Small Entity Impact

5 U.S.C. 603 OMB: We do not currently have all the data necessary for a comprehensive analysis of the effects of this proposed rule on small entities.

USDA contracted with Kansas State University for the purpose of obtaining data necessary to analyze the effects of this proposed rule on small entities. Other pilot projects in various states captured data on the cost to small entities. Public Disclosure/FOIA indicates that the USDA, as well as State Department’s of Agriculture are indeed aware of the costs to the small farmer.

Just as the FDA should not approve a drug it does not know is safe, neither should the USDA approve a program where it must solicit from farmers what the “potential effects” of the program may be. Once again, pilot projects conducted by the USDA and your State Department’s of Agriculture, by Cooperative Agreement tested and gathered information on “potential effects” for the design and implementation of the NAIS. These pilot projects included data on cost to equipment provider and producer [farmer and rancher] as revealed in FOIA and Public Disclosure documents. These same documents revealed significant impact to the producer [farmer and rancher] and went so far as to say, for the record, “the producer will receive no benefit.”

Furthermore to “protect’ the integrity of the NAIS program was designed to detect and correct errors by use of sophisticated algorithms.

APHIS itself acknowledges a “significant economic impact” and so is compelled to provide a “transition” to take place “without placing a significant economic burden” on the producer [farmer and rancher]. This transfers the “significant economic impact” and “sustainability” from APHIS to the producer [farmer and rancher].

Costs

APHIS invites “comments concerning potential effects […] interested in determining costs to eartag manufacturers and livestock producers [famers and ranchers].”

APHIS.1: “transition to take place without placing a significant economic burden on livestock producers”.

APHIS.2: “Requiring the use of the 840 prefix for the AIN is not expected to have significant economic effects on the livestock industry”

APHIS.2 then contradicts what it has said elsewhere when it says, ‘‘requiring the use of the 840 prefix for the AIN is not expected to have significant economic effects on the livestock industry’

APHIS knows through pilot projects, algorithm, Cooperative Agreement and other contractual agreements (agreements by other names) that the ‘tagging business’ is a billion dollar industry.

APHIS.3: “Potential costs would include reformatting expenses for eartag manufacturers as the USA and manufacturer’s code numbering systems are eliminated.” Continue reading →