A Thought for FSA Personnel

Chris Clayton of Progressive Farmer has tweeted asking USDA for answers on prevented planting.

I  expressed doubts as to whether leadership could make fast, good decisions.  That's not necessarily a criticism of Sec. Perdue and his team--I wouldn't have had great confidence in the capability of any of the leadership teams during my time at agriculture.  It seems to me the prevented planting issue has spun up very quickly, more quickly than I can remember situations in the past.  With MFP1 there was a longish lead up, during which the analysis people could get their acts together and the implementation people in DC and KC could get prepared.  MFP2 is different, although to the extent it covers 2019 production there won't be that much impact.  Where it's key is on the plant/no plant/change crop decision.(

Another factor is FSA doesn't have recent experience with prevented planting.  Back in my early days in the agency the disaster program included PP. Then, as FSA  was phased out of the disaster business in favor of crop insurance, we lost that institutional memory.  The inclusion of PP in crop insurance policies means the implementation process is going to be more complicated than it was in the old days.)

(Can't resist noting that the combination of Trump's trade war and flooding has undercut the idea that crop insurance could mean the end of ad hoc disaster programs.)

Bottom line: FSA personnel in DC trying to implement whatever decisions are made are having a bad few weeks.  FSA personnel in the field are in worse shape: face to face with farmers desperate for information to make their decisions and lacking the direction from DC.   

My sympathy for both groups, but particularly the field.

More on the Disaster Aid Bill and Payment Limitation

From the text of the bill:

"Sec. 103. (a) (1) Except as provided in paragraph (2), a person or legal entity is not eligible to receive a payment under the Market Facilitation Program established pursuant to the Commodity Credit Corporation Charter Act (15 U.S.C. 714 et seq.) if the average adjusted gross income of such person or legal entity is greater than $900,000.

(2) Paragraph (1) shall not apply to a person or legal entity if at least 75 percent of the adjusted gross income of such person or legal entity is derived from farming, ranching, or forestry related activities.

(b) In this section, the term “average adjusted gross income” has the meaning given the term defined in section 760.1502 of title 7 Code of Federal Regulations (as in effect July 18, 2018)."

So someone whose gross income combines farm and nonfarm sources has an additional hoop to jump through.  My impression is that FSA enforces the basic AGI limit by passing the appropriate ID to IRS and gets back data (likely just a flag) on whether the $900,000 limit is exceeded or not.  Now they'll have another determination to make, after that.  I'm sure FSA welcomes the additional work (NOT).

What's in the Disaster Aid Bill for Farmers

Here's the Senate summary of the contents of the just-passed disaster aid bill (emphasis added, given my post of yesterday).

AGRICULTURE, RURAL DEVELOPMENT, FOOD AND DRUG ADMINISTRATION, AND RELATED AGENCIES
Farm Disaster Assistance: $3.005 billion is provided for the USDA Office of the Secretary (OSEC) to cover producers’ net exposure to losses stemming from 2018 and 2019 natural disasters. Assistance is also provided to cover blueberry and peach crop losses resulting from freezes and hurricanes in 2017 and producers impacted by Tropical Storm Cindy. USDA would administer funding through the Wildfire and Hurricane Indemnity Program (WHIP) under OSEC.

Emergency Forest Restoration Program: $480 million is provided for the Emergency Forest Restoration Program (EFRP) for non-industrial timber restoration.

Emergency Conservation Program: $558 million is provided for the Emergency Conservation program (ECP) for repairs to damaged farmland.

Emergency Watershed Protection Program: $435 million is provided for the Emergency Watershed Protection Program (EWPP) for rural watershed recovery.

Rural Community Facilities: $150 million is provided for Rural Development Community Facilities grants for small rural communities impacted by natural disasters in 2018 and 2019.

 Nutrition Assistance for the Commonwealth of the Northern Mariana Islands (CNMI): $25.2 million is provided for disaster nutrition assistance for the CNMIs impacted by typhoons.

Market Facilitation Program AGI Waiver: Language is included to waive the average gross income requirement for producer eligibility under the administration’s Market Facilitation Program. 

Puerto Rico Nutrition Assistance: $600 million is provided to supplement disaster nutrition assistance for Puerto Rico stemming from 2017 hurricanes.

Puerto Rico Nutrition Study: $5 million is included for an independent study, including a survey of participants, on the impact of the additional benefits provided through disaster nutrition assistance.

American Samoa Nutrition Assistance: $18 million is provided for a grant to American Samoa for disaster nutrition assistance.

Hemp Crop Insurance: Language is included to ensure crop insurance coverage for hemp beginning in the 2020 reinsurance year.

Rural population waiver: Language is included to provide eligibility to designated communities impacted by a natural disaster for certain Rural Development programs.

Payment Limitations in the News Again

Been a busy day so I didn't get a chance to follow up on this piece.

What strikes me is the idea that the payments were on a US Treasury database.  I assume it's a result of the more general law requiring transparency on US payments  Wonder how EWG and the farm community will react.

Incredible Stat: Spending on Trump Security Versus Mueller

The end of an Anne Applebaum piece in the Post:

"The British state will spend 18 million pounds (about $22 million) on his security; the U.S. taxpayer will spend many multiples of that sum; hundreds of hours will have been wasted on planning. And all so that one man’s fragile ego can be boosted for another day."

