Cattle ID Group Seeks Extended Comment Period On Proposed ADT Rule
The Honorable Tom Vilsack
U. S. Department of Agriculture
1400 Independence Ave., S.W.
Washington, D. C. 20250
Dear Mr. Secretary:
The Cattle Identification Group (CIDG) was formed a couple of years ago to provide input into the U.S. Department of Agriculture’s (USDA) development of an Animal Disease Traceability (ADT) framework and plan for the identification and traceability of cattle moving interstate. The participating members of the CIDG represent all classes of cattle and segments of the cattle industry with membership spanning the length and breadth of this country.
As development of USDA’s ADT program proceeded over time, the CIDG as well as its individual industry organizations have been active participants in the various meetings and discussions that USDA has held around the country throughout the development of the program. In that regard, we very much appreciate USDA’s efforts to develop the ADT program with transparency, openness and an evident desire to have the cattle industry’s input on a regulatory program that is sure to have a huge impact on every livestock operation in the United States.
The proposed ADT rule (Docket No. APHIS-2009-0091) was published in the Federal Register August 11 with a 90-day comment period, ending November 9. Within weeks of the proposed ADT rule, the CIDG met to begin our discussions on the various aspects of the proposal and what, if any, remaining concerns and/or questions we have respective to the ADT program as established in the proposed rule. It was obvious from the very beginning of our initial discussion on the ADT proposed rule that there remains a great deal of work yet to be done by the CIDG and our individual organizations in assessing all the numerous repercussions, connotations, and consequences of the many different aspects of the proposed rule. It also looks likely that we will need to do some additional work on assessing the cost to industry stakeholders in complying with the ADT rule, particularly once all cattle are required to be identified. In addition, numerous questions are being raised about various elements of the proposal that will need clarification by USDA staff in order for us to responsibly inform and respond to the membership of our organizations in the short time that remains of the current comment period.
While the CIDG and our individual organizations are feverishly scheduling additional meetings to work through the proposed rule, it has become very apparent to us all that a proposed rule of this importance and magnitude, with all it potential impacts and disruption of the cattle industry, will require that cattle industry stakeholders be given additional time to consider and develop the industry’s response to the proposed ADT rule. Also, our respective organizations are finding it difficult to schedule meetings right now with our leadership, committees and members to get their guidance on outstanding issues with the proposed rule as we enter later than usual summer harvest in some parts of the country, fall harvest in the Corn Belt, the fall run of feeder cattle moving to market, the increased marketing of cattle due to severe drought in parts of the Southwest and now, recent flooding conditions along the East Coast.
At a time of economic uncertainty, high unemployment, and limited funds for new programs such as ADT, it is an absolute necessity that any new regulations imposed on the cattle industry be as cost effective, efficient, workable and no-nonsense as is humanly possible and that all the time necessary to achieve that result is made available to the industry. Many improvements have been made by APHIS in the last two years regarding this challenging issue. We would not want an inadequate length of the proposed rule comment period to derail all of our collective efforts and negate any positive progression of cattle identification for animal health purposes. Thus, as the industries’ most affected by this proposed rule, we respectfully request that the current comment period be extended an additional 60 days to give affected stakeholders the needed time to thoroughly review, discuss and develop in-depth comments on this extremely consequential regulatory proposal.
For questions or in responding to the CIDG’s request for an extension of comments, please contact Ms. Nancy Robinson, CIDG Coordinator; Livestock Marketing Assn., 10510 NW Ambassador Drive, Kansas City, MO 64153; phone 800-821-2048; e-mail: firstname.lastname@example.org.
The Cattle ID Group
American Angus Association
Dairy Farmers of America
Livestock Marketing Association
National Cattlemen’s Beef Association
National Livestock Producers Association
National Farmers Union
Red Angus Association of America
Southeastern Livestock Network
Texas Cattle Feeders Association
Texas and Southwestern Cattle Raisers Association
U.S. Cattlemen’s Association
cc: APHIS/VS Deputy Administrator Dr. John Clifford; House Committee on Agriculture Chairman Frank Lucas; House Committee on Agriculture Ranking Member Collin Peterson; Senate Agriculture, Nutrition and Forestry Committee Chairwoman Debbie Stabenow; Senate Agriculture, Nutrition and Forestry Committee Ranking Member Pat Roberts