Hello and welcome to the Farm and Ranch Freedom Alliance e-news alert.  We know you want to stay informed about what is happening and how you can make a difference.  Feel free to forward this email to your friends and acquaintances.
 
Included in this alert is information about a recent USDA notice regarding the NAIS and a USDA notice regarding proposed grass-fed standards. 

OPPORTUNITY TO COMMENT TO THE OFFICE OF MANAGEMENT AND BUDGET

The USDA has published a notice relating to NAIS.  This notice is very limited – USDA is not seeking comments on NAIS in general.  Rather, USDA is conducting “information collection” to support the implementation of NAIS, and has submitted information on its activities to the Office of Management and Budget (OMB).   The notice includes two information collection programs:
(1)  how animal identification numbers are to be assigned to tag manufacturers and resellers, and
(2)  the requirements for entities to apply to participate in managing the databases.
 
Even though the scope of comments is limited, you may still wish to use this opportunity to tell the OMB and your legislators about some of the problems with NAIS that relate to the tags and databases.  Below are some points you may wish to make.  There is no hard deadline, but OMB is encouraging people to submit comments by August 18.
 
Discussion Points:  (the numbers refer to the OMB’s docket number for each notice, so that your comments are properly considered)
 
1.  For both dockets: The information collection will not have practical utility because NAIS cannot legally be implemented.  NAIS, as set out in the USDA’s documents, would violate multiple constitutional provisions, including the 1st, 4th, 5th, and 14th Amendments.  Moreover, Congress has not statutorily authorized the USDA to implement NAIS.
 
2.  For OMB Control Number: 0579-0283. (Information Requirements for Animal Identification Number Tag Manufacturers, Managers, and Resellers): The AIN Management System is based on several false assumptions.
    a.  The first false assumption is that individual identification is necessary and beneficial.
    b.  The second false assumption is that the benefits of individual identification outweigh the costs.  An independent, unbiased cost/benefit analysis must be conducted.
    c.  The third false assumption is that electronic identification can function to protect against intentional introduction of disease.  The current generation of microchips has been proven to be susceptible to cloning, hacking, and infection by computer viruses.
    d.  Last, the stated preferred technology, ISO 11784/17785 microchips, cannot provide unique individual identification.  The ISO technology is designed to be reprogrammable, making it both cheap and easy to change ID numbers even after the microchip has been inserted under the skin of the animal or into a physical tag.  Thus it cannot provide unique, traceable numbers.
 
3.  For OMB Control Number: 0579-0288. (Information Requirements for Private and State Animal Tracking Database Owners):   The USDA’s program creates unethical conflicts of interests.  Entities that are on the working groups developing NAIS and that are supposed to be representing the public interest can apply to run private databases. This creates a profit motive that undermines the fairness of the entire NAIS process.
 
4.  For OMB Control Number: 0579-0288. (Information Requirements for Private and State Animal Tracking Database Owners):   The USDA’s methodology is flawed because it does not provide any protections against fraud, deceptive trade practices, unfair bargaining, or other abuses by the private entities contracting with the government.  The public has been left vulnerable to entities enrolling them in the databases without informed consent, under the guise of a voluntary government program.
 
5.  For OMB Control Number: 0579-0288. (Information Requirements for Private and State Animal Tracking Database Owners):   USDA’s program is based on false assumptions because the contracts with private databases have been used to obscure the true costs of this program and avoid conducting the cost/benefit analysis that the agency must conduct before adopting regulations.
 
6.  For OMB Control Number: 0579-0288. (Information Requirements for Private and State Animal Tracking Database Owners):  USDA’s methodology is flawed because it has not developed a practical design for the entire program, including what the system will and will not address.  The piecemeal fashion in which USDA is implementing NAIS will significantly increase the costs, and perhaps even the technological viability, of the program.
 
You can submit comments online to the Desk Officer for Agriculture, Office of Information and Regulatory Affairs, Office of Management and Budget (OMB), OIRA_Submission@OMB.EOP.GOV or fax (202) 395-5806 and to Departmental Clearance Office, USDA, OCIO, Mail Stop 7602, Washington, DC 20250-7602.
 
In addition to submitting your comments to the OMB, send them to your Representative and Senators.  If you don't know who they are, go to http://www.congress.org/congressorg/home  and enter your zip code in the box on the left-hand side of the screen.  Your official’s contact information will be provided. 

We must educate Congress as well as the agency. The USDA and OMB are secondary, because ultimately Congress controls what happens.  So focus your energy and efforts on your Representatives and Senators, not the agencies.

OPPORTUNITY TO COMMENT ON USDA’S PROPOSED STANDARD FOR “GRASS-FED” LABEL

Below is an action alert sent by the president of the American Grassfed Association.  Although FARFA has not taken an official position, we thought that many of the people on our mailing list may be interested in this issue and wanted to make you aware of it.
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 The USDA has published for comment grass fed standards to define what the term Grass Fed means. This claim defines grass fed to mean animals who receive 99% of their lifetime energy supply from grass and forage. However, it falls short of defining where this forage diet can be fed.
 
To most consumers the term grass fed means animals humanely raised in grass pastures from birth to harvest, the way nature intended. The USDA proposal would allow animals to be kept in confinement, fed harvested forage, corn silage and other grains that have not been separated from their stalks. If this proposed claim passes into regulation you could see feedlot beef fed antibiotics, hormones and legally be labeled grass fed.
 
We feel so strongly about this we are asking for your help in responding to the USDA. We are quite sure you don't want grass fed animals standing in confinement for 160 to 220 days, without shade, eating corn silage and being fed antibiotics and growth hormones. We ask you to please take the time to insure the term Grass Fed  means range or pasture raised not Factory Farmed, confinement raised.
 
As a producer we strongly feel that any grass fed standard must address and restrict confinement feeding as an integral part of that standard, otherwise the label will lose its integrity. As a consumer, we believe you will agree with us and ask that you please E-Mail the USDA at marketingclaim@usda.gov to allow your opinion to be known. Refer to Docket No. LS-05-09.
 
The deadline for accepting comment is August 10. Simply comment that you as a consumer believe that the standard for grass fed must include reference to being raised on pasture and a restriction of confinement feeding systems.
 
Patricia Whisnant, DVM
President, American Grassfed Association
Owner, American Grass Fed Beef
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SUPPORT FARFA’S WORK

If you are not yet a member of FARFA, please consider joining us.  Memberships start at $35/year.   Membership fees and donations support our efforts to educate the public through articles, advertisements, conference tables, and town hall meetings, as well as lobbying at both the state and national level.  Whether you are a farmer or a rancher, a consumer of local foods, or someone who cares about protecting our rights and traditional freedoms, FARFA is working for you!  If you would like to join FARFA, please visit our membership page at http://www.farmandranchfreedom.org/signup.html
 
Thank you for everything you are doing to help in the fight against the National Animal Identification System!  Working together, we can make our voices heard.
 
Judith McGeary
Executive Director
Farm and Ranch Freedom Alliance
1-866-687-6452
info@farmandranchfreedom.org
www.farmandranchfreedom.org