Brought to you by the Indianapolis Chapter of the Weston A. Price Foundation FRIDAY, MAY 8TH Meet the authors of The Liberation Diet 6:30 – 8:30 p.m. Open to the public Source Yoga Center (Across from the Fishers Train Station) 8609 E. 116th Street, Fishers, IN 46038 www.sourceyoga.net Donation: $5 Questions: info@indywapf.org or (317) 842-3757 Books will be available for purchase Kevin BrownCPT, CNWC Kevin Brown is President of Visionary Trainers Inc.(http://www.visionarytrainers.com/), one of the largest personal training companies in the Northeast, as well as LiberationFitness.com , an interactive online fitness program, which makes personal training affordable to everyone. He serves as a Fellow on the National Board of Fitness Examiners, and is an A.F.A.A certified fitness trainer, weight lifting specialist and nutritional counselor. Kevin is also a Weston A. Price Chapter Leader in New Jersey. Annette PresleyRD, LD, CPT Annette is a Registered Dietician, with a degree in Nutritional Science from the prestigious California State University, Los Angeles. Annette owns FindYourWeigh.com weight loss and wellness counseling program in Midland, Texas. She is also a Weston A. Price Chapter Leader. Americans of all ages have become SICK, FAT, and CONFUSED. By cracking the extensive and calculated code of misinformation, The Liberation Diet uncovers the mystery BEHIND the obesity and chronic disease epidemic in our modern society. Learn true health secrets Big-Business does not want you to know! REAL food returns to its anchor position: its rightful place in our lives. Amazing results abound as people lose weight and gain excellent health. Best of all, they maintain it long term! Be ‘liberated’! Finally enjoy foods you love without the guilt brought on by so called ‘health authorities’. Leslie D Gray

This Old Farm (Smith Family)
This Old Farm raises organically fed, pastured chicken, turkeys, eggs, pork, lamb, goat shares and cow shares.
location: 7206 N 950E
Darlington, IN 47940
phone number: (765) 436-2186
website:  www.thisoldfarminc.com

Message to Obama:  Please Fix the USDA’s Organic Mess

Overhaul of Management and Culture Needed

Please urge President Obama and new USDA Secretary Tom Vilsack to take immediate action to repair the USDA’s increasingly dysfunctional National Organic Program (NOP).  Suspect imports of grains, nuts, and vegetables from China and other countries, questionable organic milk, beef, and eggs from giant factory farms, and the erosion of opportunity for family farmers are plaguing the organic sector.

Make your voice heard by downloading the proxy-letter from

The Cornucopia Institute’s web sit: http://www.cornucopia.org/actionalerts/USDA_ProxyLetter.pdf

We will hand deliver your letter to both Mr. Obama and Secretary Vilsack.

The Cornucopia Institute, a national organic watchdog representing family farmers, has sent a formal letter and briefing paper to the President and USDA Secretary: http://www.cornucopia.org/actionalerts/USDA_NOP_Recommendations.pdf

The letter specifically asks that they take “a very strong and proactive posture in turning around management at the National Organic Program,” which they described as being “Katrina-ed” by the Bush administration.

“The stewardship of the organic program at the USDA has been an absolute abomination,” said Mark A. Kastel, Cornucopia’s senior farm policy analyst.  ”It was not just management by neglect-it was an intentional monkeywrenching of the Department’s oversight of the industry.”

In the last several years, audits prepared by the American National Standards Institute and the Inspector General’s office have blasted the NOP for failing to ensure that independent certification agencies, which verify organic farming and production practices, are competent and properly performing their jobs.

During the Bush administration, USDA political appointees significantly softened penalties for organic lawbreakers, overruling stiff enforcement actions recommended by career civil servants, for factory farms that were found willfully violating federal organic standards.  Other complaints detailing abuses on factory farms were quashed or went uninvestigated.

The Bush administration also stacked the National Organic Standards Board (NOSB) with representatives from corporate agribusiness instead of, as Congress intended, a broad spectrum of the organic community.  The President and Secretary need to hear that the organic community wants the very best new, independent nominees on the 15-member NOSB.  Our new governmental leaders need to hear from you, now!

Cornucopia’s “Change@USDA” campaign is helping stakeholders in the organic community unite for rehabilitation of the NOP.  We need a sweeping management shakeup at the National Organic Program.  We need your help to build momentum for change.

