Friday, August 31, 2018

No Instructions or Form for MFP

At least, I can't find any at the appropriate places on the fsa.usda website or on the website.  That site provides links to the other forms which are required or may be used.

Thursday, August 30, 2018

Any Double-Dipping on MFP

Still no FSA notice on the MFP, but there is a notice on the Dairy Margin Protection Program.  I have not kept up with program, but from the following Background paragraphs my guess is it's a revenue insurance type program, but run by FSA and not RMA.
"MPP-Dairy payments are triggered when the difference between the National all milk price and the National average feed cost (the margin) falls below the producer-selected margin trigger, ranging from $4 to $8, calculated monthly. USDA prices for milk and feed components required to determine the National average margin for July were released on August 29, 2018. The actual National average margin for July is $6.71815/cwt. As a result, dairy operations that elected margin coverage of $7.00, $7.50 and $8 will be issued a payment.
Payments for margins triggered will be issued directly to producers. MPP-Dairy payments issued will not be offset by premium balances due. The full balance of the premium is due September 28, 2018."
It raises the question to me, which I may have mentioned before, of whether there will be double-dipping under the MFP.  In other words, crop insurance has products, on which I'm not expert, which can cover loss of revenue from a base, a loss which might be caused by production losses and/or market price dips.  Producers have to sign up for such products and pay premiums.  MFP is essentially a free one-shot policy covering market price dips. So producers who signed up for the DMPP or a revenue crop insurance policy will receive two payments for the same loss.  That doesn't seem right, but from a program administration standpoint it immensely simplifies the operation.

Wednesday, August 29, 2018

MFP Form Is Missing?

USDA now has some material on the MFP other than the press release up its website,

They give the name of the application form, CCC-910, but it's not available in the FSA Forms database.  Nor is there any notice on MFP listed in FSA notices.  I assume any training for administering the program would also show up in a notice there.

Tuesday, August 28, 2018

MFP Notice of Funds Availability

As usual, I'm fast and sloppy.  OFR has the NOFA for MFP here.

OMB gave FSA a 6-month emergency approval for the paperwork.  (Why didn't they do that for ASCS back in the day when I was handling them.)

The NOFA does have the Catalog of Federal Domestic Assistance number for MFP--10.123.

I have to carp at this paragraph: "If supporting documentation is required for the amount of actual production and for ownership share, it needs to be verifiable records that substantiate the reported amounts. The participant’s production for the commodity is based on verifiable or reliable production records. Examples of reliable production records include evidence provided by the participant that is used to substantiate the amount of production reported when verifiable records are not available, including copies of receipts, ledgers of income, income statements of [? shouldn't it be "or,"]deposit slips, register tapes, invoices for custom harvesting, and records to verify production costs, contemporaneous measurements, truck scale tickets, or contemporaneous diaries that are determined acceptable by the county committee."

The first sentence and second sentences seem to be at odds--my guess is the intention is clarified by the definitions of "verifiable" and "reliable" (but not verifiable) evidence in the next paragraphs, but that isn't what the first sentence says.

Where Are the Regulations and the Forms?

USDA has officially announced Sept. 4 as the beginning date to sign up for the Market Facilitation Program. That's the press release.

What I, as an old FSA bureaucrat, am wondering is:

  1. when will FSA issue a directive, presumably a notice, on the MFP?
  2. when will the regulations (presumably an interim final reg) be published by the Office of the Federal Register.  Note: I typed the previous sentence, then did a search on the OFR site.  The regulation was filed with OFR this morning.  It has this notation:  "This document is scheduled to be published in the Federal Register on 08/30/2018 and available online at, and on"
  3. when will the signup form(s) be available?  They have to be cleared by OMB. 
Some comments on the regulations, written as I scan it.
  • USDA OGC and OMB have come up with a dodge which is new to me--a "Notice of Funds Availability".  I've not seen such a document before, but Googling shows it's been used by other departments.  My guess is the lawyers approved (lawyers can approve anything if the pressure is on) this as a measure to work around existing rules in the Administrative Procedure Act and Trump's EEO--I'd bet a fair amount that NOFA's aren't considered "regulations" for those purposes.  Note: There's some logic to the step--the "regulations" which get conservatives upset usually shape behavior: OSHA and EPA type regs.  The regulations for farm program payments used to be considered "regulations", but no body was forced to take the payments--the regulations were really the conditions for receiving the payment.  
  • I'm waiting with bated breath to see whether the applications for payment get OMB clearance.  Seems to me they have to, but the MFP regs say the form will be specified in the NOFA.
  • Turns out OMB has a category of "transfer rules" which are not covered by the two for one Trump rule (doing away with two old regulations for each new regulation).  That dates back to April 2017.
  • I see one glitch here: "The title and number of the Federal Domestic Assistance Program found in the Catalog of Federal Domestic Assistance to which this rule applies is TBD – Market Facilitation Program and number".  The number wasn't assigned.
  • I think it's fair to assume that eligibility and payments are on a farm basis, rather than an operator.  
I never was an expert on the price support side of FSA; they are the people who dealt with production evidence.  With that said, where could a dishonest producer game the program?  The incentive for fraud would be to exaggerate one's production, by duplicating evidence to multiple county offices, forging evidence, or having different producers claiming ownership of the same production.  FSA has long experience with production evidence, so existing validation checks and spotchecks will likely work. However, as a cynic, I'm sure a few farmers will try to get more than they should.

