Personalize these sample comments for the greatest effect!  

Re: Docket No. APHIS-2009-0027

Dear Secretary Vilsack:

I urge the USDA to stop implementation of the National Animal Identification System (NAIS).  I am a _______________________ [state who you are – a farmer, consumer, or horse owner -- and why you care about this issue]    The NAIS is fundamentally flawed for multiple reasons:

1) No significant benefits: USDA’s assertions that NAIS will provide benefits for animal health are not supported, and actually contradict basic scientific principles.   Disease must be addressed on a species-specific basis, with an understanding of the causes of the different diseases and the ways the diseases are transmitted. A one-size-fits-all program is useless.

2) 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.

3) 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.  The USDA’s recently released cost-benefit analysis severely underestimated the costs to small farmers, homesteaders, and pet owners.  Even so, the study acknowledged that the cost to people with just a few animals would be significantly higher than the costs to large producers.  This is an inherently unfair program that will favor factory farms over family farms.   

4) Unworkable and intrusive:  Tracking over a hundred million animals at millions of farms and homes is not feasible.  The databases to register the properties, identify each animal, and record billions of “events” will dwarf any system currently in existence.   Moreover, requiring individuals to submit information about their homes, property, and movements to a database makes each person vulnerable to accidental release of the information, hackers, and misuse by commercial interests. 

5) Diverts resources from better alternatives.  Instead of NAIS, I encourage USDA focus on disease prevention through vaccination and improved animal husbandry practices, and disease detection in currently uninspected livestock imports.

For all of these reasons, I urge the USDA to stop implementation of the NAIS.

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