NOTE:  More specifics on Cornucopia’s CHANGE@USDA campaign can be found at:
http://www.cornucopia.org/2009/02/demand-change-reform-the-usdas-organic-program/

Please make additional copies of the proxy-letter for your friends and family and mail them back to The Cornucopia Institute ASAP … at PO Box 126, Cornucopia, WI 54827 … and please forward this message on to others!

If you wish to be removed from our list, please email info@westonaprice.org

IMPORTANT ACTION ALERT
FLAWED FOOD SAFETY BILLS IN CONGRESS

Many of you have been hearing about HR 875, a food safety bill that has been introduced in Congress.  Although much of what has circulated the internet is not accurate, HR 875 does pose serious problems for sustainable farmers and their consumers. Unfortunately, there are already four other “food safety” bills that also pose serious problems:  HR 814, HR 759, S 425, and S 510.  HR 814 is essentially a mandatory NAIS bill, while the others focus on produce, processed foods and game under FDA jurisdiction.

Consumers who buy nutrient-dense foods from local, sustainable farmers can feel secure about the safety of their food.  The same is not true for the majority who buy their food in grocery stores from mass-production industrialized operations.  We understand the pressure that Congress faces to improve the safety of that mainstream system.  But it is critical that the laws not interfere with the right to choose local foods or with our farmers’ ability to raise safer, healthier foods!

Small sustainable farms are fundamentally different from factory farms, and should not be regulated the same way!  All of the proposed food safety bills suffer from a “one-size-fits-all” approach.  And even though the bills’ sponsors might intend for them to apply only to food crossing state lines, the federal agencies regularly take a broader view of their jurisdiction.  The FDA’s and USDA’s past actions clearly show that Congress must place strict limitations on these agencies, or they will impose burdensome and unfair regulations and enforcement actions on small farms.

We don’t know which of these bills will move forward to committee hearings — or perhaps another bill, not yet filed, will be the one to move forward.  So we encourage everyone to send a clear message: Protect our farms from bad regulation!

TAKE ACTION:  Call your U.S. Representative and Senators.  If you do not know who represents you, you can find out at www.congress.org or by calling the Capitol Switchboard at 202-224-3121.  Ask to speak to the staffer who handles food safety issues.

Talk with the staffer about why you support local foods.  Tell them you oppose the five bills listed above.  Ask that they support a food safety bill that focuses on the real threats to food safety, such as uninspected imports from China and lax inspections of massive slaughterhouses and other factory processing, and ask that any new laws explicitly exempt small farmers. Explain that this issue cannot be left to the agencies’ discretion, and you want a clear focus on the broken factory farm system and not on small, sustainable farmers.

UPDATE: Congressional Hearing on NAIS

Last Wednesday, the U.S. House Subcommittee on Livestock, Dairy and Poultry held a hearing on NAIS.  The questions and comments of several of the Subcommittee members revealed that they view NAIS as a food safety program and critical for animal health in case of a “catastrophic outbreak.”  One member said, in essence, that the costs to farmers financially and in loss of privacy must be weighed against the “cost in human life” if NAIS isn’t implemented.

Yet USDA continues to provide absolutely no scientific evidence to support the claim that NAIS will do anything at all to improve animal health or food safety!  What NAIS will do is impose government surveillance and significant expense on animal owners for no real benefit to the public.  The only ones who will benefit from NAIS are the meat packers and exporters, tag manufacturers, database managers and other large corporations.

TAKE ACTION #2:  You can send written testimony to the Subcommittee before Friday, March 20.  Send your testimony to the Hearing Clerk, Jamie Mitchell, atJamie.Mitchell@mail.house.gov

Put “March 11 Hearing – Animal Identification Programs” in the subject line.  Keep your comments clear, polite, and concise.

And be sure to send a copy to your Representative and Senators!  A copy of your letter to the Subcommittee makes a great follow-up to the phone call we suggest above.

The issue of the National Animal Identification System (NAIS) is heating up in both Congress and the USDA.  Below are two important actions alerts explain how you can help protect your right to farm and our food supply!

SUBMIT COMMENTS TO THE USDA BEFORE MARCH 16

The USDA has proposed a rule to require all farms and ranches where animals are raised to be registered in a federal database under the NAIS for existing disease control programs.  The draft rule covers programs for cattle, goats, sheep, and swine.  It also sets the stage for mandatory NAIS animal identification in the future.

