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Fertilizer Usage Data, Improve Outreach, and Better Leverage 
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Report to Congressional Requesters: 

United States Government Accountability Office: 
GAO: 

November 2010: 

Agricultural Chemicals: 

USDA Could Enhance Pesticide and Fertilizer Usage Data, Improve 
Outreach, and Better Leverage Resources: 

GAO-11-37: 

GAO Highlights: 

Highlights of GAO-11-37, a report to congressional requesters. 

Why GAO Did This Study: 

The use of pesticides and fertilizers contributes to U.S. agricultural 
productivity and helps ensure a generally stable, plentiful, and 
inexpensive food supply. However, these chemicals may also harm human 
health, water quality, and food safety. The U.S. Department of 
Agricultureís (USDA) National Agricultural Statistics Service (NASS) 
collects, analyzes, and disseminates Agricultural Chemical Usage (ACU) 
data to meet regulatory, business, and other informational needs. In 
fiscal years 2007 through 2009, NASS substantially scaled back the ACU 
program before restoring it in 2010. GAO was asked to examine (1) what 
factors NASS considered in reducing the ACU program; (2) how ACU data 
users were affected by the temporary cutback, and their views on the 
dataís quality and usefulness; and (3) the extent to which 
agricultural pesticide and fertilizer usage data are available from 
sources other than NASS. GAO reviewed relevant NASS documents and 
interviewed NASS officials as well as 25 selected ACU data users. 

What GAO Found: 

Operating under the constraints of a continuing resolution in fiscal 
year 2007, NASS considered a number of factors in reducing the ACU 
data program. These factors included NASSís assessment that there 
would be no impact on the agricultural commodities market and that 
chemical usage data were available from other sources. However, the 
agency did not consult ACU data users in its decision making or gauge 
the potential impact of the programís cutback on usersí regulatory, 
business, and other needs for the data. Federal guidance directs 
agencies managing information to consult, and consider the effects of 
decisions on, data users, yet NASS officials told GAO they did not 
formally communicate with users until the 2007 budget was finalized. 
NASS officials also said that they had limited information on who used 
ACU data and why, which hampered the agencyís ability to gauge the 
impact of the programís reduction. The ACU data users GAO interviewed 
said they generally disagreed with NASSís decision factors because 
they perceived the factors to be irrelevant or misapplied to the ACU 
program. 

Most users told GAO they relied on older ACU data during the programís 
reduction, which hindered their ability to make informed decisions 
because agricultural chemical use can change from year to year due to 
the emergence of new pests, weather variations, changing market 
conditions, and other factors. All 25 users also said they regard ACU 
data to be high quality and generally useful for their purposes, but 
they identified some areas for enhancing the data. Specifically, 
nearly all users said the ACU data would be even more useful if the 
data were disseminated more frequently, in greater geographic detail, 
or with additional data elements. Toward that end, NASS has entered 
into cooperative agreements with some states to provide additional ACU 
data, but the agencyís ability to enter into such agreements may not 
be widely known by state agency officials due to limited outreach by 
NASS. In addition, ACU reports, data tools, and related resources on 
NASSís Web site are difficult to locate, and the online data tools are 
incomplete, which hampers usersí ability to access and use ACU data. 
While NASS has several mechanisms to gather input from its data users, 
such as general comment forms on NASSís Web site, most users indicated 
these mechanisms are not effective in ensuring ACU data continue to 
meet their needs. 

Agricultural pesticide and fertilizer usage data are also available 
through several state, private, and other sources. These data sources 
vary in their cost, geographic and crop coverage, level of detail, and 
other attributes. While many ACU data users reported that they rely on 
other sources to supplement NASSís data, nearly all emphasized that 
other sources do not replace ACU data. These users said, and GAO 
found, that NASS is the only source of publicly available data 
reflecting the actual application of pesticides and fertilizers on a 
wide array of crops on a national scale. However, NASS has not 
systematically identified and evaluated other publicly available data 
sources. As a result, the agency does not have assurance that it is 
fully leveraging limited government resources, maximizing 
efficiencies, and minimizing potential overlap in its ACU data 
collection. 

What GAO Recommends: 

GAO recommends, among other things, that NASS establish a formal 
mechanism to identify and consult ACU data users on an ongoing basis 
and that NASS identify and evaluate other publicly available 
agricultural chemical usage data sources to better leverage resources 
and reduce potential overlap. USDA agreed with GAO's recommendations 
and noted specific actions it will take to implement them. 

View [hyperlink, http://www.gao.gov/products/GAO-11-37] or key 
components. For more information, contact Lisa Shames at (202) 512-
3841 or shamesl@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

NASS Considered Five Factors but Did Not Consult Users before Reducing 
ACU Data Program: 

Users Relied on Older ACU Data During Program Reduction and Said the 
Data Are High Quality but Could Be Enhanced: 

Other Sources Provide Agricultural Chemical Usage Data, and NASS May 
Not Be Fully Leveraging Resources or Minimizing Overlap with These 
Sources: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Other Sources of Agricultural Chemical Usage Data: 

Appendix III: Comments from the U.S. Department of Agriculture: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: NASS Cooperative Agreements with States to Provide Additional 
ACU Data, Fiscal Years 2006 through 2010: 

Table 2: Selected Attributes of Other Agricultural Pesticide and 
Fertilizer Usage Data Sources: 

Table 3: ACU Data Users Selected for Interview, by Type: 

Table 4: Terms Used in This Appendix and Questionnaire Definitions: 

Figures: 

Figure 1: A Tractor Applying Pesticides to Lettuce in California: 

Figure 2: Time Line of Key Events Related to NASS's Decision to Reduce 
and Restore the ACU Program: 

Figure 3: NASS's New "Agricultural Chemical Use Program" Web Page, as 
of October 2010: 

Abbreviations: 

AAPCO: Association of American Pesticide Control Officials: 

AAPFCO: Association of American Plant Food Control Officials: 

ACU: Agricultural Chemical Usage: 

ADA: Arizona Department of Agriculture: 

APMC: Arizona Pest Management Center: 

CDMS: Crop Data Management Systems: 

CDPR: California Department of Pesticide Regulation: 

EPA: U.S. Environmental Protection Agency: 

ESA: Endangered Species Act: 

FQPA: Food Quality Protection Act of 1996: 

FSA: Farm Service Agency: 

IDALS: Iowa Department of Agriculture and Land Stewardship: 

MDA: Minnesota Department of Agriculture: 

NASDA: National Association of State Departments of Agriculture NASS 
National Agricultural Statistics Service: 

NRCS: Natural Resources Conservation Service: 

OMB: Office of Management and Budget: 

USDA: U.S. Department of Agriculture: 

USGS: U.S. Geological Survey: 

WSDA: Washington State Department of Agriculture: 

November 4, 2010: 

The Honorable Brad Miller: 
Chairman: 
Subcommittee on Investigations and Oversight: 
Committee on Science and Technology: 
House of Representatives: 

The Honorable Lynn Woolsey: 
House of Representatives: 

The use of pesticides and fertilizers contributes to U.S. agricultural 
productivity and helps ensure a generally stable, plentiful, and 
inexpensive food supply. Over the last 40 years, according to an 
industry group, the use of such agricultural chemicals--an industry 
with more than $24 billion in sales in 2007--has helped increase U.S. 
crop productivity by as much as 50 percent. However, the use of 
agricultural chemicals may also harm human health, water quality, 
animal and plant species, and food safety. For example, atrazine, one 
of the most widely used pesticides in the United States, has been 
found to be a common contaminant in drinking water and waterways and 
may harm aquatic plants and invertebrates. In addition, fertilizers 
contain nitrate, which can contaminate the groundwater that provides 
drinking water for over 100 million Americans and can harm infants and 
pregnant women. Consequently, federal agencies such as the U.S. 
Environmental Protection Agency (EPA), state agencies, chemical 
manufacturers, commodity groups, public interest organizations, 
academic researchers, and others monitor the extent, amount, or 
frequency of agricultural chemicals applied on U.S. crops. These 
entities use the U.S. Department of Agriculture's (USDA) Agricultural 
Chemical Usage (ACU) data, which are collected, analyzed, and 
disseminated by USDA's National Agricultural Statistics Service 
(NASS), to meet regulatory, business, and other informational needs. 

