Browsing Posts tagged cattle producers

R-CALF United Stockgrowers of America

 

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

 

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

December 23, 2011                                                                                          Phone: 406-252-2516; r-calfusa@r-calfusa.com

 

10 Days of Opposition to USDA’s Proposed Mandatory Animal Identification Rule:  Part X of X-Part Series

Billings, Mont. – Today’s news release is the final installment of the 10-day series in which R-CALF USA 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 it has brought 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 X:  APHIS’ Proposed Rule Is Based on False Information Regarding the U.S. Cattle Industry and Is an Affront to the Hard Working Men and Women in the U.S. Cattle Industry

  1. Additional Concerns Regarding APHIS’ Proposed Rule
  1. 1.      APHIS’ proposed rule is functionally deficient because it is silent on producer liability.

The proposed rule fails to address one of the most critical concerns raised by thousands of cattle producers during USDA’s NAIS listening sessions. That critical concern was producer liability. Under APHIS’ proposal, which is a book-end identification system, the person who applied the animal’s tag likely would be the primary suspect in any disease traceback, even if he/she sold the animal years earlier and the animal was later comingled with higher-risk Mexican cattle or trader cattle on multiple occasions. As a primary suspect, the original ear-tagger likely would bear the cost of testing and retesting his/her entire herd. This is unacceptable and APHIS has not even attempted to estimate the tremendous cost that U.S. cattle producers likely would bear as a result of APHIS’ proposed rule.

  1. 2.      APHIS’ proposed rule will significant disrupt interstate commerce by prohibiting the use of back tags on cattle destined for slaughter.

USDA’s proposed rule will significantly increase the cost of interstate movement by disallowing the use of expedient back-tags for cattle destined for slaughter. Back tags are a proven, effective, humane and expedient means of identifying cattle destined for slaughter and the elimination of this device will disrupt commerce, increase animal injuries, and add unnecessary cost to an industry incapable of passing additional costs to those that may benefit from USDA’s new imposition on cattle producers.

  1. 3.      APHIS justifies its proposed rule based on false cattle industry information and information that is too broad and ambiguous to meaningfully inform decision makers.

R-CALF USA remains concerned that APHIS continues to not only ignore the unique characteristics of the U.S. cattle industry, but also, it continually presents misleading information to the public. For example, APHIS’ supporting documents for the proposed rule states:

Although the total cattle inventory fell by 15 percent between 1979 and 2009, commercial beef production grew by 22 percent. The decline in cattle inventory has been offset by a 23 percent increase in the average dressed weight of federally inspected cattle.

APHIS, fails to inform the public that the 22 percent growth in beef production between 1979 and 2009 also was due to the influx of imported live cattle that were subsequently slaughtered in the U.S., with their resulting beef added to the United States’ commercial beef production. Live cattle imports from Mexico and Canada increased by 1,269,560 head between 1979 and 2009. Based on the average carcass weight in 2009 of 748 pounds, those imported cattle contributed about 950 million additional pounds to commercial beef production.  !

Commercial beef production increased from 21.262 billion pounds to 25.966 billion pounds between 2007 and 2009.  This represents about a 4.7 billion pound increase during that period. However, nearly one billion pounds (about 950 million pounds) of that increase was attributable to beef derived from imported cattle.  Therefore, the growth in commercial beef production attributable to increased dressed weights was less than 18 percent while the contribution of imports to that growth was 20 percent, i.e., beef from imported cattle accounted for approximately 20 percent of the growth in domestic beef production between 2007 and 2009.

Thus, APHIS’ assertion that the decline in cattle inventory has been offset by a 23 percent increase in the average dressed weight of federally inspected cattle is false. APHS would have been accurate to state, however, that 1.2 million head of the U.S. mother cow herd had been offset by the growth in imported cattle, which increased by 1.2 million head between 1979 and 2009.

Also, and as mentioned previously, APHIS describes the U.S. cattle industry as one in which the average number of cattle per cattle operation has increased to nearly 100 head for all cattle operations. This description fails to recognize, describe, or disclose the profound, segmented nature of the U.S. cattle industry. For example, in 2010 the average size of the U.S. beef cow herd was fewer than 42 head per herd; the average size of the U.S. dairy herd was 146 head; the average number of cattle in the 75,000 remaining farmer feedlots with capacities of less than 1,000 head was only 34 head per feedlot; and, the average number of cattle in the 2,140 commercial feedlots! with capacities of more than 1,000 head was 5,380 head per feedlot.

This information provides a far more accurate description of the U.S. cattle industry and provides far more valuable information to people making decisions that impact the U.S. cattle industry. R-CALF USA urges APHIS to be truthful and accurate when representing the U.S. cattle industry so as to avoid the propagation of erroneous information that invariably leads to bad public policy, such as APHIS’ proposed rule now under consideration.

  1. Conclusion.

There is absolutely no need for a federally mandated animal identification system. The 50 states already have animal health import and export rules that rely upon and reference existing official animal identification devices. If USDA wishes to assist the 50 states and the nation’s tribes to improve disease traceability, it should work in cooperation with the states, tribes and cattle producers to develop best practices guidelines for the import and export of cattle among and between the states and tribes and assist those states and tribes in developing specific programs that work best for them.

For all the foregoing reasons APHIS’ one-size-fits-all proposed rule is, at best, an absolute boondoggle and must be immediately withdrawn. If APHIS does not immediately withdraw the proposed rule, the U.S. cattle industry will suffer irreparable harm.

