We were forwarded this very candid email ( way down below) from a well recognized industry association. Dr. Edmiston was replying to concerns about TAHC proposals. While we applaud Dr. Edmiston candor, respect what is obviously his honest feelings, we respectfully do not agree with him. I would also like to point out it is not our intent to ridicule anyone especially people that volunteer their time.

The most notable thing is this. The Commissioner's statement appears to back allegations of what many have been saying from the get go the primary purpose of premise registration is to generate TAX revenue for TAHC ( or reimburse the general fund of the State of Texas which ever way you want to look at it) . Premise registration is being implemented for the wrong reason.

It is our opinion that the agency wishes to collect $10.00 per year TAX from every living person in the State of Texas that has livestock on their land. Pet chicken owner $10.00, pet pig owner $10.00, backyard horse owner $10.00, one old Betsy the Jersey cow $10.00, Average 30 head beef cow heard $10.00, 10,000 head chicken house $10.00, million dollar feedlot operation $10.00, 500 head US government subsidized dairy the same $10.00.

The point is the Commissioner seems to think it is fair and equitable to TAX the owner of a property that has one chicken the same amount as the owner of a chicken farm that has 10,000 birds. The whole problem you see is that most TAHC services are free. TAHC does not charge for veterinary services.

Big operators are the ones that usually get the services of TAHC. Little operator use TAHC very little. The Commissioner seems to think it would be unequitable to charge $10.00 per head for service rendered to handle a bird crises based on the number of birds in the flock, for example he quotes "For instance, TAHC responds to an Exotic Newcastle Disease outbreak, decides to endemnify and euthanize flocks of chickens, and then tell the owner he owes $10 per head for the service".

I personally do not see his reasoning, the guy with one bird pays his $10 the guy with 10,000 pays his $100,000 or handles the problem on his own. After all unlike the back yard bird owner, he is trying to make a buck. He should take the good with the bad.

I ask everyone, how can this be fair? Individual pet owners that have livestock, horse owners ( which are not sold for food in the USA), why should they be forced to subsidize large commercial livestock corporations? How is it equitable that the many private individuals must support a few big money makers ?

How is it equitable to force private individuals to jump threw hoops of red tape and allow government to snoop in their private lives. How is it equitable to setup unsuspecting non farm people to be criminals, all for the sake of TAHC to fleece them of their money to support big business.

 

Dr. Edmiston's email response verbatum:

Subject: Re: Response to Prem ID questions by Wm Edmiston  
Dear Marvin, 

Thanks for forwarding the NAIS/SWG document.  I am indeed aware of it, having been at the ASI meeting, as you were, where it was discussed and adopted. I am in agreement with your assessment of the premise ID program as a fee levied by the legislature to allow TAHC to generate fees for the General Fund. Up until this last Leg. session, TAHC did not generate substantial fees for services rendered, being funded almost entirely by the State's General Fund, and funds recieved from the Federal Govt. (USDA)through cooperative agreements for specific disease programs. During budget hearings, we (TAHC) were asked how much we generated in fees, answered none due to lack of statuatory authority to do so, resulting in a law being passed allowing us to generate funds from premise registration to offset costs of operating our agency. We are one of the last, if not the last, State agency to charge fees for services rendered, so are following trends set by State Government to pay for necessary services. We changed the health certificate form and now charge Veterinarians $5 per form, which I am sure they are passing along to those persons needing a HC, and thus pay for regulatory efforts required by that process. The Premise ID fee is to generate funds in the same fashion, allowing all livestock enterprises to participate in funding the TAHC.  All livestock producers benefit directly or indirectly from TAHC actions, and have been asked by the Legislature to pay for same.  From horses with EIA eradication program, to fowl with END and Avian Influenza surveillance, to cattle with brucellosis and TB programs, to confining fever ticks along the border, to sheep and goats with Scrapie eradication, to wildlife with CWD concerns, to swine with Pseudorabies and brucellosis issues, to name a few, we livestock producers all benefit, at a reasonable cost. Bearing the cost of supporting a State Agency we all benefit from is not an unreasonable expectation, in my opinion.  The premise ID requirement and fee is a way to evenly distribute the cost over all producers, irrespective of size of operation.  $10 per year is little enough for all, even when paid two years at a time.  The income from Prem Id is indeed part of our budget for the Biennium, and while talk of improving or correcting budgetary matters sounds good, it doesn't pay salaries or support ongoing programs in the meantime.  The old joke about our State being safer since the Legislature only meets every two years comes to mind. We set the fee structure to be one size fits all, and low enough to not be an economic burden on any, because it is much simpler to assess and collect. Does AMGA vary their membership fees by livestock head count of producers? Would producers prefer to be charged on a direct fee for serve basis?  For instance, TAHC responds to an Exotic Newcastle Disease outbreak, decides to endemnify and euthanize flocks of chickens, and then tell the owner he owes $10 per head for the service. Or arrive to test a flock of sheep or goats for a possible Scrapie exposure, and assesses a $40 per head fee for services rendered. I fail to see the logic of exempting groups of producers within certain parameters from any animal health program.  All livestock is subject to the recognized rules of epidemiology and disease transmission, regardless of size of herd. Suspectibility and exposure have more to do with style of management and level of isolation, and disease resistance is increased by excellent husbandry practices.  Neither of these factors of epidemiology rely on group size, but management, management, management.  Who is likely to be a better manager, a person whose livelihood depends on his livestock, or a person who works at a job for a living, and raises livestock as a hobby or as supplemental income or a food source?  Excellent managers prosper at all levels of production, and abysmal managers muddle through, too. TAHC has been roasted since the premise id regulations have been proposed, mostly by people who seem to not be in favor of NAIS, especially the reporting of livestock movements, particularly on and around the premise of origin.  Premise Id is the first step in implementation of an orderly livestock traceback system necessary to disease surveillance. Please don't mistake our proposed implementation of the Premise Id requirement in Texas as an endorsement of the entire NAIS as currently written. I cannot speak for the TAHC,(and can only speak as an individual unless we are acting in official capacity at a Commission meeting) but personally there are many parts of the NAIS as currently proposed that I find very problematic.  There is a great gulf between the necessity to report livewstock movements after animals leave my operation and entering commerce, and the intrusion of expecting me to report the goings on, on my operation, which are strictly between me, my banker, and the Good Lord. The NAIS is currently a work in progress, and with diligent and ardent input, it can be morphed into a workable and important asset to the livestock industry.  A lot of anger, frustration, and energy is being directed at TAHC which could and should be directed to the USDA to shape that program to fit our needs and capabilities. As you know from the work you are doing with RFID tags in goats, the capability to track animal movements with them is a pipe dream when measured against the standard of movement at the speed of commerce.  I agree and support our petition to use the current NSEP id requirements for sheep and goats, until a proven and workable improvement can be phased in, in the distant future. At and after our last Commission meeting, several industry groups have been attacked and belittled for their support and partnership with TAHC in the proposed Premise ID regulations.  These industry groups, whom I will not name for fear of leaving one out or generating more ire, have been with TAHC through the Budgetary cat fight of securing funding to support our agency in the Legislature.  I really appreciate their counsel, support, and allegiance in assisting us when we needed staunch allies.  Getting funds in a tight budget year is a real challenge, and a committment to generate funds from fees for service rendered are part and parcel to that process.  I appreciate and applaud industry's ongoing role in assisting us in the budgetary process, and encourage all those affected by TAHC to participate next round. Don't be the little dog barking at the parade, put on your costume and join the parade.  And help the clowns running the parade figure out how to get it paid for. I have been misquoted and misrepresented several times recently, and subsequently put lots of thought and time into this response to your email.  I am perfectly happy for this to be used to forward or use as you like, in fact I will copy to several others. My only request is that it remain substantially intact and taken as a whole, so as not to be editted  for use piecemeal misrepresentation. 

 Respectfully Yours, William Edmiston, DVM