It is CRITICAL that the USDA and Congress hear from the hundreds of thousands of people who will be adversely affected by the NAIS program.  This includes not only animal owners, but also consumers who care about local and sustainable foods, taxpayers who object to wasteful government programs, and advocates for a safer food system.

TAKE ACTION:  Submit comments to USDA online or by mail.  The comments must be received by USDA by Monday, March 16, 2009.

You can submit comments online at the USDA’s official site:
http://www.regulations.gov/fdmspublic/component/main?main=DocketDetail&d=APHIS-2007-0096

An easier way to comments online is through the Organic Consumers Association’s system, at:
http://salsa.democracyinaction.org/o/642/campaign.jsp?campaign_KEY=26665

Please be sure to personalize the letter!  It can be as easy as a couple of sentences at the beginning stating who you are (for example, a farmer, consumer, property rights proponent) and why you care about NAIS.

Or mail two copies of your comments to USDA at : Docket No. APHIS-2007-0096, Regulatory Analysis and Development, PPD, APHIS, Station 3A-03.8, 4700 River Road Unit 118, Riverdale, MD 20737-1238.  Clearly state that your comments refer to Docket No. APHIS-2007-0096.

Sample comments can be downloaded from the Take Action page atwww.FarmAndRanchFreedom.org

CONGRESSIONAL HEARING ON NAIS, MARCH 11

The U.S. House Subcommittee on Livestock, Dairy and Poultry will hold a hearing on “animal identification programs” on Wednesday, March 11, 2009.  This is the first time in several years that any Congressional Committee will hear testimony about NAIS!  It is critical that the thousands of farmers and consumers who oppose NAIS make their voices heard in this process!

STEP 1: Before the Hearing:

At the end of the alert is a list of Subcommittee members.  If one of the Subcommittee members is from your state, call that member.  If your state does not have any representation on the Subcommittee, contact your own Representative and ask him or her to approach the Subcommittee to urge them to oppose NAIS.  If you’re not sure who represents you, go tohttp://www.congress.org

When you call, ask to speak to the staffer who handles agricultural issues, and talk with them about your concerns about NAIS.  Use a brief personal story to explain how NAIS would impact you.  Emphasize that you want them to ask hard questions of both the industry and USDA representatives, and to make sure that people representing those who oppose NAIS are also heard at the hearing.

STEP 2: At the Hearing:

If you are in the DC area, please try to come to the hearing!

WHEN: Wednesday, March 11th – 10:00 a.m.
WHERE: 1300 Longworth House Office Building  (go to http://www.aoc.gov/cc/cobs/lhob.cfm for maps and parking information)
WHAT: Subcommittee on Livestock, Dairy, and Poultry — Public hearing to review animal identification systems.

The subcommittee will hear invited testimony only, so you won’t be able to speak at the hearing.  But it is still good for the subcommittee to know that a lot of people care enough about this issue to show up in person!

Immediately after the hearing, we encourage you to visit the Subcommittee members’ offices.  Be polite and concise during your visit.  Let them know that you were at the hearing because you are against NAIS.  Briefly bring up one or two points that you felt weren’t covered at the hearing that show the problems with NAIS.  Keep your visit short and thank them for their time.

STEP 3: After the Hearing:

You can submit written testimony to the subcommittee before the hearing, at the hearing, or up to 10 days after the hearing.  Send your testimony to the Hearing Clerk, Jamie Mitchell, atJamie.Mitchell@mail.house.gov Be sure to put “March 11 Hearing – Animal Identification Programs” in the subject line.  Keep your comments clear, polite, and concise.

We will send out some guidance after the hearing for key points to make in your testimony, based on what is said at the hearing.  If you are submitting comments before the hearing, you can draw ideas from the comments submitted by FARFA on the USDA’s proposed rule for NAIS, posted at:
http://farmandranchfreedom.org/content/files/090202_FARFA_Comments_USDA_rule.pdf

SUBCOMMITTEE MEMBERS:

Below are the Subcommittee members, their party and state, and phone numbers.  You can also send an email by using this format: firstname.lastname@mail.house.gov We strongly recommend that you make at least your initial contact with the ag staffer with a telephone conversation.

