PUBLIC SUBMISSION | As of: February 11, 2009 Comments Due: July 11, 2006 |
Docket: APHIS-2006-0066
New Information Collection; National Animal Identification System; Information Requirements for State, Tribal, and Private Animal Tracking Database Owners
Comment On: APHIS-2006-0066-0001
Notice of Request for Extension of Approval of an Information Collection; National Animal Identification System; Information Requirements for Private and State Animal Tracking Database Owners
Document: APHIS-2006-0066-0026
Comment from Karen Nowak
Brookfield, NY,
Comments on NAIS in general:
NAIS is a program that is clearly to benefit large scale producers at the expense
of the small scale farmers/homesteaders, who have been the backbone of this
country since it's inception.
If the rationale for NAIS is protection of our food supply and "improving consumer
confidence", why not spent this money hiring and training more inspectors for feed
manufacturing plants, slaughterhouses, meat processing plants AND our portals of
entry? If the introduction of FAD's is such a huge concern, why have inspections
at our portals of entry DECREASED? Is this not the most likely place for them to
gain entry into this country?
If NAIS is truly voluntary, why does the first paragraph on page 3 of the April 2006
NAIS Implementation Plan state:
"If the marketplace, along with State and Federal identification programs, does not
provide adequate incentives for achieving complete participation, USDA
may be required to implement regulations. USDA will evaluate whether the
participation levels are increasing at rates that will achieve full participation by
2009. Based on that analysis, USDA will determine if the market-driven incentives,
along with industry ?buy-in? for improved animal disease programs, is resulting in
adequate participation and growth rates for NAIS to be successful by the
established target dates. If participation rates are not adequate, the development
of regulations through normal rulemaking procedures will be considered to require
participation in certain aspects of the program."
If NAIS is truly voluntary why do you hang the threat of it becoming mandatory over
our heads?
If NAIS is truly voluntary then why have Wisconsin and Indiana already adopted
regulations making premises registration mandatory? Furthermore, why is
Wisconsin regularly referred to as the model implementation if NAIS is intended to
be voluntary?
If NAIS is truly voluntary then why have some states registered premises using
other data - without producers knowledge or consent? For example, in my home
state of NY, equine premises were registered in 2005 from the information on our
coggins test results. We were not asked if we wished to participate. In fact we
not even informed about the existence of NAIS AT ALL!!
As to horses, why are 42% of the members of the ESWG representatives of the
racing industy when only NINE% of the horses in the USA are used for racing?
What outbreak of a contagious disease in horses has NOT been quickly contained
and eradicated using our current system? The outbreaks of EHV-1 and vesicular
stomatitis in the last 2 years are proof that our current system works!
The equine species working group recommendations to the USDA for reportable
events are:
?Ports of Entry
?Quarantine Facilities
?Auctions and Sales
?Breeding Farms
?Boarding Facilities
?Training Facilities
?Equine Clinics and Hospitals
?Racetracks
?Show/Exhibition/Competition Facilities
?Public and Private Stables
?Rodeo Arenas
?Fairgrounds
?National or State Parks
?Universities (Educational/Research Facilities/Diagnostic Laboratories)
?Ports of Exit
?Dude Ranches
Every single one of these facilities/events has compete information on the horses
who have passed through - name, age, breed and description of the horse as well
as the name, address and phone number of the owner and the person who
competed with/is managing the horse (if different from the owner).
Why must horses be included in NAIS when the information already exists at
these reportable events? How will NAIS speed trace-back ability in the above
listed events? The answer is that it will NOT!
Have you considered the immense amount of data that will have to be entered into
this database on a daily basis? Information that already exists and is easily
retrievable in our current system of recordkeeping for these events? Have you
considered the cost of entering this data on a daily basis? Will horse owners be
charged for every entry?
We already pay fees on top of fees to compete at horse shows, regardless of
size. This will add yet another layer of fees that are not only totally unnecessary
but will also prove to be cost-prohibitive for many people. It will also serve to close
down smaller shows and other gatherings such as training clinics, who will find the
costs of purchasing scanners, a computer and software prohibitive.
How can you expect us to voluntarily buy into a system when we are not told what
the costs will be? What business operates WITHOUT a cost/benefit analysis on
new technology?! Small farmers, homesteaders and independent ranchers are
barely surviving now. How can you expect them to buy into something that may
put them out of business? The projected cost to the individual animal owners
MUST be clearly defined FIRST!
There is a lesson to be learned from Australia's experience with their beef
industry. The initial projected cost was $3 a head when they "bought into" their
national identification system. The Australian Beef Association reports that the
cost in reality is currently $37 a head. The American Horse Council and the
ESWG have admitted the cost to horse owners may be $150 to $200 per horse.
We already pay for registration of our horses. Those of us who compete pay up to
$200 per horse for a USEF Horse Recording Number. Why must we pay for yet
another number for a system which provides us no benefit at all?
You state that the "USDA believes strongly that small farms have an integral role
in our country?s system of agriculture. USDA fully recognizes that NAIS must be
practical and affordable for all sectors of agriculture. This continues to be a priority
for USDA as we work with State officials and producers to develop the system in
greater detail." If this is true, you MUST inform us of the TRUE cost and assure
that what happened in Australia does not happen here.
What has been accomplished to ensure that these databases will be truly
secure? The most recent hacking event in your own database comes immediately
to mind.
While the USDA will only request data in response to animal disease outbreak,
what assurance do we. the animal owners, have that the owner/manager of the
private database will not access this information for other purposes such as
monitoring the number, location and animal sales (reportable events) from small
organic farms or independent ranchers that might prove to be competitors of the
large corporate agribusinesses that will be investors in the database companies?
These questions demand answers before anyone can "buy into" NAIS.
Karen Nowak