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The USDA’s New Strategy for NAIS and a New Texas Program of Cattle “Tuberculosis ID Requirements” Effective October 13, 2007

Over the past several months, the evidence has been mounting that the USDA’s much criticized National Animal Identification System (NAIS) is being restructured to accomplish the same ends – namely, a huge unprecedented national data collection of real-property information (“premises ID”), the electronic identification of nearly all domestic livestock (“animal ID”), and a “forever” database of each animal owner’s activities with each animal (“animal tracking”) — through much less transparent means. The USDA and other NAIS proponents, including some state agriculture officials and many powerful representatives of private-sector agri-industry, were startled and stymied in 2006 to find that the actual owners of animals – farmers, ranchers, homesteaders, plain rural citizens – did not want this program. Citizen grassroots movements and sympathetic state legislators blocked efforts to implement NAIS through the normal processes of enabling legislation and agency rulemaking on both the state and federal levels. One notable example of citizen uprising occurred in Texas, where the Texas Animal Health Commission, led by its director and longtime NAIS proponent Dr. Bob Hillman, was poised to adopt NAIS mandatory premises registration rules in the winter of 2006. But then the unheard-of happened – hundreds of farmers, ranchers, and animal owners submitted written comments decrying the rules and appeared at public hearings, threatening rebellion and noncompliance. The TAHC and Hillman briefly attempted end-runs around the objecting citizens by the abrupt re-scheduling of hearings and the moving of TAHC meetings to locations less conducive to citizen attendance. (See M. Zanoni, “Let Those Who Have Ears Listen Very, Very Closely: USDA and State Agency Doublespeak on Mandatory Animal ID,” Small Farmer’s Journal (Sisters, OR), Spring 2006.) But finally the citizens had their way and the TAHC was stopped – but as we shall see, only temporarily – from its objective of implementing NAIS.

During the course of 2006 the USDA increasingly backed off from its plan for a “mandatory” NAIS, finally announcing in November 2006 that the federal program would remain “voluntary.” But at the same time the USDA was encouraging the states to use all means necessary to bring more participants into the USDA’s premises ID database, the National Premises Information Repository maintained at the USDA/Animal and Plant Health Inspection Service (APHIS) facility at Fort Collins, Colorado. The USDA also began prompting states to move on toward the second phase of NAIS, individual animal identification, which involves the electronic tagging or microchipping of nearly all individual animals with a nationally unique “Animal Identification Number” (AIN).

The tactics recommended by the USDA and/or adopted by some state agriculture departments were, in the view of many farmers and animal owners, aggressive or even relentless; often deceptive; and sometimes coercive. For example, to meet USDA quotas (required as a condition of USDA grants to the states) for numbers of premises registered, the states of New York and Pennsylvania datamined their own state-level farm program records, dumped these state records into the USDA/APHIS National Premises Information Repository, and got premises ID numbers assigned to the farms, all with no awareness on the part of the farmers that the states were signing them up for this so-called “voluntary program.” When some farmers in New York demanded a way out of the program, the New York Department of Agriculture & Markets sent the farmers a letter containing a form with a box to check if the farmers wished to “decline to participate” in NAIS. The letter also discouraged such “non-participation,” stating that “non-participation” would “degrade[]” the system and cause “increased risk” to other “livestock operations.” Many New York farmers misunderstood the complicated letter and form, and thought returning the form would be an “opt in” to NAIS (understandable, since the government was proclaiming loudly and often that the program was “voluntary” and had not informed farmers that the state itself had already surrendered their farm information to the federal National Premises Information Repository). Because New York farmers presumed filling out the form would get them into NAIS (when actually the state had already put them in, and the form was necessary to get out), an undetermined number of farmers who would have wished to “opt out” nonetheless did not return the form. Even those farmers who did understand the Ag & Markets letter well enough to submit the “opt out” form still were not taken out of NAIS by Ag & Markets. Instead, Ag & Markets sent them another letter warning of the consequences of a “catastrophic animal health event” and urging the farmers not to “opt out” of NAIS. This second Ag & Markets letter included yet another form that the farmers had to submit to “decline to participate” in NAIS.

