FSA Offices Closed; NRCS Offices Open

That's the word.  For NRCS here.

BTW, neither agency has updated its "farm bill" page to reflect the signing of the 2018 farm bill.

The Parable of the Forms

This paper is written by a law professor, so it's directed at legal procedures, but he uses the design and use forms as a way to make his point.   I'd say the logic applies as well to the design of agencies: one reason why we have recurrent efforts to simplify how USDA deals with farmers, and recurrent failures.  The view from on high is much clearer than the view at the grassroots, and the grassroots typically have more staying power. 

Recommended for bureaucrats.

Infoshare: Once More Unto the Breach

Thought I was quoting The Charge of the Light Brigade, but it turns out it's Shakespeare's Henry V.

This is triggered by an FCW piece/ report on a GovExec conference, quoting  Chad Sheridan, the CIO of RMA, discussing USDA's plans to consolidate CIO's, combine mission support functions of FSA, NRCS, and RMA, and serve as the pilot for a GSA program.  See also this FCW piece.

The new website, farmers.gov, went online February 1.  They're starting small, very small, which is good.

This is what they promise:


"Check back monthly for new features, including:

Mobile-friendly service center locator
Program descriptions with an interactive requirements tool
Improved account login process for easy access to USDA accounts
Customer and mobile-friendly digital forms
Calendar of local events and program due dates
Customizable data dashboard
And much more"

USDA Reorganization

A post here on it at ThinkProgress.

The USDA report to Congress on the proposal.

Basically it would move NRCS, RMA, and FSA under one new Undersecretary, leaving FSA and FS each with their own Undersecretary.

This sentence from the USDA post perhaps hints that there will be more attention to the consolidation/cross-agency work that has been going on over the last 26 years:

Locating FSA, RMA, and the Natural Resources Conservation Service under this domestically-oriented undersecretary will provide a simplified one-stop shop for USDA’s primary customers, the men and women farming, ranching, and foresting across America.

 The proposal gives more prominence to the FAS and international trade, which is strongly supported by the ag interest groups, which may be enough to overcome concerns among the conservation types over a possible/perceived downgrading of conservation.

We'll see.

Editing Common Land Unit

A QandA from the notes of the NASCOE convention:

": Are there discussions regarding allowing NRCS to edit our CLU layer?
A: Brad Pfaff: Yes those discussions are happening to have NRCS edit the CLU and SCIMS. Darren Ash: They are looking at the impact it could have allowing other agencies to have that type of access.  The goal is to have agencies be able to share information since we have common customers, but they are looking for an appropriate way to administer this."

I'll suppress some emotions here by making a couple points:

1. the "Common" in the CLU refers to the idea it would be shared between FSA and NRCS. I've a vague memory that we made some compromises or changes in the business rules for it in order to support NRCS data.  Essentially it's the lowest common denominator between ASCS acreage data and NRCS. 
2. the dream of enabling one change to update both ASCS and SCS databases for name and address and land data dates back to the late 1980's, as a result of the impact of the sodbuster/swampbuster rules in  the 1986 farm bill.  So thirty years later we're still struggling with the issue.
3. as a liberal, I usually support government programs, but sometimes I wonder how capable we bureaucrats really are.  (Of course, I quickly turn to blaming Congress for many of the failures. :=))

Love It--the Eternal Silos of FSA and NRCS

Just realized I hadn't heard from NASCOE in a while so I checked the website, which has been completely redone.

Here's what I love.

NATIONAL OFFICE RESPONSE: (combined sources)
At this point, FSA employees with access to existing systems can access FSAfarm+ using their employee eAuth Level 2 login; however, we have not added NRCS employees to the list of authorized users. The website was built as a customer self-service portal and FSA employee access has been authorized so employees may assist our customers with questions regarding the website. NRCS FSAfarm+ access has been discussed with leadership and they are looking into obtaining the required approvals.

They've got a new process for submitting field office concerns and getting responses from DC.  This response is to a request that FSA give NRCS access to their records.  This was Sec. Madigan's concept back in 1991.  As you can see from the response, those silos are still standing tall.

Why Didn't We Do a Joint Legacy Viewer

DOD and VA have had problems integrating their health care IT systems.  Now they've focused on a "Joint Legacy Viewer", which uses the principle of "write locally, read globally".

