Page 90 - Summer2009

poultry or lambs for their own food or as pets. ers and micro-farmers are not covered. Yet these
Fourth, the study makes unsupported as- people would be covered by NAIS. The USDA’s
sumptions about many of the costs that will be own premises registration statistics reveal the
imposed. For example, the study recognizes that severe undercounting of affected people. While
the cost of RFID readers will not be economical WKH &HQVXV OLVWV RQO\ ³SUHPLVHV´ LQ 0DV-
for small producers, so it advances the premise sachusetts, the USDA has registered 8,066 prem-
8
that a new business will spring up to do custom ises in that state—227 percent of the estimate!
reading. It then assumes that there will be cus- $QG VLQFH WKH FRVW EHQH¿W DQDO\VLV UHOLHV RQ WKH
7
WRP WDJ UHDGHU EXVLQHVVHV ZLWKLQ WZHQW\ ¿YH Census estimates, the estimates of the total costs
miles of each small farm, even though ranches of NAIS—to both individuals and the govern-
in the West and Southwest may encompass more PHQW²DUH IXQGDPHQWDOO\ ÀDZHG
WKDQ WZHQW\ ¿YH PLOHV RI WHUULWRU\ HDFK ,W DOVR 7KLV ZDV D FRVW EHQH¿W DQDO\VLV VR ZKDW
assumes that the cost of RFID reading will be DERXW WKH EHQH¿W SRUWLRQ" 7KH PDLQ EHQH¿WV
comparable to the cost of brand inspections, discussed by the study are related to the export
even though brand inspections do not require market. Indeed, in identifying the “three key
expensive equipment, unlike RFID tagging and points” from the study, USDA lists the value to
UHDGLQJ %DVHG RQ WKRVH IXQGDPHQWDOO\ ÀDZHG the export market and the global marketplace
assumptions, the study claims that someone with DV WKH NH\ EHQH¿WV Not only are the alleged
9
In essence, ¿YH KHDG RI FDWWOH ZRXOG SD\ RQO\ EHQH¿WV EDVHG RQ VSHFXODWLRQ UDWKHU WKDQ IDFW
per head) to have someone drive out to their farm this approach is entirely improper. The majority
individual and electronically read the tags. of the costs of NAIS will be borne by individual

rural $QRWKHU ÀDZ RI WKH VWXG\ ZKLFK KDV EHHQ animal owners ranging from pet owners to large
Americans’ a recurring issue in many debates about NAIS, UDQFKHUV %XW WKH H[SRUW PDUNHW EHQH¿WV ZLOO
is the massive underestimation of the number of accrue almost entirely to a handful of large com-
version of “premises” affected by NAIS, and as a result, the panies who participate in the export market. In
Main Street underestimate of the total costs of the program. essence, individual rural Americans’ version of

will be taxed All of the cost estimates are based on data from 0DLQ 6WUHHW ZLOO EH WD[HG IRU WKH EHQH¿W RI %LJ
the USDA Census. Yet the USDA Census, by Ag’s version of Wall Street.
for the benefit GH¿QLWLRQ FRYHUV RQO\ WKRVH RSHUDWLRQV WKDW ,Q VXPPDU\ WKH 86'$ FRVW EHQH¿W DQDO\VLV
of Big Ag’s have $1,000 or more of agricultural product for is rife with improper statistical manipulations,
version of sale in the census year. Not only do many people unsupported and illogical assumptions, and a
fail to respond to the Census, but hundreds of cavalier disregard for the people who will actu-
Wall Street. thousands of hobby animal owners, homestead- ally bear the costs.

TAKE ACTION!

USDA is accepting written comments through the end of June (and possibly longer). You can use our sample comments:
http://farmandranchfreedom.org/content/Sample-comments. Be sure to personalize them to have the greatest impact!
Submit comments ONLINE: http://www.regulations.gov/fdmspublic/component/main?main=DocketDetail&d=APHIS-
2009-0027. The Federal Register site can be confusing and difficult. Here’s what to do:
1) Click on the yellow balloon under the “add comments” column.
2) Fill out the required fields and type in your comments. If your comments are more than a paragraph or so, we
recommend that you first write them in a word document and then copy & paste them into the comments
field.
3) Click on “next step.”
4) At the end of the process, you should receive a confirmation number.

or MAIL to: Attn NAIS, Surveillance and Identification Programs
National Center for Animal Health Programs, VS, APHIS,
4700 River Road Unit 200, Riverdale, MD 20737

88 Wise Traditions SUMMER 2009