection Certificates as a Condition for Leaving a Brand Inspection Area and Discriminates Against Cattle Producers Within Those States that Pay for and Rely on Brands and Brand Certificates to Identify Their Cattle

 

  1. APHIS’s proposed rule ignores the historical effectiveness, functionality and permanence of the hot-iron brand as a means of identifying cattle and groups of cattle.

 

APHIS is acutely aware of the superior permanence of the hot-iron brand as compared to ear tags.  In its final rule to allow the importation of Canadian cattle 30 months of age or older (OTM rule), APHIS distinguishes brands as “permanent identification,” while separately requiring, in addition to permanent identification, an official ear tag to be placed in imported Canadian cattle (EXHIBIT 24, p. 53378 col. 1). In fact, ear tags are not even mentioned as acceptable means of permanent identification, with only freeze brands, hot-iron brands, and tattoos expressly listed among the acceptable, permanent means of identification (EXHIBIT 24, p. 53378 col. 1). In addition to permanent identification, the OTM rule also requires the individual identification with an official ear tag of the country of origin (EXHIBIT 24, p. 53378 co! l. 1).

 

APHIS’ purpose for requiring permanent brands on Canadian cattle along with ear tags is succinctly explained in the OTM rule. APHIS stated, “We recognize that animals can lose eartags at various points in the process. . . (EXHIBIT 24, p. 53340 col. 1).”

 

The foregoing discussion reveals that for disease traceback purposes, even for cattle originating in regions that APHIS has deemed a “minimal-risk” for disease, APHIS requires a three-prong traceback system:  1) it requires the permanent identification of the animal using a brand or tattoo; 2) it requires individual identification with an official ear tag; and, 3) it requires visible information on the animal to denote the animal’s origin (EXHIBIT 24, p. 53379 col. 1).

 

R-CALF USA agrees that this three-prong traceback system is a science-based means of achieving functional traceability on livestock that may be subject to a disease investigation.  The system has needed redundancy to address the inherent propensity for ear tags to be lost, and it provides visible information that enables any person to identify the origin of the animal.

 

APHIS’ proposed rule fails completely to explain why the three identification elements needed from minimal-risk regions are not needed to provide a science-based traceback system for U.S. cattle. Nor does APHIS explain which of the three elements are most important to ensure the ability to conduct tracebacks, e.g., is it more important to have permanent identification or are loss-prone ear tags equally functional for disease tracebacks? And, APHIS fails completely to explain why the ability to visibly identify the origin of the animal is not even necessary for domestic traceback purposes.

 

If the requirement contained in the OTM rule is science-based, than the proposed requirements in the proposed rule are not.  This is because the proposed rule incorporates only one of the three elements required in the OTM rule, and the one it has incorporated is not even recognized by APHIS as a permanent form of identification. The proposed rule depends exclusively on an official ear tag that bears a U.S. shield and a number:  it does not require permanent identification (indeed it expels permanent identification from its list of official animal identification devices), and it does not require ear tags to bear visible information to i! dentify even the state from which the animal originated. APHIS further fails to explain why privately-owned U.S. cattle must bear a U.S. shield for the privilege of moving across a state line. Such a shield is of no use to disease investigators and if a shield is to be required at all, it should be the shield of the state from which the animal originated, at least then a person could immediately initiate a disease investigation by calling the animal heath officials in the state of origin should an animal be detected with a disease. Better yet, the animal should bear the shield of the property’s owner – which is precisely what is accomplished with a registered hot-iron brand.

 

APHIS contends it cannot require all states to accept brands because all states do not have brand inspection programs. At the same time, however, APHIS’ proposed rule requires all states to accept ear tags that do not allow any visible means with which to ascertain the origin of an animal. For example, the APHIS approved 840 ear tag does not contain an identifier that denotes the state of origin.  Therefore, an animal health official without immediate access to an expensive, electronic wand or a national database has no means of initiating an immediate traceback of the animal. On the other hand, if an animal was transported to a state with a brand, then the animal health official could immediately narrow the animal’s potential origin to those states that have a ! recognized brand authority that issues brand certificates. APHIS is disingenuous in its claim that non-brand states cannot accept brands while it simultaneously requires non-wand states to accept 840 electronic tags.

 

APHIS’ proposed identification requirements for cattle lack any scientific justification. APHIS has thrown the proverbial baby out with the bath water by refusing to adopt even the core elements of current U.S. disease programs that APHIS itself acknowledges were “tremendously successful” in the agency’s efforts to eradicate brucellosis.. See 76 Fed. Reg. 50081, col. 3. The highly successful brucellosis program, not surprisingly, incorporated each of the three prongs APHIS requires of Canada:  1) the program recognized brands as official identification, which provided a high level of redundancy; 2) the program required an official ear tag! ; and, 3) the ear tag contained visible information with which to immediately identify the state of origin.

APHIS’ claim that its goal is to shorten the time necessary to conduct disease tracebacks is proved false by APHIS’ failure to adopt the historically proven, simple, and visible state identifier, such as two-digit numeric code that denotes the tag’s state of origin, on all of its approved ear tags.

