Below are a few Snippets from a recent FTCLDF Newsletter:
Action Alert!!!! Comment Period Closing on NAIS Business Plan!!!
The USDA released a draft Business Plan for implementing NAIS (National Animal Identification System) in December 2007. It left the comment period open, with no end date mentioned. The USDA recently announced that the comment period will close on April 15, one week from today...
...TAKE ACTION #1: Submit Comments. ... Send your comments to:
animalidcomments@aphis.usda.gov ...
...It's important that people submit individualized comments, not form letters. Talking points are included below to help you develop what you would like to say.
TAKE ACTION #2: Send a copy of your comments to your Representative and Senators. It is critical that Congress knows that people are notifying the USDA of their objections to NAIS....
...TALKING POINTS ON DRAFT BUSINESS PLAN...
...Don't be limited by these suggestions! Read the document, write your own comments, and be sure to contact your Congressman as well as the USDA. Please refer to Farm and Ranch Freedom Alliance for more detailed analysis.
* One of the fundamental problems is that the USDA starts with the assumption that NAIS is a positive program, and the only question is how to implement it. The USDA has not addressed the numerous concerns raised by animal owners regarding whether the program is needed or practical.
* The agency still has not provided any scientific evidence to support the program. In particular, the agency has provided no basis for its claim that 48 hour tracking is "optimal" for disease control, the basic premise of NAIS.
* The agency still has not completed a cost-benefit analysis. No business would develop a Business Plan for implementing a program without such an analysis.
* The USDA continues to ignore lower cost and less burdensome options. Although it mentions the "bookend" approach (p.12 of the Bus. Plan), it clearly views this as simply a step along the path to tracking every movement.
* The Business Plan proposes to track every horse that needs a certificate of veterinary inspection or Coggins test when moved (p.26). Because of state regulations, this would include many horse owners who never even go to shows, but who simply go on a local trail ride or take their horses to a breeding facility. The Business Plan also proposes to establish a national Coggins testing requirement, bringing in yet more horse owners.
* The Business Plan proposes using breed registries to implement NAIS (p. 28). This method would create economic coercion on people whose animals would have little economic value without registration.
* The Business Plan makes it clear that the USDA plans to use existing disease control programs to promote NAIS (p. 30). Yet, as with the entire NAIS program, the USDA has failed to show why this change is necessary or cost-effective.
* The USDA confuses the goal of "expanded electronic government" with imposing an electronic-based system on individuals (p. 32). NAIS is not just about government agencies using electronic systems, it is about requiring individuals to use such systems regardless of their objections.
* The USDA continues to promote the cooperative agreements with states (p.36). Yet the USDA has refused to address the problems that have happened because of those agreements, including mandatory or coercive programs being implemented in Wisconsin, Indiana, Michigan, Colorado, Illinois, N. Carolina and elsewhere. The USDA cannot continue to rely on cooperative agreements to implement this unpopular program while avoiding responsibility for the outcomes.
* The species working groups (p.37) are fundamentally flawed. They are largely composed of large industry interests and technology companies, and provide little representation for the millions of small farmers, homesteaders, and pet owners who will be impacted by NAIS.
* The plan to use veterinarians to promote NAIS (p.38) is likely to lead to distrust on the part of many animal owners. Anything that discourages animal owners from seeking help from veterinarians is counterproductive for disease control.
* The USDA ignores the technology problems that have been apparent in trials of the NAIS technology (p. 40). With electronic identification already mandatory in Michigan, animal owners deserve a better answer than feel-good claims that the technology will "continue to improve."