As is often the case, I think back to the 1990's (old geezers live in the past, you know) and the idea of integrating the USDA farmer  service agencies, at least in their IT.  At that time our (my) focus was always creating one database to serve the agencies.  In retrospect that was wrong. 

In 1992 we were demoing a mocked-up viewer of ASCS data.  Maybe we should have tried to build on that, rather than going for the big top-down solution.

Aerial Photography and Drones

Farm Policy reports that NRCS got questioned over the possible use of drones for their work:

Rep. Sanford Bishop: “Can you tell us if you have any plans to utilize drones to assist in the collection of information, because you do a lot of photography, put a lot of contracts out to take pictures, and there’s a tremendous amount of interest in the use of drones in agriculture, particularly in assisting the optimal design and layout of fields for water assessments and other related issues.
“Have you looked at this issue? Are there any current interagency discussions with FAA or other agencies concerning the growth in the use of drones? Obviously there are some security issues involved, but there’s also a great deal of interest for commercializing that practice and using it in agriculture.”
Mr. Jason Weller: “Absolutely. It’s a new technology, but we also have to be careful because folks do have privacy concerns. The FAA also had safety concerns. So in part NRCS, we sort of said full stop, let’s wait for FAA to actually come out with a rule.
“Now that the rule has been issued, we’re trying to figure out how the NRCS can work within that to do remote sensing, but in a way that protects privacy, assure landowners who are not there there’s a regulatory component, because I know folks have some concerns when the federal government starts flying drones over their property. So we just need to make sure NRCS is doing this technology in a way that’s appropriate, that’s sensitive to landowners’ concerns, but also then helps us do a better job of managing resources.”

 The question may be whether the use of drones by USDA agencies evolves from the field/bubbles up or is top-down, or some mixture.  My guess is there will be more experimentation at the local office level than WDC is expecting or will realize.  Drones are too cheap for it to be otherwise.

USDA and OIP

FCW refers to the 6-month review of the digital government strategy.  Via links, I come on this page from USDA.  From what I see, it appears USDA is bragging on the Office Information Profile system.

I'm amazed, really amazed. OIP was a result of work in the 1990's, Paul Whitmore from FSA and someone from NRCS and RD, which had actually evolved from Gerry Deibert's efforts to construct a database of USDA offices back in the day when Sec. Madigan was trying to consolidate field offices.

Unfortunately, it got done as a separate silo from SCIMS, which was unfortunate, or at least I thought so then.  Anyhow over the years I've occasionally looked at the OIP page(s) just to see what's happened.  I could swear, though I might be wrong, that NRCS had dropped the links to it, though it seems to be back now.  It's not evident on the USDA web page.

It looks to me as if maybe they blew the dust off the old software, added in the link to the Bing map  (which is good) and resurrected it.  I wonder what sort of usage statistics USDA maintains on it.  Pardon my doubts, but I think the design too closely reflects the bureaucracies involved, rather than meeting the needs of the user.  If I'm looking for an FSA/NRCS/RD office:

• I might be looking for the closest one to my current location, or a specific location.  In that case, I'd be best off if office locations were integrated with Google maps (and Bing, etc.). In other words, if I stick Reston, VA in Google maps, and add the ": FSA office", it should flag the closest office.  Or if I add ":gov", it should show the closest government offices.  Seems to me this would be good for OMB or whoever to work on.  I tried this sort of search a few times and the results vary.  The closest FSA office to Reston is at 14th and Independence, but it didn't show the county offices.  RD and NRCS didn't get that result.
• if I want to know which office services a specific geographic area, the OIP does okay, except for the fact you need to drill down through state, to county, to agency.  If you ask Google: "what FSA office serves Mills County, IA?, I get the state office, not the county office.

Cross Compliance

In the old days "cross-compliance" simply meant if you participated in the program for crop A on your farm you couldn't expand your acreage of crop B. ("Offsetting compliance"  meant you could n't expand your acreage on other farms if you participated in one farm.

These days "cross compliance" refers to sod/swamp, and it's controversial.  A set of organizations sent a letter asking for no cross compliance.  Former NRCS chiefs sent a letter supporting it.

The requirement was in effect from 1986 to 1995.  I suspect, but don't know, that it wasn't very effective.  SCS and ASCS had big problems working out how to enforce it and I suspect FCIC/RMA was never much involved, at least until well into the 90's.

