ANIMAL OWNERS and TAXPAYERS‏


From: Weston A. Price Foundation (info@...)
Sent: Fri 2/13/09 3:01 AM
To: gibbkathy@...

ANIMAL OWNERS AND TAXPAYERS
NAIS ALERT! Protect your right to farm and the food supply!

The USDA has proposed a rule to require all farms where animals are raised to be
registered in a federal database under the National Animal Identification System
(NAIS) for
existing disease control programs. The draft rule covers programs for cattle,
sheep, goats,
and swine. It also sets the stage for the entire NAIS program to be mandated for
everyone,
including anyone who owns even one livestock animal, for example, a single
chicken or a
horse.

It is CRITICAL that the USDA and Congress hear from the hundreds of thousands of
people
who will be adversely affected by the NAIS program. This includes not only
animal owners,
but also consumers who care about local and sustainable foods, taxpayers who
object to
wasteful government programs, and advocates for a safer local food system.

STEP 1: Submit comments to USDA online or by mail. The comments must be received
by
USDA by March 16, 2009.

Submit comments online at:
http://www.regulations.gov/fdmspublic/component/main?
main=DocumentDetail&o=090000648081c664
Click on the yellow balloon next to "add comments."

Or mail two copies of your comments to USDA: Docket No. APHIS-2007-0096,
Regulatory
Analysis and Development, PPD, APHIS, Station 3A-03.8, 4700 River Road Unit 118,
Riverdale, MD 20737-1238. Clearly state that your comments refer to Docket No.
APHIS-
2007-0096.

You can download sample comments at
www.farmandranchfreedom.org/content/files/090202_sample_comments.doc or see the
sample comments at the end of this alert


STEP 2: Send a copy of your comments to your Congressman and Senators.
You can find who represents you, and their contact information, at
www.congress.org

Organic Consumers Association has set up an automated system for folks to submit
comments on the proposed USDA NAIS rule

http://salsa.democracyinaction.org/o/642/campaign.jsp?campaign_KEY=26665

STEP 3: Spread the word! Forward this alert to your friends, neighbors, and any
agriculture
or food-related mail lists you are on. You can also download a flyer and the
sample
comments at http://farmandranchfreedom.org/content/take-action to put out at
local
farmers markets, riding stables, feed stores, etc.

BACKGROUND

The USDA has been working for over five years to force NAIS onto American animal
owners. NAIS is designed to identify and track each and every individual
livestock and
poultry animal owned by family farmers, hobby farmers, homesteaders, and pet
owners
across the country.
USDA claims that NAIS is a disease tracking program, but has refused to provide
any
support for its claims. In reality, NAIS will impose high costs and government
surveillance
on every farmer and animal owner for no significant benefits, and will likely
force many
small producers out of business.

NAIS does nothing to improve food safety for consumers or prevent animal
diseases. This
program is a one-size-fits-all program developed by and for big Agribusiness.
NAIS will
increase consolidation of our food supply in the hands of a few large companies
and put
the brakes on the growing movement toward local food systems.

Despite promises to the contrary, the USDA's new proposed rule would make
portions of
the NAIS mandatory for thousands of people in every state. Anyone who
participates in
federal disease control program for cattle, sheep, goats or swine will have
their premises
registered. The NAIS Premises Identification Number (PIN) will become the only
form of
premises identification acceptable for USDA animal health purposes, with no
opt-out
provision.

The proposed rule would also limit official Animal Identification Numbers to the
NAIS-
compliant 840-numbering system, laying the groundwork for future regulations
that
would limit people's options on the types of tags they could use.

The proposed rule is not final yet. You can help stop it by visiting the Federal
Registry and
making a comment. Go to http://www.regulations.gov/fdmspublic/component/main?
main=DocketDetail&d=APHIS-2007-0096 and click on the yellow balloon under "add
comments." And send a copy of your comments to your elected officials, letting
them
know how you feel about NAIS.

The grassroots movement has already successfully stalled USDA's plans for NAIS,
which
originally called for the entire program - premises registration, animal
identification, and
tracking - to be mandatory by January 2009. The proposed rule is an opportunity
to get
thousands of objections in the formal record, and have an even greater impact.
It is
imperative that people speak up to protect our right to farm and our food
supply!

FOR MORE INFORMATION

Go to www.FarmAndRanchFreddom.org or contact Judith McGeary, 512-243-9404 or
Judith@...


SAMPLE COMMENTS

[Mail two copies to the address below. Or submit comments online at:
http://www.regulations.gov/fdmspublic/component/main?
main=DocumentDetail&o=090000648081c664 ]

Date: ____________________

Docket No. APHIS-2007-0096
Regulatory Analysis and Development PPD, APHIS
Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238

Re: Docket No. APHIS-2007-0096

I urge the USDA to withdraw its proposed rule to implement portions of the
National
Animal Identification System (NAIS), Docket No. APHIS-2007-0096.

