NAP Supporting Statement 2016

UNITED STATES DEPARTMENT OF AGRICULTURE

Farm Service Agency

(Commodity Credit Corporation)

OMB Number 0560-0175

7 CFR 1437, Noninsured Crop Disaster Assistance Program and Report of Acreage (formerly OMB Number 0560-0004)

Purpose:

The purpose of this request for OMB review is to obtain approval on an extension of a currently approved collection with a revision. The name of this request is changed to Noninsured Crop Disaster Assistance Program and Report of Acreage.

Change: The approved information collection requirements contained in OMB control Number 0560-0004 in the 7 CFR 1404.9, Report of Acreage for the Noninsured Crop Disaster Assistance Program, have been merged with approved OMB control number 0560-0175, 7 CFR 1437, Noninsured Crop Disaster Assistance Program. FSA is also revising the estimates currently approved under OMB control number 0560-0004 to the numbers to reflect current respondents, responses and burden hours.

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(b), (c), and (h)) is not available

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

7 CFR 1437 covers the general provisions, determining yield coverage using actual production history, prevented planted acreage, forage intended for animal consumption, and in the tropical region for NAP.

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), industrial crops, and sea grass sea oats, biomass, sweet sorghum and biomass sorghum.

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 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 by the subsequent year’s latest acreage reporting deadline for the Administrative County

• 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. 7 CFR 1437 covers the general provisions, determining yield coverage using Actual Production History, prevented planted acreage, forage intended for animal consumption, and in the tropical region on NAPs.

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 the 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 and eligible crops 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 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 limited resource producer by responding to a single question of whether the applicant meets the definition of a targeted underserved according to 7 CFR Part 1437. 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, buy-up options, organic option, and direct market

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

C. CCC-575, Record of Marketing History

Form CCC-575, Record of Marketing History is used to document certification of direct marketing and/or Historical Marketing History. Producers must initiate the request and provide production and final uses for fresh, processed and/or juiced commodities.

D. FSA-578, Report of Acreage

Form FSA-578 is used to collect identification of the crop (including type and variety), practices, organic certification, intended uses, planting patterns, and predominant species of forage vegetation (including intended method of harvest, that is mechanically harvested or grazed); dates crops were planted or planting was completed (including age of perennial crops); number of acres of each planting of the eligible crop in which the producer has a share in the administrative county; number of acres intended but prevented from being planted; share interest; FSA farm serial number or location of commodities not associated with a farm serial number such as colonies of bees for honey production (including the number of bee colonies belonging to the unit); aquaculture production (including the name, type, or variety of each aquaculture species in a physical location of acreage on which the facility resides such as ponds and waterbeds); ornamental nursery (including the size and origin, that is container or field grown, of plants belonging to the unit); mushroom facilities; turfgrass sod (including the average number of square yards per acre and all unharvested acres); and trees for maple sap production (including number of eligible trees, average size and age of producing trees, and total number of taps placed or anticipated for the tapping season).

E. 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.

F. 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.

G. CCC-577, Transfer of NAP Coverage

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 payment instructions.

F. Recordkeeping requirement and require to provide documentations (7 CFR 1437.8).

The producer follows the retention of records of production of the applicable crop to substantiate the certifications as required in the 7 CFR 1437.8. Also, the producer requires to provide documentations of any salvage value received or available for the quantity of the commodity that cannot be marketed or sold in any market; and of any marketable or usable harvested production bearing little resemblance to the intended commodity, or commonly identified with a different unit of measure or value when the intended use (Secondary Use).

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, CCC-471, CCC-576, CCC-576-1 (for County use only), CCC-578 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.

FSA 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. FSA will continue the pursuit of partnerships with USDA entities and State governments to standardize the information collection and management processes.

FSA is partnering with RMA to implement the Acreage Crop Reporting Streamlining Initiative (ACRSI) that is still ongoing and expanding to other crops. This initiative is a major process improvement initiative that simplifies and standardizes data reporting requirements such as production, planted and harvested acreage, and other key program participation information. This joint effort between producers, FSA County Offices, and RMA Approved Insurance Providers (AIP) will eliminate redundant reporting requirements between the agencies and streamline service.

USDA will add crops to the data sharing list in the future; however, the current 13 crops cover 93% of the acreage annually reported nationwide.

Producers may file their 2016 common crop acreage for the following eligible crops, one time, and share the data to support reporting requirements for both agencies.

Alfalfa	Corn	Cotton
CRP	Peanuts	Oats
Rye	Wheat	Soybeans
Fallow	Sorghum	Grass
Rice

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 and 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.  However for the form of FSA-578, the producer is required to certify the report on or before the earlier of the reporting date, or 15 days before the beginning of harvest which is a fewer than 30 days.

