ACRSI Comments

FSA has ACRSI data collection out for comment in the Federal Register:

Need and Use of the Information: This initiative is being conducted in phases by geographical area and additional commodities. Counties are selected based on their commonality of historical crop reporting, high percentage of producers participating in both RMA and FSA programs and the high level of interest of the private agricultural service industry (precision-ag and farm management) in the pilot phases. It will reengineer the procedures, processes, and standards to simplify commodity, acreage and production reporting by producers, eliminate or minimize duplication of information collection by multiple agencies and reduce the burden on producers, insurance agents and AIPs. Information being collected will consist of, but not be limited to: Producer name, location state, commodity name, commodity type or variety, location county, date planted, land location (legal description, FSA farm number, FSA track number, FSA field number), intended use, prevented planting acres, acres planted but failed, planted acres, and production of commodity produced. Failure to collect the applicable information could result in unearned Federal benefits being issued or producers being denied eligibility to program benefits.

Description of Respondents: Individuals and households.

Number of Respondents: 501,012.

Frequency of Responses: Reporting: One time.

Bureaucratuc Conflict in Acreage Reporting

Just read a report of research on the effectiveness of resolving civil wars by joining the opposing armies into a unified command.  (I forget where--Crooked Timber perhaps.)  The bottomline was that incorporating two armies into one didn't work to create peace.  If the underlying conditions were right, there might not be failure of peace to hold, but it wasn't a magic bullet.

So too in bureaucracy, maybe.  Different bureaucracies have different cultures and norms, and different interests.  The idea of helping farmers to file one acreage report to serve both crop insurance and farm programs is nice, but it doesn't resolve the underlying tensions.  Take this from a recent NASCOE post:

NASCOE provided DAFP leaders several of the documents that some of the Approved Insurance Providers have mailed producers soliciting them to not report to FSA but to them instead. This has been troubling to county office field level personnel and NASCOE membership. ACRSI was designed to be able to transfer common data between RMA and FSA. The two pilots have reinforced that FSA is good at taking comprehensive acreage reports. Regardless of what some of these AIP documents are saying, producers should have every confidence that FSA stands prepared to continue to accept the producer supplied aerial photos and complete the producer’s comprehensive acreage report.

Presumably crop insurance agents get paid for taking acreage reports just as FSA positions depend on taking acreage reports.  So each bureaucracy has a rational motive to try to monopolize acreage reports. In addition, the bureaucracy which deals with the farmer face-to-face will reap some benefits; whether in supplemental information or simply loyalty, the benefits are real.

These are interesting times.

Congratualtions to FSA and RMA--Expansion of ACRSI

FSA issued its notice on the expansion of ACRSI to all counties.  This means producers can file acreage reports with their insurance provider or FSA.  It's a limited set of crops, though because the major field crops are covered it will handle most crop acreage, It's a goal it's taken 25 years to achieve. ( Since they've done pilot testing, I assume the new expansion will be successful so it's not premature to credit its success.)

I do have some comments, of course:

• I wonder about the experience in the pilots--were most reports filed with FSA or with the company--is there a structural bias to the system?  
• Did the pilot include surveys of producers using it?
• Will the savings of a more efficient system, besides benefiting producers, mean a reduction in funding for FSA operations or government support for insurance company administration?  
• How is the spot-checking of acreage reports affected?  If errors/fraud is discovered, what's the reporting process?

I'm sure there are answers to the questions and other questions I'm missing.  But the bottom line is I congratulate the FSA bureaucrats (and the RMA types) for the achievement.

Request for Information on Acreage Reporting

USDA is:

investigating the use of a commercially available service to provide a reporting system to support Farm Service Agency (FSA) and Risk Management Agency's (RMA) common acreage and crop reporting compliance and other program needs. The objective of this RFI is to investigate whether commercial capability presently exists that can supply a viable alternative to the current Java based in-house system. 

The actual RFI is here.

Looking at the template for responding, I'm wondering whether there's been previous extensive meetings with potential respondents.  If there hasn't, the respondents may be at a loss to complete many of the items.  

FSA Gets Publicity for Midas

Farm Futures has a post on FSA implementation of MIDAS, based on some interview/speech by Dolcini.

I see they're doing a pilot project in a few IL/IA counties to handle acreage reporting for both FSA and crop insurance.  I wish them the best, though if you search on "acreage reporting" in this blog you'll see it's been a long slog.  I wonder if FSA got the $10 million Congress promised for progress by last Sept. 30.

What's Up--ACRSI

I've seen a recent jump in page views on the blog.  A popular page is the one I did in 2011 on the Federal Register request for comments on the Acreage Crop Reporting and Streamlining Initiative (being able to share data between RMA and FSA). I hadn't noticed much activity since, at least not enough to get me motivated to blog about it again, but my curiosity is aroused so I googled.