 

The role of the permanent brand in contributing to the United States’ “tremendously successful” disease program is profound. In a March 9, 2010, article by James C. Clement, D.V.M., Cow-Calf Research & Consulting, Dr. Clement explains the profound contribution that brands and brand programs make to generating animal tracking data every day, along with describing how critical tracking data are compiled.  Dr. Clement states:

 

Animal tracking data is generated every day in Brand States and is the byproduct of routine record-keeping processes that involve cattle marketing businesses and SBIS [State Brand Inspection Systems]. SBIS create inspection certificates associated with the movement of 27,000,000 head of livestock (primarily cattle) on an annual basis (EXHIBIT 25).

 

APHIS cites no study, nor does it have any nationwide experience in conducting animal disease tracebacks without relying upon the animal tracking data generated by brand states. Indeed, APHIS has not cited any system in the world that can hold a candle to the brand states’ ongoing generation of animal tracking data for 27 million head of livestock, primarily cattle, which represents about one-third of the entire U.S. population of cattle and calves.

 

APHIS has no scientific basis for delisting the hot-iron brand accompanied by a certificate from a recognized brand authority from the list of official animal identification devices or methods, or in any way demoting the hot-iron brand to a level below any other form of animal identification.

 

Based on the hot-iron brand’s role in generating animal tacking data for tens of millions of livestock, APHIS’ proposed rule that delists the brand from the list of official animal identification devices will reduce the United State’s ability to timely trace disease suspects to the disease source.

 

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

R-CALF United Stockgrowers of America

 

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

 

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

December 18, 2011                                                                                          Phone: 406-252-2516; r-calfusa@r-calfusa.com

 

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

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

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

Part V:  Marketplace Premiums for Traceable Cattle Will Evaporate Under the Proposed Rule

 

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

 

  1. 3.      APHIS’s cost estimates completely overlook and ignore the market value of the information intrinsic to an individually identified animal and the effect of APHIS’ proposed rule will be to steal that value from U.S. cattle producers and gift it to the U.S. meatpacking industry.

 

APHIS asserts the primary benefit of the proposed rule would be to minimize losses and quickly reestablish foreign and domestic markets. See 76 Fed. Reg. 50097, col. 3.  But, APHIS completely overlooks and ignores the fact that foreign markets already have assigned a market value to information that would enable traceability to the herd of origin. Primary export markets such as Japan, South Korea, and Hong Kong already require beef exported to them to be from animals that are traceable. Japan requires beef to be derived from cattle t! hat are individually identified and traceable back to ranch records (EXHIBIT 16). South Korea requires beef to be derived from cattle that are of U.S. origin or fed in the U.S. for at least 100 days if they originate from Mexico or Canada, which requirement necessitates individual animal identification (EXHIBIT 17). Hong Kong requires beef from cattle that are traceable to the last location and to the herd of origin in the event of a BSE outbreak (EXHIBIT 18).

 

The fact that the above mentioned export markets each require some form of traceability of cattle from which the exported beef is derived indicates they each have assigned a market value for traceability and are willing to pay for that additional value in the price they pay for U.S. beef. This market driven incentive to provide traceability as a product attribute for foreign markets has already been embraced by many R-CALF USA members. Anecdotal information from R-CALF USA members indicates that the marketplace has assigned economic premiums ranging from $30 to $60 per head for producers who are voluntarily providing traceable livestock for use in the beef export market.

Dr. Kris Ringwall’s 2007 testimony to the U.S. ITC succinctly explained that traceability has a market value:

 

Steve Holcombe, founder and chief executive officer of Pardalis, Inc. (which is a third-party data storage company that values and treats data the same as money) noted: “The challenge is to effectuate regulations that are inclusive of small producers, and that recognize that there now are two distinct products being produced along agricultural supply chains today: (1) the traditional livestock product (the calf) and (2) an informational product that describes the ‘pedigree’ of the traditional product.”

 

This is important to understand. Today’s producer markets a calf but also markets the information about that calf, a process that is still struggling in the pens and alleyways of the cattle business. The free marketplace determines calf value, but the value of the information associated with the calf has not been determined. But one point is becoming very clear; the actual information contains the keys to unlock the various doors needed to enter the more complex market place, not only domestically but also internationally (EXHIBIT 12, p. 1).

 

The proposed rule is void of any economic analysis regarding the potential loss of all or part of the economic premiums that export-oriented cattle producers are presently receiving by choosing to add information to their cattle that describes the pedigree of their cattle. The proposed rule would interfere with the free market system by forcing all cattle producers to pay the cost of providing traceability and then gifting any and all of the market value associated with traceable cattle directly to the nation’s meatpackers, which, of course, are in the business of selling beef, not cattle. APHIS’ failure to analyze the loss of economic premiums, specifically the portion of the economic premium assigned to basic traceability, is fatal as the effect of its proposed rule would be to transfer wealth from U.S! . cattle producers to the purveyors of the commodity beef – the U.S. meatpacking industry.

