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Natural Horse Home >> Withinthelaw

NAIS UPDATE

Open Letter to the American Horse Council
February 20, 2008
By Judith McGeary

The Farm and Ranch Freedom Alliance (FARFA) sent a public email last month alerting people to statements in a recent government document that call for breed registries to implement the National Animal Identification System (NAIS).  We encouraged people to contact their breed registries (1) to find out if they planned to be part of this implementation and (2) to express the members’ opposition to being part of NAIS.  Many horse owners acted on this information and contacted their registries.

Based on the government documents, if NAIS becomes mandatory, it will require anyone who owns or manages property with even one horse or other livestock animal to register their home in a federal database and be assigned a permanent premises identification number (PIN).  Next, each animal will be assigned an internationally unique 15-digit animal identification number (AIN) and be tagged, in many cases with electronic identification.  The last step would be to track the animal’s movements, particularly any movements that involve ‘commingling’ (mixing) with other horses or livestock.

The American Horse Council (AHC) took exception to FARFA notifying horse owners of the issue of breed registries potentially implementing NAIS.  AHC sent a letter to breed registries claiming that: ‘misinformation has been going around regarding the USDA’s business plan for the NAIS’. This seems to be orchestrated in part by a group called the Farm and Ranch Freedom Alliance’.’  The full text of the AHC letter is included at the end of this response.

AHC has not contacted FARFA and their reasons for objecting to the FARFA alert are unclear.  After all, FARFA’s alert is based directly on the USDA’s published documents.

AHC seems intent on downplaying what the USDA has published in its most recent document.  The USDA’s Business Plan to Advance Animal Disease Traceability: Through the Harmonization of State, Federal, and Industry Programs and Convergence with the National Animal Identification System was released on December 19, 2007.  In a table of planned actions and target dates, it states: ‘initiate use of AIN in breed registry programs,’ with an ‘action target date’ of March 2008.  (Business Plan, p.52).  AHC’s letter instead claims that ‘the timeline (below) states that USDA plans to initiate these discussions in March 2008.’  Since when does ‘initiate use’ of something mean ‘initiate discussions’?  If AHC is privy to information that has not been made public, it needs to share that information.

Perhaps AHC’s objection is the statement in FARFA’s alert that USDA plans to use breed associations to force NAIS registrations.  AHC continues to promote the claim that NAIS is voluntary, stating: ‘As the NAIS is a voluntary program, it is the choice of each breed registry for all livestock species to decide whether they would like to utilize the NAIS options of AIN and PIN, and whether that will be mandatory or voluntary for their specific program.’

But while it may be voluntary for a breed registry to decide whether to require NAIS, it is not voluntary for the animal owners who utilize a registry that requires NAIS.  A coercive choice between being forced to participate in a government program to which one objects or having unregistered animals ‘ which can have severe economic consequences - is not truly voluntary.

AHC has not told horse owners about some of the non-voluntary and coercive measures already being used to force NAIS on people in several states:

● Premises registration is mandatory in Wisconsin and Indiana;
● Horse owners in New York have reported receiving letters thanking them for registering their property in the NAIS database after having taken their horses for routine Coggins tests;
● Premises registration and NAIS-compliant electronic tags are mandatory for cattle in Michigan;
● Drought stricken farmers in North Carolina are required to register their farms to obtain hay from the state;
● Children in Colorado, North Carolina, and Illinois are required to register in NAIS in order to compete in the state fairs.
In addition, the USDA Business Plan contains several other measures that will affect horse owners that the AHC has failed to mention:

● The Business Plan specifically calls for equine organizations and associations to implement NAIS-compliant electronic identification technology by January 2009: ‘Implementation of the 840 AIN RFID [Radio Frequency Identification Device] technology by all industry organizations that provide services to horse owners/breeders.’   (Business Plan,p.55)  (emphasis added) .
● USDA’s focus on horses is not limited to just competition horses.  ‘Horses that, when moved, require either a test for Equine Infectious Anemia or a health certificate, are also included in Tier 1.’  (Business Plan, p.2).  That would cover almost every single horse in Texas and many other states.
● USDA has plans to expand the requirements for Coggins testing nationwide, to capture more people into NAIS.  ‘Efforts are underway to develop a USDA national State-Federal cooperative program for the control of EIA that would establish national EIA (Coggins) testing requirements for (a) interstate movement and (b) change of ownership. ● Overall, establishing regulations to require premises registration in association with Coggins testing would substantively increase the number of both premises registered and horses identified.’  (Business Plan, p.26-27) This means a national mandatory Coggins, for which horse owners will be required to provide a PIN and AIN.
To our knowledge, AHC has not alerted its organizational or individual members to these provisions of the USDA Business Plan.  Instead, the AHC directs people to the Equine Species Working Group’s (ESWG’s) website for more information on NAIS.  The ESWG is an advisory group that makes recommendations to the USDA about how NAIS should apply to horses.  The USDA is not bound by any of these recommendations and may choose to disregard any or all of the recommendations.  Moreover, the ESWG website fails to mention these coercive provisions of the USDA Business Plan, what is really happening around the country with NAIS, or the costs of the program.

For more information USDA’s documents about horses and NAIS, go to www.farmandranchfreedom.org/content/horses-and-NAIS.

The American Horse Council claims to speak for horse owners across the country.  Yet, rather than inform its members of the contents of the USDA’s documents, it attacks a grassroots organization for urging people to find out what their breed registries are planning.  It’s time AHC answered some questions from horse owners.

Judith McGeary (horse owner)
Executive Director
Farm and Ranch Freedom Alliance
www.farmandranchfreedom.org
866-687-6452