New York - Horse People Against NAIS

 

NY Cooperative Agreements with the USDA for Implementation of NAIS

Initially the USDA called for the NAIS to become mandatory in 2009.  In response to public outcry, the USDA published a revision of their plan on November 22, 2006 stating the NAIS would be “voluntary at the Federal Level”.  The key words are “at the Federal Level”, for while they publicly stated NAIS would be “voluntary with a capital V”, they continued to funnel money to each individual state through Cooperative Agreements (grants) to implement NAIS.

Copies of all documents pertaining to the Cooperative Agreements between the USDA and New York State Dept of Agriculture and Markets (NYSDAM) were obtained via the Freedom of Information Act.  The Freedom of Information Act ensures transparency in government.  Simply put, we have a *right* to know where and how our tax dollars are being spent!  Outlined below is information taken directly from those documents.

The USDA and NYSDAM frequently claim that “premises registration is free”.  It is NOT ‘free’ for we, the citizens of the USA have paid for Federal grant monies through our tax dollars!  We, the citizens of the state of NY, have paid yet a second time for the amount contributed by NY State through our state tax dollars.

Cooperative Agreements between the USDA and NY Ag and Markets 2005 through 2007

Date

Award from USDA

Amount from NYS

Total for Fiscal Period

Feb 2005 – Feb 2006

$115,000.00

0

$115,000.00

Sept 2005 – Sept 2006

$250,000.00

0

$250,000.00

Sept 2006 – Dec 2006

$206,941.00

$51,006.00

$253,946.00

Jan 2007 – Dec 2007

$275,980.06

$126,248.43

$402,228.49

Total

$847,921.06

$177,254.43

$1,021,174.49

The Work Plan in each fiscal year’s Cooperative Agreement outlines the work the state will do.  The Work Plan for Feb 2005 through Feb 2006 is reprinted in its entirety below as I believe the citizens of NY have a right to see just what was agreed to.  The Work Plans for the 3 later Cooperative Agreements reprinted below will show only that information which refers to equines.

My comments will be displayed in [blue brackets] and are NOT part of the Cooperative Agreements.

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Feb 2005 – Feb 2006 Work Plan

WORK / Financial Plan for NAIS

Background

The identification of one Holstein cow affected with Bovine Spongiform Encephalopathy (BSE) in Washington State in December 2003 gave extra impetus to implementing a National Animal Identification System (NAIS) in the United States. The NAIS consists of three parts. The first is the identification and registration of premises where animals commingle. A National Premises Identification Number is assigned to each of these premises as part of this process. Various parts of the animal industry infrastructure (e.g. market sale barns, slaughter facilities, animal collecting stations, renderers, veterinarians, etc.) will also receive Non-producer Participant Numbers. The second aspect of the NAIS is the voluntary identification of individual animals or groups/lots of animals with unique, official identification numbers (devices) on the farm of origin or at the first assembly point after animals leave the farm of origin. This official identification number (Anima/Identification Number) is specifically tied to the farm of origin which has a National Premises Identification Number assigned to it. The third component of the NAIS involves tracking animal movements or events at various points along the animal production pathway and reporting these events to the National Animal lD Data Base. This information will be crucial to a rapid (48 hours or less), complete traceout of animal contacts when the need arises.

Objective

The goal of the New York State Department of Ag and Markets (NYSDAM) is to establish a producer mailing account number and register associated premises where animals commingle using the Standardized Premises Registration System (SPRS). Premises housing cattle (beef, dairy, and bison), camelids (alpacas and llamas), cervids (deer and elk), goats, horses, poultry, sheep, and swine are targeted for this project. NYSDAM also plans to obtain Non-Producer Participant Numbers for those individuals or entities that do not own or manage livestock but are directly involved in some aspect of animal agriculture. Although this program is voluntary, NYSDAM will enroll all known premises located in New York State.

