0002-fieldcrops-07-SSA-rev.wpd

Supporting Statement  -  Part A

FIELD CROPS PRODUCTION

OMB No. 0535-0002

TERMS OF CLEARANCE

“In accordance with 5 CFR 1320, the information collection is approved for a period of 2 years. Upon resubmission, the agency must provide a plan for improving response rates for surveys with low levels of response. The agency should also address an analysis of non-response bias and evaluate how potential low response combined with non-response bias affects the usefulness of the surveys.” (03/28/2005)

For Field Crops Surveys (0535-0002), the latest response rate figures are little changed from the previous submission, as shown below.

Field Crop Response Rates

Survey	Sample Size	Freq	Response Rate %
			2003	2006
Alfalfa/Clover Seed	350	1	86.7	88.5
Dry Beans	6,000	3	77.9	76.4
Mint	300	1	79.7	76.0
Oilseeds, special	1,900	1	n/a	63.5
Potatoes	4,500	3	75.6	70.9
Sugarbeets	6	4	98.4	100.0
Sugarcane, Firms	17	6	85.0	93.9
Sunflower, non-oil	2	3	n/a	100.0
Sweetpotatoes	1,500	3	83.9	78.2
Tobacco	2,500	5	79.3	49.4
Wheat & Barley Variety	14,000	1	58.6	67.7
Acreage (County Estimates)	300,000	1	est 50	56.8
Crop Progress	4,000	40	55.8	55.1

Two surveys in particular among the lowest reported response rates, tobacco and acreage (county estimates), however, have special circumstances and are still very useful.

• Forty percent of the tobacco sample is in one State, where the majority of operations are either Amish or Mennonite; the former do not have telephones and the latter are reluctant to respond to government surveys. Also, the list frame is difficult to maintain for tobacco operations because of the buy-out programs; the response rate is likely under-stated because questionnaires must be sent to the whole list frame, knowing that a significant portion of it now contains operations that are no longer in business.

• The acreage surveys–by far the largest in this information collection--are follow-on surveys of small operations to provide additional averages and percentages for county level indications since the national probability commodity surveys (OMB #0535-0213) do not sample heavily enough to support that level of estimates. The probability surveys, moreover, already account for the great majority of crop coverage because they select increasingly large operations at increasingly higher rates, e.g., the largest operations (stratum 1) are all probability = 1.0. Supporting Statement Part B has additional information concerning these items.

A task force in Headquarters has been reviewing these county estimates over the last 18 months with the goal of standardizing questionnaires, data collection, summarization, and estimation. They will also be designing ways to try to improve response rates, which will help reduce potential non-response bias.

Agency efforts to address non-response bias in a systematic way have begun with the most complex survey NASS conducts, the Agricultural Resource Management Survey (ARMS) (OMB No. 0535-0218), which has many data variables that can be compared against the Census of Agriculture (OMB No. 0535-0226). Preliminary results have been informative and investigation of non-response bias measures is continuing--a second report will be forthcoming in early 2008. NASS views non-response bias analysis as an iterative process, each information collection analysis contributing to the next, with the ARMS surveys as the first step. The rest of NASS surveys with response rates below 80 percent will follow.

A. JUSTIFICATION

There are no changes (yet) to methodology or procedures; two additional commodity-specific surveys are now accounted for and most sample sizes have changed somewhat.

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The primary function of the National Agricultural Statistics Service (NASS) is to prepare and issue current State and national estimates of crop and livestock production, value, and disposition. Survey data are collected for selected field crops to set these estimates. NASS conducts probability surveys where possible, as documented in OMB docket No. 0535-0213, the Agricultural Surveys Program. Because of unique field crop characteristics such as concentration of a crop in localized geographical areas or the relative importance of the crop, the use of supplemental follow-on surveys is needed. The surveys in this docket use a combination of mail questionnaires, telephoning, and personal interviews. They are conducted to ensure that there are sufficient samples to provide accurate indications for NASS published estimates.

Commodity-specific surveys for alfalfa/clover seed, dry beans, mint, special oilseeds, potatoes, sugarbeets, sugarcane, sunflowers (non-oil), sweetpotatoes and tobacco are used in those States where better coverage of localized growing areas is needed. Results are published in the next monthly Crop Production release. Commodity price information is also collected during some of these surveys in order to send the respondent fewer questionnaires and reduce respondent burden.

Variety surveys are conducted in several States to estimate acreage planted by wheat and barley variety. The wheat variety survey is conducted as part of State cooperative agreements. The barley variety survey is conducted in nine States as part of a cooperative agreement with the American Malting Barley Association.

The large Acreage and Production Survey for small grains is conducted each year at the end of the growing season to help estimate field crops acreage harvested and final production at State and county levels.

The weekly Crop Progress and Condition Survey published in Crop Progress provides timely information about the development and condition of crops between issues of the monthly Crop Production release.

