Comment from Daniel Hilburn

The proposed rule makes mention of both "confidential business information" and "certain business information." Sticking to confidential would help avoid confusion. Under 340.10(4) we recommend that USDA specify the standard for state employee CBI training. The proposal mentions storage and sharing of "paper records." Protected electronic records would be preferable. We suggest USDA develop a way for approved reviewers to look at the CBI without having to download, print, or copy it. The system would be more secure if the state reviewers could see it on a screen, but never take possession of it. It would also be nice if we didn't have to download BRS applications and draft permits in order to review them. Thank you.