0039-fruitnut-10-SSA

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. During this approval, the agency should work with OMB to address issues of non-response bias in these surveys. In the next request for approval, the agency must include, at the very least, a plan and timeline for addressing non-response bias. (01/28/08)

In the fall of 2009, the National Agricultural Statistics Service (NASS) began working on several new initiatives to improve the overall quality of data NASS publishes. These initiatives encompass most of the activities involved in data collection, analysis, summarization, and publication of data.

Many of the fruit, nut and specialty commodities covered under this OMB docket, use questionnaires that contain questions that are either a part of the National program, or were added to existing questionnaires, in response to requests from State cooperative agreements with data users. The new initiatives that NASS is undertaking has begun standardizing and streamlining the questionnaires to improve the ease at which a respondent can complete the surveys. NASS is also looking at ways in which we can improve our accessibility to electronic versions of the questionnaires, to make them more user friendly, for anyone wishing to complete the surveys, through the internet. We are also looking at ways in which we can use data collected from other surveys to improve the quality of data collected by this docket, to help reduce respondent burden and to help eliminate any potential for non-response bias.

NASS Senior Management has set a target completion date for the new initiatives for the Spring of 2012 (approximately two and a half years from start to finish). This will allow time to develop new software that will support the changes in the overall functions of NASS, which includes the development, testing, analyzing, and publishing of data using numerous new tools.

In the mean time, NASS management has stressed to our Field Offices the need to improve the response rates of all surveys, and to also concentrate their current data collection activities on maximizing their coverage of data. This coverage of data, involves the follow-up attempts (phone and field enumeration) at collecting data from the larger producers so that we have at least 80% of the data accounted for even though NASS may not be able to achieve a greater than 80% response rate.

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. There has been some minor changes to questionnaires to standardize the questions from State to State collections. NASS has also been able to combine several specialty surveys into one form to reduce the respondent burden. Some States have been able to merge commodity price questionnaires with existing production or processing surveys.

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. 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, specialty crops and Hawaiian 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 (RMA) for crop insurance issues and by the Farm Services Agency (FSA) 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 the larger 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. Using the new initiatives (that are mentioned on the first page of this document), NASS is investigating ways in which we can make it feasible to create and support EDR instruments for all surveys conducted by NASS. Currently, less 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 the commodities in this docket, if information is available from State agencies and other federal agencies, then NASS will use 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. Also, using data collected from the 2007 Census of Agriculture (0535-0226) sample sizes for each State were adjusted to better reflect changes in industry. 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.

In order to further reduce the overall respondent burden, NASS is incorporating stratified samples where possible, rather than conducting a complete enumeration of any group of specialty commodity producers. This allows NASS to concentrate more on the larger producers and greatly reduce the burden on the smaller producers.

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. The diversity of commodities included in this docket and the varying seasonality of each commodity warrants the frequency of data collection currently used by NASS. Data is collected for the different stages of production and consumption of the different commodities, for production, sales, prices, processing, and stocks.

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 August 31, 2009, on page 44817. The two public comments received and the one response letter are 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, U.S. Code Title 7, Section 2276, and Subtitle A of the Confidential Information Protection and Statistical Efficiency Act of 2002 (CIPSEA), (Public Law 107-347) 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 (NASDA) must read the regulations and sign a statement of compliance.

NASS and NASS contractors comply with OMB Implementation Guidance, (Implementation Guidance for Title V of the E-Government Act, CIPSEA). CIPSEA supports NASS’ pledge of confidentiality to all respondents and facilitates the agency’s efforts to reduce burden by supporting statistical activities of collaborative agencies through designation of NASS agents; subject to the limitations and penalties described in CIPSEA.

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. Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

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

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 16,489 hours is multiplied by $24 per hour for a total cost to the public of $395,736.

13. Provide estimates of the total annual cost burden to respondents or record

keepers resulting from the collection of information, (do not include the cost of any hour burden shown in items 12 and 14). The cost estimates should be split into two components: (a) a total capital and start-up cost component annualized over its expected useful life; and (b) a total operation and maintenance and purchase of services component.

There are no capital/start-up or ongoing operation/maintenance costs associated with this information collection.

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 $5.5 million, a reduction of approximately $500,000. Virtually all of the total costs are for personnel costs associated with data collection, analytical review, summarization, and publication of reports. While there was an overall increase in sample size and respondent burden, NASS was able to reduce overall costs, through the use of improved tools used for data collection, summarization and analysis of data.

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 16,489 hours is up 3,582 hours above the previous inventory of 12,907 hours. The increase is a result of several miscellaneous factors. Of the total increase in hours 1,245 of these are due to program changes, the remaining increase in hours is due to adjustments in NASS estimates.

The new annual number of responses of 93,806 is up 8,514 above the previous number of 85,292. Of the total increase in responses, 3,700 were due to program changes, the remaining increase in responses of 4,814 is due to adjustments in NASS estimates.

The program changes include the addition of a new pomegranate survey, the renewal of a maple syrup survey that is conducted once every five years, the merging of several smaller specialty surveys into a couple of more comprehensive surveys, along with several other miscellaneous activities. Following the data capture of the 2007 Census of Agriculture data, NASS was able to adjust its sample size estimates. The sample sizes used to calculate the burden hours in the table in paragraph A-12 were based on the data captured from the Census data.

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.

January, 2010

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