For related articles and more information, please visit OCA’s Farm Issues page and our National Animal Identification System Information page.

The letter below was sent to the U.S. Office of Management and Budget on September 14, 2012.  The pdf version with footnotes is available here

The 63 undersigned organizations, representing family farmers, ranchers, and consumers, urge you to return USDA’s final rule on Animal Disease Traceability (ADT) to the agency for a legally adequate, thorough, and complete cost analysis. 

ADT has been criticized by thousands of individuals and organizations because of the undue burdens that it will impose on producers.  The cost of tagging and the extensive recordkeeping requirements under the rule will impact farmers and ranchers, as well as related businesses such as sale barns and veterinarians, and will ripple through our rural economies.

As detailed in our letter of July 24, the USDA has significantly underestimated the costs of its rule to both cattle producers and poultry producers.  While the agency claims that the costs are under $100 million annually, independent studies indicate that the costs could be three to five times that high for cattle producers alone.  Moreover, the USDA failed to even attempt to estimate the costs to small-scale poultry farmers, a failure that, by itself, is sufficient cause to reject the rule.

Ultimately, the cost will be more than dollars and cents.  If producers cannot afford to meet the new requirements, they will be unable to purchase new animals or market their animals out of state, which could lead to more of them going out of business.

Farmers and ranchers nationwide are already struggling just to keep their cattle alive through the drought.  Over 75 percent of the contiguous U.S. is experiencing drought conditions, and almost half the country is in severe or worse drought, including the major farming and ranching regions.

The impact on livestock and poultry producers has been devastating.  The forage and feed situation is the worst this country has seen since the 1930s Depression,  as producers with parched pastures, rangelands, and crops face expensive hay, grain, and shipping costs.   Increased feed costs have led to a reduction in profits per livestock animal by more than $100 just since June 1.   One agricultural economist has estimated that 2013 feed prices could triple the 1990-2004 average.   Rapidly depleting livestock water is forcing many producers to haul water, which is also expensive and time-consuming.

Families who have been the agricultural backbone of this nation are now at the breaking point.   Many have already sold a large part of their herds, and the slaughter of many breeding age cows will mean that it will take a decade of normal rainfall to rebuild the cattle population in America.

Traceability programs, such as USDA’s ADT rule, also impose costs on livestock-related businesses, such as sale barns and veterinarians.  It was recently reported that sale barns in New Zealand have added a new surcharge for cattle sales due to the additional equipment, staffing and administrative costs required for their NAIT (national animal identification and tracing) program.   It is likely that similar costs under ADT will be passed on to U.S. farmers and ranchers.