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The New Deal era farm programs are models for an economic stimulus that we greatly need today.  We must remember that these programs were supported in the banking committees, in the Steagall Amendment of 1941.  (This is not the depression era Glass Steagall Act.)  Economists argued that one dollar in agricuture generated seven more dollars throughout the economy.  Today we desperately need this kind of a powerful economic multiplier.  We need to have this worked out between the Agriculture Committees and the Banking Committees.  We need the money.  This was a successful Democratic approach in the past.  We need work on it today.

Iowa Senator and Senate Agriculture Committee Chairman Tom Harkin is the key "person with the power to decide" on this issue.  He was the national leader on it, with his Harkin-Gephardt farm bill of the 1980s and 1990s.  Banking chair Chris Dodd also needs to be brought into the discussion.  Dodd expressed understanding of Harkin-Gephardt issues when he campaigned in Iowa prior to the caucuses.  The Democrats switched away from Harkin-Gephardt to a greened up version of the Republican "Freedom to Farm" act when Harkin became chair prior to 2002.  They apparently wanted something that was winnable for Harkin in that political context.  Remember, however, the 1996, 2002 and 2008 farm bill Commodity Titles were worse than Reagan/Block (1985) and Nixon/Butz (1970s).

Today we have entered a "teachable moment," as in the New Deal, and we are very well positioned.  We have the Democratic victory and the huge Obama symbolic victory.  We have Harkin as Agriculture Chairman and Dodd as Banking Chairman.  But we also have a new farm bill that will very likely fail, well before its five year time period is up, for the simple reason that cost of production is skyrocketing (Iowa State University projections up 45% 2007-2009), but the farm bill made no cost of living increase (again) in compensatory farm subsidies.  For all of these reasons, we have a new winnability potential, given the mobilization of appropriate leadership.  The stage is set for a return to Democratic, New Deal, non subsidy, farm based wealth creation.

The New Deal era farm programs featured price floors and supply mangement on the bottom side, and price ceilings with strategic commodity reserves on the top side, just like the Harkin-Gephardt farm bill of the 1980s and 1990s, and the current Food from Family Farms Act of the National Family Farm Coalition.  There were no commodity subsidies (ie. none, 1933-1961, except for some cotton subsidies 1934-1939, "Direct Government payments by program, United States, 1933-95" USDA-ERS).  The government actually made money on the programs, $13,000,000 1933-1952 according to Mark Ritchie ("Crisis by Design," League of Rural Voters Education Project; all sources here are online).

In the Steagall Amendment of 1941 these programs were supported at levels that brought parity (or "100% of parity") with non agricultural sectors of the economy.  The Steagall Amendment went through the Banking Committees.  Parity is a term of equity (comPARITIVE). 100% of parity is basically a standard for "living wage" prices and "fair trade" exports.  U.S. agriculture then had 100% of parity or more every year, 1942-1952, until Eisenhower reduced the price floor levels.  At the same time, they never exceeded 115% of parity, moderating price spikes, volatility, and speculation, factors that have raised havoc recently.  

One indication of the success of these programs is that we had no farm depression following World War II, as we had after World War I and as we had in the 1980s following the price spike of the 1970s (resulting from the massive purchases during the secret Soviet grain deal).  Recently we've again had an incredible farm price spike.  The dramatic speed of the spike has fueled huge cost increases AND a huge push for supply increases, setting the stage again for future oversupply and low prices.  As agricultural economist Daryll E. Ray has warned, "...extraordinary increases in crop prices ... sets up a world supply response that sentences farmers everywhere to years of low prices" ("Supply response to sky-high prices," 12/5/08).  

The "parity" farm programs of the Democratic New Deal and Steagall Amendment were degraded from 1952-1996 as price floors were lowered and supply management was reduced.  These mechanisms were ended in 1996 (in farm bills:  1996, 2002, 2008).  Overall agricultural parity fell below 100%, decade by decade:  (1960: 80%; 1970: 72% 1980: 64%; 1990 54%; 2000: 38%).  As of September 2005, parity figures for major commodities were:  corn: 25%; rice and cotton: 26%; wheat and soybeans, 32%.  By this fair-trade, living-wage standard, 2005 prices were in need of quadrupling or tripling.  (This has been misunderstood in almost every article I've read on the "food crisis."  Typically export dumping, the key issue behind this poverty for decades, (up to a few years ago,) is forgotten, no standard of fair trade prices is even considered, and a call for a return to more dumping is emphasized (without using that word,) or at least implied.)

