NAP supporting_statement_ 2015_OMB Comments FSA edited.

UNITED STATES DEPARTMENT OF AGRICULTURE

Farm Service Agency

(Commodity Credit Corporation)

OMB Number 0560-0175

7 CFR 1437, Noninsured Crop Disaster Assistance Program

Purpose:

FSA is requesting for a revision and an extension of a currently approved collection.

FSA described the revision of information collection activities and the changes to the burden hours due to the new respondents in the request for public comment that was published in the Federal Register on October 15, 2014 (79 FR 61484–61489). FSA added the changes required for the buy-up for additional coverage, organic crops, and mollusks that was described in the published interim rule on December 15, 2014 at 79 FR 74562-74583. The collection of information from the respondents remains the same except the new respondents with organic crops and mollusks, at the same time, to reflect the current numbers of respondents and annual burden hours in the NAP. One new form is added to this information collection request.

1. Justification

1. Circumstances and legal or administrative requirements that necessitate the collection of information.

7 U.S.C. Section 7333 specifies that the Secretary (of Agriculture):

• operates a noninsured crop disaster assistance program (NAP) to provide coverage equivalent to catastrophic coverage under section 508(b) or additional coverage under sections 508(c) or 508(h) under the Federal Crop Insurance Act (7 U.S.C. 1508) in those areas where that coverage is not available

• waives the required service fee for producers who qualify as limited resource, beginning, or socially disadvantaged farmers.

The purpose of NAP is to help manage and reduce production risks faced by producers of eligible commercial crops or other agricultural commodities during a coverage period. NAP reduces financial losses that occur when natural disasters (damaging weather or adverse natural occurrence that is an eligible cause of loss) cause a loss of expected production or actual value for value loss crops, or where producers are prevented from planting an eligible crop because of an eligible cause of loss in a coverage period.

NAP coverage is available to eligible producers and eligible crops for which catastrophic coverage under section 508(b) or additional coverage of sections 508(c) or 508(h) under the Federal Crop Insurance Act (7 U.S.C. 1508) (excluding pilot policies or plans of insurance) is not

available. Eligible crops include commercial crops and agricultural commodities (except livestock) that are produced for food or fiber or specifically included by statute, including floriculture, ornamental nursery, Christmas trees, turfgrass sod, seed crops, aquaculture (including ornamental fish), sea grass and sea oats, camelina, sweet sorghum, biomass sorghum, and industrial crops (including those grown expressly for the purpose of producing a feedstock for renewable biofuel, renewable electricity, or biobased products).

To qualify for assistance, the losses of eligible crops must be due to damaging weather or an adverse natural occurrence, as determined by the Secretary.

Furthermore, the statute requires that producers:

• submit a NAP application for coverage at a local FSA office of the Department of Agriculture

• pay a service fee to the Secretary at the time they submit an application for coverage

• pay a premium, if electing additional coverage levels

• provide annually to the Secretary records of crop acreage (planted and prevented from being planted), by the designated acreage reporting date for the crop and location

• provide annually to the Secretary acreage yields and production for each crop

• have suffered a loss of a noninsured commodity as the result of an eligible cause of loss to be eligible for a NAP payment

• elect whether to receive NAP assistance or assistance under another program when the producer is eligible to receive NAP assistance and assistance for the same loss under any other program administered by the Secretary (excluding assistance under the Livestock Forage Disaster Program (LFP), Tree Assistance Program (TAP), and Emergency Assistance for Livestock, Honeybees, and Farm-Raised Fish Program (ELAP))

• have their production adjusted upward by the amount of the production equal to the amount of a guaranteed payment for planted acreage, as opposed to delivery of the crop production

• provide detailed documentation of production costs, acres planted, and yield for the crop year in which assistance is requested or if the Secretary determined these records inadequate, proof that the eligible crop, had it been harvested, could have been marketed at a reasonable price when the crop acreage in the administrative county in which the unit is located increases by more than 100 percent over any year in the preceding seven crop years or significantly from the previous crop year and the producer is denied an assigned yield.