General authority for these data collection activities is granted under U.S. Code Title 7, Section 2204 (attachment A). This statute specifies that "The Secretary of Agriculture shall procure and preserve all information concerning agriculture which he can obtain ... by the collection of statistics ... and shall distribute them among agriculturists."

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

Crop forecasts published in the monthly Crop Production report and other releases are used by farmers, agribusinesses, and many government agencies in analyzing the nation's production and marketing of field crops and grains. The Secretary of Agriculture uses estimates of crop production to administer farm program legislation and import-export programs.

The weekly crop progress and condition inquiry, published in the Crop Progress report every Monday, provides an efficient way for the Department of Agriculture to closely monitor agricultural developments across the country which may affect the nation's food supply. Numerous briefing reports are prepared for the Secretary of Agriculture on crop condition, phenological development, and harvest progress. The reporting of insect and disease damage can put farmers in other areas on alert to take preventive measures, thus minimizing possible damage. Information on shortages of soil moisture and extremes in temperatures can presage possible affects on yield.

County estimates for field crops are needed by the Farm Service Agency (FSA) and the Risk Management Agency to carry out their respective legislative mandates. Their primary use of the data is to determine average yields by county, used in determining participating farmers’ compensation payments.

Variety surveys are used by the Agricultural Research Service, plant breeders, researchers, and growers to determine the acreage by variety and measure acceptance of new varieties. The impact of insect or disease outbreaks can be measured from variety surveys after the tolerance of a particular variety is determined. Varietal data on wheat are used for determining production and available supplies by class. Class data are of great importance to government analysts and exporters in planning the disposition of U.S. wheat crops since exports comprise approximately one-half of total use.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

Nearly all of NASS information collections have been converted to Web-based data collection, what NASS calls electronic data reporting or EDR. Some or all of the survey instruments for the following commodities have been converted: dry beans, mint, special oilseeds, potatoes, sugarcane, non-oil sunflower, sweetpotatoes, tobacco, and the weekly crop progress and condition report. The conversion of several more of the smaller surveys will be completed this year. The remaining instruments that will not be converted are too infrequent or too impractical to use that mode of data collection. The current proportion of survey responses that employ the Web is about 48% for crop progress and about 0.6 % for the overall information collection.

The main portal for our on-line surveys is http://www.agcounts.usda.gov. Once there, the respondents have to enter the valid survey code and the user ID printed on the label of the questionnaire mailed to them. We do not want anyone other than a selected respondent to access the survey web pages. The address for the crop progress is different, however, because it was the first survey NASS converted to the Web: http://cpcsweb.nass.usda.gov.

4. Describe efforts to identify duplication.

NASS cooperates with State Departments of Agriculture and land grant universities to conduct agricultural surveys. These surveys meet both State and Federal needs, thus eliminating duplication and minimizing reporting burden on the agricultural industry. There is no duplication of questions asked of producers in this docket except for the probability surveys conducted by NASS, which they supplement. In addition, respondent lists are carefully compared to ensure there is no overlap.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

Information requested on surveys included in this docket can be provided with a minimum of difficulty by respondents, generally without having to consult their record books.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

Collecting data less frequently would eliminate information needed to keep the U.S. Department of Agriculture abreast of changes at the State and national level. Timing and frequency of the various reports have evolved to meet the needs of Department clients, including producers, agribusinesses, and government agencies, yet minimize burden on the reporting public.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner requiring respondents to report information to the agency more often than quarterly; requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;...

Survey data is collected weekly and monthly depending on the need for information to keep the U.S. Department of Agriculture abreast of changes at the State and national level.

8. Provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8 (d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments.

The Notice soliciting comments was published in the Federal Register on December 1, 2006 on pages 69533-69534. One public comment was received; it is included in the attachments.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultations with plant breeders, researchers, growers, industry associations, and other government agencies such as FSA are carried out to ensure that data collected reflect all varieties and the proper timing to obtain accurate information.

9. Explain any decision to provide any payment or gift to respondents.

There are no payments or gifts to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

All questionnaires include a statement that individual reports are kept confidential. U.S. Code Title 18, Section 1905 and U.S. Code Title 7, Section 2276 (attachment B) provide for the confidentiality of reported information. All employees of NASS and all enumerators hired and supervised under a cooperative agreement with the National Association of State Departments of Agriculture must read these regulations and sign a statement of compliance. (Privacy Impact Statement is attachment C.)

11. Provide additional justification for any questions of a sensitive nature.

There are no questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statement should indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

Average completion time per questionnaire is based on time required for other surveys of similar length. Calculation of burden hours is shown in the table below. Estimated response counts are based on an 80% target response rate and minutes per response shown are the maximum average times for all questionnaires used for the commodity.

