Attorneys for the Farm-to-Consumer Legal Defense Fund today sent a Notice of Intent to Sue letter to USDA and the Michigan Department of Ag (MDA) over implementation of the National Animal Identification System (NAIS). It asks USDA and MDA to "immediately suspend the funding and implementation of NAIS," and "fully and fairly examine" the need for such a program.

MDA has implemented the first two stages of NAIS – property registration and animal ID – for all cattle and farmers across Michigan as part of a mandatory bovine tuberculosis disease control program.

The Notice (www.farmtoconsumer.org) charges USDA has never published rules regarding NAIS, in violation of the Federal Administrative Procedures Act; has never performed an environmental impact statement or an environmental assessment as required by the National Environmental Policy Act; is in violation of the Regulatory Flexibility Act that requires analysis of proposed rules for their impact on small entities and local governments; and violates religious freedoms guaranteed by the Religious Freedom Restoration Act.