Letter to NAIS Committee Regarding Animal Identification System

 

Dear Chairman Scott, Chairwoman Clarke, and Ranking Members Neugebauer and Lungren,

 

            On behalf of the National Federation of Independent Business, the nation’s leading small business advocacy organization, I am writing you in regards to the Animal and Plant Health Inspection Service (APHIS) proposed rule mandating the National Animal Identification System (NAIS) [Docket No. APHIS-2007-0096]. This rule would mandate domestic livestock be identified using animal identification numbers, which would cost small and family farms thousands of dollars to be compliant. 

 

NFIB understands the importance of creating a system to respond to a national animal disease outbreak. Such an outbreak would not only severely hurt America’s agricultural economy, but damage the economy as a whole. Cattle, swine, poultry and sheep are among the top exports of the United States, and we need to ensure that any government regulations don’t reduce the competitiveness of our livestock industry. 

 

APHIS’s recent report on the NAIS cost-benefit analysis concluded that the cattle industry would incur the highest cost on implementation. Cattle Fax reports there are over 800,000 ranchers and farmers in the United States that will be affected. The costs for individual radio frequency identification devices were estimated from between $2.00 to $2.60; for a farm of 500 animals that could cost up to $1,300, plus tagging cost and relevant software. Total cost to the cattle industry is estimated over 200 million dollars. To include swine, sheep and poultry that number jumps to close to 230 million dollars.

 

Instructing APHIS to fully mandate this program will create another layer of government bureaucracy, forcing ranchers and farmers to take time out of running their business to create new business practices, including filing more paper work, which slows down operations.  According to a 2003 NFIB Research Foundation Poll on Paperwork and Record Keeping, the estimated average per hour cost of paperwork and record-keeping for small businesses is $48.72. 

 

NFIB has consistently fought against unnecessary government regulations.  We have heard from many small business owners about how this regulation would adversely affect their businesses, and NFIB continues to support a voluntary NAIS program.

 

Please keep small and family farmers in mind when considering the impact of this program. We look forward to working with you on this important small business and agriculture issue.

 

 

 

                                                                        Sincerely,

           

                                                                        Susan Eckerly

                                                                        Senior Vice President

                                                                        Public Policy