In thinking about the possible problems with such a provision, a good part of the problem is timing. Ideally the first contact a farmer has with a USDA agency, including crop insurance agency, should involve a checking of the conservation compliance status for the farmer's operation.  If she has highly erodible land is there a conservation plan of operation in place and up-to-date?  If there's wetland, what's the status? If there's a problem, the farmer needs to fix it or bypass crop insurance.  In the 90's sharing access to that information would be difficult because it wasn't all in one place.  These days it should be technically feasible, if probably still bureaucratically difficult.

I wonder if crop insurance is subject to the administration's Do Not Pay rules?

EWG and Conservation Compliance

EWG has a paper on conservation compliance out Monday, in advance of a hearing tomorrow.

I'm no expert on the subject, particularly since my knowledge of the matching process between NRCS data and FSA data is so out of date. But the study seems professional and hits all the bases, although it obviously is pushing for changes in conservation compliance. 

Some notes:

•  the report says linking crop insurance with conservation compliance was dropped in the 96 farm bill to encourage participation in crop insurance. It argues that goal has been achieved so the requirement should be reinstated.
•  the report's interesting on the process of easing up on the initial 1986equirements.  I was sort of peripherally aware of some of the changes, but mostly of the fact NRCS did not at all like having to change from a service/educational agency to a regulatory one.

 A couple quotes I found interesting: 

there has been less focus on the FSA officials who have had the lead administrative responsibility for the law from the outset. FSA officials are responsible for making final determinations on whether producers qualify for the most important exemptions and variances, including the good faith exemption, graduated penalties and eligibility for relief because of economic or personal hardship. NRCS’s more limited role is to provide the technical information and guidance for the decisions made by FSA. According to some observers, FSA officials, who have extensive experience with enforcement of commodity program rules, have been largely unwilling to deny farm program benefits to farmers who do not actively implement their conservation plans. It is FSA that bears the greatest burden of responsibility for the law’s ineffectiveness and the apparent acrimony between FSA and NRCS officials. [page 18]

ongoing rancor between USDA’s Farm Service Agency, which has the lead responsibility for enforcement, and the Natural Resources Conservation Service, which provides technical assistance to farmers and conducts spot checks of compliance, has contributed to enforcement failures.  [page 22]

I wonder whether part of the resistance to the idea of combining SCS and ASCS in the early 1990's was the fear that, if you put everyone in one agency, the enforcement of conservation compliance would have been more effective.

ACRSIP and USDA

Mr. Scuse sees FSA getting acreage reports directly from the farmer's precision agriculture equipment, according to this post. The lede:

The U.S. Department of Agriculture’s Acreage Crop Reporting Streamlining Initiative Project (ACRSIP) may well be the “most important thing that USDA has ever done,” according to Acting Under Secretary for Farm and Foreign Agricultural Services Michael Scuse.

 In the interview (at the link) he says the idea is first to allow producers to report acreage once from home with the data supplied to crop insurance (also NRCS and NASS as applicable I assume) and FSA.  The "ultimate" step is to get the data from the precision equipment.  Timing: a pilot this fall, partial implementation in 2012, fuller later.

My comments:

• the interviewer said he'd called it the most important initiative USDA had ever done.  Scuse didn't quite agree with that.  I'd comment again that the prerequisite for such reporting is GIS and the common land unit. (For those not affiliated with USDA, the common land unit is an attempt to identify the lowest common denominator of land/land usage recognized by everyone in USDA.  It's necessary so you can provide different totals for different purposes.)  And I'd again recognize Kevin Wickey and Carol Ernst for that.
• as usual, management plans are over-optimistic.As far as I know there's little or no existing infrastructure for developing and testing software which spans the agencies. That was being developed in the late 1990's, when I retired, but I think it became a NIH item when the Bushies came in.  Once again, the Harshaw rule: you don't do things right the first time. While the agencies have a little experience in developing software for farmer usage, I've not seen anything impressive nor have I seen evidence of an active feedback system where farmers are suggesting improvements.
• a fall pilot presumably would cover the fall-seeded small grains.  That's a good starting point, representing  the easiest and simplest set of situations to handle, no double cropping, little land tenure complexities.  But I'd question whether the experience with such reports is an adequate basis for expanding in crops and scope by spring of 2012.  Maybe it can be done, but I'm a bit leery.  (Then, when the System/36's were rolled out, I was leery then too.)
• because the acronym is new, at least to Google, I wonder how well management has laid the basis for the changes in FSA and the other agencies which will likely follow.  