Compensatory subsidies were added, not as a price or supply affecting mechanism (which they have never been,) but as political tools to placate farmers.  Feedgrain (ie. corn, barley, oats) and wheat subsidies were added in 1961, cotton subsidies in 1964, and rice subsidies in 1976).  The 1985 Republican farm bill, in response to the 1980s "farm crisis," "pumped a lot of money into the rural economy," they spun.  In truth, the subsidies were increased downwards.  The corn price floor was lowered from $2.55 in 1984 to $1.57 in 1990, a drop of 98¢.  The compensatory subsidy trigger for corn was lowered a smaller amount, from $3.03 to $2.75 over the same period, resulting in an increase in the maximum potential subsidy from 48¢ to $1.18, an increase of 70¢.  So prices floor mechanisms were lowered by 98¢ and compensatory subsidy mechanisms increased by 70¢, resulting in a potential net loss of 28¢ under this Republican program of "pumping in money."  Reagan even subsidized "the evil empire" with below cost grain.

USDA-ERS data illustrate the expected results.  Between 1981 and 2006 corn, wheat, cotton, rice, soybeans, grain sorghum, barley and oats rarely netted above zero in the marketplace (excluding subsidies and versus full costs).  (ERS, "Commodity Costs and Returns: U.S. and Regional Cost and Return Data")  If you multiply this net per acre by acres and sum the eight crops, only 1996 was above zero.  The yearly amount below zero averaged in the billions, with U.S. corn and wheat each netting nearly $70 billion in the red overall over the period.  

The U.S. lost billions of dollars on farm commodity exports under these programs, because we weren't willing to charge prices above our costs.  This was true, even though we are said to have 40% of the export market.  We had as high as 80% to 90% export market share for some commodities and still chose to lose money, exporting our wealth out to foreign mills, processors and livestock interests (and also exporting our own meat and processed items fed/created with these below cost raw materials).  This contrasts sharply with OPEC, for example, which, has managed supply and charged higher prices.  Decades ago you could get a barrel of oil for a bushel of wheat.  Today wheat is about $5-$7 per bushel.  Oil is no longer $140, but it's way above wheat.

These low prices, of course, are the main general cause of poverty behind the "food crisis."  Decades of export dumping (far below costs) has devastated Least Developed Countries around the world.  Least Developed countries are 73% rural (UN, 2005).  Farming is huge in their economies.  With low prices (and with WTO pressure to open their markets to dumping) their economic multipliers are gutted and wealth creation bottoms out.  Though food has been plentiful, nearly a billion people can't even afford to pay "dumped" grain prices.  And we've lost billions of potential customers, as rural based wealth has shrunk, fomenting poverty around the world over these decades.

From an economic point of view, there are several additional considerations.  First, these policies have had a dramatic impact on infrastructure (U.S. and world).  We massively built up whole industries on the foundation of below cost pricing, including things like high fructose corn syrup, transfats, ethanol, and concentrated animal feeding operations.  We built it up, first of all, with these massive below cost gains.  Timothy Wise and Elanor Starmer of Tufts University have estimated that Tyson and Smithfield got more than $2.5 billion each in these non compensatory, hidden, (not in the government budget like compensatory farm subsidies) gains 1997-2005.  We've also built up some of these infrastructures with very large governmental subsidies.  

With recent higher prices, however, this infrastructure got into trouble.  We've seen recently that, with higher corn prices, the ethanol industry has taken a huge hit.  This has been a front page story in the farm press for months.  

At the same time, alternative agricultural infrastructure was allowed to decay (U.S. and worldwide).  The prime example here is on-farm livestock, diversified livestock-based farming.  With grain available at prices far below costs to feed livestock, large corporate entities have been encouraged to take these key value added enterprises away from diversified farmers.  Here in Iowa, on most farms, livestock facilities (buildings, fences) are no longer used, and younger family members may not know how to raise livestock.  