Another tactic used by some states during 2007 to meet premises ID quotas involved requiring children to place their parents’ farms into the USDA premises ID database if the children wished to show animals at a fair or to participate in extracurricular activities sponsored by 4-H or Future Farmers of America. This use of children to compel reluctant property owners into NAIS backfired badly in Colorado where, after some children and their animals were excluded from the state fairgrounds for lack of a premises ID, angry parents forced the reconsideration of a state-fair premises ID requirement for 2008, and also forced 4-H and FFA to rescind a requirement for premises ID for participating children. (“Extension Office Drops Premise ID Requirement,” The Pueblo Chieftain, Oct. 3, 2007; “Legislation Takes Aim at State Fair Dispute,” Rocky Mountain News, Aug. 30, 2007.)

These considerable difficulties in implementing the first NAIS component, premises ID, have not deterred the USDA from moving forward with the even more controversial second component, individual animal identification. While animal owners object to premises ID as an unprecedented compilation of a federal database on citizens merely because they engage in an innocent and commonplace activity (animal ownership), the animal ID component raises even more profound objections based on religious commitments to oppose systems of secular control over Creation, and based on philosophical, social and political opposition to NAIS’s wholesale adoption and promotion of the industrial confinement-farming view of sentient creatures as mere “production units.” Animal ID, due to the USDA’s requirements for radio-frequency identification (RFID) external tags or implanted microchips and due to the fact that what is being tracked and recorded is the owner’s actions involving the animals, raises the same privacy and civil-liberties concerns as the use of those devices in the context of passports and other personal identification documents, the coercive use of microchipping as a condition of employment, or the use of these tracking devices for the developmentally disabled, Alzheimer’s patients, military personnel, or others whose free choice in the matter is impaired. (See, e.g., “Ethical Questions Raised Over Implantable Chips,” National Public Radio, All Things Considered, Nov. 12, 2005; “VeriChip Off the Old Block,” Smartmoney.com, June 2, 2006.) These privacy and civil-liberties concerns are heightened by the fact that a major manufacturer of RFID devices and microchips for animals, Digital Angel Corp., is related, through their common parent corporation Applied Digital Solutions, Inc., to the principal manufacturer of such devices for people, VeriChip Corp. An expansion of the mandatory use of these devices in animals thus will provide revenues to accelerate the advertising and promotion of RFID and microchipping for human applications. This relationship of NAIS to privacy and civil-liberties concerns raised by the uncontrolled technological development of tracking devices is the more troubling because it arises in the context of a government initiative – a relentlessly pursued government initiative – to create enormous new government-owned and/or government-accessible databases of all real property locations where food animals and other livestock are held, of all the animals themselves, and of all their owners’ transactions or physical movements involving the animals. A model system is already well underway to track and monitor the movements of horses and horse owners. Numerous states have agreed to accept a “horse passport” as a government-approved document for traveling across state lines with horses. The owner of the horse would be required to keep a log of all movements and travels with the horse for the effective period, usually 1 year, of the horse passport. The owner’s log would have to be turned in to the state veterinarian of the issuing state at the expiration of the “horse passport.” Renewal of the passport would start the clock for the keeping of a new owner’s log, which in turn would have to be submitted to the authorities at the next expiration date. (Karen Nowak, “Impact of the ESWG [NAIS Equine Species Working Group] Recommendations on Horse Owners,” Mar. 2007, revised Oct. 2007, p. 2.)

Despite the many foregoing objections and questions, the USDA has worked with the State of Michigan to impose a statewide requirement of NAIS individual animal ID for all cattle. The Michigan Department of Agriculture (MDA) has mandated, effective March 1, 2007, that all cattle must be marked with an RFID tag before being moved from their premises of origin. There has been significant objection to this requirement by Michigan farmers, and many devout Christians who are opposed to it on religious grounds, such as the Amish, already have abandoned cattle farming in Michigan because of the RFID requirement. Members of the Michigan legislature have voiced considerable disapproval of the MDA’s program but to date, have taken no effective action. (“Farmers Say No to Animal Tags,” BusinessWeek.com, Dec. 19, 2006; “Battle Over Cattle Tags,” Kalamazoo Gazette, Aug. 19, 2007.) The Michigan program is a very significant step in the development of NAIS not only because it moves from premises ID squarely into the realm of individual animal ID, but also because it signals the USDA’s and states’ transition from a frank reliance on international trade as the motive for NAIS, to a public-relations and legal tactic of couching the motive in terms of “disease control” or eradication.