Monday, August 27, 2018

Market Facilitation Program--Signup Sept. 4

Here's the USDA press release on the programs to offset the impacts of Trump's trade war on farmers.

Some things strike me, though my information is 20 years out of date.

The MFP (administered by FSA) covers pork and milk, as well as the commodities: cotton, corn, wheat, soybeans, and sorghum (not sure if ELS cotton is covered); oats, rice, and barley are not.  While FSA is used to collecting production data for the commodities, it has less experience with pork and milk.

Applications for  the "first payment period" starts Sept. 4 (actually presumably the later of Sept 4 and the completion of harvest for the commodities), but it's not clear to me what the payment period means--presumably the 2018 harvest for the commodities, while pork and milk are based on snapshot data as of August 1 and June 1, respectively.

Payment's on 50 percent of actual production, with the second payment period beginning Dec. 2018 to cover the remaining 50 percent.  Presumably that will be announced if there's no end to the war or farm prices don't bounce back.

[Addition: not clear whether application is on a farm basis, or the entire farming operation.  Possibly could be either, but the entire operation would limit the possibility of moving production evidence from one farm to another.]

Sunday, August 26, 2018

Honor the Silent Generation

Ross Douthat had a nice tweet on Sen. McCain, but he led off by calling him a member of the Boomer generation.  He was quickly corrected, by many, including me.

We Silents get no respect--we're stuck between the so-called "Greatest Generation" and the big Boomers.  We got no president--all our candidates lost (Mondale, Dukakis, McCain), and we lost or drew our wars: Korea and Vietnam.  But for all that, we survived and so did the country.

Saturday, August 25, 2018

Ceremonies Where America Comes Together

One of the few times when America comes together, other than the Super Bowl, is funerals, specifically funerals of ex-Presidents and a select few other public figures (MLK, RFK).  We can foresee three such ceremonies in the relatively near future.  The first will be Sen. McCain who, though not a figure comparable to MLK, has a life story which attracts sympathy from different elements of America.  The second and third are less, clear, but neither Jimmy Carter nor George H.W. Bush can be expected to live many more years.

IIRC correctly President Clinton's remarks at Nixon's funeral was praised.  That's just an example of the close scrutiny we give to the pageantry and words at such funerals.

Monday, August 20, 2018

Puzzles of Human Society I Don't Understand

Two things about human society I don't understand:

  1. Sometimes things change fast.  I'm thinking of things like the change in the US in attitudes towards homosexuals, particularly gay marriage.  Or the changes in Ireland in social attitudes generally.  Or the changes in Chinese society over the last 40 years or so.
  2. Sometimes things change slow.  I'm thinking of things like Gregory Clarks research on the long lasting effects of social position in British society.  Or things like the research on the effects of the slave trade on African countries which were or weren't affected by the trade.  Or things like the beer/wine divide in Europe.  Or the effects of Roman roads on subsequent development.
If I weren't lazy at the moment I could provide links, but as I am you'll just have to trust me.  

I suppose there's some logic to the differences, but I've not seen it addressed anywhere.

Sunday, August 19, 2018

USDA and Amazon Search for Locations

USDA has issued their request for proposals from cities for facilities  for ERS and NIFA.  (For those like me who might be confused by some of the publicity around the proposal: no, NIFA is not ARS (the Agricultural Research Service based in Beltsville), they're something else.

The request is for 70,000 sq ft for ERS and 90,000 sq. ft. for NIFA, total of 620 employees, deadline for "expressions of interest" is Sep. 14.

Now I hope that Amazon makes up their mind about their second headquarters by late September so the losing cities will have a chance at ERS/NIFA.  Actually, my guess would be Ft. Collins and Ames, IA might be choices.

620 mostly professional employees might be close to $100 million.

Saturday, August 18, 2018

The Ants Say: Pareto Was Wrong

I've always believed the Pareto 80/20 rule had broad applicability.  But now scientists report it's even broader than I knew, but Pareto had the numbers wrong--it's really 70/30.  It turns out 70 percent of ants let the others do the digging of tunnels, which is important because otherwise you violate the "too many cooks in the kitchen" rule--the extra workers just run into each other.

Monday, August 13, 2018

Sometimes I'm Stupid

Although I'm not sure whether it's plain stupidity, impatience, or stress.