NASS reports ACU data for selected states and crops, aggregated at the 
individual state level and at a combined "program states" level for 
all states covered by a given survey. ACU data elements include the 
number of planted acres, percentage of planted acres treated with a 
given chemical, amount of active ingredient applied per acre 
(application rate), number of applications, and total amount applied 
during a production year. NASS typically surveys farmers in the fall 
at the end of the production year and releases ACU data the following 
spring or summer. These data are available to the public for free and 
are disseminated on NASS's Web site. From 1990 through the 2006 
production year, NASS conducted in-person surveys of farmers to 
collect and disseminate data on the actual application on the land of 
agricultural pesticides and fertilizers on a wide array of major 
field, fruit, and vegetable crops, as well as pesticide use on 
livestock animals and facilities, nursery and floriculture crops, and 
postharvest crops in storage. NASS started collecting these data 
following public outcry in the late 1980s over a pesticide called 
Alar, a plant growth regulator formerly used on apples and other 
crops. Lacking information on farmers' actual application of Alar or 
the level of exposure risk, consumers panicked by avoiding apples and 
apple products, severely harming the U.S. apple industry. After EPA 
proposed banning the pesticide based on evidence that lifetime dietary 
exposure may result in an unacceptable cancer risk, the manufacturer 
removed Alar from the marketplace in June 1989. 

According to NASS, the agency spent $7.6 million on the ACU program in 
fiscal year 2006, but starting in fiscal year 2007, the ACU program 
was substantially scaled back because of budget constraints associated 
with operating under a continuing resolution.[Footnote 1] As a result, 
NASS reported chemical usage only on apples, organic apples, cotton, 
and nursery and floriculture crops in fiscal year 2008, and no ACU 
data were reported in fiscal year 2009. After NASS made the decision 
to scale back the ACU program, NASS officials said the Secretary of 
Agriculture and other senior USDA officials received hundreds of 
letters, as well as many e-mails and telephone calls, from a wide 
range of ACU data users--including state pesticide control officials, 
commodity groups, chemical manufacturers and industry organizations, 
and public interest groups--urging the department to restore the 
program. Users also expressed their concern about the loss of ACU data 
to various congressional committees. 

Subsequently, the Senate Appropriations Committee directed USDA to 
carry out the ACU program in fiscal year 2009 and notify the committee 
in advance of any termination of other ongoing NASS activities. In 
addition, an explanatory statement accompanying the Omnibus 
Appropriations Act, 2009, directed $2.45 million to the ACU program in 
fiscal year 2009, and the 2010 Agriculture Appropriations conference 
report directed another $5.75 million to the program, from the 
agency's general appropriation. In May 2009, NASS announced its plans 
to conduct the fruit chemical usage survey, which was conducted that 
fall, and in fiscal year 2010, NASS fully restored the ACU program by 
resuming the field crop, nursery and floriculture, and postharvest 
surveys as well. Agency officials plan to continue the program in full 
in future years, including vegetables and potentially livestock, 
assuming funding remains stable. 

In this context, and in response to your request, our objectives were 
to determine (1) the factors NASS considered in reducing the ACU 
program in fiscal years 2007 through 2009; (2) how ACU data users were 
affected by the temporary cutback, and their views on the quality and 
usefulness of the data; and (3) the extent to which agricultural 
pesticide and fertilizer usage data are available from sources other 
than NASS. 

In conducting our work, we reviewed NASS documents, Office of 
Management and Budget (OMB) guidance to federal agencies managing 
information resources, and other relevant federal agency documents. We 
also interviewed NASS officials and a nongeneralizable sample of 25 
ACU data users, including officials from EPA and other federal and 
state agencies; representatives from chemical manufacturers, commodity 
groups, and public interest organizations; and academic researchers. 
We identified the selected ACU data users through interviews with NASS 
officials and other users, letters written by users urging USDA to 
restore the ACU program, and other methods. We also reviewed NASS's 
controls for the information system that stores the ACU data. To 
determine the factors that NASS considered in reducing the program, we 
reviewed documents from NASS and interviewed NASS officials and the 25 
selected ACU data users. To determine how the selected ACU data users 
were affected by the temporary cutback, and their views on the quality 
and usefulness of the data, we interviewed them and reviewed documents 
they provided. To determine the extent to which agricultural pesticide 
and fertilizer usage data are available from sources other than NASS, 
we first identified as many sources as we could through our 
interviews, document review, and other methods. We then distributed a 
questionnaire to these sources to collect information on the 
attributes of their data. We analyzed interviews, documents, and 
questionnaire responses to identify main themes and develop summary 
findings. For the purpose of characterizing the 25 selected ACU data 
users' views throughout this report, we identified specific meanings 
for the modifiers we used to quantify users' views, as follows: 
"nearly all" users represents 21 to 24 users, "most" users represents 
16 to 20 users, "many" users represents 11 to 15 users, "several" 
users represents 6 to 10 users, and "some" users represents 3 to 5 
users. Appendix I contains a more detailed discussion of our scope and 
methodology, including a complete list of ACU data users we 
interviewed. 

We conducted this performance audit from October 2009 to November 
2010, in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Background: 

In 1990, NASS began surveying farmers to determine the types and 
quantities of pesticides and fertilizers being used on selected field 
crops, fruits, and vegetables. NASS launched this ACU data collection 
to provide reliable data to improve government decisions on food 
safety and water quality, assist in the analysis of pesticide 
policies, and inform the public of the safety of the nation's food 
supply. Key objectives of this effort were to (1) collect 
comprehensive, statistically valid, and scientifically based pesticide 
usage data and (2) provide EPA with data that it could use in making 
decisions to approve (register) pesticide products. Figure 1 shows a 
tractor applying pesticides to a crop. Because fertilizer runoff 
affects water quality, agricultural fertilizer usage has also been 
part of the ACU program since its inception. Under the Clean Water 
Act, states prepare management programs to control pollution from 
nonpoint sources, which include agricultural runoff. 

Figure 1: A Tractor Applying Pesticides to Lettuce in California: 

[Refer to PDF for image: photograph] 

Source: USDA. 

[End of figure] 

The ACU program covers selected field crops, fruits and vegetables, 
postharvest chemical usage, nursery and floriculture, and livestock 
animals and facilities, as follows: 

* Field crops are surveyed annually with varying crop coverage: corn, 
cotton, and potatoes are surveyed in odd-numbered years; soybeans and 
wheat are surveyed in even-numbered years; and other field crops, 
including sugar beets, sugar cane, oats, peanuts, rice, and barley, 
are surveyed less frequently, often in conjunction with USDA's 
Economic Research Service. 

* Fruits and vegetables are each surveyed every 2 years on an 
alternating schedule, and these surveys have covered a total of 25 
fruits and 29 vegetables in recent years. 

* The postharvest survey is done annually on selected field crops, 
fruits, or vegetables surveyed the prior year. 

* The nursery and floriculture survey is conducted every 3 years and 
has included 19 crops in recent years. 

* The livestock survey--which has covered beef and dairy cattle, 
swine, and sheep in the past--is done in conjunction with USDA's 
Animal and Plant Health Inspection Service, and there is no 
established frequency of these surveys. 

All ACU surveys cover pesticide use and pest management practices, 
while the field crop, fruit, and vegetable surveys also cover 
fertilizer use. The ACU fertilizer data includes information on the 
four primary nutrients found in fertilizers: nitrogen, phosphate, 
potash, and sulfur. In addition, NASS compiles and disseminates 
supplemental reports on topics such as restricted-use pesticides, 
[Footnote 2] which excerpt and summarize information contained in the 
standard ACU data disseminated in a given year. 

NASS operates through a network of 46 field offices, which serve all 
50 U.S. states and Puerto Rico. These field offices are generally 
funded and staffed with both federal and state resources, which, 
according to NASS, is more efficient than operating separate federal 
and state agencies. For each ACU survey, NASS relies on data 
collectors--also called enumerators--to conduct in-person interviews 
with farmers and to review documentation of their on-farm use of 
pesticides and fertilizers. Farmers provide this information 
voluntarily on a confidential basis. The NASS field offices oversee 
the data collection and analysis to produce state statistics before 
headquarters officials further analyze and disseminate the data. ACU 
data do not represent the total use of any agricultural chemical at 
the national or state level. Instead, NASS collects ACU data in states 
which collectively represent at least 75 percent, and as much as 100 
percent, of the planted acres nationwide for each crop surveyed. Farms 
in these states that produce the crops of interest are eligible to be 
included in the sample surveyed and are selected on a probability 
basis proportional to their acreage. 