Mike Rogers (R-AL), (p):  202-225-3261, (f): 202-226-8485
Dennis Cardoza (D-CA), (p): 202-225-6131, (f): 202-225-0819
Jim Costa (D-CA), (p): 202-225-3341, (f):  202-225-9308
Joe Baca (D-CA), (p): 202-225-6161, (f): 202-225-8671
Betsy Markey (D-CO), (p): 202-225-4676, (f): 202-225-5870
David Scott (Chair), (D-GA), (p): 202-225-2939, (f): 202-225-4628
Leonard Boswell (D-IA), (p): 202-225-3806, (f): 202-225-5608
Steve King (R-IA), (p): 202-225-4426, (f): 202-225-3193
Walt Minnick (D-ID), (p): 202-225-6611, (f): 202-225-3029
Frank Kratovil, Jr. (D-MD), (p): 202-225-5311, (f): 202-225-0254
Adrian Smith (R-NE), (p): 202-225-6435, (f): 202-225-0207
Tim Holden (D-PA), (p): 202-225-5546, (f): 202-226-0996
David P. Roe (R-TN), (p): 202-225-6356, (f):  202-225-5714
K. Michael Conaway (R-TX), (p): 202-225-3605 or 866-882-3811, (f): 202-225-1783
Randy Neugebauer, Ranking Minority Member (R-TX), (p): 202-225-4005 or 888-763-1611, (f): 202-225-9615
Bob Goodlatte (R-VA), (p): 202-225-5431, (f): 202-225-9681
Steve Kagen (D-WI), (p): 202-225-5665, (f): 202-225-5729

For more information about NAIS, go to www.FarmAndRanchFreedom.org

USDA COMMENT PERIOD ENDS MARCH 16

In January, the USDA proposed a rule to require farms and other properties where animals are raised to be registered in the federal NAIS database for existing federal disease control programs.  The rule also sets the stage for future mandatory animal identification.  If you haven’t already submitted comments on this proposed rule, please be sure to do so before March 16!  An easy way to comment online is through the Organic Consumers Association’s automated system, at http://salsa.democracyinaction.org/o/642/campaign.jsp?campaign_KEY=26665

Please be sure to personalize the letter!  It can be as easy as a couple of sentences at the beginning stating who you are (for example, a farmer, consumer, property rights proponent) and why you care about NAIS.

CONGRESSIONAL HEARING ON NAIS, MARCH 11

The U.S. House Subcommittee on Livestock, Dairy and Poultry will hold a hearing on “animal identification programs” on Wednesday, March 11, 2009.  This is the first time in several years that any Congressional Committee will hear testimony about NAIS!  It is critical that the thousands of farmers and consumers who oppose NAIS make their voices heard in this process!

STEP 1: Before the Hearing:

At the end of the alert is a list of Subcommittee members.  If one of the Subcommittee members is from your state, call that member.  If your state does not have any representation on the Subcommittee, contact your own Representative and ask him or her to approach the Subcommittee to urge them to oppose NAIS.  If you’re not sure who represents you, go tohttp://www.congress.org

When you call, ask to speak to the staffer who handles agricultural issues, and talk with them about your concerns about NAIS.  Use a brief personal story to explain how NAIS would impact you.  Emphasize that you want them to ask hard questions of both the industry and USDA representatives, and to make sure that people representing those who oppose NAIS are also heard at the hearing.

STEP 2: At the Hearing:

If you are in the DC area, please try to come to the hearing!

WHEN: Wednesday, March 11th – 10:00 a.m.
WHERE: 1300 Longworth House Office Building  (go to http://www.aoc.gov/cc/cobs/lhob.cfm for maps and parking information)
WHAT: Subcommittee on Livestock, Dairy, and Poultry — Public hearing to review animal identification systems.

The subcommittee will hear invited testimony only, so you won’t be able to speak at the hearing.  But it is still good for the subcommittee to know that a lot of people care enough about this issue to show up in person!

Immediately after the hearing, we encourage you to visit the Subcommittee members’ offices.  Be polite and concise during your visit.  Let them know that you were at the hearing because you are against NAIS.  Briefly bring up one or two points that you felt weren’t covered at the hearing that show the problems with NAIS.  Keep your visit short and thank them for their time.

STEP 3: After the Hearing:

You can submit written testimony to the subcommittee before the hearing, at the hearing, or up to 10 days after the hearing.  Send your testimony to the Hearing Clerk, Jamie Mitchell, atJamie.Mitchell@mail.house.gov Be sure to put “March 11 Hearing – Animal Identification Programs” in the subject line.  Keep your comments clear, polite, and concise.

