Reply to Public Comment from Rural Coalition

United States Department of Agriculture
National Agricultural Statistics Service

June 3, 2024

Rural Coalition
1029 Vermont Ave NW #601
Washington, DC 20005
Dear Sir or Madame:
Thank you for the letter of support of, and some of your findings from, previous Tenure,
Ownership and Transition of Agricultural Land (TOTAL) surveys and the 2022 Census of
Agriculture. Thank you also for your recommendations for the upcoming TOTAL survey. Your
recommendations have been provided to the survey team for consideration. A proposed
questionnaire and supporting statements will be made available later this summer for a 30-day
public comment period. A Federal Register Notice for OMB Control Number 0535-0240 will be
published when that happens followed by instructions on how to review and comment further on
the survey before the Office of Management and Budget (OMB) takes official action on
approving the survey.
Your submitted letter included some recommendations for the upcoming TOTAL survey. NASS
conducted two qualitative research projects over the past year to investigate legal entities for
agricultural landowners with the following goals in developing the 2024 TOTAL questionnaire,
which helped us:
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learn about data needs from some members of our data user community;
understand the respondents’ comprehension of questions and terminology;
understand barriers to the retrieval of information requested on the questionnaire,
including any record keeping practices;
observe the respondents’ judgement and communication of the information requested,
and how to align with response to the question/questionnaire’s intent, and;
glean ways to reduce respondent burden while maximizing overall response strategies.

To address some of your recommendations:
Page 1 of your letter mentions, “In the upcoming TOTAL survey we urge NASS to include the
study required under Sec. 12607 of the 2018 Farm Bill that covers land tenure, land transitions,
barriers to entry for socially disadvantaged (SDA) and beginning farmers, and farm profitability
and viability. The 2024 TOTAL survey coupled with the Access to Farmland report can provide
valuable data on the degree to which land is held in absentee ownership, or in undivided interests
with no administrative authority (heirs property).” One finding from our qualitative researchers
was that absentee landowners with no involvement with the agricultural operation are unlikely to
USDA is an equal opportunity provider and employer.

respond to a survey like the TOTAL, given that the survey will be sent to names and addresses
associated with the land. Under these constraints, it is difficult to identify absentee landlords to
serve as survey respondents, which would be the only path to obtain the desired information
about absentee landlords.
Page 5 of your letter mentions, “The next TOTAL survey data will be improved with a wider
range of definitions and categories included to better understand the various types of corporate or
real estate trust farmland ownership. We recommend this data break be collected and analyzed in
a way that makes clear the diversified kinds of land holdings of all non-farm operator entities.”
One finding from the cognitive test was that distinguishing between legal entities and “private”
owners is not straightforward, which affects respondents’ understanding of their reporting unit.
Work was done to improve the legal entity lines of questioning to help the respondent clearly
understand what land is being referred to for the legal entity during the remainder of the
interview.
Page 7 of your letter mentions, “Many people and genders make up corporations and trusts, these
entities cannot be assigned to a group of individuals, these types of ownership arrangements are
necessarily excluded from the demographic data calculations. Revisions to the data collection
process for corporations, trusts, hedge fund firms, and investment firms is necessary to ensure
they are counted separately and with no exclusions.” As mentioned earlier, work was done to
improve the legal entity lines of questioning to help the respondent clearly understand what land
is being referred to for the legal entity during the remainder of the interview. Demographics are
planned to be collected from the senior partner of the legal entity, which was not part of the
previous TOTAL Survey.
Page 8 of your letter mentions, “We strongly recommend the use of a comprehensive data
collection process for all corporate-owned farmland to help policy makers understand the various
types of land ownership be they a trust, an investment group, hedge fund firm, or individual or
entity landlords. Landlords whether individual or entity.” NASS utilizes multiple data collection
methods for its surveys. The first method will likely be by mail (with a Computer-Aided SelfAdministered Interview option). Operators who do not respond by a certain time will be
attempted by either a phone or field enumerator for an interview. The phone enumerators will
use a Computer Assisted Telephone Interview (CATI) system. The field enumerators are
equipped with Apple iPads and will conduct a Computer Assisted Personal Interview (CAPI).
This is done to maximize the number of complete reports possible with the goal of publishing as
many summarized statistics as possible while protecting respondent confidentiality.
As mentioned earlier, work was done to improve the legal entity lines of questioning to help the
respondent clearly understand what land is being referred to for the legal entity during the
remainder of the interview, which we believe will result in better and richer data being collected.
Page 9 of your letter mentions, “We further urge USDA to request full funding for the TOTAL
Survey and of the authorized funds to conduct the Section 12607 Land Tenure Study. We further
recommend that NASS collect data that will allow better understanding of the types of entities
that are investing in land whether by farmland ownership by corporate, trust, partnership, hedge
fund, and or other investment and that also examine the degree to which land that is held in
undivided interests moves to absentee ownership. We further urge NASS to continue to employ
the analysis begun in the 2022 study that analyzed variations including by race, ethnicity and
gender.” The TOTAL survey is conducted when funding is available. Realize that a survey of
land tenure arrangements comes at a significant cost and requires a tremendous amount of human
capital.

We will keep you informed of any other modifications through Federal Register Notices.
Sincerely,

LANCE
HONIG

Digitally signed by
LANCE HONIG
Date: 2024.06.06
13:12:21 -04'00'

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