Indeed, the forces promoting NAIS had begun using the “disease” rationale in 2006, but at that time it did not prove successful. For example, according to farmers who attended the Vermont hearings on mandatory premises ID in the summer of 2006, Vermont’s then Commissioner of Agriculture, Steve Kerr, threatened that substantial numbers of Vermonters could die from “avian flu” if his agency were not given a mandatory premises ID regulation. As the media-driven “avian flu” panic quickly subsided in 2006, the Kerr rationale was perceived as a somewhat desperate gambit to force premises ID on an unwilling public and it failed, with the Vermont mandatory premises rules finally withdrawn from consideration by late summer 2006. The Vermont 2006 failure of the “disease” gambit, however, did not cause the abandonment of that tactic by the USDA and the states, but rather, motivated its refinement and enhancement as a tool for a new way to impose NAIS on an unsuspecting and unwitting public.

The new way depends upon the USDA’s existing authority in many animal disease programs. After the lack of success in 2006 in implementing NAIS through normal channels of legislation or rulemaking, during 2007 the USDA has taken numerous subtle steps to prepare for imposing NAIS through those existing programs. The lynch-pin of the new NAIS was the USDA’s adoption as a final rule, on July 18, 2007, of an interim rule, first published in November 2004, which authorizes the use of NAIS premises IDs (PINs) and animal identification numbers (AINs) in the USDA’s existing tuberculosis, brucellosis, scrapie, and Johne’s disease programs. (It should be noted that none of the foregoing diseases in animals is presently a significant threat to human health in the United States. For example, tuberculosis in people in the U.S. today is spread by human-to-human means, not typically by contact with animals; brucellosis in humans is very rare in the U.S. (www.cdc.gov/ncidod/dbmd/diseaseinfo/brucellosis_g.htm#howcommon); and there is no evidence that scrapie is transmissible to humans. Indeed, today these are not particularly significant as livestock diseases in the United States, occurring only in isolated geographical areas and only very occasionally.)

The significance of the July 2007 final rule on livestock numbering systems for the USDA’s new NAIS strategy cannot be overstated. Doreen Hannes, a prominent leader of the NAIS opposition in Missouri, has noted that the ultimate result of the final rule will be that nearly all animal movements will trigger mandatory NAIS identification. From the USDA’s subsequent publications and actions, we can see that the agency is using the rule to impose mandatory use of NAIS premises ID and animal ID even in routine surveillance programs, such as instances where animal owners test their livestock voluntarily in low-risk environments. Although the final rule does not specifically “require” the use of NAIS in existing disease programs, the rule in the USDA’s view permits the agency to use NAIS in the disease programs at its own discretion and without informing animal owners in advance that they are being put into the NAIS system. Each of the disease programs covered by the rule has previously operated under a numbering program independent of NAIS, with no apparent problems. Nonetheless, the final rule contemplates phasing out the prior numbering systems and, at some unspecified point, using only NAIS IDs in the disease programs. (72 F.R. 39301, 39302.) Thus, in effect, the existing disease programs will become an extensive underground system of forcing animal owners into NAIS participation without their prior knowledge, quite similar to the way that New York and Pennsylvania have assigned NAIS premises IDs to animal owners without their prior knowledge or consent.

The procedure used for adopting this final rule was out of the ordinary and resulted in an avoidance of the normal and more transparent routine procedures. Under the Administrative Procedure Act, an agency can pursue either normal rulemaking or a process often referred to as “interim” rulemaking. See 5 U.S.C. § 553. “Normal” rulemaking entails publishing a proposed rule in the Federal Register, allowing a period for submission of public comments, and agency consideration of relevant issues raised by the comments, before a rule can go into effect. 5 U.S.C. §§ 553(b), (c). In contrast, an “interim” rule goes into effect immediately and is only supposed to be used in special circumstances where the usual notice-and-comment requirements would be “impractical, unnecessary, or contrary to the public interest;” or in instances where the rule is a minor “interpretive” statement, essentially cosmetic and insignificant. 5 U.S.C. § 553(b). The public can submit comments after an interim rule goes into effect and before it becomes “final,” but obviously the opportunity for public opposition to stop a rule from being put into effect is much reduced when the “interim” rule process is used. Although the USDA chose to employ the unusual “interim” rule process in this instance, it is questionable whether the livestock-numbering interim rule in fact met the statutory criteria for a valid exception to the normal notice-and-comment rulemaking procedure.

