After speaking my alotted three minutes at the NAIS Listening Session in Riverside, I decided to write up my comments, so that I could include all the detail and submit them to the Federal eRulemaking Portal at<http://www.regulations.gov/fdmspublic/component/main?main=DocketDetail&d=APHIS-2009-0027>. This turned out to be easier said than done.
After several tries, posting my comments to the Comment section for the original Notice and receiving a tracking number, my comments failed to appear. Subsequent comments by others have appeared, so I assume that my submission was not made correctly. Failing at the electronic method, I decided to try the phone numbers listed. The one listed for APHIS NAIS inquiries, 301-734-0799, has a full mailbox and does not allow further messages to be recorded. There is no answer at the other, for Dr. Adam Grow, Director, Surveillance and Identification Programs, National Center for Animal Health Programs, 301-734-3752.
Growing increasingly frustrated, I started calling other numbers posted for contacts in the Public Affairs department. The emergency phone number for reporters on deadline finally was answered by a live person. She, however, knew nothing about how to post comments, nor was anyone available, at 4 pm on a Friday, to answer such a question.
I've spent a fair amount of time on computers, and if this system is foiling me, I'm probably not the only one.
I shall send my comments by regular mail to USDA-APHIS, addressed to Dr. Grow, National Center for Animal Health Programs, VS, APHIS, 4700 River Road Unit 200, Riverdale, MD 20737. But I couldn't have invented a more telling experience about dealing with the USDA on the issue of NAIS.
My submission to the USDA's NAIS Listening Session:
Statement from Christine Heinrichs, SPPA Historian, on behalf of the Society for Preservation of Poultry Antiquities:
I am grateful for the opportunity to give voice to the opposition the poultry breeders of the Society for Preservation of Poultry Antiquities have to the National Animal Identification System.
In the cover letter of John R. Clifford, Deputy Administrator for Veterinary Services dated May 7, 2009, he states that the goals of the sessions are to “develop a system that we can all support – one that facilitates tracing diseased or exposed animals and assists in safeguarding animal health, one that promotes our exports, one that stands out among other country’s (sic) systems, and one that is workable for everyone involved in producing and marketing livestock.”
Regarding animal disease tracing: The National Poultry Improvement Plan continues to work well in managing several significant poultry diseases. NAIS is not needed. An effective plan is already in place. Monitoring for Avian Influenza in Live Bird Markets has been effective for Low Pathogenic AI. No High Pathogenic H5N1AI has been found in North or South America. This speaks well for the effectiveness of these programs.
Crowding animals together in filthy conditions, living in their own waste, maintained on subclinical doses of antibiotics, is the textbook way to develop virulent animal diseases that might then be transmitted to humans. I commend the USDA for being concerned about animal disease. The best way to avoid developing such infectious agents is to stop keeping birds in such conditions and encourage more small flock owners to raise birds in clean, healthy conditions. The USDA’s burdens on small farmers while encouraging increased development of Concentrated Animal Feeding Operations suggests that the agency is less committed to healthy birds than it is to the interests of large, wealthy industrial producers.
Reducing animal disease through preventive measures and supporting animal health would be a better use of resources than tracing it after the fact. In a world where we must make choices about how to allocate limited resources of time, money and expertise, SPPA recommends continuing the well-accepted programs presently in use and expanding support for small flock owners. Consumers are indicating their support for a choice of poultry products by buying locally raised meat and eggs. Demand for these products consistently exceeds the supply.
Regarding promoting exports: Whatever animal identification is required for birds being raised for meat and egg exports should certainly be available to those who wish to participate in those markets. Those who do not participate in export markets should not be required to participate in an expensive, cumbersome system to accommodate those who do. Inspections of imported animals and agricultural products should be effectively increased. Entry of animals from countries with known disease problems should be carefully examined and tested or barred entirely
Regarding our standing with respect to other countries: This country could have a system that stands out among other countries’ by supporting the small flock owners and the maintenance of traditional breeds. These birds could be the envy of the world. They could play a significant part in international recovery, by providing stock that is adapted to local conditions. Commercial hybrids cannot fill the needs of feeding people in developing countries.
Regarding workability: NAIS is technically unworkable. The databases for tracking every bird and the infrastructure to follow them have not been demonstrated. NAIS accomplishes too little for too much cost. It is practically unworkable, because farmers will not sign up, as the USDA must now, after these Listening Sessions, be aware.
The USDA’s report on the Benefit-Cost Analysis of NAIS makes no mention whatsoever of small flock poultry keepers. While NAIS has minimal costs, on a per-bird basis, for industrial poultry operations, for small flock keepers, it is burdensome and intrusive.
Small flock owners, especially those who keep historic breeds, are doing a service to American food systems by keeping unusual genetic stock alive. Punishing them by requiring premises registration, individual bird identification and movement tracking does nothing to prevent or cure disease and will certainly force many out of business.
The claim that 35 percent of the relevant premises have registered is misleading. Many of those were registered without their knowledge or consent, when they participated in testing or vaccination programs, per the NAIS Business Plan. Those who do not know that their premises have already been registered are unlikely to take the steps, now available through as a result of court decisions, to be removed.
This lack of transparency and deliberately misleading actions increases the suspicion with which the USDA is viewed by small flock owners.
The USDA has vacillated between ‘mandatory’ and ‘voluntary.’ The only way this system can work is if it is truly voluntary: those who want it, or need it to engage in international trade or for other commercial reasons, should have it. Those who do not engage in activities that require such documentation should not be registered without their knowledge and against their will nor punished for declining to participate.
Issues of animal disease are confused with issues of food safety. NAIS will not make processing facilities cleaner or reduce food contamination. Creating policies that decentralize the livestock industry and encourage local, diversified farms would increase animal health, food security, and food safety. Many existing laws already govern unsafe practices. By improving enforcement of those laws and improving inspections of large slaughterhouses and food processing facilities, including unannounced spot inspections, food safety could be improved. Adding NAIS does nothing of itself to improve food safety.
People are learning that sustainable integrated methods produce more and better quality foods than industrial methods. CAFOs promote disease transmission between animals. SPPA encourages the USDA to take note of the needs of the American people for a safe, secure, plentiful food system. Small producers have fed Americans for most of our history. The pollution and cruelty of the industrial system are no longer tolerable. Serving the needs of small flock owners would never produce a system like NAIS.
Wendell Berry, speaking at the NAIS Listening Session in Kentucky, said: “The need to trace animals was made by the confined animal industry – which are, essentially, disease breeding operations. The health issue was invented right there. The remedy is to put animals back on pasture, where they belong. The USDA is scapegoating the small producers to distract attention from the real cause of the trouble. Presumably these animal factories are, in a too familiar phrase, “too big to fail.”
“This is the first agricultural meeting I’ve ever been to in my life that was attended by the police. I asked one of them why he was there and he said: “Rural Kentucky”. So thank you for your vote of confidence in the people you are supposed to be representing. I think the rural people of Kentucky are as civilized as anybody else.
“But the police are here prematurely. If you impose this program on the small farmers, who are already overburdened, you’re going to have to send the police for me. I’m 75 years old. I’ve about completed my responsibilities to my family. I’ll lose very little in going to jail in opposition to your program – and I’ll have to do it. Because I will be, in every way that I can conceive of, a non-cooperator.
“I understand the principles of civil disobedience, from Henry Thoreau to Martin Luther King. And I’m willing to go to jail to defend the young people who, I hope, will still have a possibility of becoming farmers on a small scale in this supposedly free country. Thank you very much.”
SPPA seconds those sentiments.