After 29 Years, "Actively Engaged" in Farming

FSA published a proposed rule defining "actively engaged" in farming--from their press release:

Under the proposed rule, non-family joint ventures and general partnerships must document that their managers are making significant contributions to the farming operation, defined as 500 hours of substantial management work per year, or 25 percent of the critical management time necessary for the success of the farming operation. Many operations will be limited to only one manager who can receive a safety-net payment. Operators that can demonstrate they are large and complex could be allowed payments for up to three managers only if they can show all three are actively and substantially engaged in farm operations. The changes specified in the rule would apply to payment eligibility for 2016 and subsequent crop years for Agriculture Risk Coverage (ARC) and Price Loss Coverage (PLC) Programs, loan deficiency payments and marketing loan gains realized via the Marketing Assistance Loan program.

It's been a while since the 1985 farm bill, which I think may have been the first time "actively engaged" was used in payment limitation language.  As I've blogged before, I remember the DC bureaucrats trying to comprehend the statutory language and come up with regulations and handbook instructions. Was that when the "left hand" and "right hand" first entered the picture (a farmer had to contribute labor, management, capital, equipment, etc. to the operation, but not all of them so we tried to clarify which combinations would qualify by using the two categories).  Anyhow, after long effort ASCS got the rules out and the training prepared only to have enough big shots exert enough influence on their Congressional representatives to force ASCS to reverse directions.  Again, if memory serves, and it's less reliable these days, the biggest loophole was managerial contribution: in effect, if John Goldbrick Doe, living as a beach bum in Key West, but one of the heirs to Sam Hardworking Farmer Doe, participated in a conference call with the other heirs and agreed to a share lease of the inherited land to Joe Dirty Hands Farmer, JGDoe could get a share of the payments.  (I may be exaggerating.)

The bottom line is "actively engaged" is a judgment call, and there's a Heisenberg principle at work: issue a regulation and the lawyers will change the reality, at least the legal reality, so the regulation won't work as it was originally intended.

Sen. Grassley has said the FSA proposal isn't as tough as he proposed.  We'll see if it survives the comment period.

PS: this issue shows the irrelevance of the President to much bureaucratic work.

The Expansion of the Bureaucracy

I remember when a hurricane hit Guam, I think it was, and two WDC employees were sent out to help the Hawaii office administer the provisions of the disaster program (late 80's maybe).  One of the big problems they had was the fact that land was communally owned, or at least that's how I remember it.  In rhe continental US we take our land tenure system for granted, at least we whites do.  The periphery still has remnants of other systems, the Spanish system in NM, perhaps the French in LA, the native American on some reservations.

Anyhow, my mind wanders.  The trigger for this post is this post, on an attempt to get an FSA employee assigned to Saipan, out of the Guam office. (Not clear what CNMI stands for--Micronesia probably.) It's the logic of a bureaucracy: institute a program with universalist parameters and it will get applied everywhere possible.

[Update: CNMI is on the mvariety.com site: "Marianas Variety"]

Dairy Down Under

From a post at Crooked Timber on New Zealand [hat tip Marginal Revolution]:

Then you drive through a town like Edgecumbe, past something which looks for all the world like an oil refinery, and realise that it is in fact a dairy, the size of an oil refinery. Four million litres of milk go through that particular plant every day (one litre for every New Zealander), and it’s not even one of the top three Fonterra plants. A lot of the milk is converted into powder, which is sold to the Asian market. This was my first clue that I might be heading into some interesting economics – at the duty-free shop in Auckland Airport, one of the things that they pile up high next to the scent and booze is great big tubs of infant formula.

From the context sounds like CAFO's have yet to come to the land of the hobbits.

Have I mentioned the David Hackett Fischer book:  Fairness and Freedom, which compares the histories of the US and NZ. The post touches on the history of the white settlers with the native Maoris.

Agriculture and Drones

An old story and a little confused.  The guy was a fighter pilot, but operated drones in Iraq and Afghanistan, so I guess he was a converted fighter pilot.  Anyhow he's got a drone business in Idaho, has FAA approval to photograph farms, and charges $3 an acre for the data.

