Comment from Abby Shepard

As a livestock producer, the health and well-being of my beef cattle herd is of
utmost concern to me and my family. However, the reduction of New Mexico TB-
Free state twice in five (5) years is not only overkill for the situation the state is
facing, but is jeopardizing the viability of my operation without addressing the
problem at hand.
While the 9-11-08 drop in New Mexico’s status did provide for a delay in
compliance for animals in “feeder channels” which we appreciate. However,
because of fears of facing the same devastation now occurring in New Mexico,
many, many other states are imposing requirements that make it difficult if not
impossible to comply with.
As a cow/calf state with little feed growing or feedyard capacity, losing the status
at the beginning of the “fall run” when we are shipping our calf crops --- and annual
paychecks --- to other states has created an extreme hardship. Many producers
in New Mexico simply do not have the handling facilities to test and tag large
groups of animals, especially when you consider that the antiquated testing
procedure for bovine takes three (3) days and two (2) visits from a certified
veterinarian. With the decline in large animal veterinarians in the nation and in
New Mexico in particular, even scheduling time with a vet is a challenge.
Adding insult to injury is the fact that thus far, at least, the only bovine TB that
has been diagnosed in New Mexico has been in dairy operations that are
hundreds of miles from my operation. There is virtually no risk that my cow herd
has been or will be exposed to those animals that have been found to have the
disease.
The TB Rule imposed by the USDA in 2000, despite testimony and evidence that
the rule would not lead to the eradication of bovine tuberculosis in the United
States and would lead to severe economic hardship, has resulted in everything
New Mexican’s told the federal government it would. The rule was based on the
false premise that bovine TB had all but been eradicated in the U.S. With four (4)
states currently with a reduced status, some of them for the second time, and
several others just one cow away for a loss of status, that was clearly not the
case.
The 2000 TB Rule addressed pasture and confined cattle as one, required a drop
in status on the basis of only two (2) cows in separate herds being diagnosed with
TB with 48 months, and provided an impossibly expensive routes back to a Free
state. To attempt to quickly address the problem, states must depopulate entire
herds or create a “zone” where TB was diagnosed.
The idea that thousands of healthy animals and their valuable genetics are being
destroyed at a cost of millions of dollars is simply ridiculous. Eight (8) years
under the rule and tens of millions of dollars have demonstrated that it is well past
time for the USDA to revise the rule to reflect real world conditions.
Here are is a short list of items that must be addressed in a revised TB rule. This
is by no means a comprehensive list, but will provide initial guidance for the
development of a new rule.
1. A chute side testing procedure that can be completed in minutes, not
days
2. Risk-based accomplishment of TB eradication including but not limited
to:
i. Separate consideration of confined and pasture cattle
ii. Consideration of proximity of livestock to diseased animals in status
reduction
iii. Depopulation of diseased animals, not entire herds
3. Full examination of each of the risk factors that may propagate the
disease including but not limited to:
i. Regular movement of dairy and beef cattle
ii. The prevalence of TB in Mexico’s cattle herd
iii. Practices that bring susceptible breeding animals in contact with cattle
of higher risk
iv. Potential transmission from infected humans to cattle with
human/bovine interaction
v. Cost of the program versus the benefits that are received
vi. Less reliance upon geo-political boundaries rather than risk of
transmission
Thank you in advance for you attention and we look forward to participating in a
process that will address the disease issues at hand without destroying an entire
industry and families and rural communities along with it.