 

Based on APHIS’ estimate that 3.1 million calves were officially identified in 2010 (see supporting document, at 8), and assuming that those cattle are receiving market-driven premiums in the range of $30 to $60 per head, the proposed rule would financially damage those producers in a range of between $93 million and $186 million. This would be in addition to the proposed rule’s costs addressed in Section C. 2. supra. This loss would be realized by U.S. cattle producers because, once the rule is implemented, those producers who already officially identify their cattle will no longer be able to differentiate their cattle based on all or part of the valuable “pedigree” information they are now “selling” in the marketplace.

 

R-CALF USA is concerned that APHIS intends to persuade export countries to abandon, in whole or in part, their current requirements for cattle traceability as specified in the USDA Export Verification (EV) program as soon as APHIS can demonstrate that all or most cattle in the U.S. are traceable under APHIS’ mandatory identification scheme. When this inevitability occurs, U.S. cattle producers will be deprived of the income discussed above that they can now earn by voluntarily participating in currently available EV programs.

 

R-CALF USA’s concern is not mere conjecture. In the June 3, 2005, Declaration of John R. Clifford, D.V.M., then deputy Administrator, APHIS, Veterinary Services, which included exhibits, Dr. Clifford stated that he did not believe the voluntary Export Verification Program was needed:

 

The program, called the Beef Export Verification program, will set forth policies, procedures and requirements for an independent process verification of participants.

 

It is a voluntary, user-fee service available to suppliers of beef and beef products derived from cattle slaughtered in the United States.

 

The USDA Agricultural Marketing Service will conduct process verification audits of suppliers, program documentation and procedures with regard to the Beef Export Verification program requirements.

 

Details of this program are being shared with the industry and will be posted on the USDA website starting today. It will be operational on or before September 1st.

 

As I said before, we do not believe such a program is necessary (EXHIBIT 1, pp. 2,3; EXHIBIT 19). (Emphasis added.)

 

Based on Dr. Clifford’s representation that APHIS was opposed to the very inception of the Beef Export Verification program, it is R-CALF USA’s belief that it is more likely than not that Dr. Clifford and APHIS will work aggressively to dismantle this voluntary, market-driven program as soon as the proposed rule is implemented.

 

If R-CALF USA’s concern materializes, APHIS’ proposed rule would effectively steal the market value associated with “pedigree” information that enables livestock traceability (estimated at between $93 million and $186 million in 2010 alone) away from U.S. cattle producers and gift it to the U.S. meatpacking industry, even though it is the cattle producers who will continually bear the cost of providing such valuable market information.

 

As explained above, APHIS’ proposed rule directly interferes with the United States’ free market system and if the losses estimated for 2010 were calculated on the basis of the cattle industry’s lost future income potential, those losses would compound astronomically and result in an acceleration of the already contracting U.S. cattle industry. For this reason, the proposed rule must be immediately withdrawn.

 

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

 

# # #

 

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

R-CALF United Stockgrowers of America

 

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

 

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

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

 

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

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

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

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

 

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

 

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

 

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

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

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

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

 

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

 

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

 

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

 

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

 

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

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

 

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

 

# # #

 

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

R-CALF United Stockgrowers of America

 

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

 

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

December 16, 2011                                                                                          Phone: 406-252-2516; r-calfusa@r-calfusa.com

 

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

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

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

Part III:  The Proposed Rule Would Cost the U.S. Cattle Industry Hundreds of Millions of Dollars

 

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

 

  1. 1.      A three-year study shows the proposed rule will cost U.S. cattle producers hundreds of millions of dollars, if not billons of dollars

 

USDA data show the 2010 U.S. calf crop was 35.685 million head and the U.S. commercially slaughtered 34.249 million cattle in 2010. (EXHIBIT 11, p. 19) Based on the assumption that all of those cattle had to be moved at least once in 2010 – from herd of origin to grass or backgrounder, or from herd of origin to feedlot and/or slau! ghter plant, respectively – there was a potential for all those cattle to be moved in interstate commerce and to be subject to the proposed rule’s requirements (it is noted the requirement for indentifying feeder cattle would be only temporarily delayed under the proposed rule). Thus, there was the potential in 2010 for nearly 70 million head of cattle to be required to be individually identified if the proposed rule were fully implemented.

 

A study presented to the U.S. International Trade Commission (USITC) in 2007 by Kris Ringwall, Ph.D., Director, Dickinson Research Center Extension and Livestock Specialist, North Dakota State University (NDSU), that involved the tagging of 14,432 calves during the three-year period 2004-2006, concluded that the cost working each calf, tag placement and documentation was $7.00 per calf. (EXHIBIT 12, p. 2) In addition, Dr. Ringwall’s three-year project determined tha! t the tagging of calves was costly to producers because of shrink, which he defined as “weight loss while handling calves.” (EXHIBIT 12, p. 2) Dr. Rinwall stated in his testimony:

 

When we’ve measured shrink in the cattle we have worked during the project, we estimate up to $10 to $20 in lost income potential per calf, regardless of the management activity applied. (EXHIBIT 12, p. 2)

 

Based on Dr. Ringwall’s findings, the cost of tagging and documenting calves, excluding the cost of the tag itself, and the cost of the income lost due to shrink, ranged from $17.00 per head to $27.00 per head in 2006 or 2007 dollars. Based on information and belief, that cost in 2010 dollars likely is as high as $30.00 per head, if not higher. However, applying Dr. Ringwall’s 2007 findings to all cattle – cows, bulls, and calves – the likely cost of the proposed rule to U.S. cattle producers ranges from $1,190,000,000 ($1.2 billion) to $1,890,000,000 ($1.9 billion) (70 million head of cattle multiplied by $17.00 per head and $27.00 per head, respectively).  Even if only the cattle moved to slaughter in 2010 were considered, the cost to U.S. cattle producers would be $924,723,000, or about $920 million (34.249 million head of commercial slaughter cattle multiplied by $27.00 per head).