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 20, 2011                                                                                          Phone: 406-252-2516; r-calfusa@r-calfusa.com

 

8 Days of Opposition to USDA’s Proposed Mandatory Animal Identification Rule:  Part VII 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 VII:  APHIS’ Proposed Rule Discriminates Against Brand Inspection States and Brands

  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. USDA-APHIS has deceived U.S. cattle producers by proposing to remove brands from the list of official animal identification devices or methods.

APHIS’ proposal in the proposed rule to delist the hot-iron brand accompanied by a certificate from a recognized brand authority as an official form of animal identification constitutes a broken promise made by USDA to U.S. cattle producers.  In February 2010, USDA stated in regard to its new animal disease traceability framework, which has materialized into the proposed rule:

USDA will maintain a list of official identification devices, which can be updated or expanded based on the needs of the States and Tribal Nations. There are many official identification options available, such as branding, metal tags, RFID, just to name a few (EXHIBIT 10). (Emphasis added.)

Cattle producers have been outright deceived by USDA due to APHIS’ proposal to remove brands from the list of official identification devices or methods. The construction of the above sentence, along with the usual and customary meaning attached to its words and phrases, unambiguously implies that brands will remain an official identification option on USDA’s list of official identification devices or methods. Only under a perverted interpretation of that sentence could it mean otherwise.

The consequence of APHIS’ action strips from the states and tribes the option to decide to continue relying upon the brand accompanied by a brand certificate from a recognized brand authority to identify livestock. This reduces flexibility for states and tribes to adopt a system that works best for them. In addition, it strips from individual producers within each state the flexibility to decide to continue their reliance on the brand, which flexibility each individual producer could influence by persuading their respective states’ elected officials.

Under the proposed rule, however, the decision to use brands must be made jointly by two or more states or tribes. Thus, any single state or tribe would be subject to decisions made outside their jurisdiction regarding their ability to use brands for identification. This is an affront on state sovereignty. Moreover, the rights of individual cattle producers in a brand state to continue relying upon their brands would be subject to the decisions made in other states, over which they would have no control.

And, the proposed rule would effectively discriminate against cattle producers in states with mandatory brand inspection programs, which are funded in whole or in part by producer fees, by not reimbursing the producers for the cost of brand inspection fees paid when those producers leave the jurisdiction of their brand inspection authority, which generally is the state’s border, when they are required by APHIS to apply a new form of animal identification.  If APHIS does not reimburse producers that are required by their respective state to obtain a brand inspection before leaving their state, and if APHIS nevertheless requires them to incur the cost of applyi! ng a second form of identification (i.e., requires them to apply an ear tag in addition to their preexisting brand), then APHIS would effectively financially disadvantage those producers in interstate commerce by the per head cost for their mandatory brand inspection.

At the very least, USDA-APHIS has an absolute moral and ethical obligation to treat U.S. cattle producers honestly and fairly. Stating one thing and doing another is dishonest and unfair. In this case, USDA-APHIS stated one thing and did another without providing any notice to the public that it had deviated from its official commitment. Regardless of any rationalization USDA-APHIS may espouse to defend its deviant action, it has acted dishonestly, unfairly, and deceptively. For this reason alone, USDA-APHIS must restore the brand’s rightful status as an official animal identification device and withdraw its proposed ru! le.

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

 

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

 

R-CALF United Stockgrowers of America

 

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

 

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

December 19, 2011                                                                                          Phone: 406-252-2516; r-calfusa@r-calfusa.com

 

8 Days of Opposition to USDA’s Proposed Mandatory Animal Identification Rule:  Part VI 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 VI:  APHIS’ Proposed Rule Is Unscientific and Discriminates Against Cattle Producers Unlucky Enough to Live in a State Where Major Packers do not Operate Packing Plants.

  1. APHIS’ Proposed Rule Ignores Differences in Risk Inherent to the United States’ Diverse Cattle Industry; Is a One-Size-Fits-All Solution to an Ill-Defined Problem; and, Contradicts APHIS’ Pledge to Manage Animal Health Using a Risk-Based Approach to Trade and Disease Management

APHIS has long advocated that trade-related disease management and domestic disease management be addressed using a scientific, risk-based approach, as opposed to, presumably, a precautionary-based, geopolitical-boundary-based, or one-size-fits-all approach.

APHIS stated in 1997 that its goal “was to create a mechanism to establish regionalized, risk-based import requirements that are consistent with obligations of VS [APHIS Veterinary Services] under the World Trade Organization’s Sanitary and Phytosanitary Agreement (EXHIBIT 20).” (Emphasis added.)

As discussed in Part V of this series, the Deputy Administrator of APHIS represented that APHIS was opposed to the voluntary Beef Export Verification program from its inception. He claimed at the time of its inception that trade decisions should be risk-based and stated in regard to the Beef Export Verification program:

It could have been avoided if there were a more practical, risk-based approach to trade with countries, such as Canada, that have had only isolated occurrences of BSE and have responded aggressively with appropriate mitigation measures. (EXHIBIT 19).

In a July 2007 report by the U.S. Government Accountability Office (GAO) regarding APHIS’ efforts to implement the national animal identification system (NAIS), the GAO stated that APHIS officials told GAO that the agency did not expect that equal levels of involvement in the NAIS across all species “will be necessary, and that new, risk-based participation benchmarks for premises registration, animal ID, and animal tracking may be developed accordingly, which could vary by species.” (EXHIBIT 21, p. 13).

