My name is Judith McGeary, and I am the Executive Director of the Farm and Ranch Freedom Alliance. FARFA represents small farmers, homesteaders, and consumers across the country, and we are opposed to the USDA’s implementation of NAIS. We are submitting detailed written comments for the record, and we will cover just a few highlights here.

USDA says we need to trace every single animal in the country. But traceability should not be a goal in and of itself, it is simply a tool to achieve other goals. Proponents of NAIS claim that it is the solution for animal health, food safety, and food security. But NAIS will actually accomplish none of these.

With respect to animal health, existing disease control programs, combined with normal farm and sales barn practices, provide sufficient traceability already. Traceability is not the weak link in the chain for animal disease control. In fact, while the 2005 GAO report on agroterrorism identified a long list of things that USDA needed to change in order to effectively address the risk of widespread disease outbreaks, traceability was not identified as one of the problems.

USDA’s claim that we need 48-hour traceback of all animal movements is not supported by scientific studies or logic. The agency should focus on high risk situations, namely the factory farms. The agency should also look at the specific diseases of concern and how they are spread. A one-size-fits-all approach will not work. Most importantly, we need to prevent disease, not chase it.

With respect to food safety, we don’t need “farm to fork traceability,” we need “factory to fork traceability.” The source of food-borne illnesses lies with the large, centralized slaughter and processing facilities. E coli and salmonella contamination occur at the slaughterhouse, and we need traceability from the slaughterhouse to the consumer. Tracing live animals, as NAIS does, will do nothing to improve food safety. Instead, NAIS will provide false reassurance to consumers, while the USDA continues to avoid making critical improvements that would actually improve food safety.

Ultimately, NAIS will reduce food security. We’re told to diversify our investments for financial security. We need to do the same thing with our food – diversify our food supply by encouraging millions of small, local farms and processors. NAIS tries to substitute high tech solutions for the inherent safety that comes from diversity, and it will fail.

While not providing any real benefits for farmers or consumers, NAIS will impose significant costs. The cost-benefit analysis released by USDA last month has more holes than a block of Swiss cheese. The study violates accepted statistical practices by lumping more than ¾ of the producers into one category, disguising the real costs to small farms and people with just a few animals.

The study did not even try to quantify the costs of individually identifying poultry or feeder sheep. Instead it assumed that all poultry and feeder sheep would be identified as groups, even though the USDA’s definition of group identification limits its applicability, in practice, to factory farms. The study makes numerous unsupported and indefensible assumptions about the costs of the technological infrastructure of NAIS as well as the realities of animal-related businesses.

The cost-benefit analysis reflects the true push behind NAIS: the economic concerns of Agribusiness and technology companies. The government should not impose a program on millions of people for the benefit of a handful of huge corporations.

This box contains approximately 2,000 pages of petition signatures, from all over the country. No one was paid to collect these signatures – they are from the volunteer efforts of regular people who will be impacted by NAIS. This is the grassroots saying No to NAIS.