 

Applying Dr. Ringwall’s findings to APHIS’ assertion that “[a]pproximately 20 percent of cattle are not currently eartagged as part of routine management practices” (see 76 Fed. Reg., 50097, col. 1) and based on the assumption that APHIS used the Jan. 1, 2011, U.S. cattle and calves inventory number of  92,582,400 head, it would cost U.S. cattle producers a high of nearly $500 million to tag the 20 percent of cattle not already tagged (20 percent of 92,582,400 cattle equals 18,516,480 cattle multiplied by $27 per head).

 

Using APHIS’ data relied on in its supporting document, only 3.1 million of the 35.685 million head annual calf crop is tagged with official identification.  Therefore, the cost of tagging the remaining 2010 calf crop would range from $554 million to $880 million.

 

Thus, based on an actual study of tagging actual cattle – not on a study of available literature upon which APHIS relies – the cost to U.S. cattle producers to comply with the proposed rule will likely be hundreds of millions of dollars, if not billions of dollars. APHIS’ upper cost estimate for the proposed rule of only $34.3 million (see 76 Fed. Reg., 50097, cols. 2, 3) is based on a complete lack of understanding of the U.S. cattle industry, and it grossly understates the cost that U.S. cattle producers actually will bear if USDA does not immediately withdraw the proposed r! ule.

 

 

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

R-CALF United Stockgrowers of America

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

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

December 15, 2011                                                                                          Phone: 406-252-2516; r-calfusa@r-calfusa.com

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

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

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

Part II:  By Deploying the Underhanded Tactic of “Bait-and-Switch,” APHIS Deceptively Scared the Livestock Industry, Congress, and the Public Into Falsely Believing that a Mandatory Animal Identification System was Absolutely Critical to Protect the U.S. from Foot-and-Mouth Disease

  1. APHIS’ Flip-Flop Regarding Its Principal Justification for a Mandatory Animal Identification System Demonstrates that APHIS has an Ulterior Motive for the Proposed Rule that Is Unrelated to the Prevention or Control of Animal Diseases

Remarkably, while APHIS touted the risk of FMD introduction and spread as the principal justification – indeed its “poster-child disease” – for a national animal identification system (NAIS) in the years, months and days leading up to its publication of the proposed rule, FMD is no longer included among the diseases APHIS identifies as justification for its proposed rule. In fact the voluminous, 28-page proposed rule does not even mention FMD, let alone reference it as a disease APHIS would expect to prevent or control should it finalize its proposed rule. Any mention of FMD is now relegated to a small, hypothetical and ambiguous section in APHIS’ supporting documents, in which APHIS provides the disclaimer that its hypothetical FMD discussion “does not specifically model conditions that may exist under the proposed rule;” and in whi! ch APHIS provides no explanation regarding how its proposed rule would, in any way, protect against a potential outbreak or spread of FMD.

It is abundantly clear that while APHIS has long assigned substantial weight to the potential to mitigate FMD introduction and spread in the United States in its historical and ongoing effort to impose a national animal identification system on the U.S. cattle industry, it has now completely abandoned its flagship disease.

In its 2008 risk evaluation of South Korea, APHIS described in detail South Korea’s evolving national animal identification system to highlight the system as a measure to effectively mitigate FMD spread following a FMD outbreak (EXHIBIT 6, pp. 24, 25). Similarly, in recent congressional testimony, APHIS testified that Japan had adopted a national animal identification system and that the need for such a unified national animal identification system had assumed greater urgency in the U.S. due to FMD (EXHIBIT 7). APHIS further claimed that a national animal identification system would be critical in mitigating the risks posed by potential FMD outbreaks, and vehemently argued that the costs of a national animal identification system must be compared with the estimated billions of dollars in losses th! e U.S. would be expected to suffer from a FMD outbreak (EXHIBIT 7). Recently, in APHIS’ risk analysis section of its risk evaluation for the agency’s proposed rule to regionalize a Brazilian state, APHIS describes Santa Catarina’s animal identification systems in significant detail and claims the systems would allow officials to trace the movement of cattle within Santa Catarina, presumably to mitigate the spread of a FMD outbreak in Santa Catarina (EXHIBIT 8, pp. 45-47). Then, within just days of publishing the proposed rule, APHIS published a notice of availability (notice) and request for comment that referenced its APHIS Evaluation of the Foot and Mouth Disease Status of Japan risk analysis as the basis for deciding whether to resume trade in FMD-susceptible products with Japan (see 76 Fed. Reg. 44503-504 (July 26, 2011)). APHIS stated in its notice: “The risk analysis will also serve as the basis for our determination whether to allow the resumption of the importation of whole cuts of boneless beef from Japan.” Id., 504, col 1. APHIS’ referenced risk analysis regarding the potential risk of FMD introduction from Japan stated, “Japan’s cattle identification system ensures adequate trace-back capability in the event of an [FMD] animal disease outbreak” (EXHIBIT 9, p. 17).

