Friday, July 17, 2009

EU Ag Payments Go to Non-Farmers

It's always nice to have company in one's problems. The NY Times reports here that EU agricultural payments often go to non-farmers and rich landowners. Even the Queen of England, who used to get payments from us as well, until the 1985 farm bill.

Books That Defeated Me--Drum

Kevin has a post with this title--the books which he started but couldn't finish--which has drawn lots of comments. It's amazing the variety of books which have defeated people. I guess people like to confess shameful secrets, such as never getting through Catcher in the Rye.

Some scholar might make something of this: what books do people feel they should read and end up failing. I didn't see anyone mentioning Jane Austin

Thursday, July 16, 2009

Permanent Drought in Texas?

That's the pessimistic possibility from an A&M climatologist here.

One of the programs of government programs (and of private corporations, look at GM) is adapting to changed conditions. Texas farmers have eligibility for some program payments based, not on what they currently grow, but on what they grew in the past: 1990's. The last I looked the only way to lower a farm's base acres was if the total of the bases exceeded the cropland on the farm, plus historical doublecropping. So if a drought convinces a farmer to take land out of cropland status he might lose base.

The same applies for yields--they generally are fixed, with little likelihood to go lower. (Not true for crop insurance--their APH is similar to what ASCS had in the early 80's as "proven yields".)

Reading SCOTUS

Been following the Sotomayor hearings on SCOTUS.blog. I want to know why the 7th Circuit doesn't allow permalinks to their decisions?

And why did Senator Sessions agree to do that crack cocaine thing?

1930's Revisited

One thing that stands out about 1930's news (see here for today's post) is the greater importance of agriculture. Every day, I think, farm prices or conditions make the summary, today it's a Wall Street Journal editorial. No, not knocking federal programs but asking the Board to make up its mind. What's the odds of that happening today.

Even in the 1950's and 60's agriculture was a big deal--issues got White House attention. But greater efficiency has shrunk the numbers so agriculture's economic impact is less, meaning its news value is less.

Tuesday, July 14, 2009

Comments on EEO Data Collection Submitted

I may have failed to note USDA was requesting comments on a data collection of race/ethnicity/sex data. The notice was originally published on May 13, 2009, as FR Doc E911109, then amended in a notice published June 19 as E9-14444. Comments are still open until July 31, and you can see the documents and file comments at http://www.regulations.gov/

Anyhow I finally got my comments composed and submitted and here's the text. You get the advantage of some working links--the regulations.gov site doesn't recognize links.


"My comments are based on my past service in ASCS and FSA, with an early connection to the Service Center Information Management System (SCIMS). Since my retirement in 1997 I've been aware of the Pigford case and some of the GAO reports in this area.

I understand the June 19, 2009 amendment to the original request for comments to constitute a backing off from a specific process of data collection, which is good, but I'm still confused on some points.

I'd think the request for comments could have been improved by:

  1. citing the relevant governing documents issued by OMB. Based on my limited research, the OMB guidance issued on October 30, 1997 for the 2000 Census, that was to apply to other Federal programs by January 1, 2003, seems to be still the latest. (This is the change separating "Hispanic" as ethnic, rather than racial and permitting multi-racial categories.)
  2. mentioning the SCIMS database now being operated by FSA. It was originally intended to provide common producer/customer/employee data for the service center agencies. I'm not clear on the extent to which this intention has been achieved, but my interpretation of paragraphs 177-179 of handbook 1-CM is that the system already collects personal identity information according to the OMB guidance. Because the FR notice doesn't specifically mention SCIMS, it's not clear to me whether the planned information collection supersedes SCIMS, is part of SCIMS, or what. As published and corrected, the data collection doesn't really make sense--it mentions only collecting race/ethnicity/sex data but I assume it's tied to an individual, meaning the person's name and address must also be collected.

Specifically in response to the four points:

1 Is the collection necessary for performance of USDA functions? Given the criticism directed at USDA (Pigford, etc.): I'd agree USDA needs to be able to point to valid statistics on race, ethnicity, etc. But given that SCIMS currently collects some data for many of the universe of respondents, it's difficult to know whether this collection would represent an improvement over current practice.