This has been a major blow to sustainability.  Pastures and hay ground, often put on the most hilly or highly erodible land, are no longer needed.  Row crops are grown there instead.  Small grains, also protective of the soil, are taken out of rotations.  Externally purchased herbicides and insecticides are needed to replace these former farm management practices.  Without legumes like clover or alfalfa, more purchased nitrogen is also needed, which is more toxic and more likely to get into surface and ground water.  With these changes, and with CAFOs, health risks and costs are also increased.  Communities become less sustainable as social structures decay.  (Note: the "way of life" of diversified, sustainable family farming provides important social services, through the private sector.)  Behind it all is the fact that well below cost feedgrains compete against these other feeds: pastures/forages/hay.

These changes in the nature of investments in farm infrastructure (U.S. and worldwide) have many important economic implications.  First, both crop and livestock farming becomes larger in scale. This is spun as an improvement in efficiency, as it is claimed that now one farmer can feed a lot more people.  In truth there has been a large hidden increase in the number of non farmers producing this very same food, hiding inefficiencies in these systems.  As agricultural economist Stewart Smith has shown, the farm share of the food dollar fell, (not to 20-25% as is typically claimed using USDA figures, where input costs are not taken out, but,) to below 8%, and is projected, (not predicted, in his latest figures,) to disappear by 2020.  That's down from a 41% farm share in 1910 and probably over 50% in 1900, according to Smith.  Don't blame farmers for your food costs!  The farm share of corn flakes and wheat bread in the U.S. is probably already down around 1% (Smith, "Sustainable Agriculture and Public Policy," and USDA food dollar figures for individual items like bread and cereal).  The "marketing share" (output complex) grew from 48% in 1910 to 73% in 1997, and the input share grew from 14% to 20%.

Second, the economic multipliers underlying the corporatized infrastructure change for livestock are much weaker than those for what they replaced.  For example, supporters of CAFOs have pointed out that in building them, jobs are created.  That's "value added."  They don't tell you about the value subtracted.  For jobs alone, the impact is devastating, according to agricultural economist John Ikerd.  For every CAFO job created, 2 or 3 independent farmers are lost ("The Economic Impacts of Increased Contract Swine Production in Missouri:  Another Viewpoint").  That is, we've invested (via farm market policies and direct subsidization like EQIP, which offers up to $450,000 per CAFO,) in infrastructure that hugely reduces jobs.  Clearly, these are not the kinds of diversified farms that can create $7 throughout the economy from each $1 invested, or 6 jobs from each 1 job.  Ikerd summed up the conclusions from dozens of recent studies on CAFOs (and important older studies):  "Virtually every study done on the subject in the past 20 years has confirmed the inevitable negative community impacts of CAFOs. Research consistently shows that the social and economic quality of life is better in communities characterized by small, diversified family farms."  ("CAFOs vs Rural Communities")  He then gives detail about a number of these specific economic findings.  Even the communities that got the most CAFO infrastructure investment were hurt. That's surely an economic multiplier below 1.0.

Today, we need to update our study of economic multipliers in agriculture, and update the New Deal Parity programs.  Bold new work in sustainable agriculture must be fully taken into consideration.  Organic farming has held its own and better against industrial farming, in spite of getting much less commodity subsidization, and only a tiny fraction of the research subsidization.  Organic markets have grown 20% per year.  The Rodale Institute found that yields were significantly higher in organic corn than in conventional corn, after a couple of decades.  Studies are also finding that organic corn is cheaper to produce per bushel, even without subsidies.  

Findings about sustainable agriculture fit with the view of Charles Hampden-Turner that the key to wealth creation is the reconciliation of values, not a mere adding of values.  When the most values are reconciled, as with sustainable agriculture, much wealth is created.  When there are inherent ecological, social, health and economic contradictions, in the case of CAFOs and large industrial farms, for example the little wealth is generated.  It's a bit like military spending, making investments, then stockpiling the results or blowing them up.

We also need to look at international supply management, commodity reserves and price mechanisms.  The Africa Group at WTO has taken the lead on this.  (IATP, "On the Right Path to Development: African Countries Pave the Way").  Some years back the EU was also on board, pushing for the United States to implement these kinds of policies, according to Mark Ritchie, when he was president of the Institute for Agriculture and Trade Policy.

