New USDA Guide—What are the costs?
by Karin Bergener, Judith McGeary & Randy Givens

Many questions have been raised about the costs of NAIS. USDA has been asked for a cost-benefit analysis, but hasn’t provided it.

The User Guide is correct that premises registration is currently free in all states. USDA admits, however, on page 26 that the states “may choose to keep premises registration free or not.”

The Texas Animal Health Commission proposed charging a fee for mandatory premises registration to fund the agency’s activities. Michigan State Department of Agriculture has stated that its mandatory RFID tagging of cattle is at “minimal” cost to owners “as long as federal funding continues.” What happens when the federal funding ends? The USDA and state agencies continue to avoid the real issue, which is how much the NAIS program truly costs in its entirety.

The estimated cost data in the User Guide is spurious and underestimated. According to USDA, “horse owners are paying $20 to have a horse implanted with injectable transponders. If the owner has the expertise to implant the transponder him/herself, the cost of the transponder would be a few dollars.” Even for those implanting the chips themselves, just the microchip and syringe costs around $18 (netposse.com). With a vet’s assistance, the cost may be anywhere from $35 to $70. Those quotes do not include the cost of hauling the horse to the vet or paying a barn-visit fee.

USDA also fails to include the costs of RFID readers, computers, or other means required for reporting to the NAIS database, and the untold hours of labor involved with tagging animals, record keeping, and reporting. Estimates from the Australian Beef Association place the total cost of tagging at $37 to $40 per animal on average. Since people who own one or a few animals don’t buy supplies in large enough quantities to qualify for the discounts enjoyed by large producers, these averages understate the probable cost for most of us.

USDA repeatedly says that competition in the market will keep reporting fees down for animal owners. The User Guide does not, however, say how these costs will be controlled or minimized. All we have are the hopes of USDA employees that NAIS will have only minimal cost impacts on animal owners.

Moreover, entities that stand to profit from running the databases have played key roles in developing the program. Experience with many areas of our economy proves that the bureaucrats’ hopes that costs will stay low are not justified, especially when private industry is actively involved in setting government policy.

USDA admits that “...no specific participation cost figures are available at this time.” So its hopeful message about costs is not based on facts.

• Alleged Benefits

Karin Bergener is an attorney in Freedom, Ohio. Judith McGeary is an attorney in Austin, Texas. Randy Givens of Paige, Texas, is a retired Army colonel. All three are livestock owners and cofounders of Liberty Ark Coalition established to defeat NAIS. Their article appeared in the Winter 2007 issue of Rural Heritage.