Jessie Bovay, Mercaris - Reply Letter

United States Department of Agriculture
National Agricultural Statistics Service

May 29, 2019
Jessie Bovay

Dear Jessie,
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: Mercaris would like to see questions related to organic land rent. We are
especially keen to learn the average land rent cost as well as rent terms as they relate to
this specialized area of agriculture.
Reply: Currently, NASS collects cash rent information under docket 0535-0002. However, there
is not a breakout for organic acres at this time, but we will look at the possibility of
adding that to next year’s questionnaire. In order to minimize respondent burden as
much as possible, we opted not to include the cast rent questions to this survey.
Recommendation 2: Mercaris would also like to see questions related to on-farm storage.
Namely—does the farm have on-farm storage and if so, what is the capacity range? This
question is applicable to every organic commodity and will help the industry to better
understand stock numbers.
Reply: Currently, NASS collects on farm grain stocks and capacity under docket 0535-0213
using our quarterly Agricultural Survey. Organic data would be included in the totals we
are currently collecting. We feel that collecting organic stock data without a time series
of data would be of minimal use. We would not know if the amounts reported would be
representative of the peak amount or a portion of their harvest. To collect sufficient

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information to qualify the data could potentially add a large amount of respondent
burden. Therefore we chose not to include these questions on this survey.
Recommendation 3: To better understand crop rotations that organic field crop producers utilize,
we would like to see this section updated to include organic acres planted with a cover
crop as a soil amendment but will not harvest it.
Reply: Currently, NASS collects cropping practices on our Agricultural Resource Management
Survey (ARMS) under docket 0535-0218. We do currently collect some of the organic
data you may be looking for. We rotate the crops that are surveyed each year, so we can
minimize respondent burden.
Recommendation 4: To better understand crop rotations that organic field crop producers utilize,
we would like to see this section updated to include organic acres that are being multi
cropped, inter-seeded, etc.
Reply: See reply above.
Recommendation 5: What percent of this operation’s total organic acres were covered by RMA
Insurance options in 2019?
Reply: After talking with an RMA representative about recommendation 5 and 6. They did not
feel respondents would be able to answer either of these questions sufficiently.
Recommendation 6: What percent of the operation’s total organic acres were covered by nonRMA Insurance options in 2019?
Reply: See reply above.
Recommendation 7: Marketing Practices for Organic Products question add elevator to
description.
Reply: NASS is focusing the marketing questions to only include the marketing practices that
align with the Local Foods Survey (0535-0259), which are; direct to consumer, and direct
to retail, institution or food hub (as in the local foods marketing survey). The remainder
of sales is assumed to be direct to wholesale channels, which would include marketing to
elevators.
Recommendation 8: Marketing Practices for Organic Products - We believe that the mileage
descriptions of locally/ regionally/ nationally/ internationally are too broad and should be
better defined. Our suggested definitions are:
- i. Locally (0-25 miles)
- ii. Sub-regionally (25-100 miles)
- iii. Regionally (100-500 miles)

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iv. Nationally (500 miles or farther but within the United States)
v. Internationally

Reply: The mileage question was removed from the current questionnaire so this will not be an
issue this time.
Recommendation 9: Marketing Practices for Organic Products - Question 5: This question
should instead appear, individually in each commodity sections, as it already is, and
should be removed from Section 14. Our reasoning for this is to better understand what
percentage of crops are production contracted in mixed operations. Certain organic
operations, for example dairy production, are commonly produced under production
contract and many of these operations are also growing grain for their operations, which
would not be under a production contract. This question, as it stands now, would not
accurately capture that nuance.
Reply: This has been done.
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 10:13:40 -04'00'

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

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