ACU data users include federal agencies, state agencies, chemical 
manufacturers, commodity groups, public interest organizations, and 
academic researchers. For example, EPA's Office of Pesticide Programs 
uses ACU data for its reregistration reviews, as well as to evaluate 
the registration of new uses for previously registered products. The 
Federal Insecticide, Fungicide, and Rodenticide Act gives EPA 
responsibility for regulating the sale and use of pesticides in the 
United States through evaluating and registering pesticide products; 
restricting the use of pesticides as necessary to protect human health 
and the environment; and periodically reviewing whether older 
pesticides continue to meet the standard for registration. In 
addition, the Food Quality Protection Act of 1996 (FQPA) required EPA 
to reassess all existing tolerances (maximum residues legally allowed) 
and to prioritize the review by focusing on pesticides posing the 
greatest risks first. FQPA also specifies that the Secretary of 
Agriculture should make aggregate data available to EPA that are "of 
statewide or regional significance on the use of pesticides to control 
pests and diseases of major crops and crops of dietary significance, 
including fruits and vegetables." According to EPA officials, the 
agency completed its reregistration reassessments in 2008 and its 
tolerance reassessments in 2007 and is currently reviewing older 
pesticide registrations on an ongoing basis as part of its 
registration review program. Meanwhile, the sale and use of 
fertilizers are generally regulated at the state level. However, 
because EPA considers agriculture to be one of the largest sources of 
water pollution in the United States, and because fertilizer is a 
primary water quality concern, EPA's Office of Water uses ACU data to 
model environmental trends at a national level and to assist states in 
their oversight of water quality in support of the Clean Water Act. 

The Department of the Interior's U.S. Geological Survey (USGS) also 
uses ACU data to analyze and model water quality data and to discern 
geographic patterns of agricultural pesticide usage over time. For 
example, USGS uses ACU data in its National Water-Quality Assessment 
Program, which assesses the condition of the nation's streams, rivers, 
and groundwater; measures how these conditions change over time; and 
explores how human activities affect these conditions. As part of this 
program, USGS uses ACU data to measure the success of integrated pest 
management implementation efforts.[Footnote 3] Agencies within USDA, 
including the Economic Research Service, Office of Pest Management 
Policy, Farm Service Agency, Agricultural Marketing Service, and 
Natural Resources Conservation Service (NRCS) also use ACU data. For 
instance, NRCS uses the data to quantify the environmental benefits 
and effects of conservation practices used by conservation program 
participants to control the runoff of agricultural chemicals. 

In addition, state government agencies use ACU data for a variety of 
purposes, including assessing pesticides' impacts on water quality and 
evaluating the need for special pesticide registrations and emergency 
exemptions.[Footnote 4] Chemical manufacturers and commodity groups 
use ACU data to identify industry trends and for marketing, research 
and development, and other business purposes. Commodity groups also 
use ACU data to help access foreign agricultural markets because ACU 
data enable them to demonstrate the types and amounts of chemicals 
typically used in the United States on crops grown for export. Public 
interest organizations use ACU data for a number of purposes, 
including measuring the impact of genetically engineered crops on 
pesticide use. Academic researchers use ACU data for a multitude of 
purposes, including measuring agricultural pesticide and fertilizer 
use to assess the environmental impact of biofuels made with 
agricultural products, assessing the impact of integrated pest 
management, and monitoring the transition to organic and sustainable 
agriculture. ACU data are also used to assess agriculture's 
contribution to climate change since, according to EPA, the nitrogen 
in fertilizer can form nitrous oxide, a potent greenhouse gas. 

NASS Considered Five Factors but Did Not Consult Users before Reducing 
ACU Data Program: 

NASS considered five factors in significantly reducing the ACU data 
program in fiscal year 2007. However, the agency did not consult users 
in its decision making or gauge the potential impact of the program's 
cutback. Users subsequently told us they generally disagreed with 
NASS's decision factors because they perceived the factors to be 
irrelevant or misapplied to the ACU program. 

NASS Considered Five Factors in Significantly Reducing the ACU Data 
Program in Fiscal Year 2007: 

NASS considered five factors in significantly reducing the ACU data 
program in fiscal year 2007. Operating under the constraints of a 
continuing resolution and faced with $7.25 million in increased costs 
related to conducting the statutorily required 2007 Census of 
Agriculture, a NASS senior executive team reviewed the agency's entire 
portfolio of programs in December 2006 and cut more than $12 million 
worth of planned expenditures to balance its budget. NASS initially 
considered several cost-cutting measures across its portfolio--such as 
reducing sample sizes, the number of states covered, and the frequency 
of data reports--but rejected these measures because they would have 
reduced data quality and consistency. Instead, NASS officials said 
they decided to eliminate or substantially scale back certain programs 
that would not compromise the agency's commitment to provide high-
quality data. The ACU program absorbed most of the shortfall, while 
other cutbacks included a freeze on NASS's hiring, travel, equipment, 
and training. Five other data programs were also eliminated or 
reduced, including quarterly farm labor surveys used by the U.S. 
Department of Labor and nursery and floriculture production surveys. 
NASS officials said that, based on an internal program review team 
that ranked the relative importance of the agency's data programs in 
2001, the senior executive team looked at nearly 40 programs that had 
been identified as lower priority, including ACU and the other 
programs it cut. 

NASS officials said that five factors determined the senior executive 
team's decision in fiscal year 2007 to cut ACU and the other data 
programs. Of those five factors, four were applied broadly, as follows: 

* the data are not principal economic indicator data, as designated by 
OMB,[Footnote 5] 

* the data do not directly impact the agricultural commodities market, 

* the data are not necessary to implement USDA programs that provide 
payments to farmers and are used to administer the farm safety net, 
and: 

* there are other data sources available. 

In addition, in its decision to cut the ACU program specifically, NASS 
officials stated another factor weighed heavily: 

* a 2006 NASS advisory subcommittee had stated "not only is expansion 
of NASS pesticide use data unfeasible, but support for the program in 
its current state is quite soft."[Footnote 6] 

In February 2007, when NASS received an additional $7 million in the 
final budget, the agency restored some of the data program cuts, 
including $800,000 for the ACU nursery and floriculture survey 
conducted that year. However, NASS did not reinstate the ACU field 
crop, fruit, vegetable, and postharvest surveys that originally had 
been planned for the 2007 and 2008 production years. In NASS's view at 
that time, the agency would have needed an additional $7.6 million to 
fully restore the ACU program to its 2006 level and, in the absence of 
such funding, NASS planned to survey in future years a limited number 
of crops' chemical usage every 5 or 6 years, and other crops even less 
frequently. 

NASS Did Not Consult ACU Data Users to Gauge the Potential Impact of 
the Program's Cutback: 

OMB guidance directs federal agencies managing information to consult 
with, and consider the effects of decisions and actions on, the public 
and state and local governments.[Footnote 7] However, all 25 ACU data 
users we interviewed indicated, and NASS officials confirmed, that 
users were not consulted before or after NASS's decision to cut the 
ACU program, and therefore the agency did not assess how users would 
be affected by the lack of data. For example, officials from the 
National Association of State Departments of Agriculture (NASDA)--
which represents state agencies who use the data and, under contract 
with NASS, hires the enumerators to conduct the ACU surveys--said NASS 
did not consult them. If they had been consulted, the NASDA officials 
stated, they would have argued that states need the data to make 
regulatory and other decisions pertaining to pesticides and pest 
management. Similarly, officials from EPA and the Association of 
American Pesticide Control Officials (AAPCO)--which represents state 
officials who regulate pesticide use in their respective states-- 
indicated they were not consulted by NASS and were taken by surprise. 
Nearly all data users learned of the decision after the fact through 
informal communication with NASS officials or from other data users in 
2007 and 2008. Several users said they also learned of the decision 
through official notices in the Federal Register that NASS published 
in May 2007 and March 2008. By then, however, the 2007 budget--and 
therefore the decision to cut the ACU program--was final. 

NASS officials told us that, as is common practice for federal 
agencies operating under a continuing resolution, they did not 
formally communicate the agency's decision to users until the 2007 
budget was finalized. We have previously reported that operating under 
continuing resolutions has created management challenges for federal 
agencies, including limiting their decision making options and making 
trade-offs more difficult.[Footnote 8] In addition, NASS officials 
said that due to the publicly available nature of their data, they had 
limited information on who used ACU data and why. As a result, the 
agency's ability to gauge the potential impact of the program's 
reduction on users' regulatory, business, and other needs for the data 
was hindered. While NASS had been aware, prior to the cut, that ACU 
data were used by other USDA agencies, EPA, and commodity groups, 
there was an outpouring of support for the program that ensued from a 
wide range of users, including organizations representing state 
agencies, chemical manufacturers, and public interest groups. 