As demonstrated above, APHIS for many years concocted a virtual taxpayer-funded fervor, both publicly and within the entire U.S. livestock industry, to advance its goal to establish a mandatory animal identification system in the United States – which goal manifested into the proposed rule – principally, if not exclusively, by claiming a mandatory animal identification system is essential to prevent the introduction and/or spread of FMD in the United States. APHIS’ absolute silence regarding any potential for the proposed rule to mitigate the introduction or spread of FMD in the U.S. is inexplicable and provides compelling e! vidence that APHIS has an ulterior motive for proposing the proposed rule, which ulterior motive has absolutely nothing to do with prevention or control of animal diseases.

APHIS’ proposed rule is a complete scam. APHIS provides no support whatsoever for its proposed rule based on its multi-year, multi-million dollar (EXHIBIT 10, p. 1), taxpayer-funded public-relations and nationwide marketing campaign to hype a mandatory animal identification system as essential to protecting U.S. livestock from the most contagious disease known to cloven-hoofed animals – FMD; and, as will be discussed below, APHIS’ proposed rule directly contradicts APHIS’ claimed objective to carry out its statutory responsibilities using a scientific, risk-based approach.

APHIS’ inexplicable abandonment of the threat of an FMD introduction as its principal justification for a mandatory animal identification system as is clearly revealed in the proposed rule is akin to the hideous and unlawful scheme known as bait-and-switch in the retail industry.  Under a bait-and-switch scheme, retailers lure consumers into their establishment by advertising an item known to attract consumers; but, when the consumer arrives at the establishment, the item that lured them there is unavailable, and the retailer hopes the unsuspecting consumer will nevertheless purchase an alternative item. This deceptive tactic is precisely what APHIS has employed to coerce unsuspecting cattle producers to buy into the proposed rule – it aggressively advertised FMD as the principal disease ne! cessitating a mandatory identification system and when the proposed rule is published, FMD suddenly is abandoned as justification for the proposed rule, with only less contagious diseases remaining.

Like the victimized consumer duped by a retailer’s deceptive bait-and-switch scheme, cattle producers have no moral or ethical obligation to comply with APHIS’ equally deceptive bait-and-switch tactic deployed in the proposed rule, and they should have no legal obligation either.

If APHIS proceeds in any way other than to immediately withdraw the proposed rule, it must fully and comprehensively explain why APHIS abruptly abandoned FMD as a justification for the proposed rule. As part of that explanation, APHIS must describe in detail the specific role that a mandatory animal identification system played, if any, during the outbreaks of FMD that occurred very recently during this decade in the United Kingdom, South Korea, Japan, and Paraguay.  Specifically, APHIS must describe in detail the degree to which traceability in those nation! s reduced the spread of FMD or otherwise assisted in combating the disease.

Further, and in addition to the proposed rule’s failure to address APHIS’ historical insistence that a mandatory animal identification system is needed to address FMD, the proposed rule also fails to explain or describe what measures and operations APHIS will deploy to control or eradicate any specific diseases. APHIS’ authority to control or eradicate diseases (note that “control” and “eradicate” have very different meaning) is conferred by the AHPA’s authorization to carry out operations and measures for those purposes. (See 7 U.S.C. 8308 (a), (“The Secretary may carry out operations and measures to detect, control, or eradicate any pest or disease of livestock. . .”). However, the proposed rule is silent on any specific “operations and measures” the agency intends to carry out to eradicat! e or control any specific disease.

Due to this additional deficiency contained in the proposed rule, and if the agency proceeds in any way other than to immediately withdraw the proposed rule, the agency must explain and describe to the U.S. cattle industry:

  1. The specific diseases APHIS intends to “control” under the proposed rule.
  2. The specific nature of the “operations and measures” APHIS intends to use to “control” each of the specific diseases APHIS intends to “control” and a detailed description of the role of the traceability contemplated in the proposed rule in carrying out such “operations and measures.”
  3. The specific diseases APHIS intends to “eradicate” under the proposed rule.
  4. The specific nature of the “operations and measures” APHIS intends to use to “eradicate” each of the specific diseases APHIS intends to “eradicate” and a detailed description of the role of the traceability contemplated in the proposed rule in carrying out such “operations and measures.”

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

# # #

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

Rustling costs ranchers millions in poor economy

By JIM SUHR, AP Business Writer

ST. LOUIS (AP) — Even with cattle theft rampant in much of the nation’s midsection, Oklahoma rancher Ryan Payne wasn’t worried about anyone messing with his cows and calves. By his estimation, his pasture is so far off the beaten path “you need a helicopter to see it.”