Additionally, NAP payments follow the rules of direct attribution, which require the total amount of payments attributed to a person to be taken into account, including direct and indirect ownership of interest of the period in a legal entity that is eligible to receive payments.

2. How, by whom, and for what purpose the information is to be used and any consequences to the NAP if the collection of information is not conducted.

The following table illustrates how, by whom, and for what purpose information collection is accomplished relative to NAP.

IF	THE PRODUCER	FSA WILL
Prior to the application closing date for the specific crop and crop year,	Files an application for coverage on CCC‑471	Compute a current crop year approved yield using Actual Production History (APH) as certified by the producer, temporary yields (T-yields), and/or assigned yields.
On or before the earlier of the reporting date, or 15 days before the beginning of harvest,	Certifies a record of acreage on Form FSA-578 for the crop year or planting period,	Accept the certification as timely filed, spot check reported crop acreage, and record determined acreage.
Following damaging weather or adverse natural occurrence and within 15 days from the occurrence or the date damage to the crop or commodity became apparent,	Files a notice of loss on CCC-576, Part B and indicates an intention to: harvest potential production	Accept the notice of loss as timely filed and approve or disapprove the notice of loss on the basis of: review of the notice of loss, and; possible inspection of the crop acreage
	abandon or destroy crop acreage or dispose of the commodity without benefit of harvest	notice of loss as timely filed and approve or disapprove the notice of loss on the basis of: review of the notice of loss, and; appraisal of potential production from the specific crop acreage
Following appraisal and harvest of the specific crop acreage and on or before the subsequent crop year acreage reporting date,	Certifies appraisal and/or production on CCC-576-1; CCC-576, Part D, E, or F; or CCC-452 and assigned production on CCC-576 Part D	Accept the certifications as timely filed; complete a spot check of production records, and; update APH data base.
	Files an application for payment on CCC-576, Part GAccept the application for payment and certification of gross revenue as timely filed and approve or disapprove the application for payment on the basis of: actual, appraised or assigned production versus approved yield

The following forms will be used to collect the producer and person certifications necessary for the proper administration of the NAP. General information, i.e. name, identification, address, and telephone number of the applicant is retrieved from an existing database and pre-filled in the electronically generated forms using information previously provided to the agency for this and other programs. Applicants who have not previously provided this information, including a permanent identification number, will be asked to provide it in conjunction with an application for coverage. FSA customers are routinely asked to verify the accuracy of database information.

A. CCC-452, Actual Production History and Approved Yield Record

Form CCC-452, Actual Production History and Approved Yield Record is used to record actual production history and calculate the subsequent crop year's approved yield for a crop. The crop name, type or variety, planting period, practice, intended use, and unit of measure are retrieved from the report of acreage provided by the producer earlier in the crop year. Other information including an indication of whether yield limitations apply, determinations of a county expected yield, and adjusted T-yield, if applicable are provided by the county office.

Information collected consists of a certification of current crop year production and that record includes a complete and accurate record of actual production history.

B. CCC-471, Application for Coverage

Form CCC-471, NAP Application for Coverage is used to identify the producer, eligible crops, and additional coverage level/options for which the producer selects NAP coverage. The application for coverage provides a venue for the applicant to request a waiver of the service fee requirement. FSA county offices use the crop identification to establish the data base to compute the approved yield for the crops, as applicable. Information collected consists of:

• The applicant's name, address, and other identifying information

• An indication of whether the applicant requests a waiver of the service fee for socially disadvantaged, limited resource, or beginning farmer or rancher by marking the applicable category. Applicants indicating they are limited resource producers are required to maintain records that substantiate annual gross income for the 2 tax years preceding the crop year for which coverage is requested.

• Identification of the selected crops by name, type, intended use, and planting period. The producer selects the crop from an existing database of crops sorted by name, type and intended uses, additional coverage levels, organic, historic market and direct market options

The producer certifies, by their signature, that all information provided is true and correct.