Two points--the 2014 farm bill requires ACRSI be implemented and this FarmForum article of a month ago.  I quote from Farmforum:

For example [of private enterprise coming up with advanced systems faster than FSA], MyAgData is already being used by Authorized Insurance Providers (AIPs) this crop year for acreage and production reporting in Iowa, Illinois, Indiana, Kentucky and Minnesota. But test programs in Illinois and Indiana at local Farm Service Agency offices this year didn’t quite work as efficiently as one might hope. The data was collected and matched to the common land units required for USDA acreage and production reports, but then was printed and had to be hand-entered at the local FSA office.

My heart bleeds (very easily--I'm a bleeding heart liberal) for those bureaucrats who've had to work on this effort--it's amazing how long it's taken to get action, though I see Congress has gotten USDA's attention by attaching money--FSA gets $10 million additional if they can show progress by Sept. 30.

Drones and Aerial Photography

Here's a piece at TPM about the use of drones within the US.  I wonder how long it will be before FSA's aerial photography is done by drones?  And disaster reporting? Fly a drone and provide a digital feed to a ground station to get good data on the extent of flooding, etc. Won't drones eventually be more economical than small planes or helicopters?  If they can stay up for 36 hours they can presumably accomplish more photography than manned aircraft.  And streaming the data back to the base station offers a lot of flexibility, particularly if you can feed it in as a layer to the GIS system.

I don't know: is FSA compliance still being done by aerial photography? Does ACRSI include spot checks?

No Super Committee Resolution and the Farm Bill

If the super committee fails to reach agreement, that kills the 2012 farm bill for this year.  Presumably the Ag committees and the ag lobbies will use the holidays to consider what they put together in a rush, and early next year we'll start to see legislation drafted.  In other words, we'll be back to the regular order of things.  The 64 dollar question is what sort of funding baseline they'll work with. Will they have the dollars they propose to the super committee, more or less?

The other question of importance is what will the farm economy be doing next spring and summer?  Recently corn and wheat prices have slid (see this Des Moines Register piece for corn.) Problem is that Ukraine and other grain producers have had good years.  (Back in the day, Ukraine used to be the breadbasket of Europe.  Just maybe modern farming methods and rational organization has finally arrived there so they can resume their place?)

I don't know enough to guess what will happen if prices have retreated significantly, but I would assume that it would change the bargaining and perhaps the framework of the programs in the farm bill.

As I've written, I now realize there's a window of opportunity for FSA/RMA to install MIDAS and ACRSI before being hit with the new farm bill.  But if the super committee fails, there may be an extended period of uncertainty over the future 2013 and on, meaning the bureaucrats have a compressed lead-time to get things in place. 

So if I'm an FSA bureaucrat do I pray for the success of the super committee, knowing it might well mean program changes which eviscerate much of the agency, or do I pray for failure, guessing it might make next fall torture?

Common Reporting Dates

From the press release announcing FMA and RMA have come up with common acreage reporting dates(ARD):

Before the streamlining, RMA had 54 ARDs for 122 crops, and FSA had 17 ARDs for 273 crops. The review team consolidated all of them into the 15 common ARDs.

 RMA and FSA will implement the July 15, 2012, and August 15, 2012, ARDs for certain commodities during the 2012 crop/program year. The remaining common ARDs will be implemented during the 2013 crop/program year.

Back in 1993 or so there was an initiative along these lines. one which obviously was unsuccessful. I wasn't involved in those discussions.   I'd be curious whether the resistance in the 1990s, and up to now, came more from RMA or FSA,. My guess, given the ratio of dates to crops between the two agencies, is that RMA had more problems.  They also perhaps had greater leverage.  Note that only 2 of the 15 common dates are being implemented next year.  That's probably because RMA needs to revise crop insurance policies, which requires a long lead time. I can imagine meetings where the prospect of such a long time to implementation was a wet blanket on any enthusiasm on the FSA side. Maybe there was more leadership from the top in 2011 than there was in 1993/4. Or maybe the people at the operating level (i.e., branch chiefs and specialists) were more capable and flexible this time around..

This is one prerequisite for the ACRSI common reporting initiative. Not sure how the software will work when you don't have common reporting dates for the crops: might be a real problem, might not be, might be something to be solved by a kludge.

NASCOE Lobbying Generates Comments

From USDA's summary of steps taken to improve regulations, this summary of comments received (over 2,000)

The vast majority of comments referenced USDA’s potential review of process improvements that could be achieved through the consolidation of information required to participate in farm programs administered by the Farm Service Agency and the Federal Crop Insurance Program, identified as the Acreage-Crop Reporting Streamlining Initiative (ACRSI). Many of these comments responded to suggestions from various commenters that the Farm Service Agency (FSA) take over delivery of the Federal crop insurance program or other administrative functions of the Natural Resources Conservation Service (NRCS) and the Risk Management Agency (RMA). ACRSI is an initiative aimed at reducing the reporting burden on USDA customers. By consolidating acreage reporting dates, linking crop codes, and sharing producer information across agencies producers will be able to provide acreage data at their first point of contact with USDA whether that be with FSA, NRCS, or their private sector crop insurance agent. Each individual agency will still be required to collect information from producers that is specific to their program(s); however, common information will only need to be collected once. This initiative will minimize the paperwork burden on producers and minimize the number of trips they need to make to a USDA office.