I took a month-old parsnip out to the compost pile yesterday, and I could tell it came from the supermarket because of the thick coating of wax that covered it. Without thinking about what I was doing, I started peeling the wax off. It was as if someone had decided, for some odd art project, to turn the parsnip into a candle, proceeded to put a few layers of wax on it, then changed their mind, and decided to sell it as a parsnip anyhow. My hands now covered with wax, I realized that I didn’t even find this waxy parsnip suitable for putting in the compost, much less eating. “Here,” I said to myself, “is another reason many people like to get their food fresh from local farms.”

As people learn more about the food supply chain and where there food comes from, there is a growing enthusiasm for purchasing food that is locally grown on small sustainable farms that use natural methods. A wide variety of people are drawn to this movement because the reasons to support it are numerous: reduced impact on surrounding land and water due to pesticide use and fertilizer runoff, improved quality of life for farm animals, health benefits of grass-fed versus grain fed meat, avoidance of genetically modified or transgenic food products, less energy used due to decreased use of machinery and fertilizers, fewer chemicals, hormones, and antibiotics used, and higher nutrient content of naturally grown vegetables.

Given the virtues of the alternative food movement, one would hope to see growth in this sector of the food economy. It is upsetting, then, that government policies are detrimental to small-scale producers and sellers, threaten their economic viability, and provide a disincentive for entrepreneurs to start their own small farms.

An issue that provides some background on the problem is the fight over the use of the term “organic.” Many small farms whose methods meet or exceed the USDA’s standards for organic certification choose not to have their farms certified as organic because of the paperwork and the cost required to do so. Turner Farm, in the Indian Hill suburb of Cincinnati, is one of the small farms that have chosen to become certified as organic. Melinda O’Bryant, who manages the vegetable operations there, says that it takes 40 hours of paperwork and $400 of fees annually to obtain their certification. This can amount to a significant portion of the profits of small family farms, which also have very few employees to do the paperwork.

In The End of Food, Paul Roberts explains how the organic movement started in the 1940’s as a reaction against the increasing size of farms, with the aim of returning to small-scale non-industrial agriculture. It is ironic that now that the USDA controls the use of the term organic, the program is tailored to benefit large-scale producers who can afford the extra costs of certification, but whose practices, some would argue, are not as sustainable as smaller operations.

Organic certification is only a minor concern to growers, because they can usually interact with their customers and shareholders, at farmers markets or at the farm, where discerning customers can check out the farm and its operations for themselves, if they wish.

A much more significant issue that is raising deep concerns among farmers, especially those with animals, is the USDA’s nascent National Animal Identification System (NAIS). It would involve tagging (most likely with RFID tags) any animal that is free to move. The farmer would then have to report each animal’s movements and interactions with other animals to a database. The official motivation behind this program is to be able to quickly identify exposed animals in the event of a disease outbreak. In previous outbreaks, numerous officials spent several weeks in a frustrating effort to track the movements of affected livestock. The USDA strongly maintains that it is essential, within 48 hours, to be able to trace the recent movements of sick animals, and then to quarantine or kill all other animals that may have been exposed to a disease source. This sounds like a perfectly reasonable idea, but problems with the NAIS program make it unfair and unreasonable for small farmers, if not intrinsically and completely flawed.

Everyone that I talked to who is involved in alternative agriculture believes that if the NAIS were made mandatory, it would no longer be economically viable for small operations to keep their animals. This would further consolidate meat and dairy production under a small number of large conglomerates, severely limiting consumer choices. According to farmandranchfreedom.org, the cost of similar programs in other countries has amounted to between $37 and $69 per head, a cost that is certain to be higher for small operations, not just because of the economy of scale, but because large confinement operations are not actually required to tag all of their animals under the currently proposed rules. Instead of Animal Identification Numbers (AIN) for each animal, they will, in many instances, need only to have one lot number and one tag per 1000 animals.

That a disproportionately high amount of the crippling burdens of the NAIS program would fall on small farms is infuriating for several reasons.

The disease risks that the program seeks to contain generally stem from the practices of large industrial operations, and are not the fault of small farms where animals are humanely treated. When animals are crammed into warehouses disease can spread rapidly through the population, similar to how the flu travels through college dorms, but to a more extreme degree. The immune systems of the animals are already weakened from eating an unnatural diet. Chickens naturally tend to have a diet that includes bugs, larvae, and some greens, but get none of these foods when kept in cages in a warehouse. Michael Pollan explained in The Omnivore’s Dilemma that a cow’s body is designed to eat grass, but in large feedlots, cows are grain fed on corn with supplemental proteins added. To keep the animals from getting sick in these conditions, they are given regular doses of antibiotics. The original concern about this practice was that antibiotics would be present in the food we eat., but now a new problem has arisen. The bacteria that cause illness in the animals are developing resistance to the antibiotics that are omnipresent in the animals’ bodies. When those illnesses are passed to humans, they will be much more difficult to treat.

