April 8, 2008
Comment period on Business Plan closes April 15, 2008
The USDA is closing the comment period on its "Business Plan" for how to implement NAIS. Comments will be accepted through April 15, and the USDA will then review the comments and issue a revised Business Plan. You can read the documents here.
TAKE ACTION: Submit comments! In its release of the Business Plan, USDA stated that it seeks comments on the released documents or other aspects of NAIS, so you don't have to limit your comments strictly to the Business Plan. Send your comments to: , or by mail to NAIS Program Staff, USDA, APHIS, VS, 4700 River Road, Unit 200, Riverdale, MD 20737. It's important that people submit individualized comments, not form letters. Talking points are included at the end of this alert, to help you develop your comments.
TAKE ACTION #2: Send a copy of your comments to your Representative and Senators. It is critical that Congress knows that people are notifying USDA of their objections to NAIS and that your Congressmen understand your objections! You can find contact information for your elected officials here.
GOOD NEWS FROM THE STATES
Kentucky HB 495 has passed the legislature! The bill has been sent to the Governor, the final stage in the process. This bill would limit the agency to a voluntary program unless the USDA takes final action in accordance with the Administrative Procedures Act. HB 495 includes protections against coercion. For more information, click here.
Illinois HB 5776 passed the House unanimously and has been assigned to the Rules Committee in the Senate. For more information, click here.
If you need more information, contact the Liberty Ark Coalition at:
MORE INFORMATION ON THE BUSINESS PLAN
You can find the new documents on the USDA's website (which is difficult to navigate) or at farmandranchfreedom.org.
Some of the flaws with the Business Plan:
- USDA starts with the assumption that NAIS is a positive program, and the only question is how to push it through. It has not addressed the numerous concerns raised by animal owners regarding whether the program is needed or practical. The agency still has not provided any scientific evidence to support the program. In particular, the agency has provided no basis for its claim that 48-hours is "optimal."
- The agency still has not completed a cost-benefit analysis. No business would develop a Business Plan for implementing a program without such an analysis.
- USDA continues to ignore lower cost and less burdensome options. For example, although it mentions the "bookend" approach (p.12), it clearly views this as simply a step along the path to tracking every movement. Similarly, it discusses a critical mass of 70%, but only as a step towards participation by every animal owner.
- The Business Plan proposes to track every horse that needs a certificate of veterinary inspection or Coggins test when moved (p.26). Because of state regulations, this would include many horse owners who are involved only with local trail rides or even just take their horses to a breeding facility. The Business Plan also proposes to establish a national Coggins testing requirement, bringing in yet more horses.
- The Business Plan proposes using breed registries to implement NAIS (p.28). This method would create economic coercion on people whose animals would have little economic value without registration.
- The Business Plan makes it clear that USDA plans to use existing disease control programs to promote NAIS (p.30). Yet, as with the entire NAIS program, the USDA has failed to show why this change is necessary or cost-effective.
- The USDA confuses the goal of "expanded electronic government" with imposing an electronic-based system on individuals (p.32). NAIS is not just about government agencies using electronic systems, it is about requiring individuals to use such systems regardless of their objections.
- The USDA continues to promote the cooperative agreements with states (p.36). Yet USDA has refused to address the problems that have happened because of those agreements, including mandatory or coercive programs being implemented in Wisconsin, Indiana, Michigan, Colorado, Illinois, North Carolina and elsewhere. USDA cannot continue to rely on cooperative agreements to implement this unpopular program while avoiding responsibility for the outcomes.
- The species working groups (p.37) are fundamentally flawed. They are largely composed of large industry interests and technology companies, and provide little representation for the millions of small farmers, homesteaders, and pet owners who will be impacted by NAIS.
- The plan to use veterinarians to promote NAIS (p.38) is likely to lead to distrust on the part of many animal owners. Anything that discourages animal owners from seeking help from veterinarians is counterproductive for disease control.
- USDA ignores the technology problems that have been apparent in trials of the NAIS technology (p.40). With electronic identification already mandatory in Michigan, animal owners deserve a better answer than feel-good claims that the technology will "continue to improve."
We need the millions of people who will be impacted by NAIS to speak up! Download materials to educate people at your local feed store, sales barn, farmers market, or co-op. Contact your legislators and explain the problems with NAIS. Help us stop this program by educating people and speaking up!