Ms. Ginny McBride
OMB Clearance Officer
U.S. Department of Agriculture, National Agricultural Statistics Service
Room 5336 South Building
1400 Independence Ave., SW
Washington, DC 20250
Re: Notice of Intent To Request a Revision to a Currently Approved Information Collection, 68 F.R. 48878, August 15, 2003; RIN 0560-AH03
Dear Ms. McBride:
The National Cotton Council of America submits the following comments concerning the notice and request for comments related to the National Agricultural Statistics Service intent to revise the Cotton Ginning Survey, published at 68 F.R. 448878, August 15, 2003. The National Cotton Council is the central organization of the United States cotton industry. Its members include producers, ginners, oilseed crushers, merchants, cooperatives, warehousemen, and textile manufacturers.
The notice invited comments on: (a) whether the proposed collection of information is necessary for the proper performance of the agency, including whether the information will have practical utility; (b) the accuracy of the agency’s estimate of the burden of the proposed collection of information including the validity of the methodology and assumptions used; (c) ways to enhance the quality, utility and clarity of the information to be collected; and (d) ways to minimize the burden of the collection of information on those who are to respond, including through the use of appropriate automated, electronic, mechanical, or other technological collection techniques or other forms of information technology.
The National Cotton Council is supportive of the continuation of this survey and greatly appreciates the opportunity to offer the following comments.
The National Cotton Council strongly believes that the collection of information for the Cotton Ginning Survey is necessary for the proper performance of the agency. The information is used widely by the industry and the survey provides a necessary crosscheck on the size of the crop and the progress of harvest. Prior to and during harvest, USDA provides monthly estimates of the cotton crop based on farmer surveys and objective boll count data, both of which provide valuable crop information. Weekly reports are released giving data on the progress of harvest. The combination of the two data provides an estimate of the amount of cotton production harvested at a given point in the season. However, the Cotton Ginnings report provides the first look at actual production. Data from the Ginnings report can be used as a crosscheck with production estimates and weekly crop progress data collected in other crop surveys conducted by the agency.
The agency’s estimate of the burden of the proposed collection seems to be accurate based on the approximately 900 cotton gins now operating and the frequency of survey requests and reports issued throughout the ginning season. We agree with the agency’s estimate.
The National Cotton Council would encourage the agency to investigate any and all methods of electronic collection of the survey data. Use of email, website or other electronic based technologies should be thoroughly investigated in an effort to reduce and possibly eliminate telephonic or faxed based written inquiries and submissions. While most, if not all, gins have internet connection capability and, thus, are able to respond electronically to inquiries, there remain a handful of operations that do not have this capability. The Council would encourage an appropriate phase in period for any new collection methodology so that the ginning industry can uniformly respond to the survey requests in a consistent electronic format that is determined to be efficient and effective. The Council would offer to assist the agency in experimenting and proving out new collection methods whenever the agency is ready to do so.
In closing, the National Cotton Council strongly encourages the continuation of the Cotton Ginning Survey and the reporting of the survey results.
Robert W. Greene, Chairman
National Cotton Council of America