In a July 2009 report describing APHIS’ action plan to address bovine TB, APHIS explained it was proposing to replace the current split-state status system used to address bovine TB with a risk-based approach that imposes movement restrictions that associate with a zone rather than an entire state (EXHIBIT 22, p. 8).

In a September 2010 concept paper for a new approach to address brucellosis, APHIS stated its new approach to managing brucellosis would “employ a flexible risk-based disease management system (EXHIBIT 23, p. 14).”

The foregoing discussion clearly reveals APHIS’ ongoing intention of using a risk-based approach to trade as well as for managing domestic disease issues. The proposed rule, however, is the antithesis to a risk-based approach to either trade or disease management. This is because the proposed rule expressly targets all livestock that are imported and exported among and between each and every geopolitical, state boundary, i.e. it targets livestock engaged in trade between and among each of the 50 states. Thus, the imposition of the proposed rule would be an economic burden on all domestic trade in livestock between and among each state, regardless of the degree of risk associated with livestock from any state.

Not only is the proposed rule void of any risk-based consideration, but also, APHIS’ implementation of the proposed rule would constitute unfair and discriminatory treatment against domestic cattle producers when compared to foreign cattle producers. This is because domestic cattle producers that must cross a state boundary to access a slaughter plant would be required to incur the cost of APHIS’ mandatory animal identification scheme as a precondition to marketing their products into the U.S. beef supply chain. Foreign cattle producers, however, are not required by APHIS, or any other agency of USDA, to participate in any mandatory animal identification scheme as a precondition for marketing their products into the U.S. beef supply chain, regardless ! of whether they must ship cattle across provinces, states, or departments within their respective countries to access a slaughter plant that is eligible to export beef into the United States.

Thus, the proposed rule would financially disadvantage certain U.S. cattle producers who have no option other than to cross a state line to access a slaughter facility while the U.S. cattle producers’ competitor – foreign cattle producers – remain unencumbered by any U.S. requirement to meet the same standards as a precondition for marketing the beef commodity in the U.S. beef supply chain.

Further, the proposed rule discriminates against U.S. cattle producers who must cross state boundaries to access a U.S. slaughter plant when compared to U.S. cattle producers that reside in a state with one or more slaughter plants. Because only those producers who must cross state lines to access a slaughter plant would be compelled to bear the cost of an APHIS-mandated animal identification scheme, U.S. producers who do not need to cross state lines to access a slaughter plant would be accorded an economic advantage in the U.S. beef supply chain by not having to comply with APHIS’ mandatory animal identification scheme.

The effect of the proposed rule, therefore, would be to financially discriminate against every U.S. cattle producer who is not lucky enough to conduct his or her cattle business in one of the few states in which the handful of remaining meatpackers have decided to set-up a slaughter plant. For example, If Cattle Feeder A is equidistant from a slaughter plant as Cattle Feeder B, but Cattle Feeder A must cross a state boundary to access the slaughter plant, then APHIS’ proposed rule has accorded Cattle Feeder B upwards of a $27.00 per head financial advantage in the marketplace because APHIS’ proposed rule would not require Cattle Feeder B to pay the mandatory cost of identifying cattle.

APHIS’ proposed rule is oblivious to the fact that known disease reservoirs (including wildlife and foreign countries) and locations where cattle are comingled are the most likely and second most likely, respectively, source of a potential disease outbreak. The location where breeding-age cattle are comingled with known disease reservoirs and with imported cattle should be the origination point for any form identification program, not at the point where a farmer or rancher ships cattle interstate. An interstate shipment of breeding-aged cows from a closed herd is least likely to be the subject of a disease investigation. USDA’s proposed rule completely ignores this fundamental and science-based principle. Only by issuing best practices guidelines and working with the states to assist them in developing a program that works best for t! hem can USDA even hope to achieve a science-based and functional disease-traceback program for the entire United States.

The foregoing discussion demonstrates that APHIS’ proposed rule, which imposes a requirement to incur the cost of mandatory animal identification based solely on whether livestock cross a state boundary, which requirement is oblivious to whether or not the livestock originate from an area of negligible risk or high risk for any disease, would financially advantage some cattle producers while financially disadvantaging many others. As a direct consequence, the proposed rule would interfere with domestic commerce by financially discriminating against cattle producers based solely on where they live in the United States, and those that would be discriminated against when compared to domestic cattle producers also would be discriminated against when compared to foreign cattle producers.

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

 

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

 

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.

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

R-CALF United Stockgrowers of America

“Fighting for the U.S. Cattle Producer”

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

December 14, 2011                                                                                                                                                                                             Phone: 406-252-2516; r-calfusa@r-calfusa.com

R-CALF USA’s Opposition to USDA’s Proposed Mandatory Animal Identification Rule:  Part I of VIII-Part Series

Billings, Mont. – As promised, R-CALF USA today launches 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 I:  By Shirking its Responsibility Under the U.S. Animal Health Protection Act to Prevent the Introduction and Spread of Foreign Animal Diseases, APHIS Is now a Leading Cause, if not the Leading Cause, of Livestock Disease Problems Experienced in the United States

  1. APHIS’ Failure and Refusal to Properly Prevent the Introduction and Spread of Foreign Animal Diseases Belies APHIS’ Claim that the Proposed Rule Is Needed to Support Efforts by U.S. Cattle Producers to Protect their Herds from Disease

APHIS’ ongoing policy of willfully and knowingly allowing the perpetual and extensive introduction and reintroduction and subsequent spread of the very diseases APHIS identifies as justification for the proposed rule, e.g., bovine spongiform encephalopathy (BSE), bovine tuberculosis (TB), and bovine brucellosis (brucellosis), is indefensible, unconscionable, and constitutes outright defiance of the agency’s statutory obligation to protect U.S. livestock from the introduction and spread of foreign animal disease.

