March 30, 2007

NAIS "How To Handbook" Discovery

USDA Internal Handbook Advises Animal-Identification Staff to Address Farmers “at the Sixth Grade Level”

The USDA’s confidential “NAIS How-To Handbook,” intended for non-public distribution to Federal and State NAIS personnel, reveals an aggressive campaign to implement NAIS in the face of farmer opposition by strictly controlling communications, manipulating media coverage, concealing the original NAIS program documents, and discrediting opponents.


Mary Zanoni, Ph.D., J.D.
P.O. Box 501
Canton, NY 13617


March 29, 2007

A USDA “NAIS (National Animal Identification System) How-To Handbook,” most recently revised in February 2007, instructs all State and Federal NAIS staff aggressively to promote the supposedly “voluntary” premises ID program. The goal of the campaign and the How-To Handbook is to “increase . . . premises registration results” and to promote during 2007 not only “continued growth in premises registration,” but also the “adoption of animal ID and tracing.” (Handbook, p. 1; USDA’s NAIS Community Outreach bulletin, Feb. 2007, p. 1.)

The Handbook demands uniformity and strict adherence to four “key messages” that staff are to present to audiences of farmers when promoting NAIS. As described by the USDA, these “key messages” “are organized into topic categories and supported with concise sentences. They are designed for an audience reading at the sixth grade level.” (Handbook, p. 41.)

The Handbook originally was designed for a meeting in Kansas City in late October 2006, attended by a total of 132 “State ID Coordinators, Federal ID Coordinators, and members of various livestock industry associations.” (NAIS Community Outreach bulletin, Dec. 2006, p. 1.) The meeting was designed to train all NAIS personnel to adhere strictly to “a communications campaign currently being implemented at the National level.” (Handbook, p. 3.) After the original USDA mandatory NAIS plan, set forth in the Draft Strategic Plan and Draft Program Standards of April 2005, met with an unexpected level of strong opposition from farmers and animal owners, the USDA hired a public-relations firm to analyze the opposition and repackage NAIS with a more congenial-sounding message. (Presentation by Dore Mobley, USDA/APHIS information officer, at the National Institute for Animal Agriculture’s “ID Expo,” August 2006.)

The apparent upshot of the professional public-relations advice was USDA’s completely new marketing campaign for NAIS, implemented in the fall of 2006. Crucial components of the marketing campaign included the Oct. 2006 Kansas City meeting, the Handbook and related promotional materials, and the release of the “NAIS User Guide” in November 2006.

When the USDA launched its new public-relations campaign for NAIS in the fall of 2006, the agency at the same time removed from its website the original NAIS documents, i.e., the Draft Strategic Plan and Draft Program Standards of April 2005. The common criticism of NAIS as “Orwellian” relies in significant part upon the USDA’s expungement of the Draft Strategic Plan and Draft Program Standards from the USDA site. The November 2006 “User Guide” stated that it superseded all previous program documents for NAIS. (User Guide, front cover.)

The “new” NAIS approach: emphasize “voluntary,” but aggressively pursue the maximum number of premises IDs and prepare for individual animal ID and animal tracking. The declared purpose of the Handbook is to “increase . . . premises registration results” (p. 1). Its primary goal is to “contribute significantly toward NAIS premises registration totals,” and reach “NAIS premises registration goals” (p. 4). Animal ID staff are told to emphasize “which messages hit home,” that is, which messages increase premises registration (p. 6). Staff are told to avoid wasting effort on strongly anti-NAIS audiences and instead direct effort toward “On The Fence” or “Pro-NAIS” “targets,” to maximize the number of premises signed up (pp. 7-8). Staff are advised not to “invest[ ] time” in “Anti-NAIS producers” and instead “locate and motivate more favorable individuals” (p. 9). While staff are to tell farmers that participation in premises ID will not compel them to participate in either individual animal ID or animal tracking (Handbook, p. 42), at the same time, staff are to pursue the second and third components of NAIS, “adoption of animal ID and tracing,” during 2007. (NAIS Outreach bulletin, Feb. 2007, p. 1).

USDA promulgates a unified, monolithic message to be used by all NAIS staff. The main purpose of the Kansas City meeting, the Handbook, and the USDA-promulgated advertising and outreach materials has been to focus the NAIS State and Federal staff on a consistent strategy and to prevent staff departures from the USDA-mandated NAIS “message.” As the USDA tells Federal and State NAIS staff, “The Handbook is designed to complement a communications campaign currently being implemented at the National level” (p. 3). The goal is to “change the perceptions of individuals who may be misinformed or confused about the details of the NAIS program.” Staff must use “uniform messages” (p. 4) and carefully follow the instructions on the “APHIS-led communication and information network” (p. 5). Federal and State NAIS staff must conform to “the key messages USDA will use at the national level” (p. 12). “USDA spokespersons are using the messages provided in the Appendix [of the Handbook] to provide consistent information at the national and local level. These messages will be used in speeches, print materials, media interviews and elsewhere” (p. 14). With apparent unconscious irony, at the very time the USDA is enforcing staff adherence to the precise assigned “messages,” the agency simultaneously acknowledges that a common objection voiced by farmers to NAIS is that the program “sounds like Big Brother government” (p. 7). Should it appear that all government presentations on NAIS are beginning to sound alike -- well, they are all alike, precisely alike, and it’s by careful design.