Users Generally Perceived NASS's Decision Factors to Be Irrelevant or 
Misapplied: 

Most ACU data users we interviewed told us that they perceived three 
or more of NASS's decision factors to be irrelevant or misapplied to 
the ACU program, and all 25 users disagreed with at least one factor. 
Specifically, many users said two factors--that ACU data are not 
designated principal economic indicator data, and that USDA does not 
need the data for its farm payment or safety net programs--may be 
meaningful to NASS or USDA, but they were not relevant to the users. 
For instance, NASDA officials pointed out that these factors did not 
reflect the reasons the ACU program was created, which was to provide 
important information to EPA and the public. Furthermore, officials 
from NRCS and USDA's Farm Service Agency (FSA) told us that they have 
historically used ACU data to inform environmental models which, in 
turn, these agencies rely on to make payments to farmers for 
conservation programs. For example, an FSA senior economist stated 
that the ACU data are used not only to help target areas where 
agricultural runoff may be impairing water quality but also to help 
assess the results of its Conservation Reserve Program by evaluating 
fertilizer usage trends. In addition, several users argued that, 
contrary to NASS's assessment, the lack of ACU data could negatively 
impact the commodities market. For example, in the absence of ACU 
data, EPA and the public might cautiously, but perhaps erroneously, 
assume a chemical of concern was used on a widespread basis--similar 
to the Alar-on- apples scare in the late 1980s that led to the ACU 
program's creation. Moreover, while there are other data sources 
available, all 25 users said that they rely on ACU data to meet their 
informational needs, largely because other sources are not publicly 
available on a national scale. (For the purposes of this report, the 
term "publicly available" refers to data that are free of charge, 
easily accessible to the public, and do not have proprietary 
restrictions on their use or dissemination.) 

Finally, most users said they disagreed with the statement made by the 
2006 NASS Advisory Subcommittee on Pesticide Use Data that support for 
the ACU program was "soft" or said that NASS had taken the statement 
out of context. For example, the subcommittee co-chair and two members 
we interviewed pointed out that while the subcommittee concluded there 
was not a groundswell of interest to increase NASS's budget to expand 
the ACU program, the subcommittee also recommended that "no changes to 
the current NASS program are advised at this time." We also confirmed 
these statements through the subcommittee's report in February 2006 to 
the full NASS Advisory Committee on Agriculture Statistics. After NASS 
cut the program, the subcommittee co-chair spoke publicly to the full 
advisory committee in February 2008 to clarify the subcommittee 
statement that NASS had cited in its decision to cut the program. The 
co-chair asserted that NASS had misinterpreted the statement and that 
without ACU data, "there would be no more transparency for regulation 
and no chance for the agricultural community to review [EPA's risk] 
assessments for accuracy." At that same meeting, the full advisory 
committee--consisting of members from commodity groups, agricultural 
companies and producers, a chemical manufacturer, academia, 
government, and other entities--then recommended that NASS restore the 
ACU program by no later than 2009. Figure 2 shows the time line of 
events related to NASS's decision to reduce and restore the ACU 
program. 

Figure 2: Time Line of Key Events Related to NASS's Decision to Reduce 
and Restore the ACU Program: 

[Refer to PDF for image: timeline] 

February 2006: 
NASS Advisory Subcommittee on Pesticide Use Data recommends no changes 
to the ACU program. 

December 2006: 
Among other budget cuts under a continuing resolution, NASS decides to 
significantly reduce the ACU program. 

February 2007: 
With the final 2007 budget, NASS restores the ACU nursery and 
floriculture survey that year, but not other ACU surveys that 
originally had been planned. 

May 2007: 
NASS publishes a Federal Register notice announcing its intention to 
suspend the ACU vegetable and field crops surveys. 

October 2007: 
NASS starts to receive letters and other communication from ACU data 
users, urging the agency to restore the program. 

February 2008: 
NASS Advisory Committee recommends that the agency ďdetermine a way to 
find funds to reinstate the Chemical Use Program by no later than 2009.Ē
 

March 2008: 
NASS publishes a Federal Register notice announcing its intention to 
suspend the ACU fruit and postharvest surveys. 

July 2008: 
Senate Appropriations Committee directs USDA to carry out the ACU 
program in fiscal year 2009 and notify the committee in advance of any 
termination of other ongoing NASS activities. 

March 2009: 
An explanatory statement accompanying the Omnibus Appropriations Act, 
2009, directs $2.45 million from NASSís general appropriation to 
ďcarry out the Fruit Chemical Use Data studyĒ in fiscal year 2009. 

May 2009: 
NASS publishes a Federal Register notice announcing its intention to 
resume the ACU fruit survey and publish the data in July 2010. 

September 2009: 
Agriculture Appropriations conference report directs $5.75 million 
from NASSís general appropriation in fiscal year 2010 to restore the 
ACU program. 

October 2009: 
In fiscal year 2010, NASS fully restores the ACU program. 

Sources: GAO analysis of relevant documents. 

[End of figure] 

Users Relied on Older ACU Data During Program Reduction and Said the 
Data Are High Quality but Could Be Enhanced: 

Most users told us they relied on older ACU data during the program's 
reduction and said that a longer data gap would have further hindered 
their ability to make decisions. All users said they regard ACU data 
to be of high quality and generally useful for their purposes, but 
nearly all users stated that the data could be even more useful with 
more frequent reporting, greater geographic detail, and additional 
data elements. However, NASS officials said that implementing users' 
suggestions could significantly increase costs. NASS has entered into 
cooperative agreements with some states, on a reimbursable basis, to 
provide additional ACU data that may have broader public benefits, but 
its ability to do so may not be widely known due to limited outreach 
by the agency. In addition, NASS's online ACU resources are difficult 
to locate and incomplete, which limits ACU data users' ability to 
access and use the data. NASS has several mechanisms to gather input 
from data users, such as general feedback comment forms on NASS's Web 
site, but most ACU users indicated these mechanisms are not effective 
in ensuring ACU data continue to meet their needs. 

Users Relied on Older ACU Data During Program Reduction and Said a 
Longer Data Gap Would Further Hinder Decision Making: 

In the absence of new ACU data in recent years, most users said they 
had to rely on older data, which hindered their ability to make 
informed decisions because agricultural chemical use can change from 
year to year due to the emergence of new pests, weather variations, 
changing market conditions, and other factors. For instance, users 
reported the following: 

* Michigan Department of Agriculture officials said that during the 
ACU program reduction, some pesticide products became obsolete while 
other, newly registered products had come into use that were not 
captured in the older data. They noted that, over time, older data 
become less valid for decision making purposes. These officials also 
said that while fertilizer products have not changed substantially in 
recent years like pesticide products have, fertilizer use rates and 
types have changed--such as decreases in phosphorous use, and liquid 
instead of dry formulations. If current data had been available, they 
could have factored fertilizer usage changes into the state's outreach 
and education efforts to commodity groups. For example, Michigan is 
currently working with local communities and the fertilizer industry 
to develop standards and regulations for phosphorous use on turf grass 
to eliminate concerns of surface water contamination. 

* AAPCO officials said that, during the ACU program reduction, the 
Nebraska Department of Agriculture had recently looked at ACU data on 
corn and soybeans because of concerns about two particular herbicides--
atrazine and metolachlor--in waterways. Because the most recent ACU 
data covered the 2005 and 2006 production years, Nebraska officials 
were limited in their ability to make informed decisions and had to 
assume, rightly or wrongly, that farmers had not changed their 
herbicide use in more recent years. These decisions pertained to 
regulatory decisions on pesticide use restrictions, estimating where 
pesticides of highest risk are used, setting priorities for compliance 
monitoring, and allocating resources. In addition, the AAPCO officials 
noted that the ACU data gap would create a visible break in the charts 
and tables that state agencies disseminate to the public to illustrate 
long-term trends in pesticide use. 

* The Fertilizer Institute--a national organization representing 
producers, importers, wholesalers, retailers, and others involved in 
the fertilizer industry--pointed out that the most recent ACU corn 
fertilizer data available are from the 2005 production year. While the 
institute's analysis of these data shows that fertilizer use per 
bushel declined from 1990 to 2005, the institute cannot determine 
whether this trend has continued or changed in recent years, when corn 
production has surged due to increased demand for ethanol. 

* An official from the Florida Department of Agriculture and Consumer 
Services--which is required by state law to compile usage information 
on restricted-use pesticides every 3 years--said his agency relies 
heavily on NASS for this information. Given the ACU data gap, this 
state agency will have substantially less information to report since 
resource constraints prevent the state from collecting its own 
pesticide usage data. In addition, since 2005, Florida--the nation's 
second-largest fruit-producing state--has grappled with the rapid 
spread of a disease called citrus greening, which has caused farmers 
to be more aggressive in applying pesticides to protect their crops. 
The Florida official said that the older ACU data do not reflect these 
changes, thus limiting the state's ability to evaluate the potential 
adverse impacts of pesticides on water resources. 