We will send out some guidance after the hearing for key points to make in your testimony, based on what is said at the hearing.  If you are submitting comments before the hearing, you can draw ideas from the “Reasons to Stop NAIS” posted on the Farm-to-Consumer Legal Defense Fund’s site at http://www.ftcldf.org/nais.html (scroll down past the news items and lawsuit information) or from the comments submitted by FARFA on the USDA’s proposed rule for NAIS, posted at:
http://farmandranchfreedom.org/content/files/090202_FARFA_Comments_USDA_rule.pdf

SUBCOMMITTEE MEMBERS:

Below are the Subcommittee members, their party and state, and phone numbers.  You can also send an email by using this format: firstname.lastname@mail.house.gov We strongly recommend that you make at least your initial contact with the ag staffer with a telephone conversation.

Mike Rogers (R-AL), (p):  202-225-3261, (f): 202-226-8485
Dennis Cardoza (D-CA), (p): 202-225-6131, (f): 202-225-0819
Jim Costa (D-CA), (p): 202-225-3341, (f):  202-225-9308
Joe Baca (D-CA), (p): 202-225-6161, (f): 202-225-8671
Betsy Markey (D-CO), (p): 202-225-4676, (f): 202-225-5870
David Scott (Chair), (D-GA), (p): 202-225-2939, (f): 202-225-4628
Leonard Boswell (D-IA), (p): 202-225-3806, (f): 202-225-5608
Steve King (R-IA), (p): 202-225-4426, (f): 202-225-3193
Walt Minnick (D-ID), (p): 202-225-6611, (f): 202-225-3029
Frank Kratovil, Jr. (D-MD), (p): 202-225-5311, (f): 202-225-0254
Adrian Smith (R-NE), (p): 202-225-6435, (f): 202-225-0207
Tim Holden (D-PA), (p): 202-225-5546, (f): 202-226-0996
David P. Roe (R-TN), (p): 202-225-6356, (f):  202-225-5714
K. Michael Conaway (R-TX), (p): 202-225-3605 or 866-882-3811, (f): 202-225-1783
Randy Neugebauer, Ranking Minority Member (R-TX), (p): 202-225-4005 or 888-763-1611, (f): 202-225-9615
Bob Goodlatte (R-VA), (p): 202-225-5431, (f): 202-225-9681
Steve Kagen (D-WI), (p): 202-225-5665, (f): 202-225-5729

For more information about NAIS, go to www.FarmAndRanchFreedom.org

Action Alert: NAIS in Appropriations Bill

The 2009 omnibus Appropriations bill, HR 1105, passed the House last week.  The bill includes $14.5 million of funding for NAIS, which is significantly less than the amount requested by the USDA for FY 2009.

Representative Obey (D-WI) included a statement in the record about the intended uses of the appropriations for the USDA, including timelines and performance goals for NAIS.  This statement does not mandate NAIS because it is not part of the bill itself.  But it implies approval of USDA’s Business Plan and pushes USDA to move forward with implementing it, including the use of existing disease control programs and other coercive tactics to implement NAIS.

Call your Senators and ask that they support an amendment to strip the NAIS funding out of the bill!  You can find your Senators’ contact information at www.congress.org or by calling the Capitol Switchboard at 202-224-3121.

The good news is that it appears that the provision that would have required the School Lunch Program to buy meats only from NAIS-registered farms did NOT make it into the omnibus Appropriations bill.  Thank you to everyone who contacted their Congressmen last summer and fall to oppose that provision!

To read the Omnibus Appropriations bill, go to www.thomas.gov and enter “HR 1105″ in the search box.  Click the option for “Bill Number” and then hit “search.”  Rep. Obey’s explanatory statement can be read by clicking on the link for “H1653-H2088″ under “Note” (towards the top of the page of the search result).

OTHER NEWS:

The House Subcommittee on Livestock, Dairy and Poultry has announced that it will hold a hearing on Wednesday, March 11, on “animal identification programs.” The agenda and list of witnesses is not yet public.  Look for an alert as soon as we get more information!

The USDA has proposed a rule to require all farms where animals are raised to be registered in a federal database under the National Animal Identification System (NAIS) for existing disease control programs.  The draft rule covers programs for cattle, sheep, goats, and swine.  It also sets the stage for the entire NAIS program to be mandated for everyone, including anyone who owns even one livestock animal, for example, a single chicken or a horse.