C. CCC-575, Record of Marketing History.. - NEW

Form CCC-575, Record of Marketing History is used to document certification of direct marketing and/or historical marketing percentages. This form is only used if the producer elects one of the direct or historic marketing options at the time they complete a CCC-471 Application for Coverage. Producers must initiate the request and provide production and final uses for fresh, processed and/or juiced commodities and/or wholesale and direct market information for consideration of a direct market price.

D. CCC-576, Notice of loss / Application for Payment

Form CCC-576, Notice of Loss / Application for Payment is used to record the crop damage/loss or prevented planting of a specific crop and the producer's subsequent request for payment. Acreage and crop information provided on the report of acreage is retrieved from the farm and crop database and pre-filled on the form.

Information collected consists of:

• The location of the damaged crop

• Identification of the damaging weather or adverse natural occurrence causing the loss or prevented planting of the crop

• The date or period the:

  1. damaging weather or adverse natural occurrence occurred, or

  2. damage or loss became apparent to the producer

• The type of loss (prevented planting or damaged crop/low yield)

• For the acreage intended but prevented from being planted, evidence of the intent to plant the acreage, (i.e. land preparation measures (tillage; applications of fertilizers, etc.), seed purchases, and arrangements for custom tillage, planting, weeding, harvesting, marketing, etc).

• The total affected acreage of the damaged crop and/or low yield

• Cultivation practices employed on the damaged crop/low yield acreage before and after the date or period of damaging weather or adverse natural occurrence

• What the producer has done with prevented planted or damaged crop/low yield acreage

• What the producer intends to do with prevented planted or damaged crop/low yield acreage

• A summary of harvested and appraised production for yield based crops including commodities harvested for secondary use and a salvage value received if available

• A computation of a value loss crop, including a salvage value received

• A certification of information provided and retrieved from existing sources, and an application for payment.

E. CCC-576-1, Appraisal / Production Report

Form CCC-576-1, Appraisal / Production Report is used to record the quantity of production appraised and measured by an authorized loss adjustor. The loss adjustor provides all the information on the form, other than general information discussed before. The loss adjustor may, in some circumstances, ask the producer questions relative to the condition of the crops, etc., as required to complete the appraisal. Generally, if possible, producers accompany the loss adjustor while the appraisal is being completed.

Information collected consists of an acknowledgment of the findings of the loss adjustor.

F. CCC-577, Transfer of NAP Coverage (The name of the form has changed.)

Form CCC-577, Transfer of NAP Coverage is used to document a request for transfer of a NAP coverage policy from one producer to another. Producers must initiate the request and provide satisfactory evidence that the transfer occurred during the coverage period, i.e., the earlier of (a) the date harvest was completed, (b) the calendar date for the end of the coverage period, or (c) the date the entire crop was destroyed. Information collected consists of the name, address, identification number of the transferee/transferor, the effective date of the transfer, nature of transfer, and crops transferred.

3. 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 and any consideration of using information technology to reduce burden.

CCC-452 Manual, CCC-575, CCC-576, CCC-576-1 (for County use only) and CCC-577 are available electronically at http://forms.sc.egov.usda.gov. In addition to electronic access, accommodations, such as the use of the mail or package delivery service are available for producers without Internet access or with circumstances that inhibit their visiting the applicable FSA county office.

4. Identifying duplication and using similar information already available.

FSA realizes that data sharing is essential to collect program information and to leverage resources; therefore, FSA has implemented a Common Information Management System (CIMS) with RMA, which is a web-based system accessible by county and State offices to reduce the incidence of both agencies requesting duplicative information from producers.

