GAO Letter Report on USDA / NAIS:
90-page "Letter Report" receives analysis
August 4, 2007

I've carefully analyzed the 90-page GAO report: "Report to the Chairman, Committee on Agriculture, Nutrition, and Forestry, U.S. Senate: NATIONAL ANIMAL IDENTIFICATION SYSTEM - USDA Needs to Resolve Several Key Implementation Issues to Achieve Rapid and Effective Disease Traceback."

The following should be of substantial interest to all that own animals and/or property. Like "voluntary compliance," "voluntary until mandatory" is the agenda.

There is no "opt out."

Premises registration equates to giving up one's ability to allow or deny access to private property. Premises registration effectively reduces property owners to tenants, with the USDA and its partners as the landlords, landlords that may enter any part of your property to "inspect" with no advance notice.

Say No now until the USDA and its accomplices, or live with the consequences in the future. The scope is so much larger and more ominous than the GAO, USDA, etc., will admit. How many steps is it from tracking movement of animals to movement of pets ... to movement of people? How many steps is it from radio-frequency ID for animals to RFID for people? Look at the number of manufacturers, from "Digital Angel" to "VeriChip." Will that, too, be "voluntary" until "mandatory?" The Amish and Mennonites believe such things to be the "mark of the beast." Who's to say they are not correct in their belief?

Years of experience and research point to the sea of red flags waving a warning to us all.

"Hindsight is 20-20." Clear and present warnings now can prevent years of regret later.

www.gao.gov/cgi-bin/getrpt?GAO-07-592 (90 pages; 3.60 MB)

See pages:

6/11 (first bulleted item)

"1. USDA does not require potentially critical information - such as the species, date of birth, or approximate age of animals - to be recorded in NAIS animal ID and tracking databases. This information can be critical for efficient traceback because it helps limit the scope of an investigation, thus saving time and potentially minimizing the economic impact. USDA officials told us that although animal-specific data can be valuable, the agency is collecting the minimum amount of information needed due to some producers' concerns about protection of their proprietary information in NAIS databases."

7/12 (first full paragraph)

(excerpt) "...we are recommending that USDA reestablish participation benchmarks to gauge progress in registering premises and identifying and tracking animals; monitor participation; and, if participation does not meet the benchmarks, take further action, such as making participation mandatory ..."

11/16 (second paragraph)

(excerpts) "During the first 2 years of the program's implementation, USDA stated several times that participation in NAIS would initially be voluntary but would eventually become mandatory to achieve full participation ..." "The plan also provided a timeline for implementation, with premises registration and animal ID to be required by January 2008 and the reporting of defined animal movements to be required by January 2009, under what would become an entirely mandatory program. The plan stated that this phased-in approach was "to support the transition from voluntary to mandatory as full implementation is achieved." In addition, the plan also stated that, "While market forces may eventually create more inclusiveness, the clear stakeholder support for transitioning to a mandatory program ..."

12/17 (second full paragraph)

(excerpt) "... USDA first needs to resolve several key implementation issues before making participation mandatory." (see text of entire paragraph, which continues on the following page)

14/19

(excerpt) "... the experts we surveyed say the program will likely need to become mandatory to achieve the levels of participation that are necessary ..." and "...

for instance, USDA reported that most individuals who spoke about this subject at the agency's 2004 listening sessions preferred, by a ratio of 3:1, a mandatory program to a purely voluntary program. USDA also reported at that time that a survey of National Institute of Animal Agriculture members showed even stronger support, by a ratio of 8:1, for a program that is or will become mandatory."

15/20 (first paragraph)

(excerpt) "... For example, officials from one major agricultural state [NOTE: This is almost certainly Colorado] told us that USDA's changed direction on whether the program would become mandatory has challenged the state's premises registration efforts, because many producers are motivated by compliance with federal requirements, not necessarily by NAIS's traceback goal alone. These officials also said that the lack of participation benchmarks had compromised the state's credibility with producers and its ability to make progress in implementation. As of early June 2007, this state had less than 16 percent of its premises registered, and the officials believed there is little incentive for producers to participate in NAIS. Moreover, three states where premises registration is mandatory by state law - Indiana, Michigan,9 and Wisconsin - accounted for about 26 percent of USDA's total premises registered nationally as of that time.."

(next paragraph, excerpt) "Overall, 27 of the 32 experts said participation in NAIS should definitely or probably be mandatory."

20/25 (first full paragraph)

"For NAIS not to impose undue costs on producers by requiring additional ID devices, stakeholders say the program must be integrated with preexisting programs and systems. However, USDA faces challenges in integrating NAIS with other animal ID requirements. For example, Sheep Working Group members told us that because the scrapie program already assigns a flock ID number to each premises-plus a unique, individual ID number to each animal-sheep producers do not see the need to participate in NAIS, which involves different premises and individual animal ID numbering systems. Another challenge is that brands identify all animals raised by a specific producer as a group, not as individuals, and the same brands are often used in different states or even in different counties within the same state. USDA's NAIS User Guide states that registered brands are not considered to be an official, individual animal ID as called for by NAIS because cattle typically move through the production process as individuals. In addition, NAIS animal tracking requirements may differ operationally from state brand laws and practices. For example, New Mexico requires state authorities to inspect all livestock moving across brand district lines, which contrasts with NAIS, where the responsibility of reporting animal movement lies with the premises receiving animals. New Mexico officials told us that if they were to implement NAIS as envisioned, the time required for state inspections would at least double if inspectors were required to read and report ID tags. The Cattle Working Group recommended, in 2004, that USDA develop protocols for integrating existing brand laws with NAIS individual animal ID requirements and for the reporting of animals' movements from brand law states to nonbrand law states."

28/33 (last paragraph)

"In fiscal years 2004 and 2005, USDA also awarded field trial cooperative agreements. Specifically, in fiscal year 2004, USDA awarded 16 cooperative agreements totaling $9.7 million to 15 states and 1 tribe. USDA estimates that $1.8 million of the $9.7 million awarded was used to support premises registration activities. The remainder was used for field trials to develop, test, and offer solutions for applying animal ID devices and collecting animal tracking information. For example, 1 cooperative agreement with the Wyoming Livestock Board tested whether existing brand inspection personnel and infrastructure could be used to track livestock changing ownership and livestock entering into interstate commerce through Wyoming livestock markets. In fiscal year 2005, USDA awarded 7 cooperative agreements totaling $1.9 million to 6 states and 1 tribe for field trials to support research, including the assessment of existing and novel ID technologies."

53/58

"Part III. Implementation of NAIS - NAIS is being implemented for all livestock species, including bison, camelids, cattle (beef and dairy), cervids, equine, goats, poultry, sheep, and swine. Countries that have already implemented national animal ID programs (e.g., Canada, EU, Australia) generally started with cattle and, in some cases, later extended their program to cover a few other species. No other country has attempted to reach the number of species that USDA aims to cover with NAIS, nor has any other country implemented a program for multiple species simultaneously."

63/68 (bottom of page)

Canada:

Julie Kay Smithson, property rights researcher

propertyrights@earthlink.net

www.propertyrightsresearch.org

"The three great rights are so bound together as to be essentially one right. To give a man his life, but deny him his liberty, is to take from him all that makes his life worth living. To give him his liberty, but take from him the property which is the fruit and badge of his liberty, is to still leave him a slave." - George Sutherland, Associate Justice of the United States Supreme Court, 1921.