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 FSA's intent to request an extension, with a revision of an approved information collection was published in the Federal Register (Volume 79 FR, No. 199) on January 21, 2016. The 60-day comment period ended on March 21, 2016. FSA did not receive any comments from the public.

FSA contacted three persons with no comments:

Seven Dot Cattle Co. LLC

HC 66 Box 10

Golconda, NV 89414

Sue Christison: 775-529-0512

Fred Jay Jackson

1469 Jays Trail

Grand Ridge, FL 32442-3832; 850-573-1921

Kula County Farms LLC

375 Koheo Road

Kula, HI 96790-7906; 808-878-8381

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:

FSA 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.

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 and ad hoc and permanent disaster programs 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 and crops, 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).

All producers completing a CCC-471 must also annually certify FSA-578, Report of Acreage for crops enrolled. The Agency estimates 108,441 FSA-578’s will be filed annually (72,294 respondents x 1.5 reports). The estimate is based on an average of 1.5 reports filed per producer. The average time to complete FSA-578 is 30 minutes. The estimated burden is 54,221 hours (30 minutes / 60 minutes = .5000 hr x 108,441 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, and 1 Notice of Loss will be filed per producer The average time to file a notice of loss is 15 minutes. The estimated burden is 7,656 hours (15 minutes / 60 minutes = .25 hr x 30,624 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, Appraisal/Production Report. 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 41,343 responses will be filed (13,781 respondents x 3). 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 (1hr x 41,343 total respondents).

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).

FSA-578, Report of Acreage: Form FSA-578 is used to collect identification of the crop (including type and variety), practices, organic certification, intended uses, planting patterns, and predominant species of forage vegetation (including intended method of harvest, that is mechanically harvested or grazed); dates crops were planted or planting was completed (including age of perennial crops); number of acres of each planting of the eligible crop in which the producer has a share in the administrative county; number of acres intended but prevented from being planted; share interest; FSA farm serial number or location of commodities not associated with a farm serial number such as colonies of bees for honey production (including the number of bee colonies belonging to the unit); aquaculture production (including the name, type, or variety of each aquaculture species in a physical location of acreage on which the facility resides such as ponds and waterbeds); ornamental nursery (including the size and origin, that is container or field grown, of plants belonging to the unit); mushroom facilities; turfgrass sod (including the average number of square yards per acre and all unharvested acres); and trees for maple sap production (including number of eligible trees, average size and age of producing trees, and total number of taps placed or anticipated for the tapping season). The estimated number of respondents is 72,294. The average time to complete the form is 30 minutes. The estimated burden for the form is 54,221 hours (0.5 (30 minutes x x 108,441 responses (1.5 responses x 72,294.

Retention of Acceptable Records and Documentation. 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 and provide 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 1,500 hours (1,500 respondents x 1.000).

Travel Time. The average producer's estimated average travel time to and from the local USDA Service Center is 60 minutes. Producers will visit the service center an estimated 572,502 times (see below). The estimated burden for travel time is 572,502 hours (1.0000 x 572,502 total respondents).

• 144,588 times to file CCC-471

• 71,966 times to file CCC-576 Part B and CCC-576-1

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

• 108,441 times to file FSA-578

572,502 Total Travel Time.

Summary

The total estimated burden on the public for implementation and administration of the NAP is 933, 528 hours, as calculated and summarized in the table below:

Title of Form, Report, or Record	Burden Hours
Travel Time	572,502 respondents x 60 min (1.000) = 572,502 hrs.
Retention of Records Time	72,294 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	216,882 respondents x 3 reports x 5 min (0.0833 hr.) = 18,066 hrs.
Form CCC-471	144,588 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 1 report x 15 min (0.2500) = 7,656 hrs.
Form CCC-576, Part G	30,624 respondents x 1 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.
Form FSA-578	108,441 respondents x 30 minutes (.5000) = 54,221 hrs.
Total	933,528 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 $32,850,850.32 (933,528 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	847,425
A statutory amendment of 7 U.S.C. 7333 enacted in 2009, and the changes did not increase the total burden of information collection.	0
Approved form FSA-578 has been incorporated in this request since the last information collection package approval. FSA is revising the estimates currently approved under OMB control number 0560-0004 to the numbers to reflect current respondents, responses and burden hours. The burden hours increase by 86.103 while the number of responses increase by 7,193. The number of respondents decrease by 219,206 (291,500 (0560-0004)-72,294 (0560-0175. The number of respondents, 291,500, under 0560-0004 was the number of producers reporting acreage nationwide for all FSA programs; therefore, the number of respondents, 72,294, in this request are only NAP participants reporting acreage for NAP eligibility. Previous ICP used the 3 previous program years of actual history from NAP databases with a 10% increase of new participation, which remains unchanged.	+86,103
Proposed Burden hours	933,528

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. Inappropriate display of the OMB approval expiration date.

FSA will display the new expiration date on the forms.

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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