· The U.S. Cattlemen's Association opposes mandatory participation in the National Animal Identification System (NAIS).

· U.S. cattle producers understand the need for an effective animal health trace back system and the risks associated with animal disease outbreaks.   Ranchers understand the economic and social consequences of a domestic animal disease crisis.   Cattle producers' steadfast opposition to the NAIS proposal sends a strong message to policy decision-makers that they are not satisfied with the fundamentals of the proposed system.  

· USCA has continued to participate in discussions surrounding NAIS, encouraging the Department of Agriculture to develop a standardized voluntary program that incorporates existing systems used to mitigate and eradicate animal diseases in the U.S.   USCA supports the continued use of existing programs such as brand inspection, health certificates, brucellosis tags, tuberculosis tags and other animal health trace back programs.   Standardizing and harmonizing existing federally administered animal disease programs should have been undertaken during the initial development of NAIS.  

· Disease controls begin at U.S. borders.   The U.S. has an excellent track record of eradicating and mitigating animal diseases because of its import standards.   We must work to strengthen those import standards rather than reduce them.   Policy decision-makers must not lose sight of what has made the U.S. the top beef producing nation in the world and the factors that have made the U.S. cattle industry competitive in the top beef consuming markets.  

· NAIS ramifications to property rights must be addressed. Private property rights associated with premises registration have been a key issue with the proposed system since its inception. USCA has repeatedly asked the Department of Agriculture to present a legal analysis that outlines why premises registration is not binding to the land and does not harm the private property rights of the landowner.   USCA supports consideration of utilizing a locator identifier that relates to the animal owner and not the animal owner's real property.  

· Further issues with premises registration numbers arise when a ranch is operated by a tenant or a leaseholder.   It remains unclear why a premises registration number would be assigned to the property and not the leaseholder.

· Recording all movements of cattle, particularly from one premises to another when both premises are part of one operation and no change of ownership is involved is unduly burdensome.  

· Federal funding of cooperative agreements to enhance enrollments in components of NAIS must be halted.  

· The recently released NAIS cost-benefit analysis is indisputable evidence of the financial burden NAIS places on the cattle industry in relation to other competing protein sources.   The total estimated cost of animal identification across all major food species groups (beef and dairy cattle, swine, sheep and poultry) is $192 million.    The estimated cost to the cattle industry according to the analysis is $175.9 million annually at the 90 percent participation level.   The analysis shows that the beef segment of the cattle industry bears the brunt of the $175.9 million in cost and will most certainly make beef less competitive in relation to other sources of protein.

· Using various models, the analysis shows that the only disease outbreak mitigation that would be dramatically affected by having mandatory animal identification is Foot and Mouth Diseasae (FMD).   The projected costs and livestock loss from an FMD outbreak are still staggering even with a mandatory animal identification system, according to the cost-benefit analysis.

· U.S. exports are at 94% of the pre-BSE levels of 2003.   Most U.S. exports are required to provide some type of trace back or age verification.   Producers selling into those markets are providing that information voluntarily and are receiving premiums for doing so.   If animal identification becomes mandatory, those premiums will be eliminated immediately because the process of providing trace back and age verification will no longer be market-driven.  

· Cattle producers raise a commodity.   Subsequently, we are price takers, not price makers.   Producers have no mechanism to pass on the additional costs this program would impose.  

· The Department of Agriculture suffers from an enormous sense of producer distrust over the issue of NAIS.   The program introduced to producers nearly a decade ago was a modern, streamlined system intended to help producers and animal health officials respond quickly and effectively to animal disease events in the U.S.   Over the course of time, the department suggested that the system would be privatized, a decision many producers viewed as premature and a risk to their confidential business information held within the NAIS database. To date, the Department of Agriculture has not addressed definitively the questions surrounding confidentiality.  

· Public discussion of the 840 tagging system under NAIS has created a great deal of confusion.   USDA has not provided any substantive clarity on the 840 system.   For example, will the 840 tags be metal, will they be a typical flat ear tag or will they be an RFID tag and will they be recognized and accepted by state and federal animal health officials administering disease programs.