The USDA released a draft Business Plan for implementing NAIS 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.

You can read the Business Plan and other documents at http://farmandranchfreedom.org/content/Government-documents
 
Take Action:  Submit comments.  In its release of the Business Plan, USDA stated that it sought comments on the released documents or other aspects of NAIS, so you don't have to limit your comments strictly to the Business Plan.  Send your comments to:  animalidcomments@aphis.usda.gov, or by mail to NAIS Program Staff, USDA, APHIS, VS, 4700 River Road, Unit 200, Riverdale, MD 20737.
 
It's important that people submit individualized comments, not form letters.  Talking points are included at the end of this alert, to help you develop your comments.
 
Take Action #2: Send a copy of your comments to your Representative and Senators.  It is critical that Congress knows that people are notifying USDA of their objections to NAIS and that your Congressmen understand your objections!  You can find contact information for your elected officials at www.congress.org.
 
For more information, contact the Farm and Ranch Freedom Alliance at info@farmandranchfreedom.org or 866-687-6452.

Good News In Kentucky and Illinois! 

Kentucky HB 495 has passed the legislature!  The bill has been sent to the Governor, the final stage in the process.  This bill would limit the agency to a voluntary program unless the USDA takes final action in accordance with the Administrative Procedures Act.  HB 495 also includes important protections against coercion, so that people cannot be forced into a so-called voluntary program.  For more information, go to http://farmandranchfreedom.org/content/kentucky-2008

Illinois HB 5776 passed the House unanimously and has been assigned to the Rules Committee in the Senate.  This bill would reverse the Illinois Department of Agriculture's current policy of requiring NAIS registration for state fairs, and would provide an explicit right to withdraw from the program.  For more information, go to http://farmandranchfreedom.org/content/illinois-2008

Talking Points on Draft Business Plan

You can find the draft Business Plan on the USDA's website or at http://farmandranchfreedom.org/content/Government-documents  Below are some talking points on the problems with the document.  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.

    * One of the fundamental problems is that USDA starts with the assumption that NAIS is a positive program, and the only question is how to implement it.  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.
    * USDA continues to ignore lower cost and less burdensome options.  Although it mentions the "bookend" approach (p.12), 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 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 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, North Carolina and elsewhere.  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.
    * 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."

Help stop NAIS by educating your community!  Download materials to put out at your local feed store, sales barn, farmers market, or co-op.  You can find materials on the Take Action page of our website, http://www.farmandranchfreedom.org/content/take-action.

Sincerely,
 

Judith McGeary
Farm and Ranch Freedom Alliance
www.farmandranchfreedom.org
866-687-6452