All of this can be viewed in light of the economic crisis and the new farm bill, which could very possibly fail, well before its five year term is up.  "Freedom to Farm" failed, and four emergency farm bills were passed, 1997-2001 to prevent an economic disaster (which LDCs, nevertheless, experienced).  The new farm bill will also fail, (if continued long enough,) because it has no provision to insure that we make a profit on farm exports.  Currently farm costs (ie. 2009 projections, corn following soybeans $4.32, corn following corn, $5.10, Iowa State University) are well above market prices (ie. probably since summer 2008, with corn, now around $3.50s-$3.70s).  Meanwhile there is no cost of production or inflation increase in the main farm program compensations (DCP).  For example, Target Prices for corn have been raised only 1% since 2002, and Loan Rates have been raised only 3% since 1996.  Meanwhile, Iowa State University Extension's cash cost projections for corn have increased regularly, including a whopping 45% just since 2007.  

Here it is:  1. no price floors or supply management, AND, farm commodities lack "price responsiveness on both supply and demand sides, so prices usually fall below costs in the free market (Daryll E. Ray, "It's Price Responsiveness! It's Price Responsiveness!! IT'S PRICE RESPONSIVENESS!!!" or "Agricultural Policy for the Twenty-First Century and the Legacy of the Wallaces").  2. Farmers get Direct Payments to compensate for expected failures of the free market of about 83.3% of 28¢.  That's like bringing cash costs down to about $4.08 per bushel.  But CounterCyclical compensations don't kick in until prices drop down to $2.63!  Then you can get 85% of 36¢, more or less (less because it doesn't account for production increases since the 1980s).  That takes you down to $2.27.  3. But LDP compensatory subsidies don't kick in until prices fall to about $1.95, leaving another gap!  The ACRE program, an alternative to countercyclical payments, works better if prices in the short run are good, but worse if prices fall.  ACRE has no cost-based compensation standard, only a floating and relativistic "market oriented" mechanism.  But again, these farm markets lack "price responsiveness."

My family remembers 7¢ corn here in the Great Depression.  The future is unknown, in our free (volatile) farm markets, but with no price floors and recent massive efforts toward overproduction, there is nothing to prevent a massive farm depression, even with the various compensations.  So far, we've had two years of agricultural prosperity heading into the current economic crisis.  We must not squander this moment by neglecting to stimulate the powerful economic multipliers in diversified, sustainable family farming.  Obama is new to this.  Vilsack too.  Harkin, however, is ideally positioned to mentor them both on these huge issues.  Harkin is the key.  We must support Senator Tom Harkin in leading us now to move in this crucial, historically Democratic, direction.

Originally posted to Iowa Farm Activist on Fri Feb 06, 2009 at 09:02 AM PST.

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Comment Preferences

  •  Thanks for the history lesson ... (14+ / 1-)

    ...and thanks for the future proposal.

    Americans do not like to think of themselves as aggressors, but raw aggression is what took place in Iraq. - John Prados

    by Meteor Blades on Fri Feb 06, 2009 at 09:08:12 AM PST

  •  Thanks for this. (6+ / 0-)

    I will have to come back to this later -- it's more than I've been able to absorb at one go -- but I just want to thank you.

    "There is only one caution. Don't let it happen again." -- edscan, 21 Jan 2009

    by ArtSchmart on Fri Feb 06, 2009 at 09:21:52 AM PST

  •  SO SORRY (2+ / 1-)
    Recommended by:
    fcvaguy, Alec82
    Hidden by:
    trashablanca

    I mistakenly troll rated (please disregard)--an absolutely well-researched and right-on-target diary--thank you!!

  •  USDA Proposal Reduces Profit Margin on Livestock (3+ / 0-)
    Recommended by:
    Wee Mama, sberel, CcVenussPromise

    Just before the Bush administration left town, the USDA filed a rule change that would result in a mandatory $2 - $3 fee, in the form of a specialized RFID tag, for each head of livestock (for now, cattle, hogs, sheep, goats).

    With the trillions of dollars tossed around, this may not sound like much, but with profit margins already reduced on livestock (lower prices at the market, higher feed costs), this extra fee could make the difference between profitability or going out of business. The cost does not include the extra labor involved for attaching the tag.

    Link

    The proposed change is not written clearly, but some of the comments explain the proposed change in a more articulate manner.

  •  The cost of production skyrocketing (1+ / 0-)
    Recommended by:
    sberel

    but the USDA wants the NAIS implemented despite the facts that, first of all, it has proven to be a failure for producers in Australia (their's is NLIS). Secondly, there is no evidence, scientific or otherwise, to merit it's implementation. And thirdly, there has been no cost analysis -- other than by a private sector and it proved to add significant cost to producers with no guarantee of effectiveness in disease tracking.

