Action Alert
January 27, 2007
Kentucky Department of Agriculture has revised its proposed regulations
On December 15, the Kentucky Department of Agriculture proposed regulations that would make the premises registration and animal identification portions of NAIS mandatory, and require a certificate of veterinary inspection (CVI) for sales, shows, and many routine movements, including trail rides. These requirements apply to both livestock animals and pets such as dogs and cats. The proposed regulations would also allow the State Veterinarian to enter any farm or "any other place where animals are handled" to inspect and test, without a warrant.
On January 22, the Department issued revised proposed amended regulations. The most significant change is that the revised proposal deletes the deadlines for premises registration and animal identification. This is a very positive step. But the revised proposed regulations retain the requirement for a CVI for sales and movements. And since the CVI would require "official individual identification - except where group/lot numbers are approved" and the "name and address of the owner/agent," the CVI requirements will effectively impose many of the NAIS requirements without calling it "NAIS." The land would not be labeled with a premises registration number in a federal database (for now), but people will still be subjected to significant burdens on their privacy, time, and finances. A proposed alternative for horse owners, the Equine Interstate Event Permit, would be equally burdensome, as it requires keeping a permanent log of all movements of an animal - essentially the movement reporting required by NAIS.
Written comments will be accepted until January 31, 2007.
Send comments on the proposed regulations to:
Robert Stout or Sue Billings
Kentucky Department of Agriculture
Office of State Veterinarian
100 Fair Oaks Lane, STE 252
Frankfort, Kentucky 40601
phone (502) 564-3956, fax (502) 564-7852.
The revised proposed regulations are available on our website at:
www.lrc.ky.gov/kar/302/020/020reg.htm
www.lrc.ky.gov/kar/302/020/030reg.htm
www.lrc.ky.gov/kar/302/020/065reg.htm
At the end of this action alert is a sample letter you can use. Focus on the issues that are most important to you and personalize your comments to have the greatest impact. It is also very important to send a copy of any letters to your elected officials. You can find who your legislator is at:
www.lrc.ky.gov/whoswho/whoswho.htm
As always, if you have questions or concerns, you can reach us at:
GET YOUR FRIENDS TO SIGN UP TO SUPPORT LIBERTY ARK'S FIGHT AGAINST NAIS. SEND THEM THIS LINK:
http://libertyark.net/pledge.dyn
Sample letter to:
Robert Stout or Sue Billings
Kentucky Department of Agriculture
Office of State Veterinarian
100 Fair Oaks Lane, STE 252
Frankfort, Kentucky 40601
Phone 502-564-3956
Fax 502-564-7852
Dear Mr. Stout and Ms. Billins:
I strongly oppose the proposed regulations under 302 KAR 20:010, 020, 030, and 065, both as initially proposed on December 15th and as revised on January 22. I am a ______ (farmer, pet owner, consumer - tell them just a little about yourself)
The proposed regulations would require a Certificate of Veterinary Inspection (CVI) for "movement or exhibition of all animal(s)," with very limited exceptions. Essentially any off-property activity would fall within the definition of movement or exhibition. "Exhibition" includes such things as fairs, rodeos, and even trail rides. Movement is defined as "the act of moving, shipping, [or] transporting, delivering, receiving or collecting animals [livestock] by any means, method, or vehicle by any person for any purpose." (Proposed 302 KAR 20:010) There have been no scientific studies conducted to show that requiring identification and certification for routine activities will provide significant animal health benefits.
Moreover, the Department has not done an analysis of the costs of this program. When one considers the costs of identification devices, the labor of installing them, the paperwork burdens, and the costs of obtaining a veterinary certificate, it is clear that these proposed regulations will impose a severe burden on animal owners. The intrusive, burdensome, and costly nature of these regulations will drive many small farmers out of business and discourage people from owning animals as pets, particularly since the regulations also apply to cats and dogs. Animal-related businesses, such as feed and supply stores, will suffer, and the economic effects will be widespread.
The proposed regulations would also give the State Veterinarian the authority to enter "any farm" or "any other place where animals are handled" after simply notice, without a warrant, reasonable cause, or any protection for the person's property or privacy rights. (proposed 302 KAR 20:030.) This proposed regulations greatly expands the scope and intrusiveness of the government bureaucracy into people's private lives and homes, without any solid evidence that such measures are needed to control animal disease in Kentucky.
I urge the Department to reject these regulations and, instead, perform an analysis of disease-specific and species-specific systems that would provide cost-effective mechanisms for protecting animal health in this State, with the proper respect for people's privacy and property rights.
Sincerely,
Your name
Address
City, State, Zip
Email if you have it
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