Letter Urging Secretary Vilsack to Extend the Comment Period on Proposed Animal ID Rule

FARFA and 48 other organizations submit a letter urging USDA Secretary of Agriculture Tom Vilsack to extend the comment period on proposed Animal ID rule.

Dear Secretary Vilsack:

The undersigned organizations urge you to extend the public comment period on the proposed rule for animal disease traceability an additional 60 days, until January 8, 2012.

As you are well aware, the proposed National Animal Identification System created widespread opposition across the country. We applauded your decision to withdraw the plans for NAIS in early 2010, but as you are also aware, many people expressed skepticism that the agency would simply re-introduce NAIS under another name.

No traceability program can succeed without the cooperation of animal owners. It is critical that the agency provide sufficient time for animal owners to read the proposed rule closely, understand its implications, and provide meaningful comments regarding its likely impact. Failure to provide this time will both further alienate animal owners and deprive the agency of useful input.

While we recognize that the agency has provided more than the minimum comment period already, the ninety-day comment period in the proposed rule is still insufficient for several reasons:

1) Many of the affected animal owners do not have internet access. According to the 2007 Census of Agriculture, more than 40% of farms do not have internet access. In addition, several of the undersigned organizations have Amish and Mennonite members, who can only be contacted by mail or through print publications. And in turn, any comments from these farmers and ranchers will need to be conveyed to the USDA by US mail. This dynamic greatly extends the amount of time for dialogue to occur in a large percentage of the affected constituency.

2) The months of August, September and October are extremely busy for farmers and ranchers, particularly this year. Because of the widespread flooding in much of the country, many farmers are still trying to cut hay and harvest small grains. At the same time, in Texas and much of the southeast, farmers face an exceptional drought that is forcing many to haul water and take other steps simply to keep their animals alive. In September and October, ranchers will be busy with the fall vaccinations of calves and shipping of their calves and yearling feeder cattle to market.

It is very important that the agency extend the comment period and that it do so as soon as possible. Our nonprofit organizations face difficult decisions in spreading the word to our members, including the use of resources to send first class mail or bulk (less expensive but slower) to reach those without internet access. Waiting until the last minute to announce the extension would impose unnecessary burdens on nonprofits who are doing a service for both the public and the government by notifying people of the proposed rule and the opportunity to comment.

For these reasons, we urge you to immediately announce an extension of the public comment period until January 8, 2012 providing a total of 150-days for public comment.

We thank you for your consideration.


American Agriculture Movement
American Grassfed Association
Ashtabula-Lake-Geauga Counties of Ohio Farmers Union
Buckeye Quality Beef Association
Carolina Farm Stewardship Association
Cattle Producers of Washington
Citizens for Private Property Rights (MO)
Colorado Independent CattleGrowers Association
Contract Poultry Growers Association of the Virginias
The Cornucopia Institute
Dakota Resource Council (ND)
Dakota Rural Action (SD)
Empire State Family Farm Alliance (NY)
Family Farm Defenders
Farm and Ranch Freedom Alliance
Farm to Consumer Legal Defense Fund
Food and Water Watch
Idaho Rural Council
Independent Cattlemen of Nebraska
Independent Cattlemen of Wyoming
International Texas Longhorn Association
Kansas Cattlemen’s Association
Land Loss Prevention Project
Mississippi Livestock Markets Association
Missouri Farmers Union
Missouri Rural Crisis Center
National Association of Farm Animal Welfare
National Family Farm Coalition
National Farmers Organization
Nebraska Sustainable Agriculture Association
North Country Sustainability Center (MA)
Northern Plains Resource Council (MT)
Oglala Sioux Livestock and Landowners Association
Organic Consumers Association
Organization for Competitive Markets
Peach Bottom Concerned Citizens (PA)
Powder River Basin Resource Council (WY)
Rocky Mountain Farmers Union
Rural Coalition/ Coalicion Rural
Rural Vermont
Rutland Area Farm and Food Link (VT)
Socially Responsible Agricultural Project
South Dakota Stockgrowers Association
Sovereignty International
Virginia Independent Consumers and Farmers Association
Western Organization of Resource Councils
Weston A. Price Foundation

For more information, contact Judith McGeary, Farm and Ranch Freedom Alliance, 254-697-2661 or Judith@FarmAndRanchFreedom.org