A coalition of agriculture and consumer organizations from across the nation is challenging the U.S. Department of Agriculture's (USDA) decision to push ahead with a complicated and expensive Animal ID program. The organizations sent a joint letter to the Congressional Office of Management and Budget (OMB) this week arguing that the rule should be sent back to the USDA because of the impacts it will have on family farmers, ranchers, related businesses, and other citizens who own animals. The letter cites research from North Dakota State University which estimated the costs for cattle as more than five times greater per animal than the USDA's estimate, potentially creating costs of over a billion dollars per year. The letter from the coalition also points out that USDA "arbitrarily assumed that only 30 million cattle" would be subject to the new regulatory requirements, even though this assumption was "contradicted by the publicly available data on the cattle industry." By underestimating both the number of animals affected and the cost per animal, the USDA estimated the fiscal impacts at under $100 million, claiming that the rule is not "economically significant" and placing it on the fast-track to be finalized after review by the OMB, which serves as the fiscal review agency for all regulatory matters. "The USDA has not done their due diligence investigating the true fiscal impact this will have on the livestock industry," said Mark A. Kastel, Senior Farm Policy Analyst at The Cornucopia Institute. "Our concern is that the economic burden of this rulemaking, some of which is duplicative of many effective disease control programs currently utilized, will fall unfairly on family-scale farmers and ranchers." The coalition's critique provides additional information on the disproportionate impact on small farmers due to the on-ranch costs for equipment and labor involved in tagging and long-term recordkeeping. The coalition also notes that the agency failed to address the increased costs to livestock-related businesses, such as for certified veterinarians and sale barns. In addition to beef and dairy cattle, the USDA's proposed rule imposes new regulatory requirements for poultry producers without any assessment of the costs. The letter states, "with respect to poultry, the agency conducted no analysis of the costs in its Regulatory Impact Analysis." This deficiency on the part of the USDA could have significant repercussions not only for farmers, but for a growing number of private citizens, in "both rural and urban settings, who own a few birds for food, show, or as pets." For more than seven years, the USDA and Agribusinesses have been pushing various animal identification proposals. Farmers, ranchers and consumer organizations have identified many shortcomings and impractical requirements in these proposals that would be harmful for small business and independent livestock operations and allege that the primary benefits of any such widespread program will accrue to major agribusinesses focusing on expanding exports. "The coalition urges the OMB," according to Judith McGeary, Executive Director of the Farm and Ranch Freedom Alliance, "to return the rule to USDA for a thorough and complete analysis, which must acknowledge that the rule is economically significant." -30- The Cornucopia Institute is engaged in educational activities supporting the ecological principles and economic wisdom underlying sustainable and organic agriculture. Through research and investigations on agricultural and food issues, The Cornucopia Institute provides needed information to family farmers, consumers, stakeholders involved in the good food movement, and the media. The Cornucopia Institute PO Box 126 Cornucopia, WI 54827 www.cornucopia.org.