* Researchers from the Center for Food Safety and The Organic Center-- 
nonprofit organizations that advocate for safe food production and 
sustainable agriculture--said the ACU data gap hampered their efforts 
in recent years to quantify an increase in the use of herbicides, 
particularly glyphosate, triggered by the adoption of genetically 
modified crops. These researchers stated that the lack of new ACU 
data, particularly for corn, has made it difficult to track and 
project herbicide use at a time when weeds have become resistant to 
herbicides, and corn production has surged. 

Nearly all users said a longer ACU data gap would further hinder their 
ability to make decisions. Examples are as follows: 

* EPA officials noted that before they knew the ACU program was being 
restored, they were discussing internally how to conduct risk 
assessments using only privately sourced pesticide use data. EPA 
officials stated that relying solely on private data sources would 
pose problems for the agency for three reasons: (1) EPA prefers to 
have multiple data sources as a quality check and has high confidence 
in NASS's statistical validity, (2) private data outputs cannot be 
disclosed to the public due to proprietary restrictions, and (3) ACU 
surveys include some crops that are not surveyed by private data 
sources. EPA prefers to make the data underlying its pesticide 
decisions as public as possible and, in doing so, EPA typically 
aggregates NASS's and private data outputs to comply with proprietary 
restrictions and avoid disclosing the private sources' specific data 
outputs. Furthermore, without sufficient chemical usage data, EPA 
officials said the agency might have to assume that 100 percent of 
crop acres were treated with a given pesticide. According to EPA, such 
an assumption would likely overstate usage, based on past ACU data 
showing that, in nearly all cases, less than 100 percent of crop acres 
were treated. In turn, this assumption could result in very 
conservative human health risk assessments showing risks above EPA's 
level of concern and lead to regulatory action, such as removing a 
pesticide product from the market, which would not occur if sufficient 
usage data were available. 

* A USGS official said that, in the long-term, a lack of current ACU 
fertilizer data would hinder federal, state, and local government 
efforts to control excess nutrients in large water bodies such as the 
Chesapeake Bay, Great Lakes, and Gulf of Mexico, as well as streams 
and aquifers. For example, the hypoxic zone in the northern Gulf of 
Mexico refers to an area along the Louisiana-Texas coast in which 
water near the bottom of the Gulf contains minimal oxygen (less than 2 
parts per million of dissolved oxygen), causing a condition referred 
to as hypoxia. Hypoxia can cause fish to leave the area and can cause 
stress or death to bottom-dwelling organisms that cannot move out of 
the hypoxic zone. Hypoxia is believed to be caused primarily by excess 
nutrients delivered from the Mississippi River in combination with 
seasonal stratification of Gulf waters. The USGS official added that 
the cost of the ACU program is proportionately small compared with the 
environmental challenges faced by regulators to control runoff from 
agricultural pesticides and fertilizers, particularly nitrogen, in 
water. 

* A NASDA official said that state agencies can temporarily rely on 
older data for planning purposes--such as targeting food safety 
samples to look for illegal chemical residues--but, in the long-term, 
the data would start to lose credibility. 

* An academic researcher at the University of Idaho noted that his 
recent analysis of herbicide use on soybeans--which supported the 
finding that U.S. farmers minimized their production costs to remain 
competitive--would not have been possible without ACU data. He 
stressed that a long-term data gap may lead to incorrect conclusions 
because older data may not reflect current practices. 

* The Director of the North Central Integrated Pest Management Center 
located at the University of Illinois commented that, without ACU 
data, it is difficult to evaluate whether targeted pest management 
practices---such as scouting to detect pests, weather monitoring, and 
analysis of soil and plant tissue--are reducing or altering pesticide 
use. 

Users Said ACU Data Are High Quality but Could Be Enhanced with 
Additional Information and Detail, Which NASS Said Would Be Costly: 

According to NASS's strategic plan, the agency's mission is to provide 
accurate, timely, and useful statistics in service of U.S. 
agriculture.[Footnote 9] As part of this mission, NASS strives to meet 
the agricultural data needs of those working in agriculture and others 
by objectively providing important, usable, and accurate statistical 
information needed to make informed decisions. All 25 users we 
interviewed said they consider ACU data to be of high quality-- 
accurate, relevant, and reliable--and generally useful for their 
regulatory, business, research, and other purposes. For example, 
several users complimented NASS for its rigor in collecting and 
analyzing what they regard to be a statistically valid sample of 
farmers, and some users complimented the agency for protecting the 
identity of individual respondents. While some users pointed out that 
data accuracy can only be as good as what farmer respondents tell NASS 
enumerators, none of the users raised any concerns about NASS's data 
collection, analysis, or storage. While we did not perform electronic 
testing of ACU data elements or trace a sample of data to source 
documents, we did review NASS's controls for the information system 
that stores the data. We found that NASS takes several measures to 
ensure the data's quality. For example, agency officials said that the 
enumerators are trained to catch and correct errors in farmers' 
responses, and NASS field offices and headquarters provide additional 
checks before and after the data are entered into NASS's information 
system. Many users also expressed satisfaction with NASS's 
transparency in disclosing the methodology used for ACU data 
collection, such as the number of respondents, acres, and states 
covered in the various ACU data reports. Several users said the timing 
of the data release-- generally in spring or summer, after the surveys 
are conducted in the fall--is reasonable and meets their needs, 
although some users, such as EPA and chemical manufacturers, would 
prefer receiving the data sooner. 

Nonetheless, nearly all users said the data would be even more useful 
if they were disseminated more frequently, in greater geographic 
detail, or with additional data elements.[Footnote 10] First, most 
users said more frequent ACU surveys of fruits, vegetables, and other 
minor crops, as well as the major field crops--corn, soybeans, cotton, 
and wheat--would allow users to more accurately track trends. For 
example, the Natural Resources Defense Council, a nonprofit 
environmental organization, has used ACU data to research what 
alternatives to methyl bromide exist for various fruits and 
vegetables.[Footnote 11] However, because crop conditions, including 
weather, change every year and impact chemical use, this organization 
said that annual data would better establish trends. Chemical 
manufacturer members we interviewed from the American 
Phytopathological Society--an organization of plant disease 
researchers--also noted that, because NASS does not survey every crop 
every year, users have to estimate the values for the years between 
data points, which may or may not be accurate, especially if there are 
unexpected pest outbreaks. Similarly, the American Nursery & Landscape 
Association and the Society of American Florists said that more 
frequent surveys of their crops-- which are currently surveyed every 3 
years--would provide a more accurate depiction of chemical use. 
According to The Fertilizer Institute, about 70 percent of fertilizer 
use pertains to corn, soybeans, cotton, and wheat, with corn alone 
accounting for about 50 percent of all fertilizer applied in the 
United States, by volume. Furthermore, corn, soybeans, and wheat 
comprise a significant portion of acres planted in the United States. 
Given the economic importance of these crops and the need to calculate 
nutrient use per unit produced, the institute believes that having 
annual data on these crops, particularly corn, is warranted. The 
National Corn Growers Association added that changes due to weather 
conditions and other factors can lead to an "outlier" year in 
pesticide and fertilizer use. Since ACU corn data are collected every 
other year, officials from this organization said that one outlier 
year can significantly skew trend analyses, whereas annual data would 
provide a more accurate picture. 

Second, many users stated that a greater level of geographic detail-- 
such as at an intrastate regional, county, zip code, or watershed 
level--would greatly enhance users' ability to focus on areas where 
chemical usage is changing and therefore assess potential 
environmental impacts. For example, officials from the U.S. Fish and 
Wildlife Service and the National Marine Fisheries Service said they 
would use ACU data more if the data included more geographic details, 
which would assist the agencies in narrowing the relevant geographic 
range for Endangered Species Act (ESA) consultations and actions. 
Currently, they said that because the data are aggregated at the state 
level, federal agencies cannot necessarily determine whether a 
chemical of concern is being used in areas where a threatened or 
endangered species has habitat. Similarly, AAPCO officials said that 
more geographic specificity would allow state pest control officials 
to target education and response efforts to help prevent or remediate 
pests and to monitor water quality impairments, such as atrazine 
contamination in small watersheds, where the source of contamination 
is unknown. For instance, an official from the Florida Department of 
Agriculture and Consumer Services--which relies on ACU data to refine 
risk assessments for pesticides based on how and where they are 
currently being used--pointed out that pest management practices for a 
crop grown in the southern part of the state may differ from practices 
used for the same crop grown in the northern part of state. The 
official said that if ACU data provided intrastate regional or county-
level detail, it would help the agency better assess potential 
exposure scenarios for nontarget organisms, such as endangered species. 