Approach

NYSDAM is engaged in implementing the first part of the NAIS. The Standardized Premises Registration System (SPRS) will first be used to submit a batch of equine farms to obtain user account numbers and National Premises Identification Numbers. Animal Industry personnel will coordinate this process and will also deal with the exceptions on an individual basis to insure consistency within this program. [Who these ‘Animal Industry’ personnel are is not stated.]  A second batch of "species related" premises will be submitted to gain more experience before submitting the batch of 6500 active dairy farms to the National Allocator. NYSDAM will sequentially submit other batch lots of premises (other species groups) and non-producer participants for registration and number assignments in the same manner. It is expected that all premises addresses for all species already in the NYSDAM databases (-20,000) will be submitted for registration and exceptions resolved during the 12 month period of this agreement. Non-Producer Participants in animal industry will also be enrolled in this phase of the program, some using the same batch submission process and others utilizing the SPRS. Producers will not be self-registering but instead will submit the necessary data to NYSDAM for review and entry into the SPRS.

This process is anticipated to involve one full-time clerk to enter data garnered from owners of premises not already existing in NYSDAM databases and deal with the exception resolution process for the next 12 months. [In other words, they are ‘mining’ existing disease/market databases to register premises without the owner’s knowledge or consent!]  NYSDAM also expects to use the equivalent of 0.5 Animal Health Inspectors to aid in verifying data about some premises including mailing address, owner, contact information; animal business activity, and GPS locations.

Outreach to the industry will be multifaceted including the following:

·          Development of a stationary informational exhibit for use at meetings and agricultural events

·          Development and maintenance of NAIS page at the NYSDAM website (www.agmkt.state.ny.us/AUAIHome.html) [Note: the URL has been changed to:  http://www.agmkt.state.ny.us/NAIS/nais.html]

·          Distribution of current USDA-APHIS-VS pamphlets (Program Aids 1797 and 1800) and future publications to program stakeholders at meetings and thru mailings.

·          Limited 60 second radio spots on Ag Radio Network

·          Development and distribution of additional educational materials as needed,

·          Press releases to agricultural publications with widespread distribution in the New York agricultural community (newspapers, magazines, Cooperative Extension newsletters, etc.)

·          Partnering with Cornell Cooperative Extension, producer groups and other industry groups in informational meetings and events throughout the state

·          Mailing a notification letter, certificate, and laminated wallet-sized card to account holders after successful registration of their premises. This announcement will also provide procedures for correcting or amending registration information as needed

Timeline and Measurable Outcome:

1. Procure stationary exhibit                   by March 2005

2. Radio spots                                       3 in February 2005, 2-3 in June 2005

3. NAIS page on NYSDAM website with premises registration information by February 2005; program updates monthly.

4. Press releases                                   1 in February 2005 and one every 3 months; more often if needed

5. Meetings and public presentations

a)       at least 4 producer informational meetings per month in February, March, April 2005 followed by reduced frequency during the cropping season (May thru Oct. 2005) then 4 per month for November 2005, December 2005 and January 2006

b)       teach class on NAIS at Cobleskill College            March 2005

6. Booth at NYS Air Breeds Dairy Convention (Jan 13-15, 2005) and Empire Farm Days ( 3 days August 2005)

7. Set up producer accounts and register animal premises

a)      batch submission of equine premises              January 2005

b)       batch submission of cervid premises                    February 2005

c)       batch submission of dairy cattle premises            March, April 2005

d)       sequential submission of other batches of premises until all batches of premises are identified and numbered

8. Registration of the exceptions and new premises not in the current NYSDAM database on an individual basis throughout the year

9. Letters of notification follow the successful establishment of account numbers and premises identification within 30-60 days.

