Reply to OMB Passback - Feb 24, 2016

Feb 24, 2016

The following text contains the questions from Bob Sivinski and Noah Engelberg concerning the Supporting Statements for the Local Foods Survey.

Supporting Statement A

OMB: To what extent, if any will the fact that this is a voluntary information collection skew the results?

NASS: No skewing is expected.

OMB: Is this the definition of ‘local’?

NASS: The target population for the Local Food Marketing Practices Survey is any farm that sells their products directly to consumers or to retail outlets that in turn sell directly to consumers for humans to eat or drink.

OMB: For informational purposes only, what are the total costs related to this survey? How frequently will it be conducted - is it in the FY 2017 Budget base?

NASS: The total cost for the Local Food Marketing Practices Survey is estimated to be $2.5 million.  The funding will come from four sources: (1) dollars saved from reducing the sample size for the 2015 Census of Agriculture Content Test, (2) dollars saved from reducing the sample size for the 2016 National Agriculture Classification Survey (NACS), (3) funding from a reimbursable agreement with the Agricultural Marketing Service (AMS), and (4) rollover funds from the Census of Agriculture FY2015 appropriations.

The Local Food Marketing Practices Survey is currently planned to be a one-time survey.  However, there is the possibility it will become a regular Census of Agriculture “follow-on” survey, conducted once every five years.  Funding availability and data needs (from within USDA and the industry) will determine if the survey will become a census follow-on.

OMB: Were all of these stakeholders involved in development or given opportunity to review?

NASS: NASS proactively engaged stakeholders who were involved in the development of this survey as well as the USDA’s “Know Your Farmer, Know Your Food” interagency working group. 

OMB: How will the results of this study be made available to potential consumers of locally –grown food?

NASS: In Item 16 we describe the type of publication NASS will generate from this survey. Due to our confidentiality rules we cannot disclose the names, addresses, etc. of any individual operation.

OMB: When will CATI be ready? Will it have novel content?

NASS: The CATI instrument and internet version will both be ready before data collection begins. The content of the instruments will be the same as the paper questionnaire. The automated skip questions will allow the respondent or enumerator to easily move through the questionnaire.

OMB: The estimated burden per response seems very low. Does answering the survey accurately require retrieving records?

NASS: The initial burden estimate was based on similar questionnaires and similar skip patterns. Following the Cognitive Interviewing and the changes that were made to the questionnaire based on our findings along with the comments provided by OMB, we feel more confident that the 30 minute burden is a good estimate of average respondent burden.

OMB: Given the estimated nonresponse, what data are being collected from non-responders to remediate bias through adjustment?

NASS: Will discuss at meeting.

Supporting Statement B

OMB: This seems at odds with later definitions that include

NASS: The definition is now consistent.

OMB: Non-farm entities? What’s an example?

NASS: As defined in SSB Item 2, prior to the survey it has not been determined if these entities are farms or non-farms.

OMB: Define these sub-strata.

NASS: State and Type of Farm

OMB: Are there any measures of quality for this source (MACE)?

NASS: This will be clarified during the upcoming meeting.

OMB: This point illustrates OMB concerns that the proposed procedure violates a key assumption of mark-recapture estimation: the chance for each individual in the population to be caught is equal and constant for both the initial marking period and the recapture period.

Please provide more information on the proposed estimation procedure, including any additional methods under consideration. Did NASS consider using dual-frame estimation techniques?

NASS: This is addressed in the revised first paragraph of this section.

OMB: This statement seems to indicate another violation of mark-recapture assumptions. In ecology terms the closed population assumption states that during the interval between the preliminary marking period and the subsequent recapture period, nothing has happened to upset the proportions of marked to unmarked animals (that is, no new individuals were born or immigrated into the population, and none died or emigrated). Another way to state this assumption is that the population is assumed to be "closed".

NASS: This is addressed in the revised first paragraph of this section.

OMB: Using control variables?

NASS: Nonresponse weights will be calculated by reweighting at the stratum or substrata level (which is based on control data)