that it will give owners an option to "opt out," of NAIS Premises reporting, since USDA has decided to "voluntary" with NAIS. Last week the USDA published its new "Users Guide to NAIS," which said that the USDA is abandoning its mandatory plan for NAIS. However, NAIS has always been voluntary at the Federal level, while they gave grants to states and other entities to build the program. It's kind of a "back door" approach to mandatory.

Recently, the new language for the Cooperative Agreements was published. It states that every state who accepts grant money to implement NAIS, MUST turn that information, such as Premises over the USDA. There are other aspects of these Cooperative Agreements that give me pause, but this is a direct contradiction to MDAR's plan to withhold information that they collect, if the owner wishes it. The state will continue to collect its data, and supposedly keep in the Commonwealth, but if they continue to accept CA"s with the USDA, can they legally withhold that information?

Governor-elect Patrick is having listening sessions all over the state to get people involved. I don't know if this issue falls under Economy, Environment or Security. So, since I probably can't make a meeting anyway, I've written the Transition Team and Working Groups and made my opinion known. I urge you to do the same.