2017 WHIP Supporting Document 2018

Supporting Statement

2017 Wildfires and Hurricanes Indemnity Program (2017 WHIP) and Citrus Trees Block Grant to Florida (FL)

OMB control number-0560-NEW

The Farm Service Agency (FSA) is requesting EMERGENCY CLEARANCE by 07/6/2018 because USDA Secretary directed the FSA to provide disaster assistance through the 2017 WHIP and Citrus Trees Block Grant to FL to eligible producers who are suffering crop, tree, bush, and vine losses related to hurricanes and wildfires occurring in calendar year 2017 and of the July 16, 2018, initial sign-up date to begin accepting applications and distributing payments. The 2017 WHIP sign-up period is from July 16, 2018 to November 16, 2018. All 2017 WHIP payments are expected to be completed by December 31, 2019 due to the funds no longer being available. The three years approval for the collection will be also requested.

1. Circumstances that make the collection of information necessary.

The Bipartisan Budget Act of 2018 (BBA, Pub. L 115-123) authorized $2.36 billion in assistance for losses to crops, trees, bushes, and vine losses due to 2017 wildfires and hurricanes. FSA is implementing the provisions of the BBA by providing up to $2 billion in assistance to eligible producers through the 2017 WHIP, and approximately $340 million through Citrus Trees Block Grant to FL to address losses to citrus trees and production, specifically for Hurricane Irma losses to citrus trees during the 2018 through the 2020 crop year, reimbursement for the cost of buying and planting replacement trees, including resetting and grove rehabilitation. The BBA requires all participants who receive 2017 WHIP payments to purchase crop insurance or NAP coverage for the next 2 available years, regardless of whether they had crop insurance or NAP coverage for 2017.

FSA will make an initial payment of up to 50 percent of the participant’s calculated 2017 WHIP payment. By issuing initial payments, FSA can quickly provide disaster assistance to those who suffered losses while ensuring that 2017 WHIP payments do not exceed the available funding and those funds are distributed equitably amount the eligible producers. If funds remain available after the initial payment, FSA will disburse the remainder of the calculated payment amount.

2. How, by whom, and for what purpose is information used.

FSA and FL will use the collected information to determine eligibility and distribute payments to eligible producers.

The producers will request for assistance at FSA County offices. The form FSA-890, 2017 Wildfires and Hurricanes Indemnity Program (WHIP) Application will be processed by a system. The system will allow all data fields to be manually entered or will pull data from other systems to automatically populate. The system will print out the completed 2017 WHIP application that the applicant will sign at the County office. The producers will be also required to complete forms FSA-891, Crop Insurance and/or NAP Coverage Agreement; FSA-892, Request for an Exception to the 2017 WHIP Payment Limitation of $125,000, if applicable; FSA-893, 2018 Citrus Actual Production History and Approved Yield Record, (Florida only), if applicable; CCC-902, Farm Operating Plan for Individual or Legal Entity; AD-1026, Highly Erodible Land Conservation (HELC) and Wetland Conservation Certification; and FSA-578, Report of Acreage, on file to receive payments. The forms of CCC-902, AD-1026, and FSA-578 (except for NAP) are exempted from PRA as specified in the 2014 Farm Bill and not included the burden hours in the request.

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 decisions for adopting this means of collection. Also describe any consideration of information technology to reduce burden.

The 2017 WHIP application (FSA-890) will be processed at FSA county office and entered in an automated system. The system will allow all data fields to be manually entered or will pull data from other systems to automatically populate. The system will print out the completed 2017 WHIP application that the applicant will sign. All the forms will be also available in the USDA eForms website.

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

The information collection request is new; therefore, no similar forms exist.

5. Methods to minimize burden on small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods to minimize burden.

The information collected does not adversely impact small businesses or other small entities. FSA estimates 28,920 small entities or businesses.

6. Describe the consequences to Federal program or policy activities if the collection is not conducted or conducted less frequently, as well as any technical or legal obstacles to reducing burden.

Failure to solicit applications will result in failure to provide payments to eligible producers as intended by the BBA. This is a one-time collection of information. Because of the short time period to receive applications and distribute payments and the need for county offices to complete portions of the application form, applications must be taken at county offices and entered in automated system.

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 that quarterly;

None.

• Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

None.

• Requiring respondents to submit more than an original and two copies of any document;

None.

• Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

None.

• 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;

None.

• Requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

None.

• 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; or

None.

• Requiring respondents to submit proprietary trade secret, 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.

None.

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

The final rule for 2017 WHIP will be published in the Federal Register, and the final rule will include the 60-day comment period required by the PRA. The consultation will be conducted and included in the 3-year approval request.

9. Explain any decision to provide any payment or gift to respondents.

There is no payment or gift given to respondents.

10. Describe any assurance of confidentiality provided to the respondents and the basis for the assurance in statute, regulation, or Agency policy.

All information collected is treated as confidential. FSA follows the policy to prohibit the giving out of individual information. This information is handled according to the Privacy Act and Freedom of Information Act.

11. Provide additional justification for any question of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.

No questions of a sensitive or personal nature are included in the application.

12. Provide estimates of the hour burden of the collection of information.

FSA estimates about 40,831 producers may apply for 2017 WHIP payments including Citrus Trees Grant Block to FL.

Completing the 2017 WHIP application (form FSA-890-automated) is estimated to take an average of 30 minutes (0.50), and the annual burden for completing that application is 20,416. hours (40,831 responses x 0.50 hours).  Also, for the form FSA-890 (continuation), the annual burden is 3,062 hours (12,250 X 0.25).  For the form FSA-891, the annual burden is 3,402 hours (40,831 X 0.083).  For the form FSA-892, the annual burden is 1,361 hours (16,332 x 0.083). For the form FSA-893 (Florida only), the annual burden is 275 hours (3,293 x 0.083). The annual burden for this information collection package is 28,516 hours. This was calculated by adding the annual burden hours determined for the 2017 WHIP application, other required forms and recordkeeping.

Respondent cost per hour was derived by using U.S. Bureau of Labor Statistics Occupational Employment and Wages, May 2017, 11-9013 Farmers, Ranchers, and Other Agricultural Managers. The U.S. mean household income, as measured by the Bureau of Labor, is $38.62 hourly. The estimated cost is $1,101,268.61 ($38.62 x 28,516 hours).

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

There are no capital, startup, or ongoing operation or maintenance costs associated with this information collection to respondents or recordkeepers.

14. Provide estimates of annualized cost to the Federal Government.

The cost of form development, printing and distribution is minimal because the form is computer generated. County employee cost per response is equal to 0.5 hours for completion of the application form multiplied by $ 19.47(estimated county employee average hourly wage; based 2018 General Schedule, Grade 7, Step 5). The total annualized cost to the Federal Government is $397,489.79 ($19.47 x 0.5 hours x 40,831 responses).

15. Explain the reason for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.

This is a new information request; the 28,516 annual burden hours will be reported as program changes in the request.

16. For collection of information whose results will be published, outline plans for the tabulation and publication.

There are no plans to publish the results of 2017 WHIP or the Citrus Trees Grant Block to FL.

17. If seeking approval to not display the expiration date for the OMB approval of information collection, explain the reasons that display would be inappropriate.

FSA will display the OMB expiration date upon OMB approval.

18. Explain each exception statement to the certification statement identified in Item 19 on OMB Form 83-I.

FSA is able to certify compliance with all provisions under Item 19 of OMB Form 83-1.