Further, APHIS’ ongoing policy of willfully and knowingly exposing U.S. livestock to an increased risk of foreign animal disease introduction, e.g., the risk of introduction of foot-and-mouth disease (FMD), is equally indefensible, unconscionable, and likewise constitutes outright defiance of the agency’s statutory obligation to protect U.S. livestock from the introduction and spread of foreign animal disease.

Specific examples of APHIS’ failure and refusal to prevent the introduction and spread of foreign animal diseases, along with examples of its actions to expose U.S. livestock to a heightened risk for disease, are enumerated below.  The following list clearly demonstrates that APHIS is a leading cause, if not the leading cause, of livestock disease problems experienced in the United States. Because APHIS is a leading cause, if not the leading cause, for ongoing animal disease outbreaks in the United States, its claimed intent within the proposed rule to protect the safety of U.S. livestock is both baseless and absurd.

Despite having conducted a 2006 quantitative risk evaluation for BSE that predicts the U.S. would import 19 to 105 BSE-infected Canadian cattle, resulting in 2 to 75 infections of U.S.-born cattle over the next 20 years pursuant to USDA’s over-30-month rule (OTM Rule) (EXHIBIT 1, p. 53347); and, despite a July 2008 court-ordered injunction directing APHIS to reopen the OTM Rule and “revise any provision of the OTM Rule it deems necessary (EXHIBIT 2, p. 21); and, despite the detection of 12 BSE infected Canadian cattle that meet the OTM Rule’s age requirement for importation into the United States (including the February 2011 case of BSE detected in a Canadian cow), APHIS continues to ignore the fully expected, continual reintroduction of Canadian BSE into the United States.

Despite having full and complete knowledge of a 2006 report by USDA’s Office of Inspector General (OIG) that states 75 percent of bovine TB cases detected in U.S. slaughtering plants originated in Mexico (EXHIBIT 3, pp. 19, 20); and, despite the OIG’s other findings that, “These infected animals were identified in 12 different States” and “animals of Mexican origin spent up to 14 months at U.S. farms before going to slaughter, with each case potentially spreading the disease” (EXHIBIT 3, pp. iii); and, despite APHIS’ own report that states, “From 2001 through February 2009, 236 out of 329 slaughter cases were traced to Mexico,” which means nearly 72 percent of all TB cases detected at slaughter were caused by APHIS’ inadequate import restrictions for Mexican cattle imports (EXHIBIT 4, p. 62); and, despite APHIS’ own finding that states, “Each year 1-2 infected animals per 100,000 animals imported from Mexico are identified [as bovine TB-infected] through slaughter detection or epidemiologic investigations (EXHIBIT 4, p. 1);” and, despite repeated requests by R-CALF USA for immediate action to address this willful introduction of bovine TB into the U.S. cattle herd, APHIS continues to cause the annual introduction and spread of bovine TB by failing to implement adequate import restrictions for Mexican cattle.

Despite having full and complete knowledge that Canadian cattle imports introduce bovine TB into the U.S. as evidence by three bovine TB-infected cattle imported into the U.S. from Canada in 2008, with a total of five TB-infected Canadian cattle detected in the U.S. during the past seven years (EXHIBIT 4, pp. 61, 62), and, despite R-CALF USA’s request that APHIS address this known disease source, APHIS continues to cause the introduction of bovine TB from Canadian cattle by failing and refusing to adequately strengthen U.S. import restrictions for Canadian cattle.

Despite having full and complete knowledge that the 11 factors used by the agency to determine the potential risk for foot-and-mouth disease (FMD) outbreaks in both entire countries and regions within a country are wholly incapable of predicting actual FMD risks (as was definitively proven following APHIS’ FMD risk evaluations for Uruguay, Argentina, the Republic of South Africa, and South Korea.), APHIS nevertheless persists in its efforts to apply the same, failed 11 factors to facilitate imports into the United States of beef and cattle from FMD-affected countries, notably from the Patagonia South Region of Argentina and Santa Catarina, Brazil.

Despite having full and complete knowledge that the relocation of the Plum Island, N.Y., research facility to Manhattan, Kansas, will increase the risk of FMD exposure for U.S. livestock, APHIS, in cooperation with the U.S. Department of Homeland Security (DHS), proposes to transfer live FMD viruses and research on live FMD viruses to the U.S. mainland.  APHIS and DHS propose this relocation despite full knowledge that: 1) there is no support for the contention that FMD research can be done as safely at Manhattan, Kansas, as at Plum Island, N.Y. (EXHIBIT 5, p. 46); 2) Plum Island is the only location determined to be of low risk with respect to the likelihood of FMD infection (EXHIBIT 5, p. 42); 3) “Plum Island’s lack of animals placed it at an advantage with respect to the likelihood that FMD virus would become established after being released and spread from the site (EXHIBIT 5, p. 42);” 4) Manhattan, Kansas, is in an area “where the virus would have ample opportunity to spread rapidly after release because of the presence of susceptible livestock and wildlife (EXHIBIT 5, p. 42); and, 5) “for all sites except Plum Island, the wind could potentially transport viral pathogens significant distances and that this pathway is not limited for them, as it is on Plum Island” (EXHIBIT 5, p. 42).

