New York Horse People Against NAIS

NY-HPAN

We beseech our state officials to impose a moratorium on any further “automatic” premise registration efforts for the USDA’s National Animal Identification System (NAIS). While “producers” have already made their opposition known, the horse people who have been erroneously lumped into this now implore you and The Senate Agriculture Committee to review the underhanded practices used to push this program forward. Horse people and their properties account for millions of dollars in tax monies and commerce, and we feel states’ rights and those of individuals should be balanced with the overall intent of NAIS.

The unethical “enrollment” practices adopted by the USDA has enabled it to boast a “70 percent penetration” in New York, even though most “registrants” are unaware, or unable to “unregister.” We understand that New York has procured approximately $847,921 in cooperative agreement grant money, but money should not outweigh the state’s duty to protects its constituents. With prodigious “incentives” given various state departments of agriculture, and other parties, such as The American Horse Council,  FFA, 4-H, state fairs, the National Pork Producers Council and the American Angus Association, it’s no wonder “member lists” were handed over for “automatic enrollment.” We feel both the state and these organizations have a duty to protect our personal data, as well as to give adequate time for feedback and exploration of programs like NAIS.

While the USDA repeatedly states this program is “voluntary,” it becomes clear that “voluntary” quickly becomes “mandatory” in states accepting federal monies. In Colorado, 4-H children have been blocked from participating in their State Fair because their premises were not registered. In Illinois, people can no longer show animals at state, county, 4-H and FFA fairs unless registered in NAIS! This type of strong-arming has incited fear and distrust of federal influence over the states. The distrust only grows when propaganda at “enrollment” meetings differs greatly from the information buried within USDA Web sites and working group documents about future “recommendations.”

We also distrust the repeated use of the word “premise,” as it locks us into a contract with the federal government. Does refusal to adhere to a program in which we were “automatically” enrolled mean we lose control of our property?

We are also troubled by the frequent fear-mongering at local meetings, after which USDA spokespeople indicate a federal response would somehow be faster or more effective than that of state and local one. We feel the state and local resources would be much quicker to respond and much more likely to be fair and balanced in decision making processes—especially around “depopulation” of herds.

In the horse world, we do not look at our animals as “meat,” but as members of our family into which we invest substantial time, money and effort. We feel that in times of emergency, local and state authorities would make balanced decisions about slaughter and quarrantine. Decisions around “depopulation” should be left to local and state authorities, which can engage the federal government as has always been the case. A process of “appeals” would not exist if the federal agents are a first-response.

People may be more likely to hide animals or lie about illnesses if they fear the federal agents would slaughter entire herds in the interest of saving money or time. There have already been instances where the federal government “depopulated,” rather than re-tested healthy animals. That had devastating effects on “premise owners,” who are humans, not just “premise IDs.”

If federal agents can swoop down on farms at the earliest rumor or complaint, farmers and horse owners need recourse to stave off abuses of power. In instances where farmers and livestock owners indeed possess poor husbandry skills or illicit intent, it will make little difference whether power is concentrated at a state or federal level. Illegal trade and black markets will exist regardless of where the power lies at a state or local level.

Overall, each state has effective disease-specific and species-specific programs in place. We feel NAIS duplicates existing state protocols, at great cost to smaller farmers and livestock owners. Horse owners already have extensive documentation and data through required health certificates, comprehensive vaccine programs, and Coggins tests.

Existing protocols balance safety with the rights of farmers and horse farm owners. There should be coordination among the states and federal government, but federal “hand-holding” is not in the best interest of the state, or its farmers.

That is especially true when it comes to data management practices. As it stands now, local organizations, associations, vets and individuals manage extensive pools of federated data, which are difficult to infiltrate. Pushing our data, or duplicating it for population of huge, centralized, government-controlled databases may expose us to more risk, as opposed to protecting us from it. More often than not, re-keying huge amounts of data into centralized databases creates a “cascading” of errors and problems.

Forcing federal control, and ultimately metal and plastic transponders into horses, will do nothing to stop  disease or contamination. It will, however, garner millions of dollars for the producers of chips and readers, and the database companies.

The solution lies at the root of the problem. As large “producers” search for the cheapest way to process meat, poultry and pork, they increasingly carry animals greater distances across state and even country lines. It is this increase in transportation of thousands of animal that raises the risk of animal disease.  Rather than burden the greater whole with federal premise IDs, RFID chips, trace-back calls and data entry, perhaps scrutiny should be paid to the key “pain points.” Rather than burden small farms and livestock owners, let’s evolve the “producer” model back to a “farming” model, which is healthier for people, and for local economies.

Although the USDA repeatedly states in public meetings that the program is “free” or “virtually free,” it is clear someone will pay the price for multi-million dollar databases, call centers and the administrative headaches.

As written in the R-CALF letter (www.r-calfusa.com) to the Senate Agriculture Committee, there are approximately 100 million head of cattle in the U.S. An NAIS-compliant RFID (radio frequency identification) tag for each would cost approximately $300 million. The approved device for horses is an implantable microchip with an average cost of $25 each. In 2006, the USAIO predicted a charge of 30-cents per entry into its database. For the “track back” to work, entries would have to be made every time an animal is transported or moved. That will greatly change the character of Rural America. Our founding fathers warned us that eternal vigilance was necessary in order to protect our liberties. NAIS, as it stands now, treads heavily on our Constitutional rights.

Rather than force premise registration and ultimately RFID chips into our animals (which have been shown to cause cancer), there are far less costly, painful, and invasive ways of fostering coordination among states and the federal government.

We implore you to evaluate the pros and cons of a program BEFORE it is legislated. This is still a government FOR the people, not FOR the database companies, chip makers and reader manufacturers.

Sincerely,

NY-HPAN