2 Evaluate the accuracy of the agency's estimate of burden of the proposed collection of information, including the validity of methodology and assumptions used: Given the modifications in the June 19 notice, it's hard to evaluate the proposal. If the idea is that the business process already has the individual's name and address, so the collection is limited to race/ethnicity and sex, most individuals could respond in a few seconds, not 2 minutes. Even individuals who might need to decide whether to reply as multi-racial are not likely to increase the burden greatly. 2 minutes might be reasonable for a collection of name, address, plus race/ethnicity and sex, but you don't describe your collection that way.

I don't know how you came up with 14 million respondents--that's way above any estimate of producers and landowners I've seen. There should be a large degree of overlap between the three agencies, FSA, NRCS, and RD.

3 Enhance the quality, utility, and clarity of the information to be collected: The notice does not specify what information is to be collected . I assume the collection will follow the OMB guidance, but assumptions should be spelled out.

Given the suspicions of USDA among minority farmers I think it's important to increase public confidence in the data collected. I'd suggest running comparisons of the USDA data against Census data--for example, in areas with a high percentage of minority inhabitants, do rural zip codes show comparable percentages--does FSA have 10 percent Hispanics while Census has 25 percent? I'd also have OIG look specifically at existing data and have the FSA county office reviewers do spot checks.

You might also consider an annual mailing of the customer statement to everyone for whom FSA/NRCS/RD have data. That's the sort of thing Social Security Administration does, and it would give producers an opportunity to review their race/ethnicity/sex data.

4 Minimizing the burden of collection. Inasmuch as SCIMS has been operational for some time, I'd suggest a careful review of its operation would be instructive. What do USDA service center offices think of the process? What do those customers who use e-Authentication and the USDA e-gov process think? Should the data collected be shown on the USDA customer statement?

Whatever is going on behind the screen of the computer, I think it is most important that employees in the service center and those using the Internet application feel there's a seamless application for recording the data for a new customer. In other words, I'd drop any idea of a separate collection just for race/ethnicity/sex. Incorporate it in a standard process for registering new customers which can bridge into individual agency processes for their own programs.

Additional comments:

The new team at USDA might consider elevating the SCIMS function (or a revised and improved customer relationship) to the departmental level to provide greater visibility and clout. And, given the mandates in the 2008 Farm Bill for dealings with producers, USDA might investigate customer relationship management software. Finally, given the subsidies given to crop insurance companies, I'm not sure why they aren't included in the data collection. Surely it's a question whether there is outreach to minority farmers in this area.


Bill Harshaw
2420 Cloudcroft Sq.
Reston, VA 20191
bharshaw@hotmail.com"

Wisdom and Experience and Backwards in High Heels

What is wisdom? I'm referring of course to Judge Sotomayor's "wise Latina" comment.

But what makes for wisdom? Is the person with the wider variety of experiences more likely to be wise than the bureaucrat who sticks to the same cubicle for all his life? I suspect most of us would say: "yes". One of the common themes of fiction and drama is: "seize the day"--search out the new and different. Mostly the logic is it's the road to a richer and fuller life, self-realization and all that. But some of the time the corollary is that varied experiences is wiser, and leads to wisdom. (The journey of self-discovery, as in Harry Potter's journey.)

So maybe I'm a wise old man--wise because old, not particularly because of diverse work experiences. Or maybe not--maybe I've just keep relearning the same thing over and over. I'd tentatively agree that, all things being equal, living longer and more widely leads to wisdom And, therefore, Sotomayor has a better opportunity to be wise than her close counterpart, Justice Alito, simply because a woman in a man's world has more varied experience than a man in a man's world.

Seems to me there is another issue than the basis of wisdom: does wisdom always lead to the same answer--Justice O'Connor's original statement seemed to say it did: a wise man and a wise woman would reach the same decision. But I don't think so--there are many decisions where only history will say whether they're wise, and many others where even history doesn't say.

Should I Sell Chinese Stocks

I've a little money in a Chinese ETF. Some scientists say I should get out in by July 17, because it's a bubble that will bust. See this post for more detail. (Essentially--yes there's a bubble but there's no rationale for the predicted period of the bust.) Since I'm lazy, I don't plan to sell, just ride it up and down and I hope back up. :-)

Monday, July 13, 2009

Forms

The Times has an article on federal forms. The writer focuses on the GSA approval process for standard and optional forms used across agency lines, but throws in the OMB estimate of reporting burden. I commented there to the effect the government needs redoing.

In the old days, GSA could work towards efficiency by identifying forms that were used in multiple agencies and then creating a standard one. That doesn't work today, because more and more of government is moving to the web. But there's no strong hand keeping people from reinventing the wheel.