It is CRITICAL that the USDA and Congress hear from the hundreds of thousands of people who will be adversely affected by the NAIS program.  This includes not only animal owners, but also consumers who care about local and sustainable foods, taxpayers who object to wasteful government programs, and advocates for a safer local food system.

STEP 1:  Submit comments to USDA online or by mail.  The comments must be received by USDA by March 16, 2009.

Submit comments online at:
http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=090000648081c664
Click on the yellow balloon next to “add comments.”

Or mail two copies of your comments to USDA:  Docket No. APHIS-2007-0096, Regulatory Analysis and Development, PPD, APHIS, Station 3A-03.8, 4700 River Road Unit 118, Riverdale, MD 20737-1238.  Clearly state that your comments refer to Docket No. APHIS-2007-0096.

You can download sample comments at www.farmandranchfreedom.org/content/files/090202_sample_comments.doc or see the sample comments at the end of this alert

STEP 2:  Send a copy of your comments to your Congressman and Senators.
You can find who represents you, and their contact information, at www.congress.org

Organic Consumers Association has set up an automated system for folks to submit comments on the proposed USDA NAIS rule

http://salsa.democracyinaction.org/o/642/campaign.jsp?campaign_KEY=26665

STEP 3:  Spread the word!  Forward this alert to your friends, neighbors, and any agriculture or food-related mail lists you are on.  You can also download a flyer and the sample comments at http://farmandranchfreedom.org/content/take-action to put out at local farmers markets, riding stables, feed stores, etc.

BACKGROUND

The USDA has been working for over five years to force NAIS onto American animal owners.  NAIS is designed to identify and track each and every individual livestock and poultry animal owned by family farmers, hobby farmers, homesteaders, and pet owners across the country.
USDA claims that NAIS is a disease tracking program, but has refused to provide any support for its claims.  In reality, NAIS will impose high costs and government surveillance on every farmer and animal owner for no significant benefits, and will likely force many small producers out of business.

NAIS does nothing to improve food safety for consumers or prevent animal diseases.  This program is a one-size-fits-all program developed by and for big Agribusiness.  NAIS will increase consolidation of our food supply in the hands of a few large companies and put the brakes on the growing movement toward local food systems.

Despite promises to the contrary, the USDA’s new proposed rule would make portions of the NAIS mandatory for thousands of people in every state.   Anyone who participates in federal disease control program for cattle, sheep, goats or swine will have their premises registered.    The NAIS Premises Identification Number (PIN) will become the only form of premises identification acceptable for USDA animal health purposes, with no opt-out provision.

The proposed rule would also limit official Animal Identification Numbers to the NAIS-compliant 840-numbering system, laying the groundwork for future regulations that would limit people’s options on the types of tags they could use.

The proposed rule is not final yet. You can help stop it by visiting the Federal Registry and making a comment.  Go to http://www.regulations.gov/fdmspublic/component/main?main=DocketDetail&d=APHIS-2007-0096 and click on the yellow balloon under “add comments.”  And send a copy of your comments to your elected officials, letting them know how you feel about NAIS.

The grassroots movement has already successfully stalled USDA’s plans for NAIS, which originally called for the entire program – premises registration, animal identification, and tracking – to be mandatory by January 2009.   The proposed rule is an opportunity to get thousands of objections in the formal record, and have an even greater impact.  It is imperative that people speak up to protect our right to farm and our food supply!

FOR MORE INFORMATION

Go to www.FarmAndRanchFreddom.org or contact Judith McGeary, 512-243-9404 or Judith@FarmAndRanchFreedom.org

SAMPLE COMMENTS

[Mail two copies to the address below.  Or submit comments online at:
http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=090000648081c664 ]

Date: ____________________

Docket No. APHIS-2007-0096
Regulatory Analysis and Development PPD, APHIS
Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238

Re: Docket No. APHIS-2007-0096

I urge the USDA to withdraw its proposed rule to implement portions of the National Animal Identification System (NAIS), Docket No. APHIS-2007-0096.

I am a ______________________________

_______________________________________

___________________________________________________________________________
[State who you are - for instance, are you a farmer, consumer, or horse owner -- and why this issue matters to you]

The proposed rule mandates the NAIS Premises Identification Number (PIN) as the sole means of identifying properties for USDA animal health purposes.  The proposed rule also mandates the use of the NAIS numbering system (i.e. the “840 numbering system”) for eartags using official animal identification numbers.  Tags using other numbering systems would be required to be linked to a NAIS PIN.

