0039-fruitnut-07-SSA-rev

Supporting Statement - Part A

FRUIT, NUTS, AND SPECIALTY CROPS

OMB No. 0535-0039

TERMS OF CLEARANCE

“In accordance with 5 CFR 1320, the information collection is approved for a period of two years. Upon resubmission, the agency should provide a plan for improving response rates. The agency should evaluate non-response bias, especially in surveys with low response rates. Finally, the agency is reminded that they should provide all information sent to potential respondents in their information collection request.’ (03/28/2005)

In preparation for the 2007 Census of Agriculture, NASS Field Offices have spent a great deal of resources on improvement of our list of farmers. This effort has not only improved the quality of our “in-scope” records for these lists of specialty commodities, but also enhanced the quality of control data or sampling information used to classify these operations. These efforts have already provided improvements in response rates and coverage of production areas by commodity.

NASS standard procedures instruct our Field Offices, at a minimum, to conduct 2 mailings followed by a telephone non-response follow-up. Although this practice is ideal, fruit, nut, and specialty crop surveys typically include a disproportionate number of small operations and limited dollars for data collection. Also, production statistics gathered from these surveys are typically weighted by the respondent’s acreage. For these reasons NASS has historically focused on obtaining responses from the larger producers, ensuring adequate coverage. Regardless, NASS is concerned about the levels of non-response and any potential bias and is researching alternate means for improving response rates.

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. 0535-0226). 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 survey as the next step. Plans for the rest of NASS surveys with response rates below 80 percent will follow. A special team has been formed at NASS to evaluate collections currently under Terms of Clearance due to low response rates and priority will be assigned to each one.

A. JUSTIFICATION

This submission is a request for approval of this long-running information collection for 3 years. There are only minor changes in the survey program, mostly updating universe/sample sizes after list frame maintenance.

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 official State and national estimates of crop and livestock production, value, and disposition. Estimates of fruit, tree nuts, and specialty crops are an integral part of this program. These estimates support the NASS strategic plan to cover all agricultural cash receipts.

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.

Data reported on fruit, nut, and Hawaii tropical crop inquiries are used by NASS to estimate crop acreage, yield, production, utilization, price, and value in States with significant commercial production. These estimates are essential to farmers, processors, and handlers in making production and marketing decisions. Estimates from these inquiries are used by market order administrators in their determination of expected crop supplies under federal and State market orders.

Other government agencies also need these data. They were used during open trade negotiations with Canada and Mexico which resulted in the 1994 North American Free Trade Agreement. Estimates for these commodities are needed by the Risk Management Agency for crop insurance issues and by the Farm Services Agency to determine disaster payments. The International Trade Commission has used these data to resolve anti-dumping investigations, such as the March 1998 resolution of the dispute involving the shipment of apples to Mexico. Additionally, the information is used as base data for the Water Quality/Food Safety surveys.

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. Conversion of the dozens of versions of the fruit, nuts, and specialty crops questionnaires is steadily progressing, where practical. Fewer than 0.5 percent of responses are from the Web.

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 their own user ID from the printed label of the questionnaire mailed to them. We do not want anyone other than a selected respondent to access the survey Web pages and enter data.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

NASS cooperates with State departments of agriculture and land grant universities to conduct agricultural surveys. This eliminates duplication of data gathering by more than one agency. For many of the commodities in this docket, information is available from State agencies and other federal agencies. NASS uses these administrative data to reduce burden on the public.

Each NASS Field Office (FO) maintains an up-to-date list frame of growers for each applicable commodity in this docket. By monitoring data collection periods for each commodity, cross-referencing growers by commodity, and combining information for multiple commodities on a single questionnaire, duplication of data collection is eliminated. This keeps total respondent burden to the lowest possible level.

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 from growers can be provided with a minimum of difficulty and generally without having to consult their record books. Information from processors can be completed from normal day-to-day operating records. Administrative data is obtained for commodities that are State or federally regulated, thereby eliminating burden on growers and processors. Administrative data from other entities are used whenever possible. In instances where administrative data provides sufficient coverage and accuracy, we consider these opportunities to discontinue surveys and reduce burden.

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 prevent USDA and the agriculture industry from being kept abreast of changes at the State and national level.

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;...

Some surveys are conducted monthly during the growing season to keep USDA and the agriculture industry abreast of changes at the State and national level. Timing and frequency of the reports have evolved to meet the needs of producers, agribusinesses, and government agencies.

Many of the specialty crop, fruit and nut surveys are conducted at times of the year that coincide with the crop growth cycle(s) and harvest or marketing periods. This helps to increase the accuracy of the data by reducing memory bias. If we conducted surveys at less frequent intervals or all at the end of the year, it would be difficult for the respondents to recall information for previous time frames.

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 Federal Register Notice soliciting comments was published on December 1, 2006, on page 69532. The one public comment received is attached.

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 the Extension Service, grower organizations, farmers, and other organizations occur on a regular basis, especially by our State Field Offices.

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 the regulation and sign a statement of compliance. (Privacy Impact Statement is in 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. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

Total hours of burden are based on calculations shown in the following table, with a targeted response rate of 80%.

* For Multiple Fruit Surveys – Processing we discontinued the Fruit Price survey in Pennsylvania (sample size of 731).

Total combined burden (responses and non-responses) 12,907 hours.

Cost to the public of completing the questionnaires is assumed to be comparable to the hourly rate of those requesting the data. Reporting time of 12,907 hours is multiplied by $24 per hour for a total cost to the public of $309,768.

13. Provide an estimate of the total annual cost burden to respondents or record keepers 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 the fruits, nuts and specialty crops surveys and prepare estimates is approximately $6.0 million. Virtually all of this is personnel costs associated with data collection, analytical review, summarization, and publication of reports.

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 new annual burden of 12,907 hours is up 2,790 hours above the current inventory of 10,117 hours. The increase is a result of States list building efforts in preparation for the 2007 Census of Agriculture. The sample sizes used to calculate the burden hours in the table in paragraph A-12 above came from the 2006 sample.

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 for all surveys in this information collection are returned to the State Field Offices and reviewed for reasonableness prior to keying into data processing media for summarization. State statisticians analyze survey results, recommend estimates or forecasts for their State, and transmit the data to Washington, D.C. State survey results are summarized nationally and by major regions or State groupings. Individual State recommendations are reviewed and changed, if necessary, to reach national and regional estimates.

During the forecast season, questionnaires are mailed to growers with a reference date of the first of the month. Most production forecasts are released in the Agency's monthly Crop Production report released between the 8th through the 12th of the same month. Exceptions are the mid-June forecasts of sweet and tart cherries and the mid-August forecast of cranberries which are issued separately.

Growers’ disposition questionnaires are mailed soon after completion of harvest for non-storage crops or at the end of the marketing season for storage fruits. End-of-season estimates for all noncitrus crops are published in the January Noncitrus Fruits and Nuts Preliminary Summary. The Noncitrus Fruits and Nuts Summary report is issued the following July to show final utilization and value estimates for storage crops such as apples, grapes, pears, and tree nuts. Also included are miscellaneous crops in California and Hawaii for which final market records and processor data were not available in December. End-of-season citrus acreage, yield, production, price, and value estimates including final utilization and price data for the previous marketing season are published in the September Citrus Fruits release.

Orchard and Vineyard Inventory Surveys are issued as special reports. Generally, inventory surveys are conducted January through March. Bearing acreage and yields per bearing acre are published by State and crop in the Citrus Fruits Summary and the Noncitrus Fruits and Nuts Preliminary Summary and final Summary.

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 January 2008

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