NAIS Comments

I tried to submit NAIS comments today, but regulations.gov seems to be either overloaded or not working well. So, for what they're worth, my two cents:

Comments on NAIS

I grew up on a small dairy/poultry farm so I can understand some of the concerns of the small producers. As a retired bureaucrat I also see the fix APHIS finds itself in. It seems to me APHIS is stuck--there's no way to go forward on your current lines because the opposition is too vocal, too numerous, and too dug in. You can't get the participation without paying the freight; you can't get the dollars from Congress to pay the freight because you can't get a broad consensus in the field.You need something different to break the logjam.

I think there are historical analogues that can be instructive. In the 1960's USDA maintained a food and feed facility directory. In the case of a nuclear attack USDA field offices would have been responsible for inventorying what was left and coordinating its use.Thank goodness it was never put to the test.

Also in the 50's and 60's we had the fluoridation controversy and the fight over whether seatbelts should be required in cars. In both cases time has cooled the flame of conflict, particularly as the older geezers died and the new generations came along. There are some issues where that's the best you can do in the U.S.--the founding fathers didn't design the government for fast efficient action.

My suggestions:

1. First, you need a more accurate title. "National Animal Identification System" must have been invented by a bureaucrat. It sucks. No wonder small farmers are scared of it. In the U.S. we rarely have national systems for anything, not in the sense the French or Japanese have a national education system, for example. What you have under the title "NAIS" is a typical federal mish-mash of organizations and standards which is successfully creating confusion. A better name for what you're doing might be: "Standards for Animal Identification Systems"--more descriptive and more accurate, and possibly less scary for NAIS opponents.
2. Rely on the USDA field offices (i.e., FSA and NRCS) to create and maintain a national list of names and addresses of people and legal entities who are raising animals and the types of animals raised. There shouldn't be much additional work required, because they already should have all farmers in the Service Center Information Management system. You'd need to get animal type information added and give access to APHIS field personnel. The offices should also try to increase their efforts to give farmers their own access info.
3. Add layers to the geographical information system (GIS) used by NRCS and FSA to reflect the addresses recorded in item 2. Ideally separate animal types by layer, so one view shows all cattle ranchers, another all sheep, etc.
   

The idea would be, after items 2 and 3 are complete, if there's a report of a disease occurrence in hogs, say H1N1 flu, you could display the locations of all hog farmers within a radius of 30 miles, 100 miles, or whatever and have a listing of their phone numbers and email addresses to use in making contact. Time required: minutes, leaving you 47 hours to work the list. This seems to me to be easily doable and it gives you a national quick response system with, I hope, a minimal intrusion on the concerns of the No-NAIS people.

My comments on the remaining issues: think tiers and 6 degrees of connection.

By "tiers" you apply different rules for producers the products of whose animals may be exported than those which sell to neighbors. (Just as OSHA applies different rules for large factories than small shops.) You apply different rules for animals whose birth is separated by 6 steps from death to consumption than those which only have 2 steps.

Finally, I think you may be relying too much on the idea of identifying animals for small farmers That was the only way to go back in the days of tuberculosis and brucellosis, pushing paper, and IBM punch card sorters. But these days, when schools have moved from sending letters home to parents to automated calling and tweets, you should be flexible and innovative.