Branding a cowThat changed last month when Payne, 37, checked on his livestock and found a ghoulish scene: Piles of entrails from two Black angus calves he says thieves gutted “like they were deer.” They made off with the meat and another 400-pound calf in a heist he estimated cost him $1,800.

“Gosh, times are tough, and maybe people are truly starving and just need the meat,” he said. “But it’s shocking. I can’t believe people can stoop that low.”

While the brazenness may be unusual, the theft isn’t. High beef prices have made cattle attractive as a quick score for people struggling in the sluggish economy, and other livestock are being taken too. Six thousand lambs were stolen from a feedlot in Texas, and nearly 1,000 hogs have been stolen in recent weeks from farms in Iowa and Minnesota. The thefts add up to millions of dollars in losses for U.S. ranches.

Authorities say today’s thieves are sophisticated compared to the horseback bandits of the rugged Old West. They pull up livestock trailers in the middle of the night and know how to coax the animals inside. Investigators suspect it’s then a quick trip across state lines to sell the animals at auction barns.

“It almost has to be someone who knows about the business, including just knowing where to take the cattle,” said Carmen Fenton, a spokeswoman for the 15,000-member Texas and Southwestern Cattle Raisers Association, formed in the 1870s specifically to combat cattle rustlers. “It’s crazy to think we’re still in business.”

There’s no clearinghouse that tracks thefts nationally, but statistics among certain states are staggering. In Texas — the nation’s biggest cattle producer — and to a lesser extent Oklahoma, some 4,500 cattle have been reported missing or stolen this year, according to Fenton’s group. The association’s special rangers managed to recover or account for $4.8 million in stolen ranch property each of the previous two years, most of it steers, bulls, cows and calves.

Such thefts also are happening in places once spared. In southwestern Missouri’s Jasper County, not far from a regional stockyard, about 100 of the nearly 180 head of cattle stolen this year were snatched during a recent six-week stretch, sheriff’s Lt. Ron Thomas said.

Branding a cow“Occasionally one or two have gotten stolen (over the years), but not this many in such a short time. They’ve gotten us big time,” he said, figuring the stolen livestock have been whisked off to another state. “These guys are not your typical fly-by-night, let’s-steal-a-cow kinda people. They know exactly what they’re doing. They’re pretty slick, and they’re bold.”

Investigators have found clues to be elusive, partly because thieves often artfully conceal their crimes by replacing pasture fences they’ve cut to get to the animals, Thomas said. Ranchers unaccustomed to counting their cattle each day may not realize any are missing for a week or more, and by then, any tire tracks or other evidence — perhaps even DNA or fingerprints from a soda or beer can discarded by the bandit — may be gone.

The other problem is that while brands are widely used in the West, three states hard hit by livestock thefts — Missouri, Oklahoma and Texas — don’t require them. That’s hampered investigators’ efforts to match recovered cattle to owners or to relay to stockyards markings to watch for when strangers haul in livestock to be sold.

Without brands, “ranchers could tell me their missing cow is brown and white, but goodness gracious, go down the road and you’ll see thousands,” Thomas said.

While a voluntary national livestock identification system exists, few ranchers and farmers participate in it and those who do fear that the rustlers will simply cut off the ID tag in seconds.

“Unfortunately, cattle don’t have a serial number that goes with them or some type of permanent ID” short of branding, said Jim Fraley, an Illinois Farm Bureau livestock specialist. “Thieves look at it as an opportunity and can market the cattle under their name. It’s a fairly easy thing to do.” Hot iron branding is the only proven method of ID that is permanent. Hide brands can not be removed or changed like electronic pens or ear tags.

In Ohio and Pennsylvania a single cattle rustler stole over $400,000 cattle. He was wise in never acquiring a single animal with a hot iron brand. Those stolen with ear marks or tags were quickly removed, therefore leaving no ID for law enforcement to track. The lack of hide brands invites a new breed of cattle rustler.

Owners’ vigilance has paid off in some cases. A Colorado rancher who was hunting prairie dogs spotted one of his branded, missing cows on another man’s property. Deputies swooped in and found 36 cows and 31 calves worth $68,000 and belonging to nine different people.

An Alabama rancher reported a couple of his cattle missing, and then two more were stolen the next night, Chilton County Sheriff Kevin Davis said. Sheriff’s investigators installed cameras on the property but got nothing before pulling them days later.

Not long after, the farmer called because he spotted two men with a pickup truck and what turned out to be a stolen trailer on his land. Deputies arrested the men and found five of the six missing cows — half of them pregnant — at various locations. The sixth animal already had been slaughtered.

Davis credited luck and the rancher’s “heightened alert” for snaring the two suspects.

“The boldness is the thing — for them to come back three different times to the same pasture,” he said. “Obviously, they didn’t feel very threatened about being caught. But I’ve never given criminals credit for having high intelligence.”

And they’re not finicky. An Ohio woman has been charged with taking $110,000 worth of frozen bull semen — which can valuable to breeders in even small amounts — from a liquid-nitrogen tank at a Moorefield Township genetics company where she once worked.

Nor are all the thefts big. Someone recently made off with two horses — ages 16 and 7 — from a home near Hanover in northeastern Illinois’ Jo Daviess County.

