June 1, 2006

American Livestock Breeds Conservancy
Statement of Concern
National Animal Identification System Proposal

The American Livestock Breeds Conservancy (ALBC) would like to take this opportunity to respond to the U.S. Department of Agriculture’s invitation to provide input on the emerging proposal relating to development of a National Animal Identification System (NAIS). The mission of the ALBC is, among other things, to protect the richness of genetic resources found in American livestock and poultry. It is recognized by the scientific and agricultural communities that much of the wealth of genetic diversity of America’s purebred flocks and herds resides in rare, endangered, and heritage breeds. The future health of the American livestock industry may well depend on being able to tap and utilize the genetic potential inherent in these animals. ALBC strongly urges all decision makers involved with developing the policies and procedures of the NAIS to pay careful attention to the effects their actions may have on the maintenance of this vital genetic resource.

For a variety of reasons, many of our country’s rare, endangered and heritage breeds of livestock and poultry are stewarded and maintained on small, independent farms and ranches. Thus, any regulations, policies or procedures that may prove sufficiently onerous or cumbersome will discourage a significant number of those farmers and ranchers currently breeding or contemplating raising such animals. The NAIS program could have serious, unintended, and unanticipated effects on the long-term viability of our nation’s livestock industry.

ALBC appreciates that some benefits can accrue from the development of a carefully considered national system of animal identification. However, as the only national organization concerned with the conservation of our nation’s livestock and poultry, we urge all NAIS decision and policy makers to be aware of the importance of conserving our national livestock genetic legacy and to be mindful that regulations and procedures designed specifically for agribusiness and large-scale production systems may have disproportionate impact on those currently maintaining these genetic resources.

Policies, procedures, and regulations that inappropriately or unnecessarily discourage farmers and ranchers from considering or continuing to steward rare, endangered, or heritage agricultural animals could lead to the extinction or functional loss of the genetic resource these creatures represent. Such a loss would diminish our country’s genetic legacy, significantly reduce the capacity of present and future animal breeders to respond to new challenges and opportunities, and potentially compromise our nation’s food security.

ALBC stands ready to have dialogue with those charged in development of NAIS to ensure this precious and vulnerable livestock and poultry legacy can be secured.

By taking a public position, ALBC may be able to amend the proposed NAIS and/or its Program Standards such that the adverse impact on breeders and small farmers is eliminated or significantly reduced.

Points of Concern

1. NAIS creates an unfair economic and administrative burden for breeders and small farmer while providing little or no benefit.

2. While the NAIS trace back system does have some merit, clearly the enhanced export markets provide no benefit to breeders and small farmers.

3. The onerous record keeping and procedures of NAIS discourage present and future breeders and small farmers, and thus adverse impact to the conservation of rare breeds of livestock and poultry is anticipated.

4. NAIS has moved into reality too quickly for fair appraisal, comment, or design.

5. No evaluation of cost to benefit has been undertaken.

Board of Directors,
American Livestock Breeds Conservancy

The American Livestock Breeds Conservancy
P.O. Box 477
Pittsboro, NC 27312
(919) 542-5704

THE AMERICAN LIVESTOCK BREEDS CONSERVANCY, founded in 1977, is a non-profit membership organization working to protect over 150 breeds of cattle, goats, horses, asses, sheep, pigs, rabbits and poultry from extinction. It is the pioneer organization in the U.S. working to conserve heritage breeds and genetic diversity in livestock.