The USDA’s timing concerning publication of the interim and final livestock-numbering rules is also somewhat out of the ordinary. The original “interim” rule was published and effective on November 8, 2004. NAIS did not come to the widespread attention of animal owners until late April 2005, when the USDA published a “Draft Strategic Plan” laying out the details of the program. In other words, the November 2004 interim rule purported to permit a “numbering” system, NAIS, whose significance was entirely opaque to the affected citizens – farmers, ranchers, animal owners. Not until six months later did the USDA release any information (in the form of the Draft Strategic Plan and related documents) that would permit anyone other than an “insider” to see the true meaning of the interim rule. Indeed, the comment period for the interim rule ended on January 7, 2005, nearly 4 months before the general public had any exposure to NAIS through the Draft Strategic Plan. And in fact, the USDA received only 16 timely comments on the interim rule, many from organizations involved in the development of NAIS; even at that, most of these comments expressed grave reservations about NAIS, but none of these reservations was considered by the USDA upon its adoption of the rule as final. (In contrast, we may note that the publication of the 2005 Draft Strategic Plan, which did not even rise to the level of a rulemaking proceeding, drew 624 comments, overwhelmingly negative.) Even more peculiar, perhaps, is the fact that USDA/APHIS waited over 2-1/2 years before making its interim rule final. Was the USDA perhaps waiting until the furor over NAIS died down because it did not want too much attention to the implications of making the rule final? Because, as we shall see, the main implication of the final rule is that, while the USDA calms citizen resistance by loudly proclaiming that NAIS is “voluntary,” the final rule in fact makes NAIS “mandatory” for vast numbers of animal owners.

Just two weeks after publication of the final rule, two back-to-back USDA announcements on August 1 and 2, 2007 revealed, albeit through a glass darkly, agency actions designed to switch NAIS implementation into the existing disease programs — all without any overt mention of NAIS. First, on August 1, the USDA announced the availability of “$35 million in emergency funding … for the bovine tuberculosis eradication program.” (USDA News Release 0207.07, Aug. 1, 2007.) This number bears an eerie resemblance to the NAIS funding amounts for fiscal years 2006 and 2007, i.e., over $33 million each year. There had been indications that Congress might not authorize specific NAIS funding for 2008. (See Philip Brasher, “Animal ID Program Loses Steam,” Des Moines Register, Oct. 7, 2007.) Of course, if the USDA effectively could implement NAIS through switching funding to “tuberculosis eradication” measures, the lack of NAIS funding from Congress might not matter. Indeed, this scenario might even present a valuable opportunity for members of Congress to pretend to small-farmer constituents that they had “stopped” NAIS funding, while at the same time pleasing big agri-industry NAIS proponents by allowing the program to be continued surreptitiously under the rubric of “tuberculosis eradication.” The new USDA NAIS tactics also neatly render impotent any citizen grassroots efforts to impede NAIS by urging Congress to reject NAIS enabling legislation or remove NAIS funding. If the USDA is now implementing NAIS through existing disease programs, the agency will purport to rely on the existing enabling legislation for the disease programs, and will be using funding from the disease programs.

On August 2, 2007, the USDA released a solicitation for bids for contracts to manufacture 1.5 million NAIS-compliant RFID ear tags. (USDA/APHIS Presolicitation Notice, Solicitation No. AG-32KW-S-07-0030, Aug. 2, 2007.) As memorialized in a press release issued three weeks later, on August 23, 2007, these RFID tags “will be used to uniquely identify U.S. livestock that are part of current animal disease programs, in particular within geographic regions where bovine tuberculosis testing and the brucellosis calfhood vaccination program are most active.” (APHIS News Release, www.aphis.usda.gov/newsroom/content/2007/08/NAIS_eartags.shtml.) Having in place the final rule allowing the use of NAIS in existing disease programs, the USDA, by ordering the 1.5 million cattle RFID tags for use in existing tuberculosis and brucellosis programs, was signaling that it would quickly move to implement NAIS through these programs, and quickly move to impose the controversial electronic individual animal identification phase of NAIS.

