The Wisconsin Department of Agriculture, Trade and Consumer Protection (DATCP) is proposing changes to rules, ATCP 10 and 12, regulating animal disease and movement and animal markets, dealers and truckers.
According to the Wisconsin Farm Bureau Federation (WFBF), these changes include massive fee increases that will be a substantial financial burden to markets, dealers and truckers that will unavoidably be passed down to farmers.
The license fee for what the DATCP calls “Animal Market Class A” would change from $420 to $7,430. A late fee for those markets would also increase by nearly 1,700% by shifting from the current price of $84 to $1,486. The registration fee paid by about 1,000 truckers transporting livestock in the state would increase 517%, from the current price of $60 to $370.
WFBF Government Relations Director Jason Mugnaini says it is important to clarify that Wisconsin’s program had historically received state funding support through DATCP, but this proposal shifts that onto industry fees.
The WFBF also reports the inspections and public health activity costs of these programs have previously been partially funded by state funding in Wisconsin, as they are in neighboring states. DATCP’s proposal shifts the full cost of these programs onto industry fees.
DATCP Secretary Randy Romanski explains the fees have not been adjusted since 2009 and the increases are needed to maintain critical animal health and transportation services.
“This program is currently in deficit because these have not been adjusted for so long,” Romanski explains. “Costs have increased during that time.”
He is transparent about the financial realities driving these increases. While the percentage increase might seem large, it reflects 17 years of accumulated cost pressures. He summarizes the goal is not to burden the industry, but to ensure the continued provision of critical animal health and movement services.
According to Sam GO, DATCP communications director, the DATCP Division of Animal Health receives federal funding through cooperative agreements for specific goals and objectives, such as animal disease surveillance and animal traceability. The cooperative agreements are separate from the programs in the proposed fee rules
She explains as federal funding for the cooperative agreements has decreased, those activities that are partially federally funded (such as animal disease surveillance and animal traceability) need to have a larger portion of their costs covered by the state animal health general program revenue. That means there is less state GPR remaining to cover the deficit in program revenue for the ATCP 10 and ATCP 12 programs.
The ATCP 10 fees support the following animal health programs: Certificate of Veterinary Inspection (CVI) Forms, Intermediate Handling Facilities, Disease Certifications (Brucellosis, Tuberculosis, Pseudorabies), Equine Infectious Anemia Retests, Equine Quarantine Stations, Feed Lots, Medical Separation, National Poultry Improvement Plan (NPIP), Farm-Raised Deer, and Fish Farms.
The Process
Romanski explains the administrative rule process is collaborative and takes about two and a half years. He says the process is designed to be collaborative with multiple opportunities for public input and engagement. He encourages stakeholders to not just critique the increases, but to offer constructive feedback and potential alternative solutions.
The current stage is specifically about public comment and engagement. He says the department wants to hear from industry members, producers and other stakeholders. They are actively seeking input that can help shape the final rule package.
The public can participate and provide feedback that can be considered by the department’s staff through several channels:
- Attending public hearings
- Submitting written comments by Oct. 15
The remaining hearings will be hosted virtually and at the Prairie Oaks State Office Building, Room 106, 2811 Agriculture Dr., Madison, WI 53708. For more information, dial-in instructions and to register for online access click on the ATCP 10 or 12.
• Monday, Sept. 15 – 1 p.m.
• Wednesday, Sept. 17 – 9 a.m.
• Tuesday, Sept. 16 – 1 p.m.
• Wednesday, Sept. 17 – 1 p.m.
Individuals can submit written comments by Oct. 15 to: Angela.fisher1@wisconsin.gov or Angela Fisher, DATCP, P.O. Box 8911, Madison, WI 53708
Romanski explains after the public comment period, DATCP staff will review all submissions, consider suggested changes, and then present any revisions to their policy-making board. This ensures multiple layers of review and public involvement.
Neighboring State Comparisons
According to the proposal document, programs in adjacent states (Iowa, Michigan, Minnesota, Illinois) are similar to Wisconsin, as all are based on federal standards. Neighboring states primarily fund these types of programs through general program revenue; therefore, they have lower fees than Wisconsin’s current fees. While Wisconsin’s program fees are collected from a small number of licensees, these critical programs have impacts and benefits across animal health, animal industries and public health.
