Reply to Public Comment from Mily Sauceda - Alianza Nacional de Campesinas - 06-13-2024

United States Department of Agriculture
National Agricultural Statistics Service

June 10, 2024

Mily Trevino Sauceda
Executive Director
Alianza Nacional de Campesinas, Inc.
P.O. Box 20033
Oxnard, CA 93034
Dear Ms. Trevino Sauceda:
Thank you for your letter pertaining to the National Agricultural Statistics Service’ (NASS)
intention to renew the surveys in the Agricultural Labor Information Collection Request (ICR).
Your support of the Agricultural Labor Survey is appreciated. Your submitted letter included
some recommendations for the upcoming Agricultural Labor Surveys and use of the summarized
data from the survey, which will be addressed here.
The Farm Labor Methodology and Quality Measures (QM) reports that accompany each Farm
Labor report address the topics of many of your recommendations. NASS is transparent in our
methodologies for data collection and estimation of the farm labor data. The Farm Labor
Methodology and Quality Measures documents can be found at this link on NASS’ public
website:
https://www.nass.usda.gov/Publications/Methodology_and_Data_Quality/Farm_Labor/index.php
The following address your specific suggestions:
Suggestion: “…we would like to see more information gathered on the migratory nature of
workers, where they work and change location over the course of the year.” This would be
outside the scope of the current Agricultural Labor Survey, as defined in QM document. Testing
would be required to determine if the Agricultural Labor Survey would be an appropriate
mechanism to obtain the desired statistics without affecting the data necessary to publish the
Farm Labor report. This recommendation can be considered if additional budgetary resources
are available for testing and expanding the scope of the current Agricultural Labor Survey.
Suggestion: “NASS should also include data on contracted labor, workers hired and paid by
third party contractors . . . We’re aware the NASS has considered the collection of this data in
the past, and we recommend further testing survey questions that are simple and ask respondents
to report on the entire number of workers regardless of who hired or paid them”. This would be
outside the scope of the current Agricultural Labor Survey, as defined in QM document. Testing
would be required to determine if the Agricultural Labor Survey would be an appropriate
mechanism to obtain the desired statistics without affecting the data necessary to publish the
USDA is an equal opportunity provider and employer.

Farm Labor report. This recommendation can be considered if additional budgetary resources
are available for testing and expanding the scope of the current Agricultural Labor Survey.
Suggestion: “ . . . we would like to see that [dairy worker] representation is accounted for as
they also are an emerging group of workers in comparison to farmworkers working on produce
operations.” Dairy operations are included in the Agricultural Labor Survey population and
sampling as with all other types of farming operations. Reference the QM document mentioned
above.
Suggestion: “We would also like to see other attributes included, for instance, gender, race,
language/s spoken, and age.” This would be outside the scope of the current Agricultural Labor
Survey, as defined in QM document. Testing would be required to determine if the Agricultural
Labor Survey would be an appropriate mechanism to obtain the desired statistics without
affecting the data necessary to publish the Farm Labor report. This recommendation can be
considered if additional budgetary resources are available for testing and expanding the scope of
the current Agricultural Labor Survey.
Number of Mailings Discussion: Please see the QM document mentioned above for a detailed
discussion of the population definition, sampling, and how nonresponse is accounted for. Prior
to each sampling cycle, survey performance is analyzed to determine if additional sample is
needed to meet the publication goals identified in the QM document.
If the Alianza Nacional de Campesinas, Inc. would like to assist with outreach to US farmers,
feel free to contact NASS’ Public Affairs Office at [email protected].
Survey Length/Content: Agricultural Labor data reported by respondents are protected by
Federal Law from disclosure as described at this link on NASS’ public-facing webpage:
https://www.nass.usda.gov/About_NASS/Keeping_Data_Safe/index.php. Language citing the
Federal Law protecting respondent data also appears on the first page of the questionnaire.
Testing would be required to determine if the Agricultural Labor Survey would be an appropriate
mechanism to obtain information on hours worked without affecting the data necessary to
publish the Farm Labor report. This recommendation can be considered if additional budgetary
resources are available for testing and expanding the scope of the current Agricultural Labor
Survey.
The Farm Labor Methodology and Quality Measures and other documents pertaining to the
Agricultural Labor Survey along with a proposed questionnaire and other comments NASS
received will be made available later this summer for a 30-day public comment period. A
Federal Register Notice (FRN) for OMB Control Number 0535-0109 will be published when
that happens; the FRN will include instructions on how to review and comment further on the
survey before official action is taken by the Office of Management and Budget (OMB).

We will keep you informed of the progression of the Agricultural Labor Survey through Federal
Register Notices.
Sincerely,
signed by
LANCE Digitally
LANCE HONIG
Date: 2024.06.13
HONIG 10:28:20 -04'00'

Lance Honig
Chair, Agricultural Statistics Board
U.S. Department of Agriculture
National Agricultural Statistics Service