Reply Letter to National Cotton Council of America - 12-20-2019

United States Department of Agriculture
National Agricultural Statistics Service

December 20, 2019

National Cotton Council of America,
National Cotton Ginners Association,
American Cotton Producers
Dear Mr. Harrison Ashley,
Thank you and your council along with the other members of the National Cotton
Ginners Association and the American Cotton Producers for your recent letter in support
of the renewal of the Cotton Ginning Survey.
The primary functions of the National Agricultural Statistics Service (NASS) are to
prepare and issue State and national estimates of crop and livestock production,
disposition, and prices and to collect information on related environmental and
economic factors, whole farm characteristics, and operator demographics. Timely,
reliable, and detailed statistics help maintain a stable economic atmosphere and reduce
risk for production, marketing, and distribution operations. NASS is the primary data
collection Agency of the US Dept. of Agriculture.
In your letter you included two recommendations for this survey.
Recommendation 1: “We would suggest that the use of ‘asterisks’ early in the season,
or when insufficient number of gins are reporting, be eliminated. The industry is
aware of gins that are operating in these states or counties, so to not show their
ginning data is a hindrance in creating necessary industry reports. We suggest
that NASS report this data or, if necessary, develop a waiver that would allow all
data to be reported.”
Reply 1: Due to NASS Confidentiality Rules we suppress the summarized data when it
would reflect an individual operation’s data. We can look into the feasibility of
getting waivers signed by all participating operations to allow for publication.
Recommendation 2: “The ginning industry has had great success in survey
participation using electronic reporting and suggests that this be made an option
for gins.”
Reply 2: NASS has had Electronic Data Reporting (EDR) or internet reporting available
for the Cotton Ginning surveys for several years. We will work with our Survey
Administrators to promote this reporting option to our respondents.
1400 Independence Ave., SW, Washington, DC 20250
(202) 720-2127 · (202) 720-3578 FAX · www.nass.usda.gov
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The content of the Cotton Ginning Survey has been developed over the years at the
request of numerous data users such as yourselves. NASS is also looking for ways to
streamline the questionnaire to reduce respondent burden and data collection costs,
while still providing data users with the detailed data they need.
Following the initial 60 day public comment period the complete docket will be submitted
to OMB, which will contain the supporting statements, sample questionnaires, samples
of publicity materials, and other documents for the public to review for 30 days. After
that OMB will be able to begin their review of the docket materials. The materials will be
available in the Office of Information and Regulatory Affairs system
https://www.reginfo.gov/public/do/PRAMain.
The Cotton Ginning Survey is extremely important to our data users. Your comments
will be provided as a part of this submission to the Office of Management and Budget.
Please let us know if you have any questions or concerns.
Again, many thanks!

JOSEPH
PARSONS

Digitally signed by
JOSEPH PARSONS
Date: 2019.12.20
14:38:28 -05'00'

Joseph L. Parsons
Chair, Agricultural Statistics Board
U.S. Department of Agriculture
National Agricultural Statistics Service

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