Reply to Public Comment from Jaime Clover Adams - Michigan Asparagus - 06-13-2024

United States Department of Agriculture
National Agricultural Statistics Service

June 10, 2024

Jamie Clover Adams
Executive Director
Michigan Asparagus
12800 Escanaba Drive, Suite A
DeWitt, Michigan 48820
Dear Mr. Adams:
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.
NASS is transparent in our methodologies for data collection and estimation of the farm labor
data. The Farm Labor Methodology and Quality Measures documents response rates along with
information how the surveys are conducted. The Quality Measures document can be found at
this link on NASS’ public website:
https://www.nass.usda.gov/Publications/Methodology_and_Data_Quality/Farm_Labor/index.php
At the conclusion of each survey cycle, NASS evaluates its performance to identify potential
improvements. The evaluation includes agency experts on agricultural labor and survey
methodology with cognitive testing of potential significant changes. This testing includes
estimating the average length of time respondents require to complete the survey. The current
average length of time needed to complete the survey (i.e., 30 minutes) is a result of this times.
However, we will inform the Agricultural Labor Survey team that this amount of time may need
to be revisited.
Hopefully, this will answer your questions about how data are collected for the Agricultural
Labor Survey.
The Farm Labor Methodology and Quality Measures document mentions that “The NASS
Agricultural (Farm) Labor Survey provides the basis for employment and wage estimates for all
workers directly hired by United States farms and ranches (excluding Alaska), for each of four
quarterly reference weeks. Selected annual average estimates are summarized from the
associated quarterly estimates.” If the H2A workers are directly hired by the operation, data for
those workers would be included in the survey. To keep survey results comparable with
previous Farm Labor bulletins, the definition should be the same.
USDA is an equal opportunity provider and employer.

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 10:25:13 -04'00'

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