Sixteen farm and ranch groups submitted a letter to the USDA last week urging them to consider alternatives to the proposed Animal Disease Traceability rule, which will replace the unpopular National Animal Identification System.
The letter, addressed to the Executive Office of Management and Budget, estimates the potential costs for the new program to be about $1 billion, with the cost per head for cattle five times greater than USDA estimates. In addition, the group explained that costs of compliance, costs to cattle-related businesses, and costs to small-scale poultry operations were not properly examined.
The new rule will require each dairy or beef animal that crosses state lines to be tagged with an official form of identification, which must be recorded and kept on file by sale barns and veterinarians for five years. The group wrote that the USDA "arbitrarily" based cost estimates for this stipulation on 30 million cattle.
"The agency's arbitrary assumption is contradicted by the publicly available data on the cattle industry," the groups wrote. They estimate that at least 50 million cattle cross state lines each year.
"The vast majority of cattle industry's capacity for feedlots and slaughterhouses are concentrated in just six states, yet approximately 55 million cows and calves are located outside of those six states," the letter said.
The groups also claim that the USDA underestimated compliance costs, citing research by North Dakota State University's Dickinson Research Center Extension and Livestock Specialist Kris Ringwall. Ringwall's data, the groups say, explain that tagging costs exceed just the cost of the tagging equipment and labor.
USDA estimates about $1-$2.50 per animal and $.018 per tag. However, Ringwall's research cited loss due to "shrink," or weight loss due to stress on the animal, making the total cost of tagging each animal between $17 and $27.
The group also examined the costs to cattle-related businesses, including sale barns and veterinarians. New requirements, they say, will require separate paperwork for each animal as well as storage for that paperwork.
"Whether the sale barns and vets pass on the costs [of paperwork] to the producers or absorb it themselves, someone must pay those costs," the groups wrote. "In addition, the agency's assumption about the costs for veterinary services failed to include the typical charges for having a vet come out to the farm, which can range from $30 to $100 for each visit."
But the ADT rule isn't just for cattle producers. Poultry moving interstate must also be identified either through group identification or with a permanent leg band.
The group says the agency conducted no analysis of the costs in its regulatory impact analysis for poultry, including costs for leg banding and handling. Management within the poultry industry, they maintain, is widely varied, which makes cost estimates for the ADT rule very difficult to obtain.
"USDA completely failed to examine the economic impacts to the poultry industry," they wrote. "If the rule is implemented as proposed, it will place disproportionate, onerous burdens on both small-scale farmers and those who raise poultry for personal use."
The sixteen groups represented asked the OMB to return the proposal to the USDA for further review.
"The agency failed to consider available data showing that the scope of the rule and its impact on the industry would be far broader, and its costs far more extensive, than the agency admitted," they wrote.