The Farm-to-Consumer Legal Defense Foundation said today that a cost/benefit study commissioned by United States Department of Agriculture proves that the costs for small farmers to implement the National Animal Identification System could put many of them out of business.
"The government's own numbers show that a small farmer will pay at least twice and in some cases nearly three times the costs per animal to particip ate in NAIS as will the operators of the large confined animal feeding operations," said acting Fund president Pete Kennedy.
The costs quoted in the study called "The Benefit-Cost Analysis of the National Animal Identification System," which was released April 29, range from $2.48 per animal for CAFOs with more than 5,000 cattle to $7.17 per animal for producers with less than 50 and who do not currently tag their cattle.
"Not only is the difference unfair," Kennedy says, "we think the numbers themselves are substantially underestimated, which will further burden the small farmers to the point of making their way of life untenable.
Kennedy also pointed to the study's unreasonably low estimate of what it would cost a small farmer to hire someone to read the tags since many of them will not be able to afford to purchase the thousand-dollar-plus electronic tag reading equipment.
"The government's time and labor costs for custom tag reading are not grounded in reality," Kennedy said. "For instance, the study estimates that a small farmer could hire a third party to travel to his farm to do it for only $1.87 per animal. That estimate seems ridiculously low, especially for farms and ranches located in remote areas."
Fund board member Taaron G. Meikle said that the unrealistic and misleading cost assumptions together with USDA's own statement about the major benefits of NAIS are further evidence that the animal identification program is being implemented to benefit CAFOs at the expense of the small farmer.
Meikle pointed to a fact sheet published by the USDA's Animal and Plant Health Inspection Service Veterinary Services that lists key points from the study. "The first one speaks to the timely recovery of export markets after a disease outbreak and the second says that traceability is necessary to participate in the global marketplace," she said. "Neither of these matter to a sm all farmer who sells his beef to his neighbors on his farm or at a farmer's market."
Meikle reiterated the Fund's position that implementing NAIS will do little if anything to improve animal health or food safety in the United States.
Most animal health problems are the result of the high-density CAFOs that concentrate thousands of animals in one location, while food safety problems begin at the slaughterhouse where NAIS traceability ends," she said.
"By implementing NAIS—which requires small farmers and ranchers to track each animal individually while allowing CAFOs to track all animals under one blanket Group Identification Number—the USDA would be rewarding factory farms whose practices encourage disease while crippling small farms an d the local food movement in the name of increased international sales.
Meikle also noted that the Fund intends to have a presence at the upcoming listening tour on NAIS that the USDA plans to conduct in seven cities beginning May 15. "The USDA is positioning these hearings as a forum to discuss "stakeholder concerns' about NAIS, when the hearings should be focused on whether or not it is needed at all, and we intend to make sure the voices of small farmers are heard."
The Fund last year filed suit in the U.S. District Court– District of Columbia against the USDA and the Michigan Department of Agriculture to stop the implementation of NAIS.
The MDA has implemented the first two stages of NAIS –property registration an d animal identification – for all cattle and farmers across the state under the guise of its bovine tuberculosis disease control program. MDA's implementation of the first two steps of NAIS was required in exchange for a grant of money from the USDA.
The Fund's suit asks the court to issue an injunction to stop the implementation of N AIS at both the state and federal levels by any state or federal agency. If successful, the suit would halt the program nationwide.