I am a _____________________________________________________________________

___________________________________________________________________________
[State who you are - for instance, are you a farmer, consumer, or horse owner --
and why
this issue matters to you]

The proposed rule mandates the NAIS Premises Identification Number (PIN) as the
sole
means of identifying properties for USDA animal health purposes. The proposed
rule also
mandates the use of the NAIS numbering system (i.e. the "840 numbering system")
for
eartags using official animal identification numbers. Tags using other numbering
systems
would be required to be linked to a NAIS PIN.

The draft rule is seriously flawed for multiple reasons:

1) Does not substantiate the alleged benefits to animal health. USDA makes
general claims
about the benefits of identifying locations where animals are kept, but the
agency does
not address the ability of existing programs to meet this purpose, nor how the
proposed
rule would improve the capability to identify locations.

2) Ignores the costs and burdens. The proposed rule would substantially increase
costs for
livestock owners and taxpayers. Costs include the development and maintenance of
a
massive database; purchase of 840-numbered tags by animal owners; changes by
state
agencies to make existing programs consistent with the rule; and increased
federal
government intrusion into the lives and daily activities of farmers and other
animal
owners.

3) Violates individuals' religious beliefs. Amish, Mennonite, and some other
individuals
have religious objections to the universal numbering system under NAIS.

4) Creates disincentives for people to seek veterinary care for their animals
and participate
in existing disease control programs. The proposed rule lists four animal
disease
programs-tuberculosis , brucellosis, scrapie, and Johne's - and will also impact
others.
These programs include provisions for veterinary care through vaccinations and
testing.
Animal owners who object to NAIS may avoid participating in these programs,
thereby
increasing health risks to the public and farm operations.

The proposed rule is a significant step towards implementing the entire NAIS
program.
Thus, the agency should address the fundamental question of whether it should be
implementing NAIS at all. In addition to the problems with the draft rule listed
above, there
are many additional objections to the entire NAIS program:

1) No significant benefits: USDA's assertions that NAIS will provide benefits
for animal
health are not supported, and actually contradict basic scientific principles.

2) High costs for animal owners and taxpayers: These costs include: (1) the
development,
maintenance, and update of massive databases; (2) the costs of tags, most of
which will
contain microchips; (3) the labor burdens for tagging every animal; (4) the
paperwork
burdens of reporting routine movements; and (5) the costs of enforcement on
millions of
individuals.

3) Impracticality: The databases to register the properties, identify each
animal, and
record billions of "events" will dwarf any system currently in existence.

4) Waste of money: The USDA has already spent over $130 million on NAIS
implementation, but has yet to develop a workable plan for the program.

5) Diverts resources from more critical needs such as disease testing, disease
prevention
through vaccination and improved animal husbandry practices, and disease
detection in
currently uninspected livestock imports.

6) Damage to food safety efforts: NAIS will not prevent foodborne illnesses,
such as e. coli
or salmonella contamination, because the tracking ends at the time of slaughter.
Food
safety is better served by focusing on programs such as increased testing for
bovine
spongiform encephalopathy (BSE or Mad Cow), improved oversight of
slaughterhouses and
food processing facilities, and increased inspections of imported foods.
Programs such as
NAIS that burden small, sustainable farmers will hurt efforts to develop safer,
decentralized local food systems

7) Discourages involvement in farming or animal husbandry: Because of costs and
government intrusion, some people will choose not to stay in farming or go into
farming.
This will result in less competition, greater reliance in foreign imports and
poor quality at
higher prices.

I urge the USDA to withdraw the proposed rule to implement portions of the
National
Animal Identification System, Docket No. APHIS-2007-0096.

Sincerely,
Name: ___________________________________
Address: __________________________________
City, State Zip: _____________________________

Additional Comments:

HAVING TROUBLE SUBMITTING COMMENTS?

Some people have reported problems with the online Federal Register comment
process. If
you don't see your comments posted on the website within a few hours, think
about these
issues:

1) Make sure you clicked on the yellow balloon under "add comments" next to the
very
first listed document (the proposed rule). You can also use this link:
http://www.regulations.gov/fdmspublic/component/main?
main=DocumentDetail&o=090000648081c664

2) Be sure to fill out all of the required fields, marked with a red star

3) Submitting attachments with other comments can sometimes cause a problem. If
you
wish to submit a word or pdf document, submit it separately from comments typed
into
the "general comments" field

4) If you don't get a page showing a confirmation number, go back through each
step.

5) Ultimately, you can always submit using the regular mail as an alternative.
Send TWO
copies to:

Docket No. APHIS-2007-0096
Regulatory Analysis and Development, PPD, APHIS
Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238




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