Browsing Posts tagged service

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. 

 

# # #

 

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 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.

Powered by WordPress Web Design by SRS Solutions © 2017 National Association of Farm Animal Welfare Design by SRS Solutions