The foregoing discussion reveals and documents that APHIS is a leading cause, if not the leading cause, for the continual introductions and spread of foreign animal diseases by failing and refusing to comply with its statutory responsibility to prevent the introduction and spread of foreign animal diseases. The diseases APHIS is causing to be introduced and spread in the United States include the very diseases claimed as justification for its proposed rule. APHIS’ proposed rule would burden each and every U.S. cattle producer that moves cattle interstate by mandating the individual identification of their cattle. APHIS could not be more disingenuous in its claim that the proposed rule is intended to support U.S. cattle producers in their effort to protect their cattle herds from disease when APHIS itself is actively facilitating the introduction of dangerous foreign animal diseases

APHIS’ actions are akin to the hideous and unlawful scheme of organized crime to rob business owners of their money and then offer to mitigate the affect of their robberies in exchange for regular payments from the business owners, while making no commitment to prevent others from continually robbing their businesses. Like those victimized business owners, U.S. cattle producers have no moral or ethical obligation to pay the cost of mitigating diseases in the United States that are directly caused by APHIS’ recalcitrance, and they should have no legal obligation either.

If APHIS proceeds in any way other than to immediately withdraw it proposed rule, it must thoroughly and comprehensively explain to U.S. livestock producers why it is planning to burden them with the cost of a mandatory animal identification system to control diseases that APHIS is willfully and knowingly allowing into the United States each year in direct defiance of its statutory responsibility under the AHPA.

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

August 9, 2011 Phone: 406-252-2516; r-calfusa@r-calfusa.com

USDA Spurns U.S. Cattle Industry: Issues Overreaching, Intrusive Mandatory Animal Identification Rule

Billings, Mont. — In direct defiance of fundamental recommendations to preserve branding as a means of official animal identification and to not include cattle less than 18 months of age in any national animal identification system made by R-CALF USA and several other U.S. livestock groups, the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service (APHIS) today released an early version of its proposed rule to implement a national animal identification system titled “Traceability for Livestock Moving Interstate” (proposed rule).

The proposed rule would remove the hot-iron brand from among the list of official identification devices that cattle producers could choose to comply with the new federal mandate. It also encompasses cattle less than 18 months of age that would be triggered at USDA’s discretion one-year after USDA determines that older-aged cattle are substantially identified.

“The proposed rule, expected to be published in tomorrow’s Federal Register, not only spurns the U.S. livestock industries key recommendations regarding the hot-iron brand and younger cattle, but also, it snubs the critical recommendation by Agriculture Secretary Tom Vilsack’s own Advisory Committee on Animal Health, which urged the Secretary to provide at least a 120-day public comment period for the proposed rule. Instead, Vilsack is only providing a 90-day public comment period,” said R-CALF USA CEO Bill Bullard.

Bullard said the 90-day comment period will run at a time when tens of thousands of livestock producers are battling perhaps the nation’s most widespread and devastating drought and coincides with the cattle industry’s busy calf-weaning and calf-shipping season.

According to Bullard, USDA’s rejection of its own advisory committee’s recommendation to give producers more time to respond to the 114-page proposed rule suggests it already has decided to force this unacceptable mandate on U.S. livestock producers.

“USDA is running roughshod over the U.S. livestock industry with its bureaucratic ‘we know better than the entire industry’ attitude,” said Bullard adding, “USDA officials have deceived livestock producers by pretending to seriously consider producer recommendations and then springing these unworkable and unacceptable mandates on us in its proposed rule.”

“It’s obvious that USDA did not listen to the multitude of U.S. livestock producers who participated in the agency’s nationwide NAIS (National Animal Identification System) listening sessions in 2009 and overwhelmingly opposed USDA’s efforts to force individual identification on younger cattle and any mandate that would limit a producer’s choice regarding how they identify their livestock,” said R-CALF USA President George Chambers.

Chambers said his group will be calling for new listening sessions to help USDA recall the serious concerns producers raised earlier but have since been either forgotten or ignored.

Chambers said the proposed rule severely restricts producer choices because it removes completely the option for a producer to unilaterally choose to continue using the hot-iron brand when shipping cattle across state lines.

“Under the proposed rule, individual producers cannot choose on their own to continue using the hot-iron brand to identify their cattle. Nor can an individual state on its own choose to identify the cattle leaving their state with a hot-iron brand. Only if two state governments mutually agree to use the now delisted hot-iron brand will that option be available to either U.S. cattle producers or individual states,” Chambers said.

He continued to explain, “USDA did not have to attack our industry’s hot-iron brand or add younger cattle to the proposed rule in order to improve animal disease traceability in the United States, but we believe it has chosen to do so to appease the World Trade Organization and other international tribunals.”

Chambers also explained that the proposed rule itself provides absolute proof that the hot-iron brand remains an effective means of identifying animals in interstate commerce:

The proposed rule expressly allows producers to use hot-iron brands on their horses when shipping across state lines. This provision completely obliterates USDA’s feeble argument that it cannot require the 36 non-brand program states to accept a registered brand originating in the 14 brand program states as an official identification device — that’s precisely what USDA is doing with horses. It’s clear USDA is misleading us to achieve some ulterior motive.

“This proposed rule reduces flexibility and reduces producer choices and we are urging U.S. livestock producers to aggressively oppose the proposed rule,” Chambers concluded.

The public can submit comments on the proposed rule by either of the following methods:

– Federal eRulemaking Portal: Go to

http://www.regulations.gov/#!documentDetail;D=APHIS-2009-0091-0001.

