Jane Sooby, CCOF - Reply Letter

United States Department of Agriculture
National Agricultural Statistics Service

May 29, 2019
Jane Sooby, CCOF

Dear Ms. Sooby,
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: Focus on surveying certified organic farms and report certified organic data
separately from exempt or transitional data.
Reply: The 2019 Organic Survey will focus only on certified organic data. The 2017 Census of
Agriculture Organic Special Tabulation, which will be released in the fall of 2019, will
separate certified and exempt data.
Recommendation 2: Report acreage data separately for certified organic, exempt, and transitional
acres, and collect data on split organic-conventional acreage.
Reply: The 2019 Organic Survey will focus only on certified organic data. The 2017 Census of
Agriculture Organic Special Tabulation, which will be released in the fall of 2019, will
separate certified and exempt data.
Recommendation 3: Gather information on the length of time an operation has been certified
organic.
Reply: NASS will be including the following two questions.


In what year did this operation first grow or raise any agricultural products?
1400 Independence Ave., SW, Washington, DC 20250
(202) 720-2127 · (202) 720-3578 FAX · www.nass.usda.gov
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

In what year did any portion of this operation become certified organic?

Recommendation 4: Retain the “GMO Presence in Organic Crops” question.
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 5: Ask about incidence of herbicide and pesticide drift and its impact on
organic sales.
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
[ ] No
Recommendation 6: Retain the “Production Expenses” section.
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 7: Stop conflating green and animal manure application in the “Organic
Production Practices” section.

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Reply: This has been done.
Green manures (cover crops plowed under to enrich the soil)?
Cover crops not plowed into soil?

Yes - No
Yes - No

Recommendation 8: Document proportion of planted seed that is certified organic vs
conventional.
Reply: NASS wants to see if this is a significant problem before adding on a new line of
questions for percentages of organic seeds planted for each commodity, thus increasing
respondent burden. NASS will be including the following question:


Was this operation able to acquire sufficient amount of organic seed in 2019?

Yes - No

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=12001000050
032
Date: 2019.05.30 10:15:09 -04'00'

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

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