The agency has identified minimal duplication of information collection within USDA. However, the agency has identified duplication of information collection outside USDA. A producer may be required to report information to multiple entities as a prerequisite to participating in local, State, regional and other Federal programs. The agency is continuing the pursuit of partnerships with USDA entities and State governments to standardize the information collection and management processes. Although the agency has identified a number of areas where duplication of information collection occurs and is actively pursuing agreements to avoid it, there are limitations to sharing this information. Barriers to sharing this information with others include the need to standardize information collection requirements; a common producer, land and crop identifier; and an electronic medium that allows each entity immediate access to the information upon producer certification.

5. Impact on small businesses or other small entities and methods used to minimize burden.

The information collection does not negatively impact small businesses or other small entities.

There are 25,027 small businesses/entities in this information collection request.

6. Consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently and any technical or legal obstacles to reducing burden.

The information collection is required for proper administration of the NAP on an as needed basis when damaging weather, etc. occurs resulting in loss of crop production. Annual collection of specific acreage and production data allows the agency to ensure compliance with program provisions while evidence of production and damaging weather remains available. Less frequent information collection would most likely compromise compliance efforts and result in a loss of program integrity and agency resources. Less frequent collection of acreage and production data could materially affect the agency's ability to respond timely to natural disaster situations, which is a fundamental purpose of NAP.

7. Special circumstances that would cause an information collection to be conducted in a special manner.

1. Requiring respondents to report informa­tion to the agency more often than quarterly. The respondents are not required to report information to the Agency more often than quarterly.

2. Requiring respondents to prepare a writ­ten response to a collection of infor­ma­tion in fewer than 30 days after receipt of it. Respondents are not required to submit a written response to a collection of information less than 30 days after they have received it.

3. Requiring respondents to submit more than an original and two copies of any docu­ment. Respondents are not required to submit more than one original and two copies of any documents.

4. Requiring respondents to retain re­cords, other than health, medical, governm­ent contract, grant-in-aid, or tax records for more than three years. Respondents are not required to retain records for more than 3 years.

5. In connection with a statisti­cal sur­vey, that is not de­signed to produce valid and reli­able results that can be general­ized to the uni­verse of study. FSA does not use any statistical survey.

6. Requiring the use of a statis­tical data classi­fication that has not been re­vie­wed and approved by OMB. All forms used by producers related to participation in NAP have been approved by OMB.

7. That includes a pledge of confiden­tiali­ty that is not supported by au­thority estab­lished in statute or regu­la­tion, that is not sup­ported by dis­closure and data security policies that are consistent with the pledge, or which unneces­sarily impedes shar­ing of data with other agencies for com­patible confiden­tial use. There are no such requirements.

8. Requiring respondents to submit propri­etary trade secret, or other confidential information unless the agency can demon­strate that it has instituted procedures to protect the information's confidentiality to the extent permit­ted by law. Respondents are not required to submit trade secret or other confidential information in this information collection.

8. Consultations with persons outside the agency to obtain their view on the availability of data, frequency of collection, the clarity of the instructions and record keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

A notice and request for comments regarding the agency's intent to request an extension, with a revision of an approved information collection was published in the Federal Register (Volume 79 FR 61848) on October 15, 2014. The 60-day comment period ended on December 15, 2014. FSA did not receive any comments.

The following persons were contacted February 2015, after the 60-day comment period ended, concerning NAP and the required paperwork. The following comments were made:

Karen Damron (Grass/Graze)

12216 N 1910 Rd

Sayre, OK 73662

580-821-6517

Comments: I like getting the letter in the mail late summer of each year telling me what NAP coverage I had the following year and allowing me to mail a check to the office and keep the same coverage.  I am mainly a Rye Graze and Grass Graze nap producer but also occasionally have Rye for Grain.  The FSA office always has to remind me what kind of production records I need to provide whether it is weight tickets or if I need to have my seed measured in the bin.  The paperwork for the NAP program seems to be less complicated than it has in the past with the computer pulling information on my farms rather than me having to write so much information manually on the farms.  There are extremely too many different programs and dates to remember so luckily the fsa office is good about sending reminders and not letting us forget any deadlines.