– Postal Mail/Commercial Delivery: Send your comment to Docket No. APHIS-2009-

0091, Regulatory Analysis and Development, PPD, APHIS, Station 3A-03.8, 4700 River

Road Unit 118, Riverdale, MD 20737-1238.

# # #

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. R-CALF USA represents thousands of U.S. cattle producers on trade and marketing issues. Members are located across 46 states and are primarily cow/calf operators, cattle backgrounders, and/or feedlot owners. For more information, visit www.r-calfusa.com or, call 406-252-2516.

Note: The Proposed Rule can be viewed at http://r-calfusa.com/animal%20id/110809USDAProposedRule.pdf

Note: To remove yourself from this list, reply to this e-mail and include the word “unsubscribe” in the subject line.

 

USDA wanting to end Fire Branding as means of ID

We should have known this would happen! Now USDA is planning to de list the hot-iron brand from the list of “official animal identification devices.” As all cattle producers know, the hot iron ID and holding brand system is the basis of historic permanent ID. If the federales oppose hot iron branding it could easily be assumed that PETA and other animal rights wackos will grab on the coat tails of USDA. A day could come that only the NAIS digital ear tags would be allowed. As with other idiot federal enforcements in the last two years, they can eventually smell egg on their own faces, and to protect their bureaucratic gravy-trains, crawfish backwards and renege their plan.

In the last few years trusted farm and cattle organizations have prostrated with USDA’s pitiful ideas. When they could have opposed bad judgement, they allowed costly enforcements to be enacted and cattle producers pay the price.

Most do not know what USDA is now planning. This is a USDA conspiratorial step to resurrect the flawed-thought of the hated NAIS. You have not been warned about this in the cattle media as they also understand the profitable nature of a passive attitude toward their consistent advertiser, USDA.

Only one organization is on their toes, alert and ready to defend the US cattle producers — R-CALF USA. The attached letter gives the position (not passive) of R-CALF. Each cattle producer should support R-CALF in their efforts to defend producers from USDA’s cumbersome-costly and ominous regulations, like delisting hot iron branding. Every professional producer understands the value of fire branding for permanent ID and prevention of cattle thefts.

If you are a USA citizen and cattle producer, it is very profitable to join and support R-CALF. Attached is a membership application.

Why R-CALF USA Opposes USDA Proposal to Delist Brands

The hot-iron brand is part-and-parcel to the culture and heritage of the U.S. cattle industry. In addition, the U.S. Department of Agriculture (USDA) has long recognized the importance of the brand as a permanent means of identifying livestock, not only for determining ownership, but also for conducting disease investigations. USDA regulations concerning interstate transportation of animals include the registered brand, when accompanied by a certificate of inspection (certificate) from a recognized brand authority, as an official identification device or method for use in existing disease programs. USDA regulations at 9 CFR 71.1 state:

Official identification device or method. A means of officially identifying an animal or group of animals using devices or methods approved by the Administrator, including, but not limited to, official tags, tattoos, and registered brands when accompanied by a certificate of inspection from a recognized brand inspection authority (emphasis added).

Under USDA’s earlier proposed Animal Disease Traceability Framework (ADTF), breeding-aged cattle would bear an ear tag containing a number identifier (such as the low-cost metal “Brite” tag) as a condition for interstate transportation. This proposal would restore traceability to levels previously achieved when breeding females were ear tagged under the brucellosis program. Like the brucellosis tag, the new tag would augment other official devices such as brands or tattoos. This augmentation enhances traceability because while ear tags are prone to loss, brands remain permanent. Brands have facilitated disease investigations throughout history.

Under this breeding-age-cattle-only proposal, interstate transportation of branded feeder cattle accompanied with a certificate would continue as it has for decades. States that identify a disease suspect in branded feeder cattle, regardless of whether the states have their own brand programs, could continue to use the brand and certificates to contact the state where the certificates were issued to identify the herd of origin – just as they have for decades.

But, USDA has now changed its position and plans to delist the brand as an official animal identification device and include feeder cattle in the ADTF. This would discredit the hot-iron brand as a means of identifying cattle in interstate transportation. Here’s why:
1) The brand and accompanying certificates would forever be delisted as an official animal identification device.
2) USDA may well be precluded from requiring permanent brands on imported cattle after brands are delisted.
3) When the trigger for feeder cattle is reached, the brand and accompanying certificates will be delisted, so USDA would need to carve out a special brand exception to allow states to continue using brands to identify cattle, causing the brand to be relegated to a secondary position in relation to USDA’s ear tag.
4) No longer will the numerical ear tag be an augmentation to the more permanent brand, but instead, the ear tag will be deemed a substitute for brands, providing justification for brand opponents such as meat packers that believe hide values would increase, and tag companies that believe sale revenues would increase, without brands.
5) USDA’s act of delisting brands will send an erroneous signal to the industry that brands are of limited use for disease traceback and likely will trigger a de-emphasis for brand programs operating in many states.
6) USDA’s act of delisting brands would be the first step toward the eventual elimination of hot-iron branding in the United States.

Please Download R-CALF Application and send it in. http://www.texaslonghorn.com/emails/R-CALF_Membership_Application.pdf

Thursday, October 07, 2010

By Chris Neefus

Thomas Dyekman displays branding irons used at his family's ranch in Loveland, Colo. (AP photo/RJ Sangosti)

Washington (CNSNews.com) According to a representative of the cattle and beef industry, America may need a “strategic hamburger reserve” if the Environmental Protection Agency (EPA) implements proposed new reguilations for cattle producers.

