A coalition led by farmers and ranchers is using a last-minute strategy to stop USDA’s new Animal Disease Traceability (ADT) program. The groups involved are using economic grounds – especially the added costs that animal identification will impose on rural America. In a 9-page letter to the Executive Office of Management and Budget, a unit of the White House, the sixteen organizations in the coalition say animal traceability could cost the U.S. cattle industry more than $1 billion a year. The so-called ADT rule is a replacement for the National Animal Identification System (NAIS), which became so unpopular with rural America that Congress for 2010 cut out its funding before it could be implemented. ADT is essentially a diet version of NAIS. It is limited to animals moved interstate, will be run by state and tribal governments, is “low tech,” and is being implemented only through transparent federal rule making. As soon as USDA opened the new program to public comments last fall, ADT came under fire almost as much as the old NAIS had. Now the opposition is centered on the financial impact ADT will have on farmers and ranchers, and some of the faulty reasoning it says USDA used in working up the proposal.  For example, it says USDA’s estimate that “only 30 million cattle” cross state borders each year is “contradicted by the publicly available data on the cattle industry.” “The USDA has not done their due diligence investigating the true fiscal impact this will have on the livestock industry,” says Mark A. Kastel, senior farm policy analyst for the organic policing group called The Cornucopia Institute.  “Our concern is that the economic burden of this rulemaking, some of which is duplicative of many effective disease control programs currently utilized, will fall unfairly on family-scale farmers and ranchers.” The organizations put the number of cattle moving across state lines annually at closer to 55 million. The farm and ranch groups, including the Billings, MT-based United Stockgrowers of America (R-CALF), point out that most feedlots and slaughterhouses are concentrated in six Midwestern and Western states. “While we cannot provide a definitive number, it is clear that more than 30 million cattle cross state lines each year,” the letter to OMB says. For that reason, the opponents say USDA underestimated the economic burden the new regulation places on cattle owners and ancillary businesses like sale barns and veterinarians. USDA’s estimate that puts cost per animal at $1 to $2.50 is also off, the groups charge.  The figure is a “gross underestimate,” they say. The letter cites research by North Dakota State University putting the cost of tag placement and documentation at $7.00 per calf. The NDSU study says when “weight loss while handling calves” is figured into the total -something it calls “the shrink,” another $10 to $20 of income potential is lost. Using the NDSU math and its estimate of 50 million head crossing state lines each year, the letter claims the cost of ADT to the cattle industry could reach as high as $1.35 billion a year. The groups, which also included the raw milk-promoting Weston A. Price Foundation, also charge that USDA did not address the cost of the ID program to poultry owners. “Many people order day-old chicks from hatcheries, commonly out of state,” they say. Finally, the opponent groups say USDA only compared ADT to NAIS, and did not compare it to other alternatives. The other groups that signed the letter, including rural and consumer organizations, are: Carolina Farm Stewardship Association, Cattle Producers of Louisiana, Community Farm Alliance (KY), Family Farm Defenders, Farm and Ranch Freedom Alliance, Farm-to-Consumer Legal Defense Fund, Kansas Cattlemen’s Association, National Farm Family Coalition, Organization for Competitive Market, Powder River Basin Resource Council (WY), South Dakota Stockgrowers Associations, Virginia Independent Farmers and Consumers Association, and the Western Organization of Resource Council.