Tom, Wolak, Wolak Farms LP (Fruits and Vegetables)

19620 Pratt Rd

Armada, MI 48005

810-459-6105

Comments:

OLD NAP PROGRAM –

BAD! REASONS WHY:

• Took forever to get paid

• If you had 2-3 bad years in a row, your APH was so low there was nothing left to even get paid on

• The early years of NAP the county yields were so high they were unrealistic

• 1988 - Macomb County’s yield was 4.2 tons an acre of green beans. There was no way producers could make that.

NEW PROGRAM NAP – BUY UP:

Currently – Macomb County Michigan is a PILOT county for red and green cabbage. This program works like MPCI. It’s great! You buy coverage in hundredweights and can cover up to 70% of production. This is a true insurance policy for specialty crop producers.

Oksana Borcharova (Vegetables)

2517 McGinnes Rd

Chestertown MD 21620

410-487-1925

Comments:

Finds it difficult to track yield info on such a small piece of cropland (operation is a small 3 acres and producing 20 + vegetables). She is only carrying the policy because her FLP loan requires her to.

Frederick Smith (Honey)

17808 Greentree Lane

Hagerstown MD 21740-7865

301-745-5932

Comments:

The application was simple with the office doing it.  It would be nice if they had a set form on line to fill out for the data and recording information before we come in. I get forgetful about some if the information that I need and how you need it.  Some of the items relating to beekeeping are not clear.

We did have 2 hives that were blown over that died and a 5 lids blown off. Those hives were also dead.  Not sure how much of a loss it will be with the rest because of the extremely cold holding on so long. When it gets that cold for a long period of time they can’t move around to get any honey to eat. There was a beekeeping in Clearspring that had 40 hives blown over. He keeps all of his hives on stands.

Sarah Kirk (Grain, Vegetable)

4111 Laurel Grove Rd

Federalsburg MD 21632

410-924-3761

Comments:

The availability of data was good and had all questions answered timely and accurately.  Instructions were clear and did not have a problem understanding the requirements.  The record keeping and reporting format was easy to do and never had a problem with the deadlines.  She stated that since they also have crop insurance this program works the same as it does. 

9. Payment or gifts to respondents.

No payments or gifts are provided to respondents other than legitimate payments for which the producer has submitted approved OMB forms and is eligible to receive related to the NAP program

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

The assurance of confidentiality of information collected is provided according to established FSA procedures implementing the Privacy Act, Freedom of Information Act, and OMB Circular A-130, "Responsibilities for the Maintenance of Records about Individuals by Federal Agencies"

11. Justification for any questions of a sensitive nature, such as sexual behavior and attitudes, etc. that are commonly considered private.

Information of sensitive nature is not collected.

12. Estimated hour burden of the collection of information.

FSA 85-1, "Reporting and Record Keeping Requirements" with the burden hour estimates for the NAP is attached and explained below:

The agency queried existing NAP databases for program years 2012, 2013, and 2014, averaged the actual totals and added an additional 10% increase for anticipated increase in participation due to the additional coverage level beginning with 2015.

The CCC-471, Application for Coverage

The agency estimates 144,588 CCC-471, Application for Coverage will be filed annually (72,294 respondents x 2 applications). The estimate is based on an average 2 applications filed per producer annually, for new legislation for which insurance is not available. The amount of information to be provided and forms to be completed per producer will not change.

Completion of CCC-471 is an automated process with the producer only having to answer a few questions regarding their identity, crops, and coverage levels etc., and sign the application. The average time to complete an application is 5 minutes. The estimated burden is 12,044 hours (5 minutes / 60 minutes = .0833 hr x 144,588 total respondents).

All producers completing a CCC-471 must also annually certify CCC-452, Actual Production History and Approved Yield Record for each enrolled crop. Assuming 3 crops per participant, approximately 216,882 (72,294 respondents x 3 crops) CCC-452’s will be filed annually. The average time to complete CCC-452 is 5 minutes. The estimated burden is 18,066 hours (5 minutes / 60 minutes = .0833 hr x 216,882 total respondents).