Budget:

Personnel

 

$77,040

1 clerk and 0.5 AHI

$42,900

 

Fringe Benefits

$17,200

 

Indirect Charges

$16,940

 

Outreach

 

$37,960

Laminated posters for livestock markets

$1,000

 

Stationary informational exhibit

$1,000

 

Pamphlets and print media

$1,000

 

Radio spots

$2,500

 

Meeting expenses

$1,000

 

Registration certificates and laminated cards

$22,460

 

Mailing expense

$9,000

 

TOTAL

 

$115,000

 

Sept 2005 – Sept 2006

The New York State Department of Agriculture and Markets (NYSDAM) is currently engaged in implementing the first part of the NAIS. Extracts of premises information currently held by NYSDAM are being used to construct batches of information to submit to the National Premises Identification Number (PIN) Allocator for premises registration and PIN assignments.

In New York the registration of premises by a large "batch lot" submission process is not working as we had hoped. The first batch of 1027 equine premises was registered with an 88.3% success rate in the late winter 2005. 907 Federal Premises Identification Numbers (PIN's) were assigned and 120 exceptions were generated. When putting together the batch of cattle premises for submission we learned that a large portion of the premises in our data base lacked part or all of the telephone contact information required to register them. As a result we are collecting the missing pieces of information to construct batches of premises which will be submitted for federal PIN's.

Sept 2006 – Dec 2006

NYSDAM has already passed the benchmark of registering 25% registration of the premises located in New York by January 2007. This work plan will help to propel premises registration toward the January 2008 benchmark goal of 70%. Stakeholder education will enable New York State to move forward with the implementation of the animal identification portion of the NAIS as well.

Work To Be Accomplished:

Premises Identification

Premises registration will be accomplished using the individual and batch registration methods of the SPRS system. Premise information used to register premises is stored in an existing NYSDAM database. NYSDAM employees will collect new or updated premise information from producers at various events throughout the state and will complete the actual registration of premises from that information. Although registration continues to be voluntary, NYSDAM will register any premises within New York State that have information located in the existing NYSDAM data base. This information will be used to batch load registrations. Exceptions will be taken care of on a case by case basis and individually entered through the SPRS system. The outreach program will enable information to be collected from those premises not in the existing database to progress toward eventual registration of all premises.

Batch registration will occur through the efforts of the third party company.  The information will be collected using self mailing response cards.  [The third party company is not identified.]

As of June 5, 2006, 12,109 premises have been registered with the USDA of the estimated 40,134 total premises of interest in New York State. This indicates a 30% completion of premises registrations in New York.

Industry Focus:

The focus will be on the bovine, equine, caprine, ovine and porcine livestock species. These species represent the majority of animal production within the state. Although these species are the primary focus of the current effort, producers who own or manage any of the other species of interest will be actively sought out to increase their overall awareness and acceptance of the NAIS.

The livestock types that will be the most significant part of this project are cattle, hogs, horses and sheep. As of 2004, there were 1,230,000 cattle in the state of New York and 15,300 premises. As of 2004 there were 84,000 hogs and 1,527 premises. As of 2004, there were 74,000 sheep and 1,800 premises. As of 2000, there are an estimated 22,300 equine premises in New York.

There are currently 39 slaughter facilities and 36 livestock markets in New York State.

Jan 2007 – Dec 2007

As of November 9, 2006, 12,941 premises have been registered with the USDA of the estimated 25,440 total premises of interest in New York State. This indicates a 51% completion of premises registrations in New York. Of those already registered 8,085 are cattle premises, 937 are equine premises, 243 are caprine premises, 119 are hog premises and 198 are sheep premises. The remaining premises included the other species indicated in NAIS.

[When looking at statistics regarding premises registration, it is important to note the large decrease in number of premises.  In the fall of 2006 the USDA began using the numbers of farms from the 2002 Ag census, which had a strict definition of a ‘farm’, rather than the number of premises where animals were kept. This significantly decreased the number in almost every state and inflated the number of premises registered.  In NY the percentage of premises registered appeared to jump from 30% in June 2006 to 51% in November 2006.  That 51% would have been 33% using the original number of estimated premises.

Note also that the number of equine premises registered had only increased by 30 from late 2005 to November 2006.]