In late August of each year, NAIS proponents gather for an “ID Expo” conference sponsored by the National Institute for Animal Agriculture (NIAA), a trade group for big livestock industry players and the manufacturers of high-technology identification and tracking equipment and systems. At the 2007 ID Expo, held from August 28 through 30 in Kansas City, the parameters of the new NAIS promotion were clear: talk about “traceability” and mention NAIS only secondarily, if at all; talk about “animal disease” and downplay the role of global trade as the motive for NAIS; and concentrate on implementing NAIS through the existing tuberculosis and brucellosis testing programs for cattle, as well as through requiring NAIS premises ID and individual animal ID for issuance of USDA/APHIS interstate shipping permits, commonly called CVIs (Certificates of Veterinarian Inspection). For example, USDA Undersecretary Bruce Knight, in a talk given on August 30, emphasized building on current ID uses in existing programs. He stressed that NAIS is moving on to individual animal ID. And while he dwelled on tales of disease events from the past, he could not help mentioning what NAIS is really about: global trade. Knight emphasized that “NAIS individual animal ID is … a valuable tool … to harmonize our own trade requirements … to make sure we are fully OIE compliant” — that is, compliant with global trade rules promulgated by the former Office International des Epizooties, now known as the World Animal Health Organization. (NIAA Newsletter, fall 2007, p. 1.)

Also appearing at the ID Expo was longtime USDA/APHIS NAIS coordinator Neil Hammerschmidt. Hammerschmidt, also speaking on August 30, discussed a forthcoming new “Business Plan” that will set priorities for NAIS. Hammerschmidt made clear that NAIS is poised to move aggressively into its second phase: “Premises registration alone will not get the job done … [Individual] animal identification is progressing.” (NIAA Newsletter, fall 2007, p. 7.) Perhaps Hammerschmidt is unaware that in Indiana and Wisconsin, states with considerable numbers of Amish farmers who have serious religious objections to NAIS as a whole and particularly to the RFID/microchip identification of individual animals, state NAIS officials have assured the Amish, in order to try to get them to accept premises ID, that NAIS entails premises ID only, with no plans for individual animal ID.

Another USDA/APHIS NAIS program coordinator, Dr. John Wiemers, explained that one current NAIS tactic is the “harmonization of animal identification systems,” including breed association and performance-recording programs. Translated, that means such private organizations as the Holstein Association, American Jersey Cattle Association, and Dairy Herd Improvement Association, all NAIS promoters from the outset, will be requiring NAIS premises ID and individual animal ID as part of registering animals and compiling production records. Another strategy that is an “immediate priority” is integration of NAIS with existing disease programs. Wiemers made clear that all such programs will in the near future require NAIS premises ID and individual animal ID. Moreover, USDA/APHIS plans to end all former, non-NAIS numbering systems by setting a sunset date when all disease programs must stop using their former numbering systems, and must start using only NAIS numbers. All these strategies are now targeted primarily at the cattle industry, because cattle are a “high priority” for the new NAIS. (NIAA Newsletter, fall 2007, p. 7.)

The USDA/APHIS new NAIS as showcased at the ID Expo is also memorialized in a four-page agency publication called “Advancing Animal Disease Traceability.” (http://animalid.aphis.usda.gov/nais/naislibrary/documents/plans_reports/tra ceability_overview.pdf) Practicing the new NAIS public-relations approach, this “Traceability” document, while all about NAIS, does not specifically mention NAIS until nearly halfway into the document, at the bottom of page 2. This NAIS-Traceability document, in its own opaque way, tells us that USDA/APHIS is going to make NAIS premises ID and animal ID mandatory in all existing disease programs and for the issuance of CVIs: “Advancing traceability requires the integration of NAIS data standards across all disease programs … USDA will take steps to adopt and apply NAIS data standards to existing disease programs, including international/interstate commerce regulations.” (Id., p. 3.) As USDA/APHIS moves forward with individual animal ID, “the beef and dairy breeding herds are the highest priority.” (Id.) The particular strategy of mandating NAIS in cattle tuberculosis and brucellosis programs is also made clear in a USDA/APHIS “Veterinarian Information” NAIS fact sheet for practicing APHIS-accredited veterinarians (the only veterinarians qualified to do program disease testing and to issue CVIs): “Brucellosis and tuberculosis programs in some states are already or soon will be using [NAIS] animal identification numbers (AINs).”

Just about a month after the ID Expo, on September 24, 2007, USDA/APHIS announced the first award of a contract for the production of the NAIS RFID cattle tags that had been specified in the 1.5 million RFID-tag APHIS bid solicitation of August 2, 2007. (See discussion of the bid solicitation above, p. 6.) The September 24, 2007 award notice tells us that USDA/APHIS has made a contract with Global Animal Management, Inc., in the amount of $546,000, for the provision of 420,000 NAIS-compliant RFID tags for cattle. (USDA/APHIS Award Notice, Contract Award No. AG-32KW-P-07-0541, Award Date Sept. 24, 2007.)