“From where I sit, (the Obama administration) appears to be aimed at destroying the cattle industry in America as we know it,” Tamara Thies, the chief environmental counsel at the National Cattlemen’s Beef Association, said on Capitol Hill last week.

“It is ironic that as we work to become less dependent on foreign oil, Obama policies are likely to make us more dependent on foreign beef. Maybe we’ll need to start a strategic hamburger reserve after the Obama administration is finished with us.”

Thies’ comments came at a hearing conducted by the House Republicans’ Rural America Solutions Group about the EPA’s proposed regulations on the industry, which include the toughest dust regulations in history – one which would significantly impact the rural economy by imposing steep fines on cattle producers who, Thies said, most likely cannot afford them.

“It is unlikely these realities are lost on the EPA, making one wonder if the real goal of the agency is to do away altogether with economic activity throughout the bread basket of this country and turn it into a vast national park,” she added.

The forum was held by Reps. Frank Lucas (R-Okla.), ranking member on the House Agriculture Committee; Sam Graves (R-Mo.), ranking member of the House Small Business subcommittee; and Doc Hastings (R-Wash.), ranking member of the House Natural Resources Committee, to consider several of the new proposed EPA regulations.

In a periodic review of its National Ambient Air Quality Standards (NAAQS), which allow the EPA to regulate certain forms of particulate matter in the air, the EPA determined that it might raise the standard so that only 65-85 µg/m3 of dust would be permitted in the air (as opposed to 150 µg/m3). Violating the proposed new NAAQS standards can result in civil penalties under the Clean Air Act.

The EPA published that draft policy assessment in the July 8, 2010 issue of the Federal Register.

“(EPA) is preparing to issue a proposed regulation that is twice as stringent as the current dust standard, and is more stringent than background levels of dust in many parts of the U.S,” Thies told the congressmen.

“Incredibly, we are talking about dust kicked up by tilling fields and harvesting crops, cattle movements, and pickups driving down dirt roads,”she said. “For agriculture, the current standard is already very difficult and costly to meet—doubling it would be virtually impossible.”

That new proposal also alarmed 75 members of Congress who represent rural districts, including Reps. Cynthia Lummis (R-Wyo.), Stephanie Herseth-Sandlin (D-S.D.), John Spratt (D-S.C.), and Bobby Bright (D-Ala.), who sent a letter to EPA Administrator Lisa Jackson on Sept. 27 urging the agency to “refrain from going down this path” on dust regulation.

“Considering the administration’s claim that it is focusing on revitalizing rural America and rural economic development, a proposal such as this would have a significant negative impact on those very goals,” they wrote. “We are hopeful that common sense will prevail and the EPA will refrain from causing extreme hardship to farmers, livestock producers, and other resource-based industries throughout rural America.

“Whether it is livestock kicking up dust, corn being combined, or a pickup driving down a gravel road, dust is a naturally occurring event in rural areas. Common sense requires the EPA to acknowledge that the wind blows dust around in these areas, and that is a fact of life.”

Jackson did not attend the forum on Capitol Hill last week despite receiving an invitation. A spokesperson for the EPA indicated they would have a reaction about why they were proposing these rules in a difficult economy, but did not do so by press time.

The dust regulation is one of several new proposals the EPA is considering, including regulating ammonia emissions from cattle operations; nationalizing standards for soil phosphorus levels, which determine where farmers can use manure; regulating greenhouse gas emissions; and greater regulation of farming on the Chesapeake Bay watershed.

“The fact is, the EPA is waging an unprecedented war to end modern production of animal agriculture,” Thies said in her testimony.

“EPA exhibits reckless indifference to scientific fact and, instead, imposes stringent regulations based on nothing more than its biased anti-animal agriculture agenda that will leave many cattle operations with no recourse but to shut down and eliminate jobs,” she added.

Thursday, October 07, 2010

By Chris Neefus

Thomas Dyekman displays branding irons used at his family's ranch in Loveland, Colo. (AP photo/RJ Sangosti)

Washington (CNSNews.com) According to a representative of the cattle and beef industry, America may need a “strategic hamburger reserve” if the Environmental Protection Agency (EPA) implements proposed new reguilations for cattle producers.

“From where I sit, (the Obama administration) appears to be aimed at destroying the cattle industry in America as we know it,” Tamara Thies, the chief environmental counsel at the National Cattlemen’s Beef Association, said on Capitol Hill last week.

“It is ironic that as we work to become less dependent on foreign oil, Obama policies are likely to make us more dependent on foreign beef. Maybe we’ll need to start a strategic hamburger reserve after the Obama administration is finished with us.”

Thies’ comments came at a hearing conducted by the House Republicans’ Rural America Solutions Group about the EPA’s proposed regulations on the industry, which include the toughest dust regulations in history – one which would significantly impact the rural economy by imposing steep fines on cattle producers who, Thies said, most likely cannot afford them.

“It is unlikely these realities are lost on the EPA, making one wonder if the real goal of the agency is to do away altogether with economic activity throughout the bread basket of this country and turn it into a vast national park,” she added.

The forum was held by Reps. Frank Lucas (R-Okla.), ranking member on the House Agriculture Committee; Sam Graves (R-Mo.), ranking member of the House Small Business subcommittee; and Doc Hastings (R-Wash.), ranking member of the House Natural Resources Committee, to consider several of the new proposed EPA regulations.