The draft rule is seriously flawed for multiple reasons:

1) Does not substantiate the alleged benefits to animal health.  USDA makes general claims about the benefits of identifying locations where animals are kept, but the agency does not address the ability of existing programs to meet this purpose, nor how the proposed rule would improve the capability to identify locations.

2) Ignores the costs and burdens.   The proposed rule would substantially increase costs for livestock owners and taxpayers.  Costs include the development and maintenance of a massive database; purchase of 840-numbered tags by animal owners; changes by state agencies to make existing programs consistent with the rule; and increased federal government intrusion into the lives and daily activities of farmers and other animal owners.

3) Violates individuals’ religious beliefs.  Amish, Mennonite, and some other individuals have religious objections to the universal numbering system under NAIS.

4) Creates disincentives for people to seek veterinary care for their animals and participate in existing disease control programs.  The proposed rule lists four animal disease programs-tuberculosis , brucellosis, scrapie, and Johne’s – and will also impact others.  These programs include provisions for veterinary care through vaccinations and testing.  Animal owners who object to NAIS may avoid participating in these programs, thereby increasing health risks to the public and farm operations.

The proposed rule is a significant step towards implementing the entire NAIS program.  Thus, the agency should address the fundamental question of whether it should be implementing NAIS at all.  In addition to the problems with the draft rule listed above, there are many additional objections to the entire NAIS program:

1) No significant benefits: USDA’s assertions that NAIS will provide benefits for animal health are not supported, and actually contradict basic scientific principles.

2) High costs for animal owners and taxpayers:  These costs include: (1) the development, maintenance, and update of massive databases; (2) the costs of tags, most of which will contain microchips; (3) the labor burdens for tagging every animal; (4) the paperwork burdens of reporting routine movements; and (5) the costs of enforcement on millions of individuals.

3) Impracticality:  The databases to register the properties, identify each animal, and record billions of “events” will dwarf any system currently in existence.

4) Waste of money:  The USDA has already spent over $130 million on NAIS implementation, but has yet to develop a workable plan for the program.

5) Diverts resources from more critical needs such as disease testing, disease prevention through vaccination and improved animal husbandry practices, and disease detection in currently uninspected livestock imports.

6) Damage to food safety efforts:  NAIS will not prevent foodborne illnesses, such as e. coli or salmonella contamination, because the tracking ends at the time of slaughter.  Food safety is better served by focusing on programs such as increased testing for bovine spongiform encephalopathy (BSE or Mad Cow), improved oversight of slaughterhouses and food processing facilities, and increased inspections of imported foods.  Programs such as NAIS that burden small, sustainable farmers will hurt efforts to develop safer, decentralized local food systems

7) Discourages involvement in farming or animal husbandry:  Because of costs and government intrusion, some people will choose not to stay in farming or go into farming.  This will result in less competition, greater reliance in foreign imports and poor quality at higher prices.

I urge the USDA to withdraw the proposed rule to implement portions of the National Animal Identification System, Docket No. APHIS-2007-0096.

Sincerely,
Name: ___________________________________
Address: __________________________________
City, State Zip: _____________________________

Additional Comments:

HAVING TROUBLE SUBMITTING COMMENTS?

Some people have reported problems with the online Federal Register comment process.  If you don’t see your comments posted on the website within a few hours, think about these issues:

1)  Make sure you clicked on the yellow balloon under “add comments” next to the very first listed document (the proposed rule).  You can also  use this link:
http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=090000648081c664

2)  Be sure to fill out all of the required fields, marked with a red star

3)  Submitting attachments with other comments can sometimes cause a problem.  If you wish to submit a word or pdf document, submit it separately from comments typed into the “general comments” field

4)  If you don’t get a page showing a confirmation number, go back through each step.

5)  Ultimately, you can always submit using the regular mail as an alternative. Send TWO copies to:

Docket No. APHIS-2007-0096
Regulatory Analysis and Development, PPD, APHIS
Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238

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14056 E. State Road 66

Rome, Indiana 47574

The website for the Lafayette/West Lafayette, IN chapter of the Weston A. Price Foundation is moving to lafayette-wapf.com. Please move your bookmarks.