All of which brings us back full circle onto the trail of Dr. Bob Hillman and his Texas Animal Health Commission. Also on September 24, 2007, the TAHC issued a press release entitled “Texas Animal Health Officials Tackle Tuberculosis Entry and ID Requirements.” Even though Texas presently is free of bovine tuberculosis, on the basis of isolated instances over the past few years of cattle reacting positive on TB tests in a few other states, the TAHC is ramping up a program of individual animal ID, supposedly as a means of TB monitoring. We are told in the press release that the TAHC has already adopted new cattle “movement” regulations, and that they will go into effect on October 13, 2007. We are not told in the press release why no similar media announcement was made before the actual adoption of the rules. We are not told whether the rules followed a normal notice-and-public-comment process – if so, it would appear odd that none of the substantial number of Texas livestock owners who stopped mandatory NAIS premises ID in 2006 seem to have noticed the implications of these rules. Perhaps these rules were adopted by some Texas process analogous to the USDA/APHIS adoption of NAIS for existing disease programs by “interim” rule. But the press release does not address the procedure behind the new Texas rules.

The new Texas rules are directed primarily at dairy cattle and require “official” individual animal ID and a CVI for sexually-intact dairy cattle entering Texas. The rules further require “[individually] identifying all Texas dairy cattle regardless of age – with an official or TAHC-approved identification device prior to movement within the state.”

As to why primarily dairy animals have been targeted by the new rules, Dr. Bob Hillman “explained that dairy animals are managed in close confinement and, therefore, are at greater risk for TB exposure if they have an infected herd mate.” The problem, however, with this rationale is its manifest untruth, on at least two grounds. First, dairy cattle are not necessarily kept in confinement. Many dairy herds are grazed on pasture and in that sense managed similarly to small beef herds. Second, the TAHC press release elsewhere notes that TB in free-ranging deer is a contributing factor to TB occurrences in livestock. Even if all dairy herds were totally confined as Dr. Hillman seems to assume (and in fact they are not), confinement would remove the possibility of infection from wild deer and therefore would seem to make TB less of a danger in dairy cattle than in beef cattle.

Beef producers are some of the most ardent opponents of NAIS; in contrast, many dairy producers have not resisted NAIS even if they may be opposed to it in principal. The difference is primarily cultural. Dairy farmers are already subject to a considerable burden of government regulation and testing of their on-farm procedures of milking and milk storage. They are also notoriously overworked. Thus, when told by state officials that they either are required to register for NAIS premises ID (e.g., in Wisconsin), or that their premises ID has already been “assigned” in a so-called “voluntary” program (e.g., in New York and Pennsylvania), dairy farmers have tended to ignore or fail to understand the implications of the NAIS program they are being compelled to join. Beef producers, on the other hand, have been the most vocal and committed NAIS opponents, primarily through their trade organization, the Rancher’s and Cattlemen’s Legal Action Fund, or R-CALF USA. Targeting beef cattle producers in Texas with a new NAIS individual animal ID requirement under the guise of “tuberculosis control” (a disease program that has been implemented successfully for decades on the basis of inexpensive metal eartags and its own numbering system) would be likely to provoke a sagebrush rebellion.

Of course, we do not know for certain from the TAHC press release whether the new Texas dairy cattle individual ID program is intended to dovetail with the USDA/APHIS new NAIS strategy of mandatory NAIS premises ID and animal ID in existing disease programs, and especially in existing cattle brucellosis and tuberculosis programs. The press release says only that dairy cattle will need an “official or TAHC-approved identification device.” The release does not tell us that these approved or official devices would necessarily be NAIS-compliant RFID eartags. This does, however, bring us to another unusual congruence. The TAHC news release occurred on the same day as the USDA’s announcement that it had contracted for the provision of 420,000 NAIS-compliant RFID eartags. According to the National Agricultural Statistics Service, for the period of 2000 through 2006, the average Texas dairy cattle population was approximately 437,000 head of adult cows and replacement heifers.

Now, unusual correspondences in dates and numbers may not be complete proof. But they should be enough to prompt all those Texas citizens who stopped NAIS in 2006, and certainly all Texas cattlemen, to start asking for whom the cowbell tolls.

Mary-Louise Zanoni
P.O. Box 501
Canton, NY 13617
315-386-3199
mlz@slic.com

Copyright 2007 Mary-Louise Zanoni. All rights reserved. Please contact the author to request permission to reprint or republish.