The Colorado Department of Agriculture has proposed a rule that would require a NAIS premises registration number in order to participate in the state fair. The proposed amended rule cover a range of topics, from alcohol consumption to camping to dogs. Our focus is on the NAIS provision, but we encourage everyone to read the entire proposed rule.
The notice and regulatory analysis are available here.
TAKE ACTION #1: File written comments.
You can submit written comments on the proposed rule before Friday, May 30, to the Colorado State Fair Administrative office, Colorado State Fair, 1001 Beulah Avenue, Pueblo, Colorado 8100. Fax: 719-560-1953.
Some talking points are below to help you write comments. It’s important that a lot of people write individualized comments! So if you only have time to write a very short letter, that’s fine. If you have time for more, then write more. But the critical thing is submitting something before Friday, May 30.
TAKE ACTION #2: Come to the hearing on Friday, May 30.
Please come to the hearing and submit written comments, show your support for other people there, or sign up to make a public statement. If you plan to make a statement, it would be safest to take written comments as well, in case the agency doesn’t allow everyone to speak.
WHERE: Creative Arts Building, Colorado State Fairgrounds, 1001 Beulah Avenue, Pueblo
DIRECTIONS: www.coloradostatefair.com
WHEN: Friday, May 30, 2008 at 9 am
TAKE ACTION #3: Contact your legislator.
Send a copy of your written comments to your legislator, and follow up with a phone call. You can look up your state Representative and Senator here, or on the state website here.
The Colorado legislature has discussed bills to stop the CDA from requiring NAIS for the state fair for the last two years. The legislators need to that you want them to step forward and ask the Department to not adopt the rule, and pass a bill next session to stop NAIS.
TALKING POINTS
- It is wrong to use our children to implement a controversial program opposed by many of their parents.
- Contrary to what the regulatory analysis says, it is not easy for people to get back out of NAIS once they have registered. The CDA has not published a procedure, and people across the state have been faced with bureaucratic barriers when they have tried to withdraw.
- Premises registration is the first step of NAIS, and the whole program needs to be considered before any of it is implemented.
- NAIS is not a good program for Colorado.
- NAIS will hurt Colorado's economy:
- There has been no analysis at federal or state level that establishes the costs or benefits of NAIS.
- Costs of the program include the cost of the tags, hardware, software, time and labor
- Many small farmer and ranchers cannot afford these costs
- Service providers (veterinarians, feed stores, auction houses, meat processors, etc.) will be harmed when the farmers and ranchers go out of business.
- Remaining farmers will pass the costs on to consumers, at a time when food prices are already skyrocketing
- Neither the USDA nor the state agency has scientific proof that NAIS will improve disease control:
- It does not address the cause, treatment, or transmission of disease, in domestic or wild animals.
- It does not significantly improve on current methods for identification and tracking of disease.
- NAIS will not improve food safety
- USDA itself has stated that this is not a food safety program
- Contamination of food with e. coli and other bacteria occurs at the slaughterhouse or afterwards, while NAIS will stop before that point.
- NAIS will not protect against terrorism and the technology is flawed
- The microchips chosen by the state can be cloned, destroyed, or infected with computer viruses, and reprogrammed. Any terrorist or thief can use this.
- The database of information, created by the state agency and available to USDA, will provide a target for hackers.
- NAIS infringes on people's constitutional rights, including due process, privacy, and religious freedom.
- NAIS unfairly attacks the rights of pet owners and those who raise animals as food for their family.
- USDA states that NAIS is voluntary at the federal level, so there is no "federal mandate" requiring Colorado to implement this program
- Other states are also rejecting or limiting NAIS, so Colorado will not be disadvantaged by refusing to participate.
The Colorado State Fair Board is currently requiring children to register in NAIS in order to participate in the state fair. HB 1129 would have reversed that policy. HB 1129 passed the House and was assigned to the Senate State, Veterans and Military Affairs Committee. It died in committee on Monday, March 3.
Take Action
1) Start laying the groundwork for next session! Contact your Representative and Senator. If you do not know who your elected officials are, click here.
MESSAGE: We need to stop implementing NAIS in Colorado.
Ask to speak to the staffer who handles agricultural issues. Have a discussion. Ask them what they already know about NAIS, explain your objections to it, and respond to the issues they bring up. Stay in touch through email after the phone call, so that they know you really care about this issue.
2) Educate your community. Download materials from the site and put them out at feed stores, farmers markets, co-ops, riding stables, and anywhere else people gather. NAIS will directly impact every single person who owns animals. It will also impact all the animal-related businesses, rural communities and, ultimately, everyone who eats! We need to educate as many people as possible, so that the next bill succeeds!
Talking Points
- It is wrong to use our children to implement a controversial program opposed by many of their parents.
- NAIS is not a good program for Colorado, even beyond the issue of our children.
- NAIS will hurt Colorado's economy:
- There has been no analysis at federal or state level that establishes the costs or benefits of NAIS.
- Costs of the program include the cost of the tags, hardware, software, time and labor
- Many small farmer and ranchers cannot afford these costs
- Service providers (veterinarians, feed stores, auction houses, meat processors, etc.) will be harmed when the farmers and ranchers go out of business.
- Remaining farmers will pass the costs on to consumers, lowering demand for local foods
- Neither the USDA nor the state agency has scientific proof that NAIS will improve disease control:
- It does not address the cause, treatment, or transmission of disease, in domestic or wild animals.
- It does not significantly improve on current methods for identification and tracking of disease.
- NAIS is not necessary for the market. Age- and source-verification is already available through the USDA's Process Verified Program
- NAIS will not improve food safety
- USDA itself has stated that this is not a food safety program
- Contamination of food with e. coli and other bacteria occurs at the slaughterhouse or afterwards, while NAIS will stop before that point.
- NAIS will not protect against terrorism and the technology is flawed
- The microchips chosen by the state can be cloned, destroyed, or infected with computer viruses, and reprogrammed. Any terrorist or thief can use this.
- The database of information, created by the state agency and available to USDA, will provide a target for hackers.
- NAIS infringes on people's constitutional rights, including due process, privacy, and religious freedom.
- NAIS unfairly attacks the rights of pet owners and those who raise animals as food for their family.
- USDA states that NAIS is voluntary at the federal level, so there is no "federal mandate" requiring Colorado to implement this program
- Other states are also rejecting or limiting NAIS, so Colorado will not be disadvantaged by refusing to participate.
- Please support HB 1159
Members of Senate Agriculture Committee
Status:
No statute authorizing NAIS (to our knowledge). Premises registration is required by rule for "call regulatory functions."
Grassroots activity:
Individuals have been writing letters and calling their representatives, as well as speaking to local organizations. The local chapters of the Weston A Price Foundation have been active in this effort.
