Julie Obudzinski, NSAC, OFRF, NOC - Reply Letter

United States Department of Agriculture
National Agricultural Statistics Service

May 29, 2019
National Sustainable Agriculture Coalition,
Organic Farming Research Foundation, and
National Organic Coalition
Dear Juli Obudzinski,
Thank you for your recent letter concerning the renewal of the Organic 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.
The content of the Organic Survey has been developed over the years at the request of numerous
data users, including, but not limited to: Risk Management Agency, Federal Crop Insurance
Corporation, Agricultural Marketing Service, Economic Research Service, Natural Resource and
Conservation Service and many others. NASS has been conducting cognitive interviews in the
larger organic producing states looking for ways to improve the questionnaire. 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.
Recommendation 1: Expand Section 9 to include more information regarding crop insurance
availability.
Which of the following best describes the reasons why crop insurance was not purchased
for the uninsured organic acres in 2019? (Check all that apply):
• Too expensive
• Not feasible for my operation
• I don’t know enough about organic crop insurance
• I rarely experience major loss on my organic production
• Organic policies are not available for what I produce
• Crop insurance agents and adjusters are not familiar with organic production
and/or policies for organic operations
• Other (specify)
Reply: In the crop insurance section the responses have been expanded to give the operator more
choices to answer the question.
Which of the following best describes the reason why crop insurance was not purchased
for the uninsured organic acres in 2019? (Check one)
1. Organic crop insurance is too expensive
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2. I am unfamiliar with organic crop insurance
4. Crop insurance agents are unfamiliar with organic crop insurance
5. Organic crop insurance is not available for the organic commodities I produce
6. Organic price elections are not offered for the organic commodities I produce
7. I do not need/want organic crop insurance
3. Other (specify): _________________________
Recommendation 2: Retain the ‘GMO Presence in Organic Crops’ (Section 10).
In the 2014 Organic Survey, the question reads:
Have you experienced economic losses that you can document due to the unintended
presence of GMO material in an organic crop you have produced for sale? (Exclude
expenses for preventative measures and testing of your crop.
NASS should replace with the following:
Have you experienced any unintended presence of GMO material in an organic crop you
have produced for sale?
Reply: NASS will be including the following question:
Have you ever experienced economic loss due to unintended GMO or genetic
contamination of a certified organic crop you produced for sale? Check all that apply
[ ] Yes, in 2019
[ ] Yes, in 2018
[ ] Yes, prior to 2018
[ ] No
Recommendation 3: Expand Section 10 to include ‘Unintended Presence of Pesticides.’
Have you experienced any unintended presence of non-NOP approved pesticides on an
organic crop you have produced for sale?
This would be followed by requesting respondents to itemize associated economic losses
by year, crop, quantity, and unit as currently described for the question on GMO
contamination. Further, we would urge NASS to rename Section 10 to “Unintended
Presence of Substances Not Approved for Use in Organic Production”.
Reply: NASS will be including the following question:
Have you ever experienced economic loss due to unintended pesticide contamination of a
certified organic crop you produced for sale? Check all that apply.
[ ] Yes, in 2019
[ ] Yes, in 2018
[ ] Yes, prior to 2018
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[ ] No
Recommendation 4: Retain questions on ‘Production Expenses’ (Section 12)
To further refine this section NASS can rephrase the opening statement with the
following:
Report total production expenses paid by this operation in 2019 as reported on your
Schedule F and the portion (percent) of those expenses used for organic production (Do
not include personal or living expenses).
a. Organic certification expenses
b. Fertilizers, lime and soil conditioners
c. Crop protection materials for pest, disease, and weed control
d. Certified organic seed and plants
e. Non-certified seeds and plants
f. Labor hired (including contract labor)
g. Livestock purchased or leased
h. Feed purchased for livestock and poultry
i. Total Expenses (line 33, Schedule F)
Reply: NASS will be including the following question:
Report production expenses paid by this operation in 2019.
 Include expenses paid by your landlords and contractors.
 Exclude expenses not related to the farm business.
a. Organic certification expense
b. Certified organic feed purchased for livestock and poultry
c. Food safety related expense
d. Hired agricultural labor including contract labor (include wages and benefit
expenses)
e. Seed, annual seedlings, and planting stock
i.
Organic seed, annual seedlings, and planting stock purchased
ii. Non-organic seed, annual seedlings, and planting stock purchased
Recommendation 5: Disaggregate data collected on use of green and animal manure (Section 13)
In 2019, did this operation use any of the following practices for organic agricultural
production?
-

