Rural Vermont's Comments on Premises Registration

August 31, 2006

TO: Vermont Agency of Agriculture
FR: Amy Shollenberger, Director Rural Vermont 15 Barre Street, Ste 2 Montpelier, VT 05602 802-223-7222 amy@ruralvermont.org

RE: Premises Registration Rulemaking
Please accept the comments below on the Premises Registration Rulemaking.

First and foremost, we would like to request that this rulemaking be stopped completely and that the Vermont Premises Registration Program plan be ended. We are opposed to any government run program that seeks to identify all premises with livestock or all animals individually. We request that the Agency of Agriculture instead pursue an aggressive strategy to work with Vermont’s family farmers to share information about contagious animal disease and the appropriate response if a farmer suspects an animal has a disease, as well as to create a secure and self-reliant local food system in the state of Vermont. The Agency has been clear that this program is a response program, not a prevention program. The information sessions indicated that this program will not stop contagious animal disease from entering the state. Rural Vermont requests that the Agency focus its financial, staff and time resources on prevention programs rather than reactive programs. In addition, the Economic Impact Statement submitted with the rule appears to be incomplete. The statement indicates that there will be no significant economic impact to the state, but even a cursory reading of this draft rule shows that this system will be costly and staff resource intensive. In addition, the fact that dozens of people have indicated they would give up their animals or stop processing meat will surely have an impact on the local food economy. In addition to these general comments and request, we have the following specific comments on the draft rule: Sec. I (definitions), (11) – “Confidential Information” – as the Agency has noted, both in the information sessions held in August and in various press articles, the Agency cannot guarantee that information will be secure from Freedom of Information Act requests. Therefore, the Agency should stop the development of this program...

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