Page 89 - Summer2009

CONGRESSIONAL HEARING 23 percent of operations among six different cat-
The NAIS is heating up in Congress as well. egories. Moreover, this approach is not consistent
After years of allowing the USDA to implement with the USDA Census, which separately counts
NAIS with federal funding, but no Congres- operations with 1-9 head, operations with 10-19
sional oversight, the House Subcommittee on KHDG DQG RSHUDWLRQV ZLWK KHDG ,Q RWKHU
Livestock, Dairy and Poultry has held two hear- words, the research team had the data available
LQJV DERXW 1$,6 WKLV VSULQJ 7KH ¿UVW KHDULQJ to estimate costs for smaller categories and
featured a line-up of Big Ag groups speaking in simply chose not to. The study uses similarly
favor of a mandatory program, sometimes us- skewed categories for pigs and sheep. Given the
ing the latest euphemism, namely “an effective 86'$¶V RZQ ¿QGLQJ WKDW FRVWV LQFUHDVH DV KHUG
2
program.” But R-CALF USA, an independent size decreases, the study’s choice of categories
cattlemen’s group, gave strong testimony about obscures the real costs to small operations.
why NAIS is not needed and some of the harms Second, the study incorrectly discounts
it would cause. costs for technological infrastructure. The study
The second hearing, done in cooperation acknowledges that NAIS will require extensive
with the Homeland Security’s Subcommittee on technological infrastructure by individuals, in-
Emerging Threats, Cybersecurity, and Science cluding computers, software and internet access.
and Technology, featured an even more biased The study also acknowledges that many small
set of panelists uniformly testifying in favor of farms do not own computers or have internet
a mandatory NAIS. A few Congressmen raised access. Yet the study then assumes that the
3
concerns about the program that were not well- hundreds of thousands of people who will be
addressed by the panelists. forced to buy additional technology would have
“other uses” for those computers, software and
COST-BENEFIT ANALYSIS LQWHUQHW DFFHVV DQG WKHUHIRUH RQO\ FRXQWV
$W WKH ¿UVW KHDULQJ VHYHUDO &RQJUHVVPHQ percent of those costs! While many farms and
DVNHG DERXW WKH FRVW EHQH¿W DQDO\VLV RI 1$,6 individuals may have use for such technology,
that USDA had commissioned almost two years that is obviously not true for everyone, and the
DJR -XVW EHIRUH WKH VHFRQG KHDULQJ 86'$ ¿QDOO\ entire computerization costs should be allocated
released the study. The study acknowledges that to NAIS.
the costs for small farms with cattle would, on Third, the study makes assumptions about
average, be almost three times higher per animal WKH XVH RI JURXS LGHQWL¿FDWLRQ IRU VKHHS DQG SRXO-
WKDQ IRU ODUJH RSHUDWLRQV $QG WKH FRVW EHQH¿W try that contradict the USDA’s own documents.
analysis grossly underestimates the true costs The study states that poultry operations “would The cost-
for small farms because of the numerous gaps, XWLOL]H H[FOXVLYHO\ ORW LGHQWL¿FDWLRQ V\VWHPV´ and benefit

false assumptions and misleading tactics used in assumed that lambs moving direct to slaughter analysis
WKH VWXG\ ,¶OO WRXFK EULHÀ\ RQ D IHZ RI WKH PRVW ZRXOG EH LGHQWL¿HG E\ JURXS RU ORWV ´ But this grossly

HJUHJLRXV ÀDZV DVVXPSWLRQ GRHV QRW UHÀHFW WKH JRYHUQPHQW¶V
First, the study manipulates the categori- plans. Hundreds of thousands of poultry and underestimates
zations to disguise the costs to small farmers, sheep owners would not be able to use group the true costs
homesteaders and other individuals with a few LGHQWL¿FDWLRQ IRU WKHLU DQLPDOV
6
animals. For example, in estimating the costs for The USDA documents state that group or for small farms
beef cattle, the study uses six categories based on ORW LGHQWL¿FDWLRQ LV DYDLODEOH ZKHUH JURXSV RI because of the
the number of cattle on the farm, and estimates animals are managed together from birth to death numerous
the costs for producers in each category. 7KH ¿UVW and not commingled with other animals. In prac-
1
category includes operations that have anywhere tice, this only occurs in the vertically integrated gaps, false
IURP WR KHDG RI FDWWOH DQG HQFRPSDVVHV FRQ¿QHPHQW RSHUDWLRQV QRW RQ VPDOO IDUPV assumptions
RSHUDWLRQV RU SHUFHQW RI WKH WRWDO Many pastured poultry and grass-fed lamb farms and misleading
number of operations. There is no valid statisti- ZRXOG QRW TXDOLI\ IRU JURXS LGHQWL¿FDWLRQ \HW
cal reason to create a single category with that USDA did not even try to quantify the costs to tactics used in
many operations while dividing the remaining these farms or to the many people raising a few the study.

SUMMER 2009 Wise Traditions 87