The total cost of the Mueller investigation might be around $34 million.

For a short week's trip the UK may spend up to 2/3 the cost of the Mueller investigation.  Toss in the US costs and we're about even

(Note: the BBC article Applebaum links to is more fuzzy on the estimate than she is.)

Re FBI; Barr Has a Point

Saw in surfing that AG Barr said something to the effect the FBI should not have investigated Trump.

I suspect my fellow liberals and Democrats will be aghast at the idea: no one should be above the law, etc.

But I'm old enough to think he has something of a point.  Apparently the FBI transcripts from their wiretapping of Martin Luther King have just been released, which should serve as a reminder of the power J. Edgar had in his heyday through the suspicion he had files on everyone in DC. 

My point is that investigations are power, and we should have checks and balances applied to the FBI when they investigate possible misdoing by high official, or candidates for high offices.  From what I understand of the background of the FBI investigation into Russian meddling and the involvement of the Trump campaign it was conducted well and had some oversight.  Certainly President Obama was aware of the proceedings and tried to take action.  But that seems to have been based on the judgment of the officials involved, not the operations of any particular legal structure.

To me, the whole Trump-Russian mess raises big questions: what sort of help can/should campaigns accept from noncitizens, from nonresidents, from citizens of friendly nations, from citizens of  possible adversaries, or members of the government of adversaries?  How is that defined in relation to the First Amendment?  To the extent we now have laws against such help, or decide to add them in the future, how should investigations of possible breach of such laws be handled?  We can't leave it to the FBI director--J. Edgar proves that.  We can't leave it to the appointed heads of Justice or the elected head of the government, can we?

Reestablishing Proper Standards of Behavior

A question raised by the Mueller Report is what are acceptable standards of behavior:

• should political actors in the US accept money from noncitizens/nonresident?
• should they accept valuable information from nonresidents?
• should they accept advertising on their behalf paid for by nonresidents?
• should they report attempts provide the above assistance to the FBI?
• should they make public the above assistance?
• should they lie about receiving such assistance?

There have been defenses of the Trump campaign arguing that searching for dirt on the opponent is standard campaign procedure.  Is that true, and if it is, should it be?  Where do you draw the lines?

Even as a devoted opponent of Trump's presidency I recognize that, with the First Amendment and the SCOTUS decisions in this area, the answers to these questions may not be what I'd like. But it does seems possible that there could be bipartisan agreement on some standards.

NPR and Furriners Buying Our Land

NPR had a piece on foreigners buying up agricultural land.  It's not clear where the correspondent's data comes from, but I'd suspect it's reports under the Agricultural Foreign Investment Disclosure Act..

I remember when the law was enacted in 1978.  That was when foreigners were rolling in dollars, partly because OPEC had successfully raised the price of oil, Nixon had taken us off the gold standard, and Japan was starting to sell cars (bought my first Toyota in that year) to us.  Those dollars were being used to buy land, causing concerns in the U.S.  That resulted in the act, requiring buyers to report their ownership to ASCS/FSA.

The regulations to implement the act were always questionable--basically it was a stand-alone requirement to report in its own little silo, with no interface to the rest of ASCS functions.  That meant there was no real enforcement, except the good will of the buyers and the conscientiousness of the county office.  But we had no way to ensure the buyers knew the requirement.. And we had no way to get data on sales by foreign buyers.

As a result, when someone looked at the AFIDA database in 2014, they found problems.  I'd have my doubts that it's been fixed since.

In the back of my mind I wanted to integrate AFIDA into the farm records system as we re-engineered it from the System/36 to the new platform.  But it never happened, never became important enough to devote the people to it, and I got fed up and retired.  I strongly suspect in the 20 years since no one involved in the redesign of FSA operations was conscious enough of AFIDA to include it in the redesign.  Such is the fate of silos; they don't have enough significance to attract attention.

I did a search on this blog to see if I'd written on AFIDA before.  I did a couple times in 2008, but using the FSA label.  One post did refer to FSA's AFIDA reports.  They're available here. But the web page hasn'te been updated for 5 years, a fact which supports my overall take on the subject.

Drills of Today and Yesteryear

Conversing with a relative, older than I, this morning.  She remembered the newsreels of the Capitol being lighted up again after the end of WWII (maybe VE day?).  She'd lived in the DC area until about 1943-4.  I asked if she remembered air raid drills--she did, many of them, in fear of German air raids.

My memory for some things is not the best, so I'm sure we had some a-bomb drills in school, but I don't remember a lot of them, or indeed any specific one. Those drills were in fear of a Soviet nuclear attack. 

Today students get active shooter drills, many of them.  Unfortunately the chances of their ever encountering an active shooter, although minuscule, are significantly greater than the chance of a German air raid on DC, but perhaps not as great as a Soviet attack on DC was (except I lived 300 miles from DC).

Drills--the ones I really remember are the penmanship ones, perhaps another drill destined for the wastebasket of history.

MFP II Addenda

Via Farm Policy News further details on MFP II--based on the USDA big shots' discussion.  The key point I take from it:

"Referring to the market facilitation program, Undersecretary Northey indicated that, “So these payments are not designed to be a market loss payment. They are a market facilitation payment. It’s not going to perfectly reflect what some producers feel the loss of these markets have been.”

FWIW I don't know what the words "market facilitation" mean, at least not as applied to the $14.5 billion part of the program.