Projected Field Crop Production Annual Response Burden Hours for 2007

Survey	Estimated Sample Size	Freq	Estimated Responses				Non-response				Total Burden Hours
			Resp. Count	Freq x Count	Min./ Resp.	Burden Hours	Nonresp Count	Freq. x Count	Min./ Nonr	Burden Hours
Commodity-specific Surveys
Alfalfa/Other Seed	350	1	280	280	10	47	70	70	2	3	50
Dry Beans	6,000	3	4,800	14,400	15	3,600	1,200	3,600	2	120	3,720
Mint	300	1	240	240	15	60	60	60	2	2	62
Oilseeds, special	1,900	1	1,520	1,520	10	254	380	380	2	13	267
Potatoes	4,500	3	3,600	10,800	15	2,700	900	2,700	2	90	2,790
Sugarbeets	6	4	5	20	80	17	1	4	2	1	18
Sugarcane	17	6	14	84	10	14	3	8	2	1	15
Sunflower, non-oil	2	3	2	6	5	1					1
Sweetpotatoes	1,500	3	1,200	3,600	10	600	300	900	2	30	630
Tobacco	2,500	5	2,000	10,000	10	1,667	500	2,500	2	9	1,676
Variety Surveys
Wheat and Barley	14,000	1	11,200	11,200	10	2,800	2,800	2,800	2	94	2,894
Acreage & Production (County Estimates)	300,000	1	240,000	240,000	20	80,000	60,000	60,000	2	2,000	82,000
Crop Progress and Condition Report	4,000	40	3,200	128,000	10	21,334	800	32,000	2	1,067	22,401
Total	335,075		268,061	420,150		112,208	67,014	105,022		3,430	115,638

Cost to the public for completing the questionnaires is assumed to be comparable to the hourly rate of those requesting the data. The combined reporting for all surveys of 115,638 hours is multiplied by $24 per hour, for a total cost to the public of $2,775,312.

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information.

There is no cost burden to respondents.

14. Provide estimates of annualized cost to the Federal government; provide a description of the method used to estimate cost which should include quantification of hours, operational expenses (equipment, overhead, printing, and staff), and any other expense that would not have been incurred without this collection of information.

The total cost to the Federal government to conduct field crop surveys and prepare estimates is approximately $6.1 million, most of which is staff cost for data collection.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I (reasons for changes in burden).

The total burden of 115,638 hours is down 13,507 hours from current inventory of 129,145 hours. This decrease is due to revision of universe sizes based on the latest pre-Census Agriculture Identification Survey (OMB No. 0530-0140); adjustments to minutes per response for several questionnaires; and better recording of responses to the largest survey, the Acreage and Production Survey.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

Questionnaires are returned by mail to the Field Office (FO) in each State and reviewed for reasonableness prior to keying into data processing media for summarization. They are summarized by crop reporting districts and the indications are weighted for the State based on the relative importance of the commodity in the district. State indications are plotted on time series charts which typically comprise 10 years of survey indications and final estimates. Three primary indicators are obtained for each crop: an identical comparison of current year acreage to the previous year acreage, acreage as a percent of total farmland, and average yield for respondents reporting.

Crop production estimates are issued from Headquarters in Washington, D.C. in the monthly Crop Production reports, the January annual summary, June acreage report, or specialty releases as shown in the table below. Crop progress and condition data are published in the weekly Crop Progress. State-funded cooperative survey reports may be released from the individual Field Offices as well as in Headquarters publications. The Weekly Weather and Crop Bulletin is prepared in cooperation with the National Weather Service Meteorologists, USDA's Cooperative Extension Service, and World Agricultural Outlook Board.

2007 Field Crops Production Surveys

Survey	Data Collection Period	Publication
		Publication Name	Release Date
Alfalfa/Clover Seed	Jul	SSO monthly release	August
Dry Beans	Jun - Nov	Crop Production	12th of month
Mint	Nov	Annual Summary	January
Oilseeds, Special	Oct - Dec	Crop Production	12th of month
Potatoes	Apr - Dec	Crop Production	12th of month
		Potatoes	Sep 20
Sugarbeets	Apr, Jun, Nov, Dec	Acreage	end of Jun
Sugarcane	Jun; varies Aug-Mar	Crop Production	12th of month
Sunflower, Non-oil	Mar, Jun, Dec
Sweetpotatoes	Mar, Jun, Dec
Tobacco	Jun, Aug - Nov	Acreage	end of Jun
		Crop Production	12th of month
Variety Surveys: Barley	Jun	Variety Summaries	mid-Jul
Acreage and Production	varies Aug-Jan	Annual Summary	January
Crop Progress	weekly Apr-Nov	Crop Progress	Mondays

These publications are available on-line immediately after release at http://www.nass.usda.gov/Publications/Reports_by_Title/index.asp. Once there, select first letter of report title from alphabet list and then specific commodity or publication.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

There is no request for approval of non-display of the expiration date.

18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions” of OMB Form 83-I.

There are no exceptions to the certification statement.

March 2007

Revised November 2007

0002-fieldcrops-07-SSA-rev.wpd