As I posted yesterday, I bought a new PC on Saturday, since the old one was giving the blue screen of death.  What I missed, what was stupid, was the fact that the good people at Microsoft had a QR code (like a 2d bar code) associated with the blue screen and error message.  Finally woke up to the fact today.  I had, fortunately, taken a picture of the screen and QR code on Friday, so I did a google search for the image--found it and an explanation of the error code.

Now I'm not sure when I follow up on the error code I'll find a cause which shows I was too hasty in buying the new PC.  But it does make me feel stupid.

Sunday, August 12, 2018

New Computer

Bought a new PC yesterday, as my old desktop was displaying multiple blue screens of death.  The process of setting it up and moving from the old one is familiar, yet a bit different.  In the old days you'd be told about moving files from old to new, because everyone upgraded their PC to the newest and greatest version.  No such instructions these days, perhaps because they know the likely reason for a new purchase is the old PC is dead?  Or perhaps they figure the newbies are not buying desktops, but tablets or laptops or whatever, and the old timers who are stuck in a rut with desktops can figure out what to do.

Friday, August 10, 2018

USDA Reorganization--ERS

Government Executive has a good piece on the USDA announcement of a reorganization of the economics people, including a move of ERS outside of the DC area.  I've no expertise in this area, but when has that kept me from commenting?

My first reaction to the move was negative, but then I read the rationale in the piece: the difficulty of getting professionals to move to the high-cost DC area.  That makes sense to me.  I remember the problems we had back in the 80's and 90's in getting people to move--one reason why we ended up hiring program technicians from county offices under SCOAP.  Single women had less difficulty moving than did married men with families, the usual targets for hiring as program people in DC.

My third reaction is triggered by the discussion in the piece.  Distance in bureaucracy is critical.  The problem in attracting professionals to DC is not limited to ERS or USDA.  Apparently the locality pay differential doesn't work at these levels, and also USDA hasn't gotten the authority to offer bigger money for such positions (like doctors in HHS/NIH or attorneys elsewhere get).

Bureaucrat Gets a Bust

Not many bureaucrats get immortalized in bronze, but Pearlie Reed did. The piece has a reference to his founding the National Association of Professional Black NRCS Employees.  When you search that website it seems that Louis E. Wright may also have been a founder, or maybe "the" founder.

Wednesday, August 08, 2018

Comparative Advantage in People

The economists have an ancient law which they call "comparative advantage".  Essentially it says a country should do whatever it does best at, even if its best is poor, poorer than other countries.  If countries follow the rule, they'll end up trading goods at the lowest possible price.  For example, American workers are good at assembling stuff, but they're also good at creating Disney films.  Chinese workers are pretty fair at assembling stuff, but they aren't not good at creating Disney films.  So the answer is obvious.

The NYTimes has an op-ed today which (mis)applies, without saying so, the theory to people.  Barbara Oakey notes that academically girls are good at reading and writing, better than boys.  But tests show that girls and boys have roughly equal aptitudes for math.  She argues that girls, finding that they do better than boys at reading/writing will think they're less good at math and so choose to focus on reading/writing and slight their math.  Her answer is to resist this, and to push girls to study math more.

Now Prof. Oakey is more focused on choices before college, not the ultimate choice of occupation. But drawing on the comparative advantage idea, she may be pushing a rock up the hill.  She ignores the psychology on the other side: boys will find themselves outclassed at reading and writing by the girls, so will tend to focus on math. 

[Caveats: all this is very general, phrased in ideal types, not real people.]

Tuesday, August 07, 2018

Jimmy Carter Reconsidered I

I'm reading "President Carter: the White House Years" by Stuart Eizenstat, who was Carter's main policy adviser in the White House.  So far about a quarter through.  It's well written, although it could use closer editing--in a couple places there's near repetition of content/points just pages apart.

That's not really important.  The big issue in the early days was energy, which Eizenstat claims Carter changed national energy policy drastically and permanently.  I'm not convinced yet, but I did run across this graph from AEI, which shows a dramatic drop in energy imports spanning 10 years from Carter's term through the end of Reagan's. 

I may post more later on Carter.

Monday, August 06, 2018

Upward Mobility Revisited

Robert Samuelson has a column in the Post on the decline of upward mobility in America.

What's being measured is inflation-adjusted incomes, comparing children and parents.  So the percentages of children who exceed their parents income has declined. A Brookings study tries to parse out which classes and which age cohorts see the change.

A couple of observations strike me:  it's (relatively) easy for poor kids to beat their parents; it's hard for rich kids to beat their parents.  The child of a welfare mother with no job only has to make it into a lasting job while the child of Warren Buffett or Bill Gates will never beat her parents.

The 1940 cohort has the greatest success, so using it as the baseline for comparison skews the results.  People like me profited by the post-war boom, the increase in productivity, which hasn't been matched in later years.