It will be interesting to see how this evolves.

Rotate NRCS and FSA Employees?

In order to get the national security types, the FBI's and ATF's and so forth, to talk to each over, some Senators are saying, let's do what we did in DOD with the "purple" reforms of Goldwater: require employees of the different agencies to rotate among them.  Maybe Congress should require the same sort of rotation among employees of USDA in the field offices?

Kudos and Brickbats FSA County Offices: Strongly Recommended

Mr. Blankenship, a wheat grower from Washington, testified before the Senate Ag committee last week.  Excerpts from his testimony

"In my case, FSA is the easiest local office to deal with. FSA personnel are better trained
than others and more familiar with the actual impacts of changes to program eligibility, payment
limits, etc."

"All in all, the partners in Blankenship Brothers probably make 10 separate visits of several hours to our FSA office per year, minimum, for sign-ups, certification of acreages, CRP status checks, SURE eligibility questions and returning paperwork once proper signatures are collected."

"This GPS-based data management system meshes very well with the GPS-based mapping
recently adopted by my FSA office"  (But otherwise interaction is all paper, with FSA dataloading.)

"The differences between administrative perspectives of offices have caused
some producers to go so far as to buy a small parcel of land in a neighboring county in order to
transfer all of their acres to that county’s FSA office."

I strongly recommend it.  NASCOE will be pleased with it, as he leans towards FSA administering programs.  What he may not fully appreciate are the limitations on making programs operate the same way.

It's good to learn that the effort people like Kevin Wickey (NRCS) and Carol Ernst (FSA) (among many others) put into GIS so many years ago has finally paid off, at least for one operator in one county office.

Customer Service and Regulatory Burden

Via NASCOE USDA requested comments on ways for reducing regulatory burden  under Obama's Executive Order 13563.  They were due by today.  So naturally I procrastinated until the last minute.  But I finally did offer my accumulated wisdom, which I've published as a Google document here.   Anyone who wants can insert comments, or even edit the damn thing.

[Updated: corrected language and added link to the FR document.]

How To Reorganize

So Obama proposed reorganizing government last night.  But by focusing on duplicated functions he implies the sort of reorganization which takes some silos and puts the silos together under one roof.   For example, taking Rural Housing and putting it under HUD, or Forest Service and combining it with Interior.  That's the sort of reorganization FSA experienced in 1994, when parts of the old Farmers Home Administration were combined with ASCS.  I'm not sure the reorganization has been terribly successful; it wasn't successful quickly. We still have county office employees who are Federal and those who are not.  16 years of effort hasn't changed that.   And I suspect we still have IT employees in St. Louis and IT employees in Kansas City. And the IT applications may not have been as integrated as they might be, as were dreamed of in 1991 under Info Share.

I'd like to suggest a different model for reorganization, particularly for rural areas.  It's a model which will drive some FSA employees, particularly a certain CED, up the wall, but I think it's worth considering and testing.

Some assumptions:

• The number of farms in agricultural areas continues to fall
• The number of people in some rural areas continues to fall
• Technology permits telework to be effective in some cases
• Many people in rural areas are competent with modern technology, but some are not.

The new model office combines a lot of technological bells and whistles, with a set of "generalists", people who know enough about lots of  things to be able to serve as intermediaries with the true experts, either by consulting them remotely by messaging, and videoconferencing, or by putting the customer in touch with the expert. In some respects it operates as a "triage" center.  Its staff is trained enough to be able to refer cases too complex for them to handle, to hand hold for cases that can be handled remotely where the customer needs the assurance and the interpretation, and to take care of routine and simple cases.

The new model  field office works with the new model Federal agency, which tries to serve the public online, but using experts more locally based as intermediaries for those who aren't comfortable with technology.  So the new model Federal agency is doing lots of basic training of the personnel in the

So you set up the new model  field office and test it.  If it works, it's the field service center for all Federal government services and some new ones. (The new ones will aggravate people who might think I'm a socialist.)  So the new office would start by serving as a post office and a passport office (which some post offices do now). It would serve FSA programs, NRCS programs, Rural Development programs.  It would handle Social Security matters.  It would handle IRS matters.  It could serve as an interface for remote medicine.