Lynn Seigfried keeps some chickens on her small farm in northwestern Ohio. About the risks of disease in poultry, she said, “In the big warehouses, the chickens are kept in small cages, where they are weakened from lack of exercise, de-beaking, and the lack of anything green in their diet. They don’t get any sun. The big flocks are more vulnerable to bird flu.”

Ralph Schlatter, of Canal Junction Natural Farm in Defiance, Ohio, converted the farm from conventional to all natural methods at the end of the 1980’s. After the cows started feeding on grass, he noticed that they became sick less frequently.

“You have to watch their behavior. If a cow stops eating, that is an indication that it is sick. Fortunately, that hardly ever happens anymore.”

No advantage would be gained by applying the NAIS program to small farms or backyard flocks. The main reason that this is true is that animals on small farms usually stay on the same farm for their entire life span. There is no need to track an animal that isn’t moving. According to Roberts, cattle are shipped to different facilities, each of which specializes in ushering them through different phases of their growth in the most efficient way possible. The NAIS is designed to be able to find which groups of cattle a diseased individual came into contact with in a number of different pens in a number of different states. Bill Nutt, president-elect of the Georgia Cattlemen’s Association, described the travels of his cattle. They are raised in Georgia, then shipped to Iowa for custom feeding, and then slaughtered in Omaha.

Green Acres farm in Cincinnati keeps their animals within approximately 120 acres of pasture for their entire development. I should note that this is the only small farm I contacted where I spoke to someone who supported the NAIS. Susan Stiner said that said that she is in favor of the NAIS, but that it would not be necessary for Green Acres to participate in the program because their animals never leave the farm.

“We don’t take our animals to shows, we just raise them for meat. They are born here and they stay here until they are slaughtered, which happens at a facility several miles away.”

Pete Kennedy, president of the Farm to Consumer Legal Defense Fund, described how easy it is to trace an animal from a small farm.

“You pick up a phone and call the farmer.”

According to testimony from the March 11, 2009 hearing of the House Subcommittee on Livestock, Dairy, and Poultry, the kill radius in the event of an outbreak is 10 km, so if an animal on a small farm was found to have a contagious disease such as BSE, every animal on the farm would have to “depopulated,” to use the USDA’s euphemism, regardless of whether or not the individual in question was tracked.

A major motivation behind implementing the NAIS is to facilitate international trade, opening up new markets for U.S. beef exports. This benefit for agribusiness was used a reason to support the NAIS by a number of its supporters at the March 11th hearing. As part of the NAIS program, animals would be tagged with a code number beginning with the number 840, indicating that the animal is from the United States. Needless to say, small farms, which are the focus of the local food movement, do not participate in international trade. It would be farcical and ludicrous to mandate this tagging and numbering system for small farms who sell exclusively to local markets, and whose animals are unlikely, over the course of being born to being eaten, to even leave their county of origin, much less the country.

If the NAIS becomes a mandatory program, the economic consequences to small farms will be drastic. The benefits will be negligible. The USDA states on its website that it has no plans of making the program mandatory, but its recent actions would indicate otherwise.

In the March 11 hearing, Dr. John D. Clifford, Deputy Administrator of Veterinary Services for the USDA, explained that the NAIS is to be implemented in three steps. The first step is the registration of all premises where animals are present. 35% of premises are registered so far. The second step is giving out AIN numbers and tagging the animals. The third step is to trace the movements of the animals in a massive computer database. Clifford maintains that “70%-90% participation is required to ensure the benefits of the system.”

The Farm to Consumer Legal Defense Fund website indicates that the USDA is pushing to make the first part of the program mandatory. A USDA memorandum from September of last year makes premise registration a requirement for farms that are visited by veterinarians as part of federal disease prevention programs. According to the website, premise registration is required in the states of Wisconsin and Indiana, and is required in order to receive hay relief in North Carolina and Tennessee.

Schlatter is concerned that some farms may go without federal veterinary assistance because they don’t want their premises to be registered.

Kennedy believes that the USDA claim that NAIS will remain mandatory is false and says, “People who refuse to have their farms registered will be forced to register them against their will.”

If you have an opinion on the NAIS, you can register a comment on record with the USDA before March 16. You can go directly to the USDA site: http://www.regulations.gov/ fdmspublic/component/ main?main=DocketDetail&d=APH

Or here: http://salsa.democracyinaction.org/o/ 642/campaign.jsp?campaign_KEY=26665