1) The agency should withdraw the proposed rule. If the export market would benefit from the proposed rule, as the agency claims, then the agribusinesses that export meat should pay the costs and offer economic premiums to livestock producers to encourage them to participate in a voluntary system.

2) The agency needs to identify the specific diseases of concern and analyze how to best address those diseases - including prevention measures -- rather than continuing to push a one-size-fits-all tracking program.

3) Significant problems with the proposed regulation include:

• Imposition of new requirements for identifying chickens and other poultry. Small farmers and backyard poultry owners should not be burdened with identifying and tracking birds, and the agency has not shown any need to impose these new requirements.
• Applying the new identification requirements to feeder cattle.
• Applying the requirements to direct-to-slaughter cattle, including both for custom and for retail sales.
• Not recognizing brands and tattoos as official forms of identification.

Please personalize these sample comments rather than doing a form letter. The personalization can be just a few sentences at the beginning of the comments, but it does make a significant difference. And if you have time to write more detailed comments, that's even better!

Dear Secretary Vilsack:

I am a __________________ (farmer, local foods consumer, backyard poultry owner, horse owner, etc.).   I am very concerned that the proposed rule will __________ (not be workable for my farm; impose costs on my farmers that will then be passed on to me; make it prohibitively expensive for me to order baby chicks from out-of-state hatcheries; etc.)

I urge the USDA to withdraw the proposed rule. If the export market would benefit from the proposed rule, as the agency claims, then the meat packing companies that export meat should pay the costs and offer economic premiums to livestock producers to encourage them to participate in a voluntary system. For disease control, the agency needs to focus on preventative measures rather than after-the-fact tracking.

There are significant problems with the proposed rule:

• The imposition of new requirements for identifying chickens and other poultry. Small farmers and backyard poultry owners should not be burdened with identifying and tracking birds, and the agency has not shown any need to impose these new requirements.
• Applying the new identification requirements to feeder cattle.
• Applying the requirements to direct-to-slaughter cattle, both for custom and for retail sales.
• Not recognizing brands and tattoos as official forms of identification.

Sincerely,

Name

Address

City, State Zip

The program is fundamentally flawed because it is not designed to address the real problems we face, and it imposes burdens on producers for the benefit of Big Agribusiness' export markets.  

We have asked USDA for data showing where the problems are in tracking animals currently. Rather than provide that data, USDA hand-picked a few anecdotes, out of the millions of animals in this country. But the agency's unsupported claims do not justify imposing broad new tracking requirements. Small farms are not the source of most disease problems in this country, yet the proposed rule will burden them unfairly.

POULTRY: Small-scale, pastured, and backyard poultry will be particularly hard hit by the proposed rule. While the large confinement operations will be able to use "group identification," the definition of the term does not cover most independent operations. Since thousands of people order baby chicks from hatcheries in other states, these birds cross state lines the first day of their lives. Even if the farmer or backyard owner never takes the bird across state lines again, they will have to use individually sealed and numbered leg bands on each chicken, turkey, goose, or duck to comply with the language of the proposed rule.

Even if the definition of "group identification" were changed to cover small operations, the result would be new paperwork requirements on almost every person who owns chickens, turkeys, or other poultry. The agency has entirely failed to justify imposing these burdens on poultry owners.

CATTLE: Along with new identification requirements imposed on all breeding-age cattle, the proposed rule would require identification and paperwork on calves and young cattle ("feeder cattle"), even though there's no evidence that such requirements will help disease control. In addition, veterinarians and sale barns will have to keep records for 5 years, even though many of these cattle will have been consumed years earlier, creating mountains of useless paperwork.

Producers will only be able to use brands or tattoos as identification if their States enter into special agreements. State agencies will have to build extensive database systems to handle all of the data, creating problems for States' budgets.

HORSES: The proposed rule also requires that horse owners identify their animals before crossing state lines. Although most, if not all, horses that are shipped across state lines are already identified in some fashion, the proposed rule creates a new complication: whether or not a physical description is sufficient identification will be determined by the health officials in the receiving state, leaving vets and horse owners struggling with significant uncertainty as they have to anticipate what will be allowed.

SHEEP, GOATS, and HOGS: The draft rule also covers sheep, goats, and hogs that cross state lines, essentially federalizing the existing programs which have been adopted state-by-state until now.

You can read the proposed rule at www.aphis.usda.gov/traceability/downloads/2011/Proposed Rule.pdf