CCC-575 Report of Marketing History. Producers who want to establish a Direct Market or Historical Marketing Percentage for fruits and vegetables must file CCC-575 Report of Marketing History. Program year 2015 will be the first time producers will be able to file and based on a report from EPAS, the agency anticipates 1500 respondents will elect to report either their Direct Market or Historical Marketing Percentage. The average time to file CCC-575 is 5 minutes. The estimated burden is 125 hours (5 minutes / 60 minutes = .0833 hr x 1,500 total respondents).

CCC-576, Part B, Notice of Loss. Producers whose enrolled crops suffer damage or apparent losses, or are prevented from planting, and who wish to receive a NAP payment, must file CCC-576, Part B Notice of Loss. The agency estimates 30,624 respondents will suffer apparent damage or loss, or be prevented planted. With an average 3 crops per producer reported as damaged, etc., there would be approximately 91,872 total respondents (30,624 respondents x 3). The average time to file a notice of loss is 15 minutes. The estimated burden is 22,968 hours (15 minutes / 60 minutes = .25 hr x 91,872 total respondents).

CCC-576, Part G, Application for Payment. Producers whose enrolled crops suffer damage, etc. who wish to receive a NAP payment, must also file CCC-576 Application for Payment. Assuming all producers who file a notice of loss will also file an application for payment, an estimated 30,624 producers will file CCC-576 Part G. The average time is based on the requirement that a producer requesting a NAP payment is also required to submit acceptable production evidence supporting their certification of production. The average time to complete the form is 15 minutes. The estimated burden is 7,656 hours (15 minutes / 60 minutes = .25 hr x 30,624 total respondents).

CCC-576-1, Notice of Loss. Producers who file a notice of loss and indicate their intention to destroy or abandon the acreage without benefit of harvest must request an appraisal of the specific crop acreage on CCC-576-1. An estimated 13,781 respondents will be filed (0.15 x 91,872 Total Notice of Loss Respondents). It is customary for producers to accompany a loss adjustor while conducting an appraisal. Upon completion of the appraisal, the loss adjustor and producers acknowledge the results by signing CCC-576-1. When disagreements with the appraisal results occur, an additional CCC-576-1 is completed with the producer's estimate of production. CCC makes a final determination. The average time to complete the form is 60 minutes with an average of 3 appraisals per respondent. The estimated burden is 41,343 hours (1 hr x 41,3432 total respondents).

NEW - CCC-577, Transfer of NAP Coverage. When land enrolled in NAP is sold or transferred to another eligible producer, the parties may request transfer of the coverage. CCC-577, Transfer of NAP Coverage, must be completed and signed by all parties. The agency estimates 200 transfer of right to NAP payment will be filed annually. Because the transfer requires the concurrence of all parties, the estimated number of respondents is 400. The average time to complete the form is 5 minutes. The estimated burden is 33 hours (5 minutes / 60 minutes = .0833 hr x 400 total respondents).

Travel Time. The average producer's estimated average travel time to and from the local USDA Service Center is 60 minutes. Producers visit the service center an estimated 525,309 times (see below). The estimated burden for travel time is 525,309 hours (1.0000 x 525,309 total respondents). The burden hours for travel time is estimated currently in this information collection request than the last information collection request.

• 144,588 times to file CCC-471

• 133,215 times to file CCC-576 Part B and CCC-576-1

• 247,506 times to file CCC-576 Part G and CCC-452

525,309 Total Travel Time.

Retention of Acceptable Records. An estimated:

• 72,294 producers must retain acceptable records of production of the applicable crop to substantiate the certification of production. The average producer certifies an average of 3 crops. The estimated times for retention of production records is 60 minutes per crop. The estimated burden is 216,882 hours (72,294 respondents x 3 x 1.0000).

