Programs Submission Response: ARC/PLC

ISSUE
There are surprising holes in NASS data-counties that have production and have always had yield info but don’t for 2014 (3 of the top 10 counties for acres planted fall into this category), we have a county with a grain yield of 175 and a silage yield of 15. And overall, there is concern that the benchmarks were established using NASS data and we hear the annual yields will use a different formula.

FACTS
Yield issues are still coming up. We have counties that are next door and similar everything. Their revenues are $138 apart. One count is capping at $70 the other is $67 short of a payment.

Producers and COF would like:

  • The final yield data. The yields are still not published as we were told they would be.
  • The information that support the yield. (Show your work on the math. How did we get to this final number?)
  • The reference to where this formula comes from. We are told the formula is not appealable. Where is the formula available? When I looked before I didn’t find it in the Federal Register or 1-ARCPLC.
  • What options were STC given to adjust benchmark and annual yields? A big issue in our counties is the benchmark yields. Were these adjusted for disasters?
  • STC was given a chance to look at yields around the 19th of October. What “rights” were they given?

SOLUTION
NASS district yield be used over the RMA yield in priority order.

NATIONAL OFFICE RESPONSE
The National Programs Chair inquired with WDC to see if they knew why there was less NASS data for 2014 then there had been previous years. WDC didn’t know for sure but hazarded that it might be due to not enough producer’s returning the surveys. FSA must use NASS data whenever it is available. Only when NASS data is unavailable can DAFP use any other data. WDC has clarified that they established a method for determining the best data available to use assigning the yield (whenever NASS data is unavailable) as RMA data then NASS district. If NASS district yields were assigned, then STC’s were asked to review them to ensure they were reasonable for the county. In order to be consistent this method was used in all states and counties.

We probably need to start educating our producers on how important providing accurate data to USDA is. I’ve heard stories of producers who under-inflate their information to NASS because they “don’t want the government to know what they’re doing”. Conversely, I’ve heard of producer over-inflating their data to RMA to try and boost their APH’s. Even the COC’s are just making the best estimates they can when they set county average yields and aren’t typically using any hard data (beside maybe their own production). The fact of the matter is that you can point to any of the yield data and find a flaw in it. I’m not defending the DAFP ranking, but I can see their reasoning. NASS data is based on statistical methods. RMA data is based on actual reported production. NASS District is regional. COC data is estimated at best or guesswork at worst. None of it is perfect, but there isn’t perfect data out there for them to use.

Finally, you asked about the state office review of the 2014 yields that appeared off. I don’t know what percentage of the submissions that DAFP may have altered, but I do know that some states submitted changes that were not accepted. I think primarily it’s because they were questioning NASS yields and ,as I mentioned before, the regs require NASS data to be used when it’s available. They may have reconsidered some RMA or NASS data yields that STO’s were concerned about, but my guess is they would have had to provide some hard data to justify a change.