Third, many users said that additional data elements, particularly the 
timing and method of application, would further enhance their ability 
to gauge trends and impacts. For instance, Washington State Department 
of Agriculture officials said the timing of application is important 
for ESA assessments because a species may be more adversely affected 
by a pesticide at certain times of its life, such as when salmon are 
hatching and spawning, and knowing the application method is useful 
because aerial application has a greater risk of impacting waterways 
than does ground application. Similarly, AAPCO officials said that, 
for monitoring purposes, the timing of an application matters because 
pesticides can have greater environmental impacts under certain 
conditions, such as heavy runoff during rainfall or irrigation. EPA 
officials noted that one private data source provides many more data 
elements than NASS--including the pests that a chemical targets and 
the method of application--which EPA finds useful for its regulatory 
purposes. For example, if EPA determines that there are risks above 
the agency's level of concern for a particular application method of a 
given pesticide, it is important to know what application methods are 
commonly used to assess the impacts of restricting the method of 
concern. Regarding fertilizers, The Fertilizer Institute has suggested 
to NASS, among other things, that the agency should collect and report 
data on the timing and placement of fertilizers, as well as the use of 
specific fertilizers designed to enhance efficient use of nutrients 
for crops such as corn, wheat, and cotton. According to the institute, 
these additional data elements would enable ACU data users to evaluate 
farmers' adoption of best management practices that promote 
conservation and would assist in environmental modeling of greenhouse 
gas emissions. In addition, the institute said that ACU data on manure 
and biosolids would provide a more comprehensive picture of nutrient 
use. 

OMB guidance directs federal agencies, among other things, to 
establish and maintain communication with data users to ensure data 
meet their informational needs. OMB also directs agencies to (1) 
periodically review information systems to determine how mission 
requirements might have changed and whether the information continues 
to fulfill ongoing and anticipated mission requirements and (2) ensure 
the information delivers intended benefits to the agency and 
customers. In addition, OMB asserts that one of the basic assumptions 
of federal information resources is that the expected public and 
private benefits derived from government information should exceed its 
public and private costs, recognizing that the benefits may not always 
be quantifiable.[Footnote 12] In this regard, we note that it is 
important for investments in federal programs, including program 
enhancements, to produce more than marginal increased benefits when 
significant costs are involved, due to limited federal resources. 

NASS officials said that implementing users' suggestions could 
significantly increase costs. In particular, they noted that 
disseminating the data at a more detailed geographic level would 
require NASS to collect and analyze data from additional respondents 
to make the data statistically reliable at that level. In addition to 
the associated cost, NASS officials stated that there may not be 
enough farmers within a smaller geographic area to produce reliable 
estimates and to protect respondent confidentiality. NASS officials 
also said that, while fruits and vegetables have been surveyed every 
other year since the beginning of the ACU program, NASS changed the 
frequency of the field crops surveyed several times from 1998 to 2004 
due to budget limitations and escalating survey costs. Officials said 
the agency consulted commodity groups and other users about these crop 
survey frequencies in face-to-face meetings over the years. More 
recently, NASS started reporting a new data element on chemical rate 
distribution in 2005, in response to a request from EPA's Office of 
Pesticide Programs, so that EPA could better understand the typical 
range of chemical usage in addition to the average usage rates that 
NASS has historically provided. However, NASS officials said they have 
not engaged users in any formal, large-scale process to consider the 
effects of potential program changes on users, or to weigh the costs 
and benefits of implementing users' suggestions. 

NASS Has Entered into Agreements with Some States to Provide 
Additional ACU Data, but Its Ability to Do So May Not Be Widely Known: 

As part of NASS's mission to provide accurate, timely, and useful 
agricultural statistics, NASS performs reimbursable survey work for 
other federal agencies, states, and private organizations to meet 
their informational needs. Toward that end, NASS has entered into 
cooperative agreements with some state agencies over the years to 
address a variety of state informational needs regarding pesticide or 
fertilizer usage and management practices. Under these agreements, the 
states reimbursed NASS for the extra costs incurred to collect, 
analyze, and provide additional data or geographic details than are 
contained in the standard ACU data disseminated to the public--or, if 
the state would have otherwise not been surveyed, to collect, analyze, 
and disseminate the standard ACU data. Although these agreements 
result in additional ACU data to meet individual states' needs, these 
agreements may also have broader public benefits. For instance, the 
additional ACU data generated from North Dakota's fiscal year 2009 
cooperative agreement with NASS was used in a paper on pesticide use 
and pest management practices in that state, which is available to the 
public on North Dakota State University's Web site. 

From fiscal year 2006 through 2010, these agreements have totaled more 
than $405,000 in constant 2010 dollars.[Footnote 13] Examples are as 
follows: 

* The Washington State Department of Agriculture entered into 
agreements totaling nearly $53,000 for NASS to collect and analyze 
data on the timing of pesticide applications for fruits and vegetables 
in fiscal years 2006 and 2007. Once the ACU program was restored in 
2010, Washington again entered into an agreement with NASS to collect 
and analyze additional fruit pesticide usage data elements, this time 
for nearly $36,000. NASS also provided these data to Washington at the 
agricultural statistics district level, which is a grouping of 
counties within a state based on geography, climate, and cropping 
practices. 

* The Minnesota Department of Agriculture--which is required under 
state law to monitor rural and urban pesticide use--entered into 
cooperative agreements with NASS from 2006 through 2010 totaling more 
than $235,000 to provide detailed herbicide management practices for 
corn in certain years and detailed pesticide usage data for corn, 
soybeans, wheat, and hay in other years. Minnesota entered into these 
agreements with NASS regardless of whether those crops were being 
surveyed as part of NASS's standard ACU data collection. A Minnesota 
official told us that, among other benefits, these cooperative 
agreements result in ACU data being collected from a significantly 
larger number of farmers and are reported in greater geographic 
detail, which helps inform the state's environmental programs and 
education and outreach efforts. 

* The Wisconsin Department of Agriculture also entered into a 
cooperative agreement with NASS in 2006 for nearly $24,000 to be 
included in the ACU field crops survey because the state would not 
have otherwise been surveyed due to insufficient acreage of the crops 
surveyed that year. 

Table 1 shows the cooperative agreements that NASS entered into with 
four states to provide additional ACU data for fiscal years 2006 
through 2010, as identified by the agency. 

Table 1: NASS Cooperative Agreements with States to Provide Additional 
ACU Data, Fiscal Years 2006 through 2010: 

Fiscal year 2006: 

State: Minnesota; 
Brief description: Phone survey for pesticide usage data from 7,600 
corn, soybean, wheat, and hay farmers; 
Amount[A]: $43,011. 

State: Washington; 
Brief description: Pesticide usage practices data for fruit crops; 
Amount[A]: $26,882. 

State: Wisconsin; 
Brief description: Pesticide usage data for field crops; 
Amount[A]: $23,941. 

Fiscal year 2007: 

State: Minnesota; 
Brief description: Phone survey for herbicide management practices 
data from 7,000 corn farmers; 
Amount[A]: $33,056. 

State: Washington; 
Brief description: Pesticide usage practices data for vegetable crops; 
Amount[A]: $26,095. 

Fiscal year 2008: 

State: Minnesota; 
Brief description: Phone survey for pesticide usage data from 7,700 
corn, soybean, wheat, and hay farmers; 
Amount[A]: $49,317. 

Fiscal year 2009: 

State: Minnesota; 
Brief description: Phone survey for herbicide management practices 
data from 7,000 corn farmers; 
Amount[A]: $31,891. 

State: North Dakota[B]; 
Brief description: Phone survey for pesticide usage and pest 
management practices data from 7,000 farmers of multiple crops; 
Amount[A]: $57,399. 

Fiscal year 2010: 

State: Minnesota; 
Brief description: Phone survey for pesticide usage data from 7,600 
corn, soybean, wheat, and hay farmers; 
Amount[A]: $48,350. 

State: Minnesota; 
Brief description: Phone survey for fertilizer usage and management 
practices data from 7,000 corn farmers; 
Amount[A]: $30,000. 

State: Washington; 
Brief description: Pesticide usage practices data for fruit crops; 
Amount[A]: $35,825. 

Total Amount[A]: $405,767. 

Source: GAO analysis of NASS-state cooperative agreements. 

[A] All amounts are in constant 2010 dollars. 

