Justification Letter

USDA
SEP 24 2020

TO:

Desk Officer for the National Agricultural Statistical Service,
Office of Information and Regulatory Affairs, OM

FROM:

William Northey
Under Secretary Farm Production and onservati USDA

SUBJECT:

Emergency Clearance Request for Notice of Revision to the Agricultural
Labor Survey and Farm Labor Reports by Suspending Data Collection for
October 2020

DATE:

September 24, 2020

The USDA is requesting emergency clearance and review through 5 CFR 1320.13 to suspend
collection for the Agricultural Labor Survey (OMB Control Number: 0535-0109, expiration date
February 28, 2022) and its associated publications originally planned for November 2020.
The primary objective of the National Agricultural Statistics Service (NASS) is to prepare and
issue State and national estimates of crop and livestock production, disposition, and prices. The
Agricultural Labor Survey provides quarterly statistics on the number of agricultural workers,
hours worked, and wage rates. Number of workers and hours worked have been used to estimate
agricultural productivity; wage rates have been used in the administration of the H-2A Program
and for setting Adverse Effect Wage Rates. Survey data have also been used to carry out
provisions of the Agricultural Adjustment Act.
USDA has determined the public can access other data sources for the data collected in the
Agricultural Labor Survey. These sources include, but are not limited to, the Agricultural
Resources Management Survey (ARMS), Census of Agriculture (COA), American Community
Survey (ACS), Quarterly Census of Employment and Wages (QCEW), National Economic
Accounts, and the National Agricultural Workers Survey (NAWS), Therefore, NASS will not be
collecting data in October 2020, as originally planned. NASS will not publish the biannual Farm
Labor report this November.
NASS will comply with information collection and recordkeeping requirements by submitting
this action to OMB for emergency review. NASS believes this emergency clearance request shall
be granted since the agency will not be able to reasonably comply with the normal clearance
procedures under the PRA and the use of normal clearance procedures.
In compliance with OMB regulations (6 CFR 1320) which implemented the Paperwork
Reduction Act of 1995 (Pub. L. 104-13), NASS submitted its 30-day Notice of the Revision to
the Agricultural Labor Survey and Farm Labor Reports by Suspending Data Collection for
October 2020 to the Federal Register for publication and public comment.