That's my idea.

NRCS and FSA--Testimony from FSA

I quote from a legislative statement dated today, the testimony of Mr. Lohr:

Both FSA and NRCS are in the process of upgrading their technology and business processes, FSA through the Modernize and Innovate the Delivery of Agricultural Systems (MIDAS) project and NRCS through the Conservation Delivery Streamlining Initiative. Having FSA administer conservation programs would go a long way towards assisting NRCS in reaching its Streamlining Initiative goals of reducing field staff administrative workloads by 80%. It would also enable their field staff to reach the goal of spending 75% of their time in the field providing conservation assistance to farmers and ranchers. NRCS has indicated concern with the administrative burden on field office technical staff from expanded roles for contract development and management. NRCS’s Streamlining Initiative encourages a move to a “natural resource centric view” concentrating on identifying and solving resource problems and moving away from a “financial assistance centric view.”

The NRCS Streamlining Initiative highlighted as one of its top objectives the implementation of programs through alternative staffing and delivery approaches designed around more efficient business processes to minimize the non-technical workload on field staff.

Now is the time to make the IT changes to enhance FSA’s administrative and NRCS’s technical capabilities .For example, FSA and NRCS use different GIS software programs, ArcGIS and Toolkit, respectively. This is not practical. It is extremely inefficient to develop and maintain two USDA systems to administer farm and conservation programs. We can no longer afford these inefficiencies.

The third from the last sentence surprises me.  So much for the work of Kevin Wickey.

House Ag and IT in USDA/FSA

House Ag committee held a hearing on the status of USDA and FSA IT, including GIS.  Only the opening statements of the witnesses are available online.  The USDA CIO and FSA Administrator testified.  Much of their statements sounded like 5, 10 or 15 years ago, addressing the same issues of outmoded equipment, stovepipe systems, decentralized chaos among the agencies.  The second session had the National Farmers Union, NASCOE, NAFEC, the National Association of Conservation Districts and the National States GIS council. 

I found the second session more interesting:  One question--why wasn't the Farm Loan organization (the old FmHA specialists) represented?  (To show how slowly things move in USDA, note I'm referring to an organization (FmHA) which disappeared 16 years ago.)  They certainly have IT concerns, although the Administrator seemed to say their systems were in the best shape of any.  A surprise--the NASCOE rep said GIS products were the single biggest workload item. An unlikely request--the National GIS rep asked for dedicated money for the NAIP (aerial photos/GIS) separate from FSA money, but was very complimentary of the Salt Lake City staff.  I wonder why that was--is it possible that because the Aerial Photography Field Office in Salt Lake is the only FSA office which produces real, tangible products (setting checks to producers aside), that it's easier for them to take a businesslike approach to its operations?

Whoopsie--Was FSA One of the Agencies Which Goofed?

Here's an example of a bureaucratic screwup, along with a somewhat exaggerated story. In sum, a 1996 law required executive branch agencies to send their final rules to Congress, but many appear to have failed to do so. (The law gave Congress the right to disapprove the final rules after being notified of them.)

In theory, the rule isn't effective until sent to Congress.  And, the answer to the question in my title is "yes", both CCC/FSA and NRCS failed to send several of their final rules over, one of which is a payment limitation rule and one an EQIP rule. (See page 20  of the CRS report.) It strikes me as a Mickey Mouse rule, as we used to say in the old days.  If an agency does something which is controversial and could be disapproved by Congress, the thing will have a life of its own.  If it's not that important, then it's bureaucratic routine.  It's not important in itself; Congress is able to read the Federal Register, after all so the appropriate staffers know when the final rule goes out.

What "Open Government" Doesn't Cover--Subordinate Offices

Here, via OMBwatch, is the text of the Obama's administration instructions to agencies on opening government. I like it, but I think there's a major problem: it treats each agency as an entity, not as a set of interrelated offices.  For example, an agency like FSA has over 2,000 county offices, state offices, offices in Kansas City and Salt Lake City.  NRCS and RD have similar structures.

So the issue, which I've hashed with at least one county executive director, is whether you have a centralized unitary open government structure or a more decentralized one. Complying with Orszag's instructions implies a centralized structure, which in a way is contrary to the open government philosophy. I'll be trying to track how NRCS and FSA implement this directive.