Cover crops (harvested or grazed) or green manures (incorporated into soil)
Animal manure

Reply: This has been done.
Green manures (cover crops plowed under to enrich the soil)?
Cover crops not plowed into soil?
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Yes - No
Yes - No

Recommendation 6: Transitional Acreage (Section 16)
We recommend that NASS expand Section 16 to include a question on plans for future
transition of additional acres, what crops/animal will be grown/raised on future acres
transitioned, and any barriers that exist to transitioning additional land into organic
production (i.e. limited availability of land, rising costs of farmland, lack of secure tenure
on farmland, etc.).
We would also urge Question 4 to be further broken down to ask about specific
commodities grown or raised on transitional acres (rather than generic “cropland”). We
would also urge NASS to explore ways to collect further granularity on the current use of
the land intended for transition into organic production (i.e. in current agricultural
production (conventional), not currently in agricultural production, currently in forest,
pasture, etc.). This data can help analyze trends underlying market shifts and organic
growth, as well as provide background information on the decision farmers make to
expand their business.
Reply: Some of this cropping practices information is already being collected in the Agricultural
Resource Management Surveys (0535-0218). To help minimize respondent burden, these
additional questions will not be included.
Recommendation 7: Record the year the operation was first certified organic.
Reply: This has been done.
Recommendation 8: Usage and Availability of Organic Seed
Report the portion of certified organic and non-certified organic seed planted for organic
crops you produced in 2019.
Organic Crop

Certified Organic Seed
(Percent Acreage Planted)

Non-certified Organic Seed
(Percent Acreage Planted)

Crop 1
Crop 2
Crop 3
Reply: NASS will be including the following question:
Was this operation able to acquire sufficient amount of organic seed in 2019?

Yes - No

Recommendation 9: Food Safety
In 2019, the new FDA rules for Produce Safety go into effect, including on-farm
inspections. Some farms are exempt from the Produce Safety Rule or most of the Produce
Safety Rule based on their annual sales, crops grown, crop use, and market venues.

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1. Do you anticipate having to meet additional produce safety requirements under
the new FDA food safety regulations? If yes, continue. If no, skip to Section xxx.
2. Please provide an estimate of anticipated annual costs of compliance, including
new infrastructure, materials, and labor.
3. Did you make any changes to your Organic Systems Plan in order to be in
compliance with new FDA regulations? If so, please specify any changes.
Reply: Without doing extensive testing we do not know how many respondents could answer
these questions about future safety requirements. Rather than add additional respondent
burden to the questionnaire for information we don’t know if we can summarize we opted
to omit these questions.
Recommendation 10: Estimated percentage of land left uncultivated for on-farm biodiversity
What percentage of your farmland do you leave uncultivated for the following purposes?
a. On-farm biodiversity, including habitat for pollinators, natural enemies for
pests, other beneficial organisms, and wildlife.
b. Buffer zones to protect organic fields and production areas from pesticide or
GMO pollen drift, agrochemicals and pathogens in runoff, or other sources of
NOP-prohibited substances.
Reply: Some of this cropping practices information is already being collected in the Agricultural
Resource Management Surveys (0535-0218). To help minimize respondent burden, these
additional questions will not be included.
Once a finalized draft of the questionnaire is ready it will be submitted to OMB along with the
supporting statements, 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 complete docket
materials. The materials will be available in the Office of Information and Regulatory Affairs
system https://www.reginfo.gov/public/do/PRAMain.
The Organic 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!
Digitally signed by JOSEPH PARSONS
DN: c=US, o=U.S. Government,
ou=Department of Agriculture,
cn=JOSEPH PARSONS,
0.9.2342.19200300.100.1.1=12001000
050032
Date: 2019.05.30 10:17:31 -04'00'

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

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