    Because... we already have disease tracking mechanisms that work.

    Sooo, why is the USDA hell bent on pushing NAIS on every livestock owner in the United States including horse owners?

    Yes, I agree with you, I like your proposal, I support it. But, you know that meanwhile there is the NAIS which will cost producers more than the problems already faced with meat packer monopolies determing price and co-mingling cheap, diseased beef from Mexico and elsewhere with U.S. Beef....

    And Mexican government demanding we drop M-COOL. Or what?

    And you know there's the the Iowa Ames lab federal employees situation -  veterinarians who are having to explain why they purchased all those prescription drugs for human use? (published at meatingplace.com, story: Vilsack comes down hard and publicly on ethics issue by Janie Gabbett on 2/5/2009)

    The USDA needs an ass whoopin. And the NAIS is pointless.

    DKos has published numerous diaries on NAIS.

    But here's one kossack's LONG explanation for why we're against it and for those on dial-up -- With my apologies for its length but this is too important and is very much attached to your proposal:

    1. No analysis or quantification of the alleged benefits to animal health. The

    preamble to the proposed rule includes general claims about the benefits of
    identifying locations where animals are kept. The USDA has never addressed the
    capacity of existing programs to meet this purpose, nor how the proposed rule
    actually improves on the current ability to identify locations. USDA claims that
    uniformity in numbering systems is required in order to ensure program benefits,
    but its repeated changes in the program rules and guidelines contradicts its own
    claim.

    1. No analysis or quantification of the costs. The preamble to the proposed rule

    states that the USDA has reviewed it under Executive Order 12866, which
    requires a cost-benefit analysis of federal regulations. But the agency has failed
    to produce the analysis for this rule, and has also failed to provide the cost-benefit
    analysis performed by Kansas State University under a grant by the USDA. This
    stands in stark contrast to the USDA’s detailed cost-benefit analysis on Country
    of Origin Labeling in its recent final rule, in which USDA discussed many different
    potential costs, including capital investment, equipment, recordkeeping,
    operational changes, labor and training, software programming, computer
    hardware, storage, procurement (including transportation and shipping), and the
    costs of tagging animals. The agency’s failure to address many of these same
    costs for NAIS is particularly striking given that there is no Congressional
    mandate to implement NAIS.

    The proposed rule would substantially increase costs, and add intrusive
    governmental burdens, to the industry and the taxpayer:

    a. The costs of maintaining a federal database with the PIN information, including
    regular updates to provide the benefits for "up-to-date" information claimed in the
    preamble to the proposed rule;

    b. The costs of 840-numbered tags to farmers and other animal owners;

    c. The costs to state agencies of implementing changes to existing programs;

    d. Overriding objections regarding increased federal government intrusion into the
    lives and daily activities of farmers and other animal owners;

    e. The costs of changes to existing programs. USDA admits in the proposed rule
    that it has changed its requirements for official tags at least three times over a
    short period of time. While the proposed rule allows for phasing in the latest
    format, repeated regulatory changes inevitably cause waste and greater cost for
    producers, manufacturers, agriculture service providers, and others having to read
    and record tag information.

    1. Violation of individuals’ religious beliefs. Amish, Mennonite, and some other

    individuals have religious objections to the universal numbering system under
    NAIS and the use of electronic tags, which are the main tags approved for use
    with the 840 numbering system.

    1. Disincentives for people to seek veterinary care for their animals and

    participate in existing programs. The proposed rule directly impacts four animal
    disease programs: tuberculosis, brucellosis, scrapie, and Johne’s. Given animal
    owners’ objections to NAIS, the proposed rule could create a disincentive for
    people to participate in the listed programs—this would actually increase rather
    than decrease the risk to the public and farm operations. Moreover, the proposed
    rule comes after several years of objectionable tactics used by USDA and state
    agencies to enroll people in NAIS, including deceptive registrations, economic
    coercion, and data mining, as well as repeated, apparently disingenuous, claims
    by USDA that it had no intention to make NAIS mandatory. The pattern of
    misleading information and repeated changes in the program has created a
    situation where animal owners may decide to avoid many other important
    programs out of fear of being forced into NAIS.

