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requirements on animal owners, the agency needs to provide solid More detail on each of these recommenda-
scientific and economic analyses to show why these steps are needed. tions is available at http://farmandranchfreedom.
• There is still no analysis of where the real problem lies. Is it truly an org/sites/farfa/files/Comments-to-USDA-Au-
animal identification problem? Or are the problems with traceability gust-2010.pdf
due to bureaucratic inefficiencies or other issues? On the issue of While the USDA develops its new proposal,
animal health, where are the gaps? the issue of animal ID remains contentious
• Government program personnel still assume that electronic ID is within Congress as well. The House Agricultural
the best approach. While USDA has committed to using low-tech Appropriations Subcommittee and the Senate
methods for the framework, there are repeated references to “progress Appropriations Committee have both zeroed out
over time,” and every government speaker emphasized the benefits of the funding for animal ID in the 2011 Appro-
RFID tags. I asked whether USDA intended to analyze the effective- priations Bill. However, as noted by the Senate
ness of the program before moving towards electronic ID, pointing Committee, the funding may be reinstated later
to the success of the scrapie program using non-electronic ID. In in the process.
response, Neil Hammerschmidt said there were no such plans. Dr. The reasons for cutting funding vary, and
Wiemers went further, and contended that, while non-electronic ID the Chair of the House Subcommittee, Con-
has worked for the scrapie program, it is not sufficient for tracing all gresswoman DeLauro, stated: “We have spent
movements. Yet the advocates of electronic ID still fail to show that over $147 million on this program since 2004
it is needed or cost-effective. . . . . We do not feel it is a good use of resources
• The proposal itself is confusing and unclear. For example, there is no to fund NAIS until the agency develops a clear
written definition of “traceability unit,” and we’ve heard three dif- plan for a mandatory system with measurable
ferent definitions at three different public meetings. At the Colorado goals, long-term funding levels, and a plan for
meeting, Colorado State Vet Dr. Roehr stated that it was a geographical successful implementation.”
unit and could be anything from the whole state to a set of counties I agree that Congress should not spend any
to a county to an individual premises. At the Utah meeting, Montana more taxpayer dollars on the program. But the
State Vet Dr. Zaluski stated that the traceability unit was either a physi- answer is not to create a mandatory program
cal location or a group of animals. At the Texas meeting, Oklahoma as DeLauro seeks to do. Rather, Congress and
State Vet Dr. Brewer stated that “ultimately” it is a premises. Three USDA should re-focus the agency on preventa-
members of the RWG, with three different statements on what the tive measures to protect animal health rather
term means! How can the public provide input when the people who than a traceability program that benefits Big Ag’s
drafted the proposal can’t even explain it clearly? export market while burdening small farmers.

In August, I submitted written comments to the USDA on the new
proposal, with the following recommendations:
ANNUAL MEMBERSHIP DRIVE
1. USDA should provide data and analyses that identify the problem to
be solved and provide a factual basis for developing an appropriate WAPF’s annual membership drive takes
solution. place August through October. Memberships
2. USDA should design the program to provide long-term support for are the life-blood and strength of the Founda-
tion; it is our thousands of members who allow
low-cost, low-tech methods of identification, and avoid creating incen- us to be independent. The more members we
tives for electronic identification. have, the more we are able to do in the way
3. USDA should clearly limit the program to interstate tracing only, of nutrition education. If each of our current
and delete the portions of the Working Group’s proposal that address members (almost 13,000 at this point) brought
intrastate tracing. in just one new member by year’s end, think
4. The regulatory framework and supporting IT systems should con- of how much more we could do!
Those who bring in five new members
nect identification numbers with contact information, not property will receive a signed copy of the deluxe edi-
identification. tion of Nourishing Traditions; sign up fifteen
5. The appointments to the Secretary’s new Advisory Committee on new members and receive a free full registra-
Animal Health should reflect the majority of animal owners, namely tion to our conference, Wise Traditions 2010.
small-scale producers. For details, contact Kathy Kramer at info@
westonaprice.org.
84 Wise Traditions FALL 2010