Emergency Memo

1400 Independence Ave., SW
Room 2055-S STOP 0201
Washington, D.C. 20250-0201

TO:

Dominic Mancini
Deputy Director
Office of Management and Budget

THROUGH:

Levi S. Harrell
Departmental Clearance Officer
Office of the Chief Information
Officer

FROM:

Erin Morris
ERIN MORRIS
Associate Administrator
Agricultural Marketing Service

SUBJECT:

Request for Emergency Approval of New Information Collection under a
New Program for Local Food for Schools Cooperative Agreements
(LFS)

Digitally signed by ERIN
MORRIS
Date: 2022.02.24 19:34:55
-05'00'

The Agricultural Marketing Service (AMS) is requesting emergency clearance and review through 5
CFR 1320.13 for a new information collection for the Local Food for Schools Cooperative
Agreement (LFS) Program.
The agency cannot reasonably comply with the normal clearance procedures due to the public harm
that is reasonably likely to result due to the food supply chain risks and unstable food prices. The
disruptions presented by COVID-19 to-date have been historic and never experienced by most
involved. The effects of the pandemic have continued to impact every stage of the food supply chain
and have drastically impacted school’s ability to obtain food for the National School Lunch Program
(NSLP).
Early in the pandemic, instability of food prices emerged due to the lack of transportation of food
from the farmer to the food processors and end users. This instability continues today; current
disruptions in the supply chain, combined with labor shortages and other lingering impacts of the
pandemic have crippled school meal procurement efforts. School food directors continue to face
severe challenges obtaining healthy nutritious food choices for their student populations. The Local
Food for Schools program will provide immediate relief to states, by providing funding for
procurements of local food that will be distributed locally. This will reduce the state’s dependency
on the national supply chain by allowing states to form new partnerships at the local. This will
provide critical and necessary relief from current supply chain disruptions and ensure that schools
can provide their students with healthy and nutritious food.
The LFS Program will provide up to $200 million for cooperative agreements to increase purchases of
local food for distribution to schools. The program will build partnerships between local and
regional farmers and producers, socially disadvantaged farmers and producers, small businesses,
and schools. AMS will enter into cooperative agreements with state governments to procure local
foods (within the state or within 400 miles) targeting these purchases from socially disadvantaged
farmers/producers and small businesses. This will allow schools to efficiently obtain foods that
are unique to their geographic area and which meet the needs of their student populations. The
program will help build and expand economic opportunity for local and socially disadvantaged

farmers/producers and small businesses who have also been hit hard by supply chain risks and
unstable food prices. The impact on school’s ability to obtain food for the National School Lunch
Program (NSLP) due to supply chain issues is a current challenge and is expected to continue into
early next school year, which begins July 2022. To meet schools’ food needs and support local
and regional supply chains, approval is needed by mid-March to allow sufficient time for
application development, review, and approval, enabling states to complete procurements and
distribute food when the school year begins in summer 2022. A delay in the approval will result in
the timeline moving beyond summer/fall harvest periods in most states and will provide little
relief to schools early in the school year when it is needed
This information collection is a result of section 5(c) of the Commodity Credit Corporation Charter
Act (15 USC 714c(c)). USDA believes the food system of the future should be fair, competitive,
distributed, and resilient; it must support health and ensure producers receive a fair share of the
food dollar while advancing equity and contributing to national climate goals. This investment
represents a component of USDA’s new Build Back Better initiative to help achieve that vision
and start building a better food system today.
There are forms associated with this information collection notice to be approved by the Office of
Management and Budget. The collection of information through these forms submitted by state
governments will enable AMS to award Cooperative Agreements through a noncompetitive
process.
AMS will comply with information collection and recordkeeping requirements by submitting this
action to OMB for emergency review and approval while the agency continues the process to receive
OMB's approval through the normal review process. AMS 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 because the use of normal clearance procedures is reasonably likely to
prevent or disrupt the collection of information that is necessary to administer the LFS. If the
emergency clearance is not granted, it is reasonably likely that implementation of the program will be
postponed, subsequently delaying efforts to help schools deal with the challenges of supply chain
disruptions brought on by the pandemic.
In compliance with OMB regulations (6 CFR 1320), which implemented the Paperwork Reduction
Act of 1995 (Pub. L. 104-13), AMS is in the process of submitting its 60-day notice on this
information collection to the Federal Register for publication and public comment.
Attached are the OMB-83-I, the Supporting Statement, AMS-71.
Attachments