Quarantine known BSE sites and require 100% premises testing for a 24 month period after the last proven BSE positive tested animal discovered.
        Exempt all nonfood animals (horses, lions, giraffes, etc.) that are not subject to BSE.
        Continue to enforce the ban on feeding animal byproducts to food animals.
        Any livestock owners can participate in NAIS on a volunteer basis.
        Allow NAIS to be a totally consumer driven ID program. If the consumer can assure that NAIS will actually provide a legitimate profit to producers, over the cost of the ID program, it will therefore behoove every producer to comply. (At that point no mandatory NAIS fines or imprisonment would be necessary.)
        Exempt all bovine females who have a USDA tattoo and OCV ear number clip which number is already in the USDA number data base. (This is already USDA data with millions of bovine records for over 50 years.)
        Allow, at an economical fee, volunteer BSE tests for any herds that desire testing to prove negative status.
        Exempt all registered livestock that are required by their individual breed association to have a legible permanent tattoo or fire brand numbering system prior to registration.
        Exempt livestock that are branded and numbered with non-duplicate private herd identification records by their owner.
        Make allowances without imprisonment or exorbitant fines for entry errors, defective, or lost identification tags.
        Do not demand any federal changes of laws that violate or take away established State Rights.
        Negotiate export agreements with Japan or other beef purchasing nations that all livestock being processed for their destination would be individually tested for BSE prior to product shipment. (Nations smaller than California have no right to demand 100% testing or numbering of all livestock in the USA.)
        The USDA should invest 5% of the projected NAIS annual cost in the development of a BSE vaccine. This would help the whole world to terminate BSE with the few hundred remaining suspect cattle.
        Renegotiate with countries any existing treaties that would cause undue hardships on USA livestock producers which would require unnecessary testing, quarantines or livestock numbering systems of questionable value.
        No state, tribe, federal, or local authority is allowed to profit from, or create taxation, or fees to be collected from livestock owners for premises enrollment.
        Hot iron brands may be used instead of ear pins for NAIS identification purposes. (Permanent hot iron livestock brands will not be infected by computer viruses, lost, removed or require annual soft ware updates. They can be read at a distance and do not require wands or computer equipment to read them.)
        Continue interstate transport health certificates with only the tests performed that are required by the state of destination.
        Enforce current laws on the books for testing of all livestock, fowl, etc., entering the USA with 100% inspections for compliance upon arrival.

        It is understood that this would not use the $400 million per year estimated annual NAIS federal budget. It would not provide new employment for thousands of extra staff for the USDA. It would not create a $350 million per year new ear pin industry. It would not create a $6 billion new computer and software industry. It would not bring into state departments of agriculture millions per year in premises fees. It would not cause thousands of large animal veterinarians to take new USDA jobs and leave their practices to become "ear pin police." These recommendations would fail miserably in all these government priority areas.

Respectfully submitted,

Darol Dickinson
740 758 5050