[B] This agreement was with North Dakota State University but was 
funded by the state's department of agriculture. 

[End of table] 

NASS can enter into these agreements through its general authority to 
use cooperative agreements with state departments of agriculture, 
federal agencies, colleges, universities, other research 
organizations, and other parties. According to its strategic plan, 
NASS has partnerships with state departments of agriculture and land-
grant universities through its 46 field offices to serve the 
agricultural data needs at both state and federal levels, eliminate 
duplication of effort, provide for state input, maintain national 
consistency, and minimize overall costs to federal and state 
governments. In addition, these partnerships are designed to maximize 
the benefits of NASS's service while minimizing the burden on survey 
respondents. For example, Washington State Department of Agriculture 
officials told us they had considered starting up a statistically 
robust, statewide pesticide use data collection but determined they 
would face many challenges-- including regulatory, disclosure, and 
technical problems--and would not likely get the response rate that 
NASS does. In addition, these state officials estimated it would cost 
them about $2 million to collect pesticide use data for the 300 minor 
crops grown in Washington alone-- an amount that exceeded their 
budget. Furthermore, Washington state officials told us that 
legislative proposals to require the state to collect its own 
pesticide usage data on this scale have been defeated because of the 
overlap with NASS's data. 

However, we found that NASS's ability to enter into reimbursable 
cooperative agreements may not be widely known by state agency 
officials due to limited outreach by NASS. For instance, AAPCO, 
Florida, and Iowa pesticide control officials told us they were not 
aware of these agreements and that, if they were better publicized, 
more states might enter into such agreements to make ACU data even 
more useful for their purposes. AAPCO, Florida, and NASDA officials 
added that, while most state agencies may not be able to afford 
collecting their own pesticide use data on a large scale, they might 
be able to provide the necessary funding to reimburse NASS for the 
marginal costs associated with the additional ACU data collection and 
analysis. While NASS officials said their field offices make the 
agency's ability to enter into reimbursable cooperative agreements 
known to heads of state departments of agriculture--not just for the 
ACU program but for a variety of data programs--they acknowledged that 
this ability may not be widely known within various departments of 
state government, and that the agency could improve its outreach. 

NASS's Online ACU Resources Are Difficult to Locate and Incomplete, 
Which Limits Users' Ability to Access and Use the Data: 

OMB guidance directs federal agencies to make electronic information 
easily accessible and useful to the public.[Footnote 14] In addition, 
we have previously reported on the importance of federal programs 
allowing users to easily access and use information on Web sites by 
providing workable navigation features and links and by refining Web- 
based tools, among other things.[Footnote 15] However, we found, and 
several ACU data users stated, that ACU reports, data tools, and 
related resources are difficult to locate on NASS's Web site and that 
the online data tools are not complete or user-friendly, limiting 
users' ability to access and use the data. Specific examples are as 
follows: 

* While there are a number of links from NASS's home page that 
eventually lead to ACU data, some of those links lead only to the most 
recently released data--but not the breadth of ACU data reports over 
the life of the program. NASS's home page also provides a search 
function for its site, which allows users to locate specific ACU data 
reports by searching terms such as "chemical use," "pesticides," or 
"fertilizers." However, this search function does not lead directly to 
NASS's dedicated Web page for the ACU data, which is labeled 
"Environmental,"[Footnote 16] where all historical ACU summary reports 
and two data tools are located. We found, and some data users we 
interviewed commented, that "Environmental" is not necessarily an 
intuitive subject heading for the ACU program and, therefore, the ACU 
data could be overlooked by other potential users. 

* Related ACU resources such as user guides--which provide an overview 
of the content, methods, and frequency of the various ACU reports--and 
the survey instruments used by the enumerators are not easily found on 
NASS's Web site, including on the "Environmental" page. Furthermore, 
the schedule for upcoming ACU data releases is not contained on, or 
linked from, the "Environmental" page. 

* Two data tools are available on NASS's Web site, but these online 
tools do not include all years or commodities covered by the ACU 
program. These tools, called Quick Stats and the Agricultural Chemical 
Use Database (ACU Database),[Footnote 17] allow users to search and 
download ACU data across multiple years and sort and analyze the data 
to fulfill their individual needs. Specifically, Quick Stats gives 
users the ability to query by commodity, state, and year, and to 
download the results into a database or spreadsheet, while the ACU 
Database offers interactive access to ACU statistics by commodity, 
state, year, and active ingredient and provides search results in 
downloadable spreadsheets, U.S. maps, and graphs. However, as of 
October 2010, Quick Stats was missing historic ACU vegetable, 
postharvest, nursery and floriculture, and livestock data. Meanwhile, 
the ACU Database had not been updated in nearly 3 years, and therefore 
it was missing the nursery and floriculture data released in 2007 and 
the apples, organic apples, and cotton data released in 2008, as well 
as the wheat and fruit data released in 2010. Incomplete data tools 
may prevent users from accessing all available information relevant to 
their purposes. NASS officials said they plan to update a newer 
version of Quick Stats with historic ACU data as resources allow, but 
they did not have specific time frames for doing so. In addition, NASS 
officials said that the agency's priority is to populate the Quick 
Stats tool before it turns its attention to updating the ACU Database 
because Quick Stats is used for all NASS data programs. 

During our review, as part of a broader effort to redesign its Web 
site and improve its delivery of electronic information, NASS created 
a new Web page for its May 2010 release of the 2009 ACU wheat crops 
data. This Web page is titled "Agricultural Chemical Use Program," 
which is intended to improve users' ability to access and use the 
data.[Footnote 18] In an effort to reduce costs, NASS also 
discontinued the annual ACU summary reports and instead released the 
2009 ACU wheat and fruit data only in its Quick Stats online data 
tool. At the same time, NASS released fact sheets and documents 
describing the methodology used for each of those ACU data releases. 
NASS officials said the new ACU Web page will be expanded to contain 
similar information for future releases of ACU field crop, fruit, 
vegetable, nursery and floriculture, postharvest, and livestock data. 
However, NASS officials acknowledged they did not consult ACU data 
users before redesigning the Web site, discontinuing the summary 
reports, or releasing the data only in the Quick Stats data tool, to 
determine if these changes would serve users' needs. For example, the 
Minor Crop Farmer Alliance--a national organization representing 
farmers, processors, and others involved in the production of various 
food, fiber, nursery, and horticultural products--said their members 
were "surprised and disappointed" about the discontinuation of the ACU 
summary reports, which had provided a useful overview of chemical use. 
This organization stated that while the Quick Stats data tool allows 
users to find information on specific pesticides, the lack of an 
easily accessible ACU summary will reduce individual farmers' ability 
to compare their chemical use with other farmers and could lead to 
lower farmer participation in future ACU surveys. Figure 3 shows how 
NASS's new "Agricultural Chemical Use Program" Web page appeared as of 
October 2010. 

Figure 3: NASS's New "Agricultural Chemical Use Program" Web Page, as 
of October 2010: 

[Refer to PDF for image: sample web page] 

Source: NASSís Web site. 

[End of figure] 

NASS Has Several Mechanisms to Obtain Data Users' Input, but ACU Users 
Say These Mechanisms Are Not Effective: 

NASS has several mechanisms to gather input from its data users in 
general: (1) semiannual USDA data user meetings held in Chicago and 
Denver; (2) general feedback comment forms on NASS's Web site; (3) the 
NASS advisory committee; (4) NASS field offices, which interact 
frequently with state departments of agriculture; and (5) NASS 
headquarters officials, who communicate with users on an ad hoc basis 
at users' request. These mechanisms are available to users of any of 
NASS's more than 500 data reports from across the spectrum of the 
agency's programs. In addition, NASS distributes annual evaluation 
forms to the field offices to gather suggestions on the procedures and 
survey instruments used for the agency's various data collection 
efforts. 

However, most ACU data users we interviewed said they did not know 
about these mechanisms or that these mechanisms are not specifically 
focused on the ACU program and, therefore, are not effective in 
ensuring that ACU data continue to meet users' needs. NASS officials 
acknowledged that the agency currently lacks a formal, targeted 
mechanism to obtain input from ACU data users on a regular basis. For 
example, the semiannual USDA data user meetings in Chicago and Denver 
focus on one particular data program at each of these meetings, and 
NASS officials said they could not recall a time when ACU had been the 
focus.[Footnote 19] In addition, an official from the CropLife 
Foundation--a nonprofit research organization supported by pesticide 
manufacturers and others--commented that while federal advisory 
committees can be effective in gathering input and making 
recommendations to an agency for improvement, their role is generally 
to report back to the agency on high-priority issues, rather than 
collect feedback on an ongoing basis. 

