Comment from Karen Nowak

Dear Secretary Vilsack: I am a small farmer who breeds heritage (rare breed) chickens, turkeys and a critically endangered breed of horse. I am very concerned that the proposed rule for tracking livestock moving between states will make it prohibitively expensive for me to buy or sell baby chicks/poults from/to other states, which will decrease our gene pool. In addition, requiring that permanent leg bands be affixed at birth reflects complete ignorance of how poultry grow! As a horse owner, I am very concerned that if Animal Disease Traceability (ADT) is implemented, the current requirement of visual ID/digital photographs on vet certificates will be replaced “down the road” with the original requirement under NAIS – microchip ID. Our system of visual ID for vet certificates has worked for decades and must not be changed. You dropped plans for the National Animal Identification System (NAIS) because the scientific and economic benefits could not be proven so why propose another cost-prohibitive program? While less sweeping than the NAIS, the proposed ADT is still a solution in search of a problem that does not exist. Like NAIS, ADT is a discriminatory program that supports large agribusiness by allowing them to use Group ID, while small farmers and ranchers will be required to use individual ID. Scale is always an issue when writing regulations. Small food sources provide healthier food and are increasingly preferred by consumers. If, as your agency claims, the export market would benefit from the proposed rule, then the meat packing companies who export meat should pay the costs and offer economic premiums to livestock producers to encourage them to participate in a voluntary system. The USDA has again failed to identify the specific problem or disease of concern. Your agency needs to focus on disease prevention measures rather than pushing a one-size-fits-all generalized after-the-fact tracking.