Back in Oklahoma, Payne replaced old wire gates on his ranch near Chelsea, with “big, old heavy-duty steel ones,” hoping to safeguard his other cows.

“That’s about all I can do,” he said. “Like everyone says, it never happens to me. I guess that’s wrong.”

Small farmers and urban poultry owners alike are threatened by the USDA’s new proposal for animal identification. The agency has proposed a rule that imposes costs and paperwork burdens on farmers, ranchers, backyard poultry owners, sale barns, vets, and state agencies in order to track animals that cross state lines.
The proposed rule is a solution in search of a problem. The USDA has failed to identify the specific problem or disease of concern, and the real focus of the program is helping the export market for the benefit of a handful of large corporations. The agency has also failed to account for the full cost to both private individuals and state governments, creating an unfunded mandate. The new rule will harm rural businesses while wasting taxpayer dollars that could be better spent on the real problems we face in controlling animal disease, food security, and food safety.
Family farmers and ranchers cannot afford additional paperwork and unnecessary expenses. Please help protect our farms and our right to own animals by submitting your comments today!
TAKE ACTION: You can submit comments either online or by mail.
The government’s online system can be difficult to navigate and there is a time limit. We encourage you to write your comments and save them in a document on your computer, then copy and paste them into the online comment form. Also, although only some of the information fields are marked as being “required,” some people have experienced problems when they left fields blank. So for the fields that are not required, you may wish to put “NA” (not applicable) in them to avoid potential problems.
BY MAIL: Docket No.APHIS–2009–0091, Regulatory Analysis and Development, PPD, APHIS, Station 3A–03.8, 4700 River Road Unit 118, Riverdale, MD 20737–1238
DEADLINE: Friday, December 9, 2011.
Please also send a copy of your comments to your Congressman and Senators. If you don’t know who represents you, you can find out at www.house.gov and www.senate.gov
Here are talking points you can use for your comments, followed by sample comments and more detailed information.
TALKING POINTS:
1) The agency should withdraw the proposed rule. If the export market would benefit from the proposed rule, as the agency claims, then the agribusinesses that export meat should pay the costs and offer economic premiums to livestock producers to encourage them to participate in a voluntary system.
2) The agency needs to identify the specific diseases of concern and analyze how to best address those diseases — including prevention measures — rather than continuing to push a one-size-fits-all tracking program.
3) Significant problems with the proposed regulation include:
  • Imposition of new requirements for identifying chickens and other poultry. Small farmers and backyard poultry owners should not be burdened with identifying and tracking birds, and the agency has not shown any need to impose these new requirements.
  • Applying the new identification requirements to feeder cattle.
  • Applying the requirements to direct-to-slaughter cattle, including both for custom and for retail sales.
  • Not recognizing brands and tattoos as official forms of identification.
SAMPLE COMMENTS: Please personalize these sample comments rather than doing a form letter. The personalization can be just a few sentences at the beginning of the comments, but it does make a significant difference. And if you have time to write more detailed comments, that’s even better!
Dear Secretary Vilsack:
I am a __________________ (farmer, local foods consumer, backyard poultry owner, horse owner, etc.). I am very concerned that the proposed rule will __________ (not be workable for my farm; impose costs on my farmers that will then be passed on to me; make it prohibitively expensive for me to order baby chicks from out-of-state hatcheries; etc.)
I urge the USDA to withdraw the proposed rule. If the export market would benefit from the proposed rule, as the agency claims, then the meat packing companies that export meat should pay the costs and offer economic premiums to livestock producers to encourage them to participate in a voluntary system. For disease control, the agency needs to focus on preventative measures rather than after-the-fact tracking.
There are significant problems with the proposed rule:
  • The imposition of new requirements for identifying chickens and other poultry. Small farmers and backyard poultry owners should not be burdened with identifying and tracking birds, and the agency has not shown any need to impose these new requirements.
  • Applying the new identification requirements to feeder cattle.
  • Applying the requirements to direct-to-slaughter cattle, both for custom and for retail sales.
  • Not recognizing brands and tattoos as official forms of identification.
Sincerely,
Name
Address
City, State Zip
MORE INFORMATION
The program is fundamentally flawed because it is not designed to address the real problems we face, and it imposes burdens on producers for the benefit of Big Agribusiness’ export markets.
We have asked USDA for data showing where the problems are in tracking animals currently. Rather than provide that data, USDA hand-picked a few anecdotes, out of the millions of animals in this country. But the agency’s unsupported claims do not justify imposing broad new tracking requirements. Small farms are not the source of most disease problems in this country, yet the proposed rule will burden them unfairly.
POULTRY: Small-scale, pastured, and backyard poultry will be particularly hard hit by the proposed rule. While the large confinement operations will be able to use “group identification,” the definition of the term does not cover most independent operations. Since thousands of people order baby chicks from hatcheries in other states, these birds cross state lines the first day of their lives. Even if the farmer or backyard owner never takes the bird across state lines again, they will have to use individually sealed and numbered leg bands on each chicken, turkey, goose, or duck to comply with the language of the proposed rule.
Even if the definition of “group identification” were changed to cover small operations, the result would be new paperwork requirements on almost every person who owns chickens, turkeys, or other poultry. The agency has entirely failed to justify imposing these burdens on poultry owners.
CATTLE: Along with new identification requirements imposed on all breeding-age cattle, the proposed rule would require identification and paperwork on calves and young cattle (“feeder cattle”), even though there’s no evidence that such requirements will help disease control. In addition, veterinarians and sale barns will have to keep records for 5 years, even though many of these cattle will have been consumed years earlier, creating mountains of useless paperwork.
Producers will only be able to use brands or tattoos as identification if their States enter into special agreements. State agencies will have to build extensive database systems to handle all of the data, creating problems for States’ budgets.
HORSES: The proposed rule also requires that horse owners identify their animals before crossing state lines. Although most, if not all, horses that are shipped across state lines are already identified in some fashion, the proposed rule creates a new complication: Whether or not a physical description is sufficient identification will be determined by the health officials in the receiving state, leaving vets and horse owners struggling with significant uncertainty as they have to anticipate what will be allowed.
SHEEP, GOATS, and HOG: The draft rule also covers sheep, goats, and hogs that cross state lines, essentially federalizing the existing programs which have been adopted state-by-state until now.
FOR MORE INFORMATION, go to www.farmandranchfreedom.org/Animal-ID-2011

