USDA Listening Sessions Public Comments

Karen Nowak, Brookfield, NY - May 22, 2009

Re: Docket # APHIS-2009-0027

National Animal Identification System

I have owned, bred and shown horses for over 40 years.  I also owned and managed a horse boarding facility for 10 years.

First and foremost, NAIS is NOT a one-size-fits-all program!  Not between species or even within the various species groups themselves.  NAIS was designed by and for the benefit of large agricultural corporations who export food and the tagging/software technology corporations, who have bragged to their stockholders about the windfall profits they will realize if NAIS is implemented.

Like many others, I have poured through the USDA/Kansas State University Benefit Cost Analysis.  I am disgusted and angry that our taxpayer dollars paid for a study that fell far short of what we have asked for since the first NAIS document was released in 2005.  Instead of providing clear, accurate, and concise information on the costs involved in this program and how it will help in disease control, this study made numerous inaccurate assumptions about the horse industry and 'guessed' at costs.  How can this be acceptable FOUR FULL YEARS after the first NAIS document was released to the public?!

What business invests in new technology without knowing the true costs as well as potential benefits?  The answer is none that is successful yet, in the worst economic recession in decades, you expect us to do just that!

We, the small farmers and horse owners, have a method of traceability in place that has proven to work time and again.  NAIS will not improve our current system and in all likelihood will make traceability more difficult for the following reasons:

1)   If the federal government cannot locate 12 million illegal aliens, how do you propose to locate and track 9.6 BILLION livestock (per the 2007 Ag Census)?  Those of us who know livestock know that number is vastly UNDERestimated as many, many small livestock owners were not included in this survey.  The fact is that it will be impossible!

2)   There is tremendous lack of trust in the USDA – for good reason.  Time and again with many of your programs, you have sacrificed the small farmer to give preference to large agri-business.  You have changed your story far too many times regarding NAIS when you play to the audience you think is listening.  One minute this is a disease control program and the next you claim it is needed for food safety.  We ALL know that NAIS is NOT a food safety program yet you persist in allowing members of Congress to believe that it is!  Last, you have failed since 2005 to answer our basic questions – ACCURATE cost and confidentiality of our information.

3)   The vast majority of horse owners and small farmers will not and cannot comply with this intrusive and expensive system for financial, personal or religious reasons.

If implemented as a mandatory system, NAIS will place an unreasonable financial and labor burden on horse and other non-food livestock owners as well as small farmers and those who sell directly to the public because we all already have full traceability in our livestock and products.

My opinion, after reading and rereading every NAIS document that has been published since 2005, is that small farmers and non-food livestock groups like horse owners will shoulder the majority of the costs of NAIS without gaining ANY benefit whatsoever.  IOW – the LARGEST group of livestock owners will suffer for the benefit of the few.  Those who need NAIS for business reasons should have it but it should be run and paid by those industries! 

The $150 million that has been spent on NAIS thus far would have been far better spent securing our borders to keep diseased animals out, improving our system of quarantine for those animals that are allowed in and improving inspection at the slaughterhouses and processing plants, which is where the vast majority of food contamination arises.  If the American taxpayer knew the true statistics for inspections both at our borders and at the slaughterhouse and processing plants, there would be an outcry the likes of which this country has not seen in a very long time.

It's long past time for the USDA to stand up and admit that 'you've been had' by the technology companies who stand to make a windfall in profits on NAIS and the multinational agriculture corporations, who once again are looking for a government handout.  Stop the “knee-jerk reaction” to the problems you have created and focus your attention on solving those very real problems.  This whole program needs to be scrapped.  Let those who stand to benefit from it pay for it and manage it!