Justification for Milk and Milk Products Change Request

SUBJECT: Justification for Milk and Milk Products Change Request,

OMB No. 0535-0020

We are submitting this change request for the Milk and Milk Products information collection, OMB Control Number 0535-0020, to address minor changes to the Dairy Product Prices questionnaires.

The Agricultural Marketing Service (AMS) Interim Final Rule was published in the Federal Register on Tuesday, July 3, 2007. That rule established a Dairy Product Mandatory Reporting Program. In preparation for this new ruling, NASS submitted an emergency review request in May 2007 to get approval of the new mandatory constraint that was added to all of the affected questionnaires. The Interim Final Rule was given an expiration date of 12 months. The Interim Final Rule had an extended comment period, which closed on December 3, 2007. In January 2008, NASS received a regular 3 year approval for the Milk and Dairy Products docket (0535-0020). Since the closing of the comment period AMS has had time to review both the comments and the Final Rule. AMS has deemed it necessary to make some fine tuning changes to the questionnaires to clarify a few points that were missed when they submitted the questionnaires for the previous approval process. These changes are non-substantive and serve to add clarity to the questionnaires and help to insure the intent of the Final Rule is adhered too.

In response to the request made by the Agricultural Marketing Service (AMS) for more detail and clarity to the questionnaires to insure standardized price reporting by the dairy industry, NASS is requesting these non-substantive changes.

Some of the detailed information that is already included on the Annual Validation Survey now is included on the weekly price questionnaires. This includes:

• Certified organic butter and butter produced under faith based practices are to be excluded,

• Transportation and clearing charges paid by the manufacturer were moved from exclude to include,

• Products sold under the Dairy Export Incentive Program (DEIP) were previously included; they are now to be excluded.

Screening questions were added to the front page of the Dairy Product Prices Annual Validation Worksheet. These questions were added to streamline the questionnaire along with reduce the amount of time (burden) it takes for the respondent to complete the questionnaire.

Additional information was added throughout the questionnaire to give greater clarity to the items listed in the questionnaire. There will be at least one trained statistician in each Field Office who will be conducting the Annual Validation Surveys in each State. This additional information is provided to the statisticians conducting the interview to help them explain any areas of confusion that the respondent may have. The majority of the questions have two columns to respond to. If the operation that is being interviewed is new to this survey the answers will be recorded in the second set of responses. If the respondent was in the sample last year and they respond “NO” to any question a mark will be made in the first “NO” column and a follow up question will be asked to see if the respondent can provide data in the desired manner.

Rounding rules and cheddar cheese moisture adjustments have been incorporated into the tables instead of being listed as bulleted items.

In response to the Inspection Report issued by the Office of Inspector General in February 2008, NASS has included two questions on the weekly questionnaires that acknowledge that the respondent has read and understands the instructions provided on the questionnaire(s).

The minor adjustments made to the Dairy Product Prices Program that AMS is managing, are scheduled to go into effect no later than July 2, 2008.

Some other cosmetic changes made to the questionnaires were done to standardize the questionnaires with other NASS surveys, but more importantly to make it easier for the respondent to complete the questionnaire in a timely and accurate manner.