PMB #106-380 4200 Wisconsin Avenue, NW – Washington, DC 20016 US

The Denver Post

As USDA turns to ear tags over brands, cattle ranchers fear end of tradition

Ordway rancher John Reid holds some of the irons he uses to brand livestock on his ranch, the Reid Cattle Co. The USDA is expected to release new interstate rules requiring individual cattle to be identified by a number stamped on an ear tag. (Aaron Ontiveroz, The Denver Post )

The future of the hot-iron brand, an icon of Western heritage, is at the center of a nearly decade-long battle over cattle identification and traceability.

“It’s the latest hot lightning rod,” said John Reid, an Ordway rancher who is past president of the Colorado Independent Cattle Growers Association.

The U.S. Department of Agriculture is expected soon to release a draft of new regulations, which will remove the hot-iron brand from its list of official identification for cattle sold or shipped across state lines.

The new rules will require each animal to be identified by a number stamped on a removable ear tag.

States would still be able to use brands as official IDs within their boundaries.

Individual agreements between states can be reached to allow brands as official IDs for interstate movement — more complications.

Critics fear this is the beginning of the end for America’s centuries-old branding tradition.

“The federal government’s action sends a signal to the entire industry that the ear tag is a superior means of identification,” said Bill Bullard, chief executive of the Ranchers-Cattlemen Action Legal Fund.

Ranchers argue that ear tags can fall off or be stolen by thieves, so are not a good form of official ID.

State brand commissioner Rick Wahlert said nothing will change for the state’s cattle producers.

However, the new system is a critical element of participation in the interstate beef market, he said.

Negative reaction to the new rules, he said, “is really about change, and a fear of the government being in your business.”

Gerald Schreiber, a third-generation rancher in northeastern Colorado, already uses ear tags for identification within the herd but bristles at the new regulations.

“It sounds good on the surface, but anytime you get the Big Brother approach, I don’t trust it,” he said. “The brand has worked for 1000 years, I don’t know why they want to disregard it. In the West, branding is more than just a tradition; it’s our identity as ranches.”

First proposed in 2002, the National Animal Identification System (NAIS) was rolled out in 2004, but flatly rejected in USDA listening sessions by over 90% of the cattle producers.

Producers across the country are skeptical about the new program, which would require radio-frequency ear tags that would let cattle be tracked from slaughterhouse to birth.

Their concerns ranged from potential costs to confidentiality of information, including fears that animal-rights advocates would be able to gain information on ranchers through the use of the federal Freedom of Information Act.

“It got pretty ugly,” said Ordway rancher Reid.

From 2004 to 2009, the USDA spent $142 million on NAIS, according to a Congressional Research Service report to Congress. Because it was a voluntary program, less than 30 percent of cattle producers participated.

In February 2010, the USDA announced it was abandoning NAIS due to mass rejection by livestock producers. Now a new name and a new program has evolved called Animal Disease Traceability.

Loss of tradition

The draft of the proposed USDA rule was due in April but has been delayed. It is now expected to be released within weeks, followed by a 60- to 90-day period of public comment. It will take an additional 12 to 15 months before the final rule is released.

“Americans want two things,” Rohr said. “They want to know their food is safe, and they have an interest in knowing where their food comes from.”

Still, the plan to remove the hot-iron brand as an official method of ID across state lines has angered Westerners, who worry about a loss of tradition and the addition of more red tape to their businesses.

“The piece of the deal that is awfully hard for producers to understand is that most disease comes from meat processing plants more than individual cattle or cattle herds.” Reid said.

The brand is the oldest and more permanent form of herd identification, while ear tags, with their unique numbers, can easily fall off in brush and trucks where cattle frequent.

“So the question is,” said Reid, “do we need individual ID or is herd ID enough?”

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