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.

MFP Form Is Missing?

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

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.

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 https://federalregister.gov/d/2018-18842, and on govinfo.gov"
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.

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.]

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.

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.

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.

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.

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.