USDA instructs Federal and State staff on how to manipulate media coverage of NAIS. The USDA makes clear to NAIS staff that spontaneous responses to the media are not acceptable. As to Federal NAIS employees, we are told, “Federal staff are not authorized to handle media interviews.” Federal staff must refer all media matters to the USDA Legislative and Public Affairs Office (p. 16). Staff are encouraged, however, to use such controlled channels as op-ed pieces, letters to the editor to correct “misinformation,” and canned interviews with experts; the USDA urges staff to rely on the “complete message control” available by communicating through a NAIS website (p. 17). The properly authorized expert communications staff are encouraged to pitch canned pro-NAIS stories to the media, to attempt to influence media editorial content through attending editorial board meetings, and to compose “opinion pieces” “to explain the value of premises registration” (p. 19).

USDA reveals results of its NAIS “Opposition Analysis” and creates standardized responses to the NAIS opposition. The NAIS How-To Handbook’s treatment of the “NAIS Opposition” carefully portrays this opposition as nameless and faceless, and avoids specifying the exact points upon which the opposition arguments are based. The USDA implies that the opposition consists of insignificant “groups and individuals” who are just somehow “mistaken”: “The opposition’s information is largely based on misinformation and misunderstanding, but their zeal and emotion appeal is real” (p. 22).

Although the USDA studiously avoids naming its NAIS opponents, in fact they include: a growing list of groups such as the Northeast Organic Farming Association, R-CALF, the Sierra Club, Food and Water Watch, the National Family Farm Coalition, Family Farm Defenders, Community Farm Alliance of Kentucky, Rural Vermont, Cattle Producers of Washington, South Dakota Stockgrowers Association, Virginia Independent Consumers and Farmers Association. Some of these groups have sponsored the introduction of antiNAIS legislation in at least 9 states in the 2007 legislative session. Similarly, the unspecified “individuals” opposed to the USDA’s implementation of NAIS in fact include medical doctors, information-technology professionals, financial planners, entrepreneurs, lawyers, public-interest lobbyists, and former government employees.

The USDA’s Handbook repeatedly refers to NAIS opponents' “misinformation,” but fails to specify any statement of the opponents that is other than completely accurate. The USDA’s most detailed list of “opposition” statements, on pp. 23-24 of the Handbook, dates from January through August 2006 and does not identify any specific individuals as sources for the statements. The websites from which the statements are taken permit comments and postings by visitors, and the USDA’s quotations are not attributed to random visitors, more formal opposition statements, or any other particular source. One statement, the last under “Theme 3: Civil Liberties” (p. 23), obviously refers to the Real ID Act (a common ancillary topic of discussion on many NAIS opposition sites), and not to NAIS at all. Indeed, nearly all the statements the USDA quotes under “Opposition Themes” (pp. 23-24) are in fact quite accurate for their time frame of Jan. - Aug. 2006. During those months, the operative NAIS documents were the Draft Strategic Plan and Draft Program Standards, which did indeed impose a fully mandatory NAIS by 2008/2009 and did indeed require the participation of all common livestock species, the microchip or RFID individual identification of nearly all animals except factory-farm chickens and pigs, and the reporting of all animal “movements” and changes of status (birth, death, sale, purchase, slaughter, and all travel off-premises) within 24 hours. Only in subsequent documents did the USDA begin to waver as to some of the original requirements of the Draft Strategic Plan. And not until the USDA’s release of the User Guide in November 2006 did the USDA’s stated policy become “voluntary” rather than “mandatory” NAIS.

Even the USDA’s most comprehensive public-relations campaign can’t sell a bad NAIS system to justly skeptical farmers. The USDA’s Handbook, like its User Guide and its present NAIS approach generally, repeatedly speaks of needing to “correct” or adjust farmers’ attitudes or beliefs about NAIS. Why doesn’t the USDA actually examine the possible flaws in the design, the reasoning of, and the justification for NAIS, and abandon this unwanted and unwarranted intrusion of bureaucracy and technocracy into the lives of farmers and animal owners? Why is the USDA, as is so obvious throughout the Handbook, concerned only with appearance or “perception,” and not with reality?

For all that the USDA may think that farmers function “at the sixth grade level” (Handbook, p. 41), farmers seem to be just too smart to be lured by even the USDA’s most prettily baited NAIS hook. In January 2007, the USDA conducted NAIS “focus groups” in Sacramento, California, Springfield, Missouri, and Harrisburg, Pennsylvania. (NAIS Community Outreach bulletin, March 2007, p. 1.) The participants in the “focus groups” were all livestock producers. The purpose of the “focus groups” was to gauge farmers’ responses to elements of the unified USDA NAIS public-relations campaign, particularly, the new NAIS promotional brochures and the USDA-imposed “key messages” for promoting NAIS. These farmers thus received only the USDA pro-NAIS messages and no “opposition” information. By the USDA’s own admission, these farmers, even after intensive exposure to the USDA’s well orchestrated campaign, would not accept premises registration. The USDA’s “key findings” about the attitudes of the focus-group farmers after they had received the USDA’s (and only the USDA’s) side of the NAIS story are:

“Respondents view NAIS as unwanted government intervention.”
“Current NAIS messaging and brochures will not necessarily motivate producers to register premises.”

So, after several years and multiple millions of dollars’ worth of pro-NAIS propaganda, farmers still want no part of NAIS. Perhaps the USDA should begin to entertain the notion that farmers might not be so “misinformed” after all. Maybe farmers are simply justifiably mistrustful of a government agency that insists on treating the very people it is supposed to serve like children.

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