    1. Confusion over the impact of the rule. The USDA has repeatedly changed its

    plans for NAIS. The proposed rule is the latest in a series of ambiguous and
    confusing documents. Under the proposed rule, it appears that tattoos and
    brands will still be allowed, but the language is confusing and unclear. This will
    increase the costs, both quantifiable (such as the costs to agencies of education
    and enforcement under the proposed rule) and qualitative (such as the loss of trust
    in agencies by animal owners).

    1. The implementation of a flawed, wasteful program. This proposed rule is a

    significant step towards implementing the entire NAIS program. Thus, the
    agency should address the fundamental question of whether it should be
    implementing NAIS at all. All of the problems identified above apply to the full
    NAIS program, as well as this specific rule. And there are additional objections:

    a. No significant benefits: USDA’s assertions that NAIS will provide benefits for
    animal health are not supported, and actually contradict basic scientific
    principles. USDA has not produced any risk analysis or epidemiology studies,
    both of which would certainly indicate that the focus of agency regulation should
    be on high-density confinement operations. NAIS does not address the
    fundamental risks associated with this production model.

    b. High costs: USDA has not addressed the wide range of costs that would be
    incurred by both animal owners and taxpayers. These costs include: (1) the
    development, maintenance, and update of massive databases; (2) the costs of
    tags that will be predominately high-tech; (3) the labor burdens for tagging every
    animal; (4) the paperwork burdens of reporting routine movements; and (5) the
    costs of enforcement on millions of individuals.

    c. Impracticality: Under the current plans, approximately 150 millions animals
    would have to be individually identified (that does not include the billions of poultry
    or millions of swine who would be group identified on factory farms). The
    databases to register the properties, identify each animal, and record billions
    of "events" will dwarf any system currently in existence. How will the program be
    enforced? How will technical errors even be identified, much less fixed? How will
    security be maintained? The experiences with existing databases – both current
    USDA programs and a NAIS-type system in Australia – indicate that the error
    rates and potential security breaches would be significant.

    d. Waste of money: The USDA has already spent over $130 million on NAIS
    implementation. Yet it still has no workable plan for the program. Even by its
    own estimates, only about 1/3 of premises have been registered, and this might
    very well be a vast overestimate of its success. The USDA’s estimates are based
    on the 2002 Census, which did not include the hundreds of thousands of horse
    owners, hobby farmers, homesteaders, and others who would be regulated under
    NAIS.

    e. Diversion of resources away from more critical needs: The USDA’s focus on
    NAIS has diverted limited resources from other, far more critical needs for
    addressing animal health. NAIS does nothing to prevent animal diseases from
    entering our country through uninspected imports, to detect diseases (including
    Mad Cow), or to prevent animals from becoming ill (such as by improved animal
    husbandry practices or vaccination). In fact, by replacing the existing disease
    control programs with one uniform tagging system, NAIS would hamper disease
    control efforts that currently rely on the ability to quickly identify which animals
    have already been vaccinated or tested, based on their tags. NAIS has also
    diverted attention and resources from measures needed to improve food safety,
    such as increased inspections of slaughterhouses.

    f. Inconsistent and unachievable promises: While this proposed rule mentions
    only the alleged (and unsupported) animal health benefits, agency officials and
    industry proponents have also claimed that NAIS will provide food safety benefits,
    address horse and cattle theft, help with blizzard responses, or many other
    promised benefits that appear to depend on the audience being addressed. Yet
    the agency has not explained how these benefits are to be achieved when NAIS is
    managed by APHIS (which is not a food safety or law enforcement agency), which
    has promised that the information collected will be confidential and used only for
    animal health purposes.

    g. Ultimately, a disincentive for individuals to be involved in farming or animal
    husbandry of any kind: Implementing this flawed program would be a significant
    cost to our entire society because of the impact on our food supply. Because of
    the costs and government intrusion, some people will choose not to stay in
    farming or go into farming. With an acknowledged crisis of an aging farming
    population, the long-term costs imposed by creating disincentives for people to
    enter or remain in farming could be extremely damaging to our ability to raise food
    in this country and to rural economies. The result will be decreased competition,
    and poor quality food at higher prices for livestock-based products.