In Iowa, a livestock market permit is $50 per year. The livestock dealer and livestock market agent permits are $10 per year. A bull breeder license is $20 every two years. A livestock dealer or order buyer permit is $50 per year. A feeder pig dealer agent permit is $6 every two years. A feeder pig dealer agent permit is $6 every two years. A pig dealer’s agent permit is $3 per year.
In Michigan, an action Class I is $400 per year. A buying station (Class II) is $250 per year. The remaining fees are waived for veterans: A dealer (Class III) is $50 per year. An agent broker (Class III) is $50 per year. A collection point (Class III) is $50 per year. A trucker (Class IV) is $25 per year.
In Minnesota, a livestock market agency and public stockyard is $300 per year. A livestock dealer is $100 per year. A livestock dealer agent is $50 per year.
In Illinois, a livestock auction market license is $200 per year. The livestock dealer license is $25 for a new license, $10 for the annual renewal, as well as $10 for each location in addition to the first location, and $5 for each employee. A feeder swine dealer license is $25, the renewal is $10, and there is a fee of $5 for each employee. There is no fee for a slaughter livestock buyer’s license, just a requirement to submit an annual report.
Industry Feedback
Both the Wisconsin Cattlemen’s Association (WCA) and WFBF have come out opposed to the fee increases.
Tressa Lacy, WCA president from Rio, Wis., voiced her concern at the first hearing on Sept. 11.
“The Wisconsin Cattlemen’s Association is in opposition to the proposed fee increases inspections and registrations related to a variety of activities by Wisconsin animal dealers, truckers and markets in ATCP 10 and 12,” she says. “I raise beef cattle with my husband and our 8-month-old in Columbia County. We both work off the farm in agriculture to financially afford our beef and hay farm operation, and I know the cost of these fees will be passed directly on to producers like us.
“The result of such significant increases will be fewer livestock marketing options, the potential for reduced disease traceability and fewer opportunities to sell livestock in the state of Wisconsin. Fewer options inevitably mean lower prices and thinner margins in an industry that is already being pushed on thin profit lines.”
She explains the inspections and animal health protections funded by these programs serve a broad public purpose — protecting animal health and consumer confidence in the meat raised in Wisconsin.
“It is fundamentally unfair to shift the entire cost onto the users as this is certainly a public food safety conversation,” Lacy adds. “I share the industry concern that these initial proposals are just the start of all programs in Wisconsin shifting to being user funded. Other states fund these programs with state support as the benefits are shared by everyone. DATCP should restore and continue the approach for these outlined programs.”
She concluded her comments saying: “WCA respectfully ask that DATCP reconsider these unreasonable fee increases and maintain a funding structure with state support that is fair, practical and supportive of both public health and Wisconsin agriculture.”
Mitch Giebel a WFBF member from Lyndon Station, Wis., also shared his thoughts on the proposed fee increases.
“I’m very concerned about the massive increases of fees being proposed,” he says. “As a young farmer, every dollar really does matter on our operation. We work hard to raise our livestock, and we already face high input costs, tight margins and unpredictability when it comes to marketing. Adding thousands of dollars in new fees, especially increases as massive as what is proposed doesn’t seem realistic. It’ll undoubtedly make it harder and tighter for the sale barns and livestock markets to survive, and unavoidably, it is probably going to be passed to us as the producers and farmers.”
He also explains programs such as animal health, disease control and traceability benefit everybody in the state, not just farmers.
“Healthy animals and safe food are the best interest for our state; other states recognize that and utilize state funding to maintain these programs and cover these costs,” he says. “Wisconsin needs to restore and maintain its state funding that has historically existed for these programs, rather than shifting a substantial burden on a small number of farmers and marketers. I am asking you to please reject these fee increases as they are written. They are too steep, too fast and out of line with our neighboring states.”
WFBF is calling on producers to share their concerns: “These unprecedented fee increases cannot move forward without your voice being heard. Share how these proposals would impact your farm, your business and Wisconsin agriculture.”