The Honorable Tom Vilsack, Secretary of Agriculture
The Honorable Edward Avalos, Under Secretary of Marketing and Regulatory Programs and Veterinary Services
U.S. Department of Agriculture
1400 Independence Ave., S.W.
Washington, D.C. 20250

Sent via U.S. Mail and facsimile: 202-720-6314 and 202-720-5775

Dear Secretary Vilsack and Under-Secretary Avalos:

The undersigned groups represent farmers, ranchers, homesteaders, and consumers who have an interest in the issue of animal identification and traceability. We applaud your decision to drop the National Animal Identification System (NAIS). Thank you for holding the listening sessions and for recognizing that the NAIS was an unworkable plan.

We have closely followed USDA’s statements about its new framework, and believe that this new program has the potential to be a cost-effective method for traceability with little intrusion into people’s privacy. But it also has the potential to become a burdensome and onerous program, as NAIS was. It is critical that the full range of affected stakeholders provide input during development.

In order to design a program, we must first understand what problem USDA seeks to address. USDA officials have specifically referred to the reduction in traceability that is occurring because of the discontinuation of mandatory tagging for brucellosis and tuberculosis in cattle, but have also indicated that the program will not be limited to cattle. Therefore, before moving forward with any framework, the undersigned organizations would like USDA to clearly identify which animals being moved in commerce are not already traceable, the flaws in the current traceability programs, and the specific problems they hope to solve through a traceability program.

As an initial step, USDA has already recognized animal traceability is just one aspect of addressing animal health. We appreciate USDA’s statement that the agency plans to strengthen the defenses against diseased animals from entering the U.S. We recommend that USDA also focus resources on the problems previously identified by the Government Accountability Office, such as improved training for veterinarians in foreign animal diseases and the development and use of rapid diagnostic tools.¹

Moreover, as the GAO report noted, the consolidation of our domestic agricultural production increases the risk of disease outbreaks. The greatest animal health and public health risks come from consolidated production and processing, and any program that increases consolidation would be counter-productive. We urge USDA to consider the ramifications on competition in animal agriculture when developing policies, both on animal identification and beyond.

Below are a few specific points of concern.

1. Transport across state lines without change of ownership

a. Transport for slaughter: Many family farmers and ranchers raise livestock entirely within one state, but cross state lines in order to reach a slaughterhouse because of the difficulty in finding slaughterhouses that will process single or small groups of animals. These livestock do not change ownership when they cross state lines, and their owners should not be encumbered with any additional identification requirements on top of those already required under current regulations.

b. Transport for shows: Livestock are transported across state lines for fairs, rodeos,and other shows. Horses, in particular, are frequently transported for shows. Currently, horses are required to have health papers and a Coggins test before such transport, and those papers include a detailed physical description of the animal. In addition, sheep must have scrapie tags. These measures are sufficient to provide traceability for these species.

c. Transport to properties under common ownership: Across the country, family farmers and ranchers own land in more than one state. Requiring identification of animals that move from one pasture owned by an individual to another pasture owned by that same individual would not significantly improve traceability, while placing burdens on these farmers and ranchers.

2. Impact on intrastate and intratribe programs: The USDA has clearly stated that the new program is intended to track animals that cross state or tribal lines back to the state or tribe of origin, and we support this limited purpose. Depending on what the program requires, however, it could potentially create pressures on intrastate, intratribe, or even private programs to adopt specific requirements or technologies through a “trickle-down effect.”

We do not ask USDA to take responsibility for the truly independent decisions of others, but we urge the agency to consider all of the ramifications of the proposed program, including the influence it will bring to bear on state and tribal authorities and market programs.

3. Shipping of poultry: It is common practice for hobbyists, homesteaders, and family farmers to order day-old poultry through the mail. There are only a few hatcheries left that provide poultry to individuals outside of vertically integrated corporate-controlled operations, so the chicks are commonly shipped across state lines. The poultry frequently do not cross state lines again during their relatively brief lives. Requiring poultry to be identified when shipped across state lines as chicks would be unduly burdensome.

4. The use of a national database: If the premises registration (now location identifier) and 840 tags continue to be available to states and individuals, how will those databases be maintained? What information will be stored? How can individuals be removed from the databases if they no longer wish to be involved or if they were originally entered without their consent? hen addressing these concerns, a one-size-fits-all program cannot work for all species.

Before moving forward in this process, these three questions must be addressed:

• What are the problems that need to be solved?
• What are the most effective ways to address them?
• Will they be cost-effective, especially for family farmers, ranchers, and small-scale animal owners?

We are concerned about the delay in establishing the Secretary’s Advisory Committee. We offer our help in moving the process forward however we can. Once the nomination procedure is published, we intend to provide nominations to ensure that all stakeholders are involved and adequately represented.

Thank you for your responsiveness to our concerns. We look forward to continuing to work with you in this process.

¹See United States Government Accountability Office, GAO-05-214, Homeland Security: Much is being done to protect agriculture from a terrorist attack, but important challenges remain (Mar. 2005).

Sincerely,

American Grassfed Association
Carolina Farm Stewardship Association
The Cornucopia Institute
Empire State Family Farm Alliance
Farm and Ranch Freedom Alliance
Innovative Farmers of Ohio
Massachusetts SmallHolders Alliance
Missouri Rural Crisis Center
Nebraska Sustainable Agriculture Society
Northeast Organic Farming Association — Massachusetts
R-CALF USA
South Dakota Stockgrowers Association
Western Organization of Resource Councils
For more information, please contact Judith McGeary, Executive Director, Farm and Ranch
Freedom Alliance, PO Box 809, Cameron, TX 76520, Judith@FarmAndRanchFreedom.org or 512-
484-8821.

CC via email:
Dr. John Clifford, Chief Veterinarian, USDA
Brian Thomas, Outreach Coordinator, Indian Nation Conservation Alliance
Glenda Davis, Program Coordinator, Navajo Nation Veterinary & Livestock Program
Anita Matt, Confederated Salish and Kootenia Tribe, MT
Ross Racine, Executive Director, Intertribal Agriculture Council
Carry Sexton, Project Coordinator, United South and Eastern Tribes, Inc.
Keith Roehr, State Veterinarian, Colorado
Becky Brewer-Walker, State Veterinarian, Oklahoma
Steve Crawford, State Veterinarian, New Hampshire
Martin Zaluski, State Veterinarian, Montana
Jim Watson, State Veterinarian, Mississippi