    1. Damage to food safety efforts. If NAIS is implemented, the result will be a

    decrease in our food safety.

    a. The NAIS will not address foodborne illnesses, such as e. coli or salmonella
    contamination, because the information ends at the time of slaughter. The vast
    majority of food contamination occurs at the slaughterhouse, food processing and
    handling facilities, or during food preparation – after NAIS stops doing anything to
    collect information that would help in a response. NAIS does nothing to address
    the risks associated with slaughterhouse practices or the failure of USDA to
    enforce current laws.

    b. The NAIS will heavily burden small and sustainable farmers, which will hurt
    efforts to develop safer, decentralized, local food systems. As evidenced in the
    recent peanut butter recalls, having a centralized food processing and distribution
    system means that contamination in even one plant can lead to deaths and
    illnesses of thousands all over the country—problems very hard to track and
    isolate. Consumers clearly support a local, sustainable d food supply, which
    means the agency needs to write rules that work for small independent farmers,
    instead of rules such as NAIS that are designed for the benefit of vertically
    integrated CAFO’s.

    c. The NAIS will waste limited public and private resources that could be better
    spent on programs that would help prevent food contamination and foodborne
    illness outbreaks, including increased testing for bovine spongiform
    encephalopathy (BSE or "Mad Cow"), improved oversight of slaughterhouses, and
    increased inspections of imported food. The agency should focus on prevention,
    not response after problems have occurred.

    d. To the extent that contamination occurs despite efforts at prevention, traceback
    efforts should focus on tracing the meat, rather than the animals. USDA currently
    avoids tracing contaminated meat from the processor back to the slaughterhouse,
    as in the case of the e. coli contaminated ground beef that was found at John
    Munsell’s packing plant. While USDA focused its efforts on shutting down
    Munsell’s family-run packing plant, the agency refused to address whether the
    contamination had actually occurred at the ConAgra slaughterhouse that supplied
    meat to Munsell for grinding. Within a few months, one woman died and dozens
    of others were made sick from beef traced to the ConAgra slaughterhouse,
    resulting in one of the largest recalls of meat in history. Tracing of the meat from
    the packing plant to the slaughterhouse might have prevented the illnesses and
    saved millions of dollars. This sort of tracking program would be far more
    beneficial, and far cheaper, than NAIS.

    For all of these reasons, the Farm and Ranch Freedom Alliance urges the USDA
    to withdraw the proposed rule to implement portions of the National Animal
    Identification System, Docket No. APHIS-2007-0096. At a minimum, the agency
    should publish its cost benefit-analysis and allow for a 60 day comment period

    C

  •  Dear Iowa farm boy, (2+ / 0-)
    Recommended by:
    trashablanca, CcVenussPromise

    Thank you for taking the effort to write such a nice diary.  I would like to "tip" (rec) you for your effort, but you did not leave a comment. :=(

    I've seen various articles around, also, about the dependency of our current agricultural system on petroleum products... how that interacts with sustainable agriculture is interesting because my understanding is that these methods end up drastically depleting the soil.

    Thanks again.

    The wide universe is the ocean I travel And the earth is my Blue Boat Home

    by sberel on Fri Feb 06, 2009 at 05:13:16 PM PST

  •  sberel comment (3+ / 0-)
    Recommended by:
    sberel, trashablanca, CcVenussPromise

    I'm sorry, I don't understand this:  " I would like to "tip" (rec) you for your effort, but you did not leave a comment."

    •  heh, I just tipped you! (1+ / 0-)
      Recommended by:
      trashablanca

      From the FAQ,

      Tip Jars

      Because diaries can't be rated, many diary authors post a comment with the Subject of 'Tip Jar' or similar. This is intended as a place to give mojo for the diary; if you feel that the diary was worthwhile, it's a nice gesture to leave a recommend in the tip jar. A tip jar should only be posted by the author of a diary. Posting a tip jar in somebody else's diary will be regarded as an attempt to take credit for the diary; at the very least, you will be yelled at by other commenters. There is no rule, however, that says commenters must wait for the diarist to post a tip jar before they can legitimately comment on the diary.

      It used to be kind of frowned upon, but now it's mainstream.  So, if people like your diary they will be looking for a comment from you to recommend (tip).

      (When people write something really unpopular, inflammatory, or offensive, someone might "hide rate" the tip jar instead.)

      The wide universe is the ocean I travel And the earth is my Blue Boat Home

      by sberel on Sat Feb 07, 2009 at 06:20:52 AM PST

      [ Parent ]

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