In a periodic review of its National Ambient Air Quality Standards (NAAQS), which allow the EPA to regulate certain forms of particulate matter in the air, the EPA determined that it might raise the standard so that only 65-85 µg/m3 of dust would be permitted in the air (as opposed to 150 µg/m3). Violating the proposed new NAAQS standards can result in civil penalties under the Clean Air Act.

The EPA published that draft policy assessment in the July 8, 2010 issue of the Federal Register.

“(EPA) is preparing to issue a proposed regulation that is twice as stringent as the current dust standard, and is more stringent than background levels of dust in many parts of the U.S,” Thies told the congressmen.

“Incredibly, we are talking about dust kicked up by tilling fields and harvesting crops, cattle movements, and pickups driving down dirt roads,”she said. “For agriculture, the current standard is already very difficult and costly to meet—doubling it would be virtually impossible.”

That new proposal also alarmed 75 members of Congress who represent rural districts, including Reps. Cynthia Lummis (R-Wyo.), Stephanie Herseth-Sandlin (D-S.D.), John Spratt (D-S.C.), and Bobby Bright (D-Ala.), who sent a letter to EPA Administrator Lisa Jackson on Sept. 27 urging the agency to “refrain from going down this path” on dust regulation.

“Considering the administration’s claim that it is focusing on revitalizing rural America and rural economic development, a proposal such as this would have a significant negative impact on those very goals,” they wrote. “We are hopeful that common sense will prevail and the EPA will refrain from causing extreme hardship to farmers, livestock producers, and other resource-based industries throughout rural America.

“Whether it is livestock kicking up dust, corn being combined, or a pickup driving down a gravel road, dust is a naturally occurring event in rural areas. Common sense requires the EPA to acknowledge that the wind blows dust around in these areas, and that is a fact of life.”

Jackson did not attend the forum on Capitol Hill last week despite receiving an invitation. A spokesperson for the EPA indicated they would have a reaction about why they were proposing these rules in a difficult economy, but did not do so by press time.

The dust regulation is one of several new proposals the EPA is considering, including regulating ammonia emissions from cattle operations; nationalizing standards for soil phosphorus levels, which determine where farmers can use manure; regulating greenhouse gas emissions; and greater regulation of farming on the Chesapeake Bay watershed.

“The fact is, the EPA is waging an unprecedented war to end modern production of animal agriculture,” Thies said in her testimony.

“EPA exhibits reckless indifference to scientific fact and, instead, imposes stringent regulations based on nothing more than its biased anti-animal agriculture agenda that will leave many cattle operations with no recourse but to shut down and eliminate jobs,” she added.

“So when you are told by the Meat and Livestock Association that our NLIS system is wonderful, or there is full traceability, they are not telling the truth.”

“We have alerted the Government to the situation but they argue the system is still being bedded down. In actual fact the percentage loss of traceability of Australian cattle herds is increasing over time.”


ABA has a beef with tags

Peter Weekes | 26th June 2010

MORE THAN a quarter of the cattle monitored by identification tags  are lost within the complex tracking system that costs $37 a head, a  summit heard yesterday.

At summit: At the Casino conference are Bill Bullard (left), CEO of R-Calf USA Ranches and Cattlemen Association, Australian Beef Association chairman Brad Bellinger, and ABA vice-chairwoman Linda Hewitt.

Doug Eton

MORE THAN a quarter of the cattle monitored by identification tags are lost within the complex tracking system that costs $37 a head, an Australian Beef Association summit heard yesterday.

The ABA’s chairman Brad Bellinger told a Casino meeting, which drew about 70 farmers from as far afield as Perth and Tasmania, the National Livestock Identification System that was foisted on cattle producers was ineffective and ‘potentially dangerous’.

The ABA recently commissioned an audit of 57,000 tags – the largest ever – to find out if the system allowed cattle to be traced back to the farm.

“The audit found 34.5 per cent did not have lifetime traceability,” Mr Bellinger said.

“So when you are told by the Meat and Livestock Association that our NLIS system is wonderful, or there is full traceability, they are not telling the truth.”

“We have alerted the Government to the situation but they argue the system is still being bedded down. In actual fact the percentage loss of traceability of Australian cattle herds is increasing over time.”

Mr Bellinger said the system’s failure was because of producer processes, not transferring cattle on the data base, tags failing out of the animals ears and being replaced by other and faulty reading equipment.

The National Livestock Identification System is Australia’s system for identification and traceability of live-stock. It was introduced in 1999 to meet European Union requirements for exports.

However, Mr Bellinger said the world’s largest beef exporter, Brazil, did not use any identification system.

He said the audit authors of Australia’s system found achieving lifetime traceability was unlikely to be ever achieved.

“To rely on NLIS for credible information to contain a highly contagious disease outbreak would be illusionary and potentially dangerous to the industry,” he said.

Mr Bellinger said the previous system of wrapping the animals’ tail around a tag and the accompanying paper trail was “more than adequate and a lot less costly”.

He also took aim at the industry’s body, the Meat and Livestock Association which has come under growing criticism since it supported the Federal Government’s recent attempts to allow imports of beef from mad-cow affected countries.

Only days before the nation’s boarders were to be opened, Federal Primary Industry Minister Tony Bourke did a back flip and, succumbing to cattle farmers’ demand for a full import risk analysis, effectively placed a two-year moratorium on lifting the import ban.

“After 13 years of an undemocratic meat industry structure, that has been shamelessly supported by both sides of politics, Australian cattle producers have had enough of trying to run enterprises with cattle prices unchanged in the last 20 years,” Mr Bellinger said.

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