I wonder how FSA/USDA aerial photography and drone photography will impact each other?

What Makes for Contented Cows? Robots!

Nathanael Johnson at Grist has a post describing on the use of robots by dairymen, quoting an observation that cows may be more contented (robotic routines are more stable [until they aren't]).

A Billion Is a Token Amount

So says the greenies, the National Sustainable AGriculture Coalition commenting on the Republican budget (from agriculture.com)

“While we continue to oppose re-opening the farm bill, we are thankful the draft House budget resolution released today is asking for farm bill cuts of only $1 billion …over the next decade, though it raises the rather obvious question of why bother to go through an agonizing re-opening the farm bill via the budget reconciliation process for such a token amount."

Sen. Ev Dirksen had the famous quote about "a billion here, a billion there, pretty soon you've got real money. Back then the federal budget was a bit over 100 billion, not the 3-4 trillion of today.

Just Say "No" in Olden Days

From a post by a museum curator discussing an exhibit of mostly 18th century shoes:

A pair of French garters (c. 1800) features early metallic clasps, as opposed to the ribbons typically used by men and women to secure their stockings just above or just below the knee. One garter says ‘Halt’ and the other ‘You can go no further.’ Some garments are on display, including one pairing of an 1837 silk brocade wedding dress and matching shoes.

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.

2008 GAO Helps Clinton on Email Records?

In the flap over Clinton's emails, I've not seen any mention of the GAO report in 2008 on problems in preserving e-records.  Turns out I included much of its summary and commented on it back then.

I won't repeat it here, but this paragraph is interesting in light of the current controversy:

"Preliminary results of GAO's ongoing review of e-mail records management at four agencies show that not all are meeting the challenges posed by e-mail records. Although the four agencies' e-mail records management policies addressed, with a few exceptions, the regulatory requirements, these requirements were not always met for the senior officials whose e-mail practices were reviewed. Each of the four agencies generally followed a print and file process to preserve e-mail records in paper-based recordkeeping systems, but for about half of the senior officials, e-mail records were not being appropriately identified and preserved in such systems. Print and file makes no sense--electronic is cheaper [regular type is GAO, italic is my 2008 comment]

 Let me repeat words: "followed a print and file process..."  In other words, the idea in these agencies, and I think generally throughout government, was:

1. not all emails were official records worthy of retention, just as not all paper documents generated within an agency were official records worthy of retention. 
2. someone was supposed to winnow the wheat from the chaff, go through the email, select the ones which merited retention, print them out, and file them in the paper filing system which was governed by records retention schedules approved by NARA. 

My comments then, though not well expressed, were based on these ideas:

1. the cost of retaining all electronic records was low, and becoming lower with every year Moore's law applied
2. the cost of reviewing, printing, and filing email as prescribed by NARA  was high
3. the likelihood of a bureaucracy doing no. 2 in an effective way was very low, as borne out by GAO's report
4. therefore, agencies should just keep all email in a searchable repository.

In the context of Clinton, there's two issues: the propriety of using a private email server for her work, on which I've no comment, and whether she complied with rules on preserving records, on which I will comment.  Clinton seems in the end to have complied better with the 2008 rules than many of the senior officials GAO looked at.  Were there changes in the rules after 2008?  I'm sure there were, as NARA continued to play a game of catchup, trying ineffectively to bring its filing systems and records retention systems into the modern word.  So I'm not saying she followed all applicable rules--she may have, may not have. I am saying her end result, in terms of selection and preservation, is well within the range for other senior officials. 

I'm also saying I was right in 2008--the simple effective rule is to retain all email records from email servers used for any government business, and let them be searchable.

It's Pi Day--Not

Both Post and Times have pieces today on Pi day, the idea that today's date, 3/14/15 expresses the first digts of Pi.  Aside from providing an excuse for mathematicians to place pieces in newspapers (otherwise a rare occurrence) and perhaps for pie shops to sell a few more, , it's a stupid idea.  In a rational world (i.e., in Europe) today's date would be 14.3.15 or 14.3.2015, with the data in ascending order.  In a rational world there would never be a Pi-day.