Joseph T. Reilly, Associate Administrator
National Agricultural Statistics Service
c/o NASS Clearance Officer
US Department of Agriculture, Room 5336A
Mail Stop 2024, South Building
1400 Independence Avenue, SW
Washington, DC 20250-2024
VIA ELECTRONIC MAIL
October 14, 2008
RE: Notice of Intent To Seek Approval To Conduct an Information Collection (Docket Number 0535-NEW, 2008 Organic Production and Marketing Survey)
Dear Mr. Reilly,
The Organic Trade Association (OTA) thanks NASS for this opportunity to comment on a matter of great interest to the organic trade.
The Organic Trade Association is a membership-based association representing over 1600 businesses from all parts of the organic supply chain. OTA’s members include farmers, certifiers, wholesalers, distributors, retailers, and others who produce or sell organic products or provide services to the organic business community.
Organic product sales in the United States are growing about 20% per year, and are outpacing the growth of non-organic agricultural product sales. This represents a significant opportunity for farmers in the United States to boost their business and meet a growing demand. Organic farmers, however, need and deserve the same level of production and market information that services like NASS provide for non-organic agriculture. OTA appreciates this strong step that NASS is taking to provide the kinds of information American farmers need to succeed and thrive in an era of rapidly changing market demands. Quantifying organic production and market practices of farmers will be a benefit for all parts of the organic supply chain. Including seven questions focused on organic production in the 2007 Census of Agriculture is a significant, substantial, and much appreciated addition to the questions asked on the 2002 Census. This work will bring a necessary and much higher level of clarity to the knowledge of organic production and marketing.
The burden of the proposed collection may be substantially less than estimated. NASS estimates the number of respondents at 15,500, which seems high. If this figure was based on the number of certified organic operations under USDA’s National Organic Program, it would include certified handlers, who, typically being manufacturers, would not have been included in the Census of Agriculture. This may be slightly offset by a few respondents who are using organic methods on their farms but are not certified, which is allowed for operations grossing less than $5000 from organic sales annually. Therefore, the estimated total burden on respondents is likely to be substantially less than 15,500 hours.
Similarly, information collected on handling, distribution, retail, and consumer purchasing patterns may be less fruitful than information on production. Operations that employ direct sales should certainly be identified and relevant information on sales collected, but information on retail or consumer purchasing patterns may not be readily available from producers who grow on contract or sell a high proportion of their products to the wholesale market. Obtaining final sales information from operations that are vertically integrated would be similarly difficult, though again, it would be very useful to ascertain the level of production and kinds of products in vertically integrated operations. It would also be helpful to know what channels organic farmers are using to sell their products, and how much product is being exported. It is certainly in the trade’s interest to identify such fundamental economic patterns as direct contracting and vertical integration, but useful information about retail and consumer purchasing patterns could be very difficult to obtain from a survey of producers.
In determining what questions should be asked, NASS should consider taking this opportunity to regress the census data of organic farmers to provide basic economic and demographic data for organic producers. The results could usefully inform the development of the NASS survey, as well as being a useful report in itself. Any data that helps identify patterns and commonalities among successful organic farmers would be useful in encouraging other farmers to consider shifting to organic methods, thereby helping to fulfill other broader goals USDA is developing concerning agriculture and climate change.
OTA also urges NASS to review the latest survey of organic farmers conducted by the Organic Farming Research Foundation (OFRF); please see http://ofrf.org/publications/survey.html for examples of the kind of information that organic farmers find pertinent and useful. The OFRF survey might suggest lines of questioning appropriate for this NASS survey.
This survey, in establishing a baseline report, could be the first step for on-going updates crucial to the informed development of organic agriculture in America. Specifically, information ERS could use to produce a market outlook report for the organic sector, which has not yet been produced, would be much appreciated. This information collection could include at least some of the data covered in such reports, including inventory, current and forecast production (planting intentions), sales, prices, inputs, and trade for both crop and livestock production. Also, questions to clarify the amount of acreage in conversion to organic production, together with conversion intentions, would greatly benefit the trade in anticipating medium-term buying and contracting possibilities. To help ensure the maximum usability of the survey, OTA requests that NASS confer with likely USDA users of NASS data, specifically ERS and AMS staff, in developing and refining the survey instrument.
In addition to general questions such as those above, there are also a number of questions that could be asked specific to organic production.
Many farms grow both organic and non-organic crops, sometimes due to a more or less permanent split operation, sometimes because of acreage in transition. Asking which crops were grown organically and of those that were not, which were in transition, would provide a useful check point for any subsequent regression of census data attempting to determine similar information. Clarifying which crops grown in mixed-use operations are organic would help reduce the likelihood of a possible misinterpretation of census data.
In addition, it would be important to quantify acreage and yields from certified organic fields, as opposed to acreage and yields from farms using organic methods but not marketing their crops as organic due to size, resistance to becoming certified, or other issues. This is important because crops grown on operations grossing less than $5000 are exempted from certification, but their produce may not be claimed as organic in manufactured organic products, and so may not enter the manufacturing supply chain.
Asking what organic production methods are used and preferred, including cultural pest and weed control measures and farm inputs (both fertilizers and materials for pest and weed control), would help in understanding the breadth of practice and any nascent consensus on practice. The OFRF survey mentioned above contains some relevant information on this, and on-going research would be helpful in determining any trends in this area.
Asking farmers to specify the number of crops in their crop rotations would demonstrate how farmers were complying with this requirement in the federal regulations, and would also be useful in determining the range of organic practices used.
OTA stands ready to assist NASS in identifying people who might use the results so that NASS can confer with them as necessary in developing and refining the survey instrument.
Thank you very much for your consideration.
Regulatory and Policy Manager