One thing the discussions, particularly Samuelson's, don't approach is a hobbyhorse of mine: in a steady-state economy every person who is upwardly mobile has to be matched by another who is downwardly mobile. That's apparent when, as here, you use inflation-adjusted income as your measure; it's less apparent when you talk about people moving from one level (decile, quartile) to another.

With dollars of income, it's possible for everyone to out earn their parents, provided only that the economy grows enough.  (Think of China, where the income measure means everyone is upwardly mobile.)

Sunday, August 05, 2018

White Anxiety and Spelling Bees, etc.

Usually discussion of white anxiety focuses on growing economic inequality, the decline of the middle class, and the influx of immigrants resulting in a minority-majority country (not that I necessarily agree with these).  But I think there's another source of anxiety which isn't often discussed: white stupidity.

What I mean is whites look around and see that South Asians are dominating the National Spelling Bee (19 of the last 23).  I don't have an article to link to but I believe that students with immigrant backgrounds are also out competing "whites" in what used to be the Westinghouse Science Competition.  The new suit charging Harvard discriminates against Asian students forces "whites" to recognize their grip on claims to superiority in test-taking is slipping away.

To rub salt into "white" dreams of superiority Asian women have dominated the LGPA.

Friday, August 03, 2018

"Milk", by Mark Kurlansky

I got this book from the library, not Amazon, so I wouldn't feel right reviewing it there.  But I think the "critical" reviews on Amazon are  generally on point. 

For someone who grew up on a dairy farm the subject is interesting.  For someone who doesn't cook all the recipes aren't interesting.  The coverage is wide and broad, but not deep.  He tries to cover milk from a variety of species around the world, tossing in recipes every two or three pages.  He wraps up with a brief look at modern US farming.  The book started as a magazine article, and it still retains some of that character.  The author leans somewhat to the side of organic/locavore dairy, finding farms which are trying to find a niche where they can charge high enough prices to stay in business.

But the author is a bit credulous, I think, in accepting some of the claims.  For example, that one Holstein could outproduce 50 Jerseys.  Not possible--the farmer must have been pulling his leg. 

There's also the claim cows stay in the herd until 3 or 4.  Seemed incredible to me--3 means one lactation, which isn't enough to cover the cost of rearing the calf.  I know we had cows in our herd aged 9 or 10, because they were still productive milkers.  Did some superficial googling and found 4 or 5 is a common figure.  Still seems low to me, but then I remembered what we did with our calves: the males went for veal, of course; some of the females we kept and others we sold (depending on whether chance had given us a run of females).  The selling is the key--dad could sell calves because there were other dairies in the region, and his herd was respected.  Today, I'd assume there's no market for female calves, so they all go into the herd. If the cow has two pregnancies, chances are she's borne her replacement.  So the economic calculation for the herd is the cost of rearing the calf until it can be bred and give birth, versus the cow's production over that time.   (I'd also assume because of better breeding the calf has a greater potential than its mother had.)

Thursday, August 02, 2018


The USDA CIO's office has a blog post touting their work towards "dashboards" consolidating access to data across the USDA.

Fedscoop notes in the second phase of the "lighthouse" project:
In this second phase, USDA plans to award contracts across the same five focus areas as Phase I — IT Infrastructure Optimization, Cloud Adoption, Customer Experience, Data Analytics and Contact Center — and an additional contract for support of its program management office.
 The same piece offers this quote:
"While the CoEs address a wide swath of IT modernization at USDA, the White House’s Matt Lira argued in June that what they all have in common is creating a better-functioning government.
“We are ultimately in the business of restoring the public’s faith in these institutions themselves,” Lira said.
I'm a little dubious of these efforts.  I do hope they are collecting metrics.  If I were feeling energetic, I'd file a FOIA request for available metrics of online usage. But then, if I were feeling energetic, I'd have better things to do than nitpick efforts.

Wednesday, August 01, 2018

The Need for Photo ID and Our Assumptions

President Trump last night said you need photo id when you go to the grocery store.  His people have defended the statement two ways: if you're paying by check, you need the id or if you're buying alcohol you need the id.  His opponents find these lame rationalizations--few people pay by check anymore and he didn't mention beer and wine.

As an opponent, I agree. But there's a danger here of accepting and reinforcing the assumption--all Americans go to the supermarket, all Americans have checking accounts, and all Americans live in single-family homes.  All, of course, are false.  Many Americans go to the local grocery, where their family may have shopped for years, and where the owner knows them and needs no id.  Many Americans have no checking account. Many Americans never go to the store, being essentially confined to their homes and dependent on others to buy their groceries for them. And many Americans  live in group settings where food is served. And some Americans live on the street and depend on food kitchens, etc.

[updated: Vann Newkirk at the Atlantic agrees.]