While several ACU data users have met with NASS officials on an ad hoc 
basis over the years, nearly all users said that a more regular, 
focused mechanism would allow them to better provide NASS with 
feedback on ways to enhance the ACU data's usefulness. These users 
said that such a mechanism--such as Web-based meetings or 
teleconferences with users interested in a specific ACU survey--would 
allow NASS to receive sufficient and timely information to ensure the 
ACU data continue to meet users' needs. Furthermore, the NASS Advisory 
Subcommittee on Pesticide Use Data recommended in 2006 that NASS 
should improve its relationship with ACU data users by soliciting 
regular feedback and hosting more frequent user group meetings--a 
recommendation that NASS officials said the agency has accepted and is 
considering how to implement. Representatives from other agricultural 
chemical usage data sources told us they employ several mechanisms to 
obtain feedback from their users on a regular or ad hoc basis or both, 
including through user group meetings, Web-based comment boxes and pop-
up surveys, conferences, agency committees, and meetings with 
individual data users. 

As we stated earlier, OMB guidance directs federal agencies to 
establish and maintain communication with users to ensure data meet 
their needs and that the expected benefits exceed costs.[Footnote 20] 
In addition, NASS's strategic plan states that data user meetings are 
a primary source of customer input that keeps its agricultural 
statistics programs on track with the needs of the user community. 
However, during our review, NASS officials stated that, due to the 
publicly available nature of their data, the agency is not aware of 
who all its data users are--which limits their ability to know and 
understand all of the purposes for which ACU data are used by various 
entities. While NASS is able to identify some of its users through e-
mail subscriptions, relationships with federal agencies, and 
cooperative agreements, it is a challenge for the agency to identify a 
wider array of users without creating barriers to users' access to 
data, such as by requiring log-in registration, or incurring 
additional cost. Officials said the challenge in identifying users 
applies not only to the ACU data program, but to the agency's data 
programs in general. Nonetheless, NASS officials said that, as of 
September 2010, they were evaluating ways to improve communication 
with users. An internal Program Planning Council recommended in spring 
2010 that NASS continue exploring opportunities to more strategically 
engage, and solicit input from, stakeholder organizations and other 
data users representing various sectors of agriculture in different 
regions of the country. Specifically, NASS officials said they are 
considering holding expanded data user meetings in conjunction with 
trade shows or other events where producers and data users from 
several agricultural sectors would be in attendance.[Footnote 21] In 
addition, agency officials are exploring advances in technology, such 
as Web-based conferences, to allow greater attendance. However, NASS 
officials did not provide specific time frames for implementing these 
efforts, and they said that an ACU-specific data user meeting was not 
scheduled as of September 2010. 

Other Sources Provide Agricultural Chemical Usage Data, and NASS May 
Not Be Fully Leveraging Resources or Minimizing Overlap with These 
Sources: 

Agricultural pesticide and fertilizer usage data are available through 
several state, private, and other sources. These data vary in their 
cost, geographic and crop coverage, level of detail, and other 
attributes. However, NASS may not be fully leveraging resources or 
minimizing potential overlap with its ACU data collection due to its 
limited knowledge of other publicly available data sources. 

Other Data Sources Vary in Their Cost, Geographic and Crop Coverage, 
Detail, and Other Attributes: 

During our review, we identified and collected information from 
several state, private, and other sources of agricultural chemical 
usage data that cover the application or sales of pesticides, 
fertilizers, or both.[Footnote 22] Specifically, seven states collect 
and disseminate publicly available data covering their own states. For 
example, Arizona collects and disseminates data on pesticide 
application, while Iowa collects and disseminates data on pesticide 
sales. Data from these state sources also vary in their crop coverage. 
For instance, New Jersey covers 32 crops, while California covers more 
than 200 crops. All seven states aggregate the data at the state 
level, five states also aggregate data at the county level, and five 
states provide other levels of geographic detail such as watershed, 
zip code, and field. Four of these states collect data via mandatory 
reports from pesticide manufacturers, dealers, or users. Other data 
collection methods include questionnaires, site inspections, and 
document review. Six of these state sources disseminate these data to 
users via their Web sites. Other data dissemination methods used by 
the states include mail, e- mail, and presentations. In addition, 
these sources variously include data elements such as the names of 
active ingredients applied or sold and the total amount of chemical 
applied or sold. 

We also identified three private sources of agricultural pesticide 
usage data in the United States: Crop Data Management Systems (CDMS), 
GfK Kynetec (formerly Doane Market Research), and Mike Buckley and 
Associates. These private sources all charge fees for their data and 
place proprietary restrictions on their use, such as requirements that 
the data not be shared with outside entities or released to the 
public. Additionally, all of these private data sources collect and 
disseminate data on both pesticide application and sales, while CDMS's 
data also cover fertilizer application and sales. Two sources cover 
multiple U.S. states, while one covers all U.S. states. These private 
data sources also vary in their crop coverage. For example, Mike 
Buckley's data cover 32 crops, while CDMS's data cover over 100 crop 
categories. All three private sources disseminate data at the state 
level, while two of them also disseminate data at a finer level of 
geographic detail, such as by county or agricultural statistics 
district, which is a group of counties. Data collection methods for 
these private sources include document review, site inspection, and 
questionnaires. The data are disseminated by various methods, 
including mail, e-mail, presentations, and on the Web. These private 
data sources all contain information on the names of active 
ingredients applied and sold, pesticide product name, application 
method, number of acres treated, and amount sold. These private 
sources may also include other data elements such as seed treatments, 
crop stage of application, and target pests. 

We also found that the Association of American Plant Food Control 
Officials (AAPFCO) collects and disseminates fertilizer sales data. 
AAPFCO is a nonprofit organization whose members include state 
fertilizer control officials. These officials collect information on 
fertilizer sales within their state and report it to AAPFCO, which, in 
turn, disseminates these data annually for free to members and for a 
nominal fee to nonmembers. AAPFCO's data cover all U.S. states and are 
disseminated at the state and county levels. Data are not disseminated 
by crop. Data elements vary by state, depending on the state's 
reporting methods and requirements, but they generally include 
fertilizer product name and amount of fertilizer sold. 

In addition, EPA publishes Pesticides Industry Sales and Usage 
reports, which are publicly available and combine NASS and other 
public and private data sources. Although these reports have not been 
issued since 2004 due to resource and time constraints, EPA officials 
said that the agency plans to publish one in 2010. This report will 
use data from NASS and GfK Kynetec for U.S. agricultural pesticide 
usage, as well as other public and private sources for pesticide use 
outside of the United States and general pesticide industry 
statistics. This publication includes information on all 50 states and 
disseminates data at the world and U.S. national levels. EPA does not 
disseminate these data by crop. Data elements include names of the top 
active ingredients, total amount applied, and total amount sold. 

Table 2 shows selected attributes of state, private, and other 
agricultural chemical usage data sources. See appendix II for a more 
detailed description of these data sources. 

Table 2: Selected Attributes of Other Agricultural Pesticide and 
Fertilizer Usage Data Sources: 

Data source: Arizona Pest Management Center historical pesticide use 
database; 
Application or sales: Application; 
Pesticides or fertilizers: Pesticides; 
U.S. geographic coverage: Arizona; 
Level of geographic detail: State, county; 
Crop and livestock coverage and detail: Over 150 crops, not 
disseminated by livestock species; 
Cost: Free; 
Restrictions on data use: No. 

Data source: California Pesticide Use reports; 
Application or sales: Application; 
Pesticides or fertilizers: Pesticides; 
U.S. geographic coverage: California; 
Level of geographic detail: State, county, watershed, farm, field, and 
section (square mile); 
Crop and livestock coverage and detail: Over 200 crops, 12 livestock 
species; 
Cost: Free; 
Restrictions on data use: No. 

Data source: Annual Pounds of Pesticides Sold in California reports; 
Application or sales: Sales; 
Pesticides or fertilizers: Pesticides; 
U.S. geographic coverage: California; 
Level of geographic detail: State, county, watershed, farm, and field; 
Crop and livestock coverage and detail: Over 200 crops, 12 livestock 
species; 
Cost: Free; 
Restrictions on data use: No. 

Data source: Iowa's Pesticide Database; 
Application or sales: Sales; 
Pesticides or fertilizers: Pesticides; 
U.S. geographic coverage: Iowa; 
Level of geographic detail: State, county, and watershed; 
Crop and livestock coverage and detail: Not disseminated by crop or 
livestock species[A]; 
Cost: Free; 
Restrictions on data use: No. 

Data