The registration of the additional 1,782 premises will be accomplished through a multifaceted approach. This will include speaking at twenty four producer meetings across the state. Workshops will be created to allow producers to have questions answered and gain understanding of the importance of the NAIS.

Field staff from both NYSDAM and USDA-APHIS will be trained concerning the program elements to aid in the education and outreach across the state in various capacities. Tradeshow exhibits will enable producers to obtain NAIS literature and materials and register their premises.

Cooperation with industry groups has already been initiated. The coordinator will continue to work with these industry leaders and groups to increase the education and outreach process as well as increase the number of premises registered.

An increased awareness of the NAIS program and knowledge of its importance and necessity will support eventual registration of all premises in New York.

Accomplishments to be Achieved:

Premises registration

Within four reporting periods of this project another seven percent of the total estimated premises will become registered. This number will equal 1,782 new premises or 7%. The species to be concentrated on will included are cattle, horses, sheep, goats, and pigs though all species included in the NAIS will be encouraged. [Grammatical error in this sentence is exactly as it appears in the original document.]

Of the 1,782 premises to be registered 890 or 50% will be equine premises, 712 or 40% will be cattle premises and the remaining 10% will consist of sheep, goat and pig premises.

The number of premises to be registered is small as we have exceeded goals in previous years. We have also encountered intense opposition from some individuals whose premises have been registered without their permission and not voluntarily. As we get closer to the goal of registering all premises each additional premise requires more resources than those which were registered early in the process. These inputs include time and effort in education and outreach activity (producer meetings, trade shows, one on one contacts) and the production of written materials

End of documents

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Note the plan to register 890 more equine premises in 2007.  Why this sudden ‘interest’ in equine premises?  Reread the original listing of ‘premises of interest’.  Horses were always listed! 

We know that involuntary registration through the mining of existing databases (dairy, scrapie, coggins) is responsible for the majority of premise registrations because the Cooperative Agreements say exactly that, over and over:
"It is expected that all premises addresses for all species already in the NYSDAM databases will be submitted for registration and exceptions resolved during the 12 month period of this agreement."

Please download and read the USDA’s August 2007 document titled ‘Advancing Animal Disease Traceability”.  Note Strategy 1:  Prioritization of Species/Sectors on page 3:
“The competition horse industry is included as a priority due in part to frequent animal movement.” 

Read Strategy 3:  Convergence of Data Standards in Disease Programs and Regulations on page 4 very carefully.

Will we be required to have our premises registered to have Coggins tests done?  Will we be required to have our premises registered to obtain a Certificate of Veterinary Inspection?  Some states have begun requiring this!  Will our horses have to be microchipped for the same in the future?  When you read and/or hear the numerous complaints about how difficult it can be to differentiate “one bay horse from another”, it is not a big stretch to believe that this IS what will be required in the future.

Do not feel secure that you will be exempted if you do not show!  This statement simply confirms that this group of horses is included in their Tier One (top priority).  The fact that ANY equines are included sets the precedent for including ALL horses, even though horses are not raised as ‘food animals’ in this country.

Last, it became clear to me in the, at times, rather heated discussion about Foot and Mouth Disease (FMD) during the recent NYSDAM NAIS presentation, that no horses will be exempted from NAIS.  While horses do not become infected with FMD, they could contribute to its spread from something as simple as riding over to a neighbor’s.  Our State and Federal Animal Health Officials are very fearful this disease will gain entrance into the USA.  (The USA has been FMD ‘free’ since the late 1920’s.)  The statement was made, and I quote, “It is not a question of IF, it is a question of WHEN FMD” gains entrance into the USA.  While I sympathize with them, there is a better answer than this intrusive, expensive system.  Secure our borders, increase the number of animal inspectors at our legal portals of entry and stop opening our borders to the importation of live cattle from other countries!

You may download the USDA’s ‘Traceability’ document here. 

 

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