Programs Submission Response: ARC/PLC Reports

ISSUE:
ARCPLC reports show only farm numbers but not producer information.

FACTS:
Researching ARCPLC can be time consuming since offices often need to manually identify which producers are associated with the farms on various ARCPLC reports. CARS reports were recently updated to list both the farm number and the operator. While some individual farm contracts may have OW or OTs with shares, having the OP listed in ARCPLC reports also would greatly speed up the research in most cases.

SOLUTIONS:.
List the OP name along with the farm number in ARCPLC reports.

NATIONAL OFFICE RESPONSE:
This enhancement is on our list for ARC/PLC. I am not sure of a timeframe due to more pressing issues but we do hope to make this change on most reports. As an interim solution I would recommend using the ARCPLC reports with the MIDAS farm record reports made available in notice CM-774.  With a little cutting and pasting in Excel users can take the list from ARC/PLC and match it to the current producer data stored in MIDAS to get the names of all the OW, OP, and OTs as needed. I do realize this will leave a few gaps for prior years but should be a huge time savings compared to looking them all up one by one.

Programs Submission Response: ARC/PLC

ISSUE:
Annual ARCPLC enrollment is scheduled to begin on December 1 of each year.  However many states have a November 15th deadline for small grains or hay.  Having enrollment begin on December 1 means that we just miss being able to enroll the producers who are coming into the office in November.  This means that the producer is likely to wait until the July reporting timeframe to complete his enrollment, which is a much busier time of year for us.

FACTS:
July is just a crazy time for us.  We used to spread the work between June and July, but with hay now being in November, we don’t see any June activity.   We’ve been looking for a way to spread out the workload in July already.  In my office we had just under 1000 farms on the July acreage reporting register last year, and that was with no DCP or ARCPLC.  This year we had a temp helping us with signup and acreage reporting and we still had over 1000 farms on the register and went into August with acreage reporting.

SOLUTION:
Allow ARCPLC enrollment to begin in October or November.  It would be easier to fit ARCPLC in November for those who had hay and ease up the work in July.  If allowing earlier signup would be something that could be considered then I think it would be greatly appreciated.

NATIONAL OFFICE RESPONSE: (paraphrased)
WDC is willing to look into moving the beginning enrollment date for ARCPLC up from December to maybe November.  This will allow producers who are making appointments in November to begin enrollment and to allow County Offices to manage workload.  Unfortunately, there is not enough time to enact these changes for the 2016 year.  However, they will endeavor to allow earlier enrollment in subsequent years.

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.

Programs Submission Response: ARC/PLC

ISSUE
When CO’s are using the “CCC Representative Electronic Approval” option for a large number of farms they are getting a URL error (screenshot attached).  This means that they are having to click a random number of each little box, which equal thousands in some cases, in order to allow the software to approve them.

SOLUTION
Can the software be updated to either remove the error and allow the user to select all farms and then approve them?  Or can the results be edited to only show the maximum allowable amount of farms to approve at a time (multiple pages), then allowing the select all/approve to work?

NATIONAL OFFICE RESPONSE:
The correction to this software defect is secluded to be released this week, after that correction is in place, users will be able to submit 5,000 approvals at a time without error.