• 1,500 producers must retain documentation of salvage value of any enrolled crop and of any marketable or usable harvested production considered as secondary use. The estimated time for retention of these records is 60 minutes. The estimated burden is:

• Salvage Value equals 1,500 hours (1,500 respondents x 1.000).

• Marketable Production equals 1,500 hours (1,500 respondents x 1.000).

Summary

The total estimated burden on the public for implementation and administration of the NAP is 847,425 hours, as calculated and summarized in the table below:

Title of Form, Report, or Record	Burden Hours
Travel Time	525,309 respondents x 60 min (1.000) = 525,309 hrs.
Retention of Records Time	72,542 respondents x 3 hrs. = 216,882 hrs.
Documentation of Salvage Value Time	1,500 respondents x 60 min. (1.000) = 1,500 hrs.
Documentation of marketable Production time	1,500 respondents x 60 min (1.000) = 1,500 hrs.
Form CCC-452	72,294 respondents x 3 reports x 5 min (0.0833 hr.) = 18,066 hrs.
Form CCC-471	72,294 respondents x 2 reports x 5 min (0.0833 hr.) = 12,044 hrs.
Form CCC-575	1,500 respondents x 1 report x 5 min (0.0833 hr.) = 125 hrs.
Form CCC-576, Part B	30,624 respondents x 3 report x 15 min (0.2500) = 22,968 hrs.
Form CCC-576, Part G	30,624 respondents x 3 report x 15 min (0.2500) = 7,656 hrs.
Form CCC-576-1	41,342 respondents x 3 reports x 60 min (1.000) = 41,342 hrs.
Form CCC-577	400 respondents x 1 report x 5 min (0.0833) = 33 hrs.
Total	847,425 Hours

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

There are no capital (including start-up, operation, and maintenance) costs or purchase of service requirements resulting from the information collection. The information that must be provided to obtain program benefits is also necessary in the normal course of operating a commercial agricultural enterprise. The information collections do not require additional record keeping on the part of the applicant. There are no special requirements imposed on applicants and therefore the agency believes the amount of burden incurred in providing the acreage information is minimal.

14. Estimated annualized costs to the Federal Government

Total cost to the Government is estimated to be $29,820,890.01 (847,425 burden hours x $35.19 average wage per hour of county office employee)

15. Program changes or adjustments reported in Items 13 and 14 of the OMB 83-I

SUMMARY OF CHANGES FROM PREVIOUSLY APPROVED INFORMTION COLLECTION TO CURRENT SUBMISSION
Description	Hours
Previously approved burden hours	2,031,830
A statutory amendment of 7 U.S.C. 7333 enacted in 2009: established definitions for native sod and de minimis acreage. The change exempted areas of 5 acres or less from native sod ineligibility rules increased application fees changed payment limitation to direct attribution for 2009 and subsequent years. These changes did not increase the total burden of information collection.	0
One new form has been introduced since the last information collection package; (CCC-575). The burden hours was increased by 125 and the responses by 1,500, which are a program change in this request. Previous ICP used estimates based on 100% participation. Proposed ICP uses the 3 previous program years of actual history from NAP databases with a 10% increase of new participation. As a result, the number of respondents were decreased by 214,206, the responses decreased by 1,000,693, and the burden hours decreased by 1,184,830 since the last OMB submission, which are an adjustment in this request.	-1,184,405
Proposed burden hours	847,425

16. Plans for tabulation and publication.

There are no plans to publish the information collected. It is to be used solely to administer the program.

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.

FSA will display the expiration date on the forms upon receiving OMB approval.

18. Exceptions to the certification statement in Item 19 of OMB form 83-I.

FSA is able to certify compliance with all provisions under Item 19 of OMB Form 83-I.

19. How the information collection relates to the Customer Service Center.

Services under this program will be delivered by FSA through USDA Service Centers. Information collected in support of this program is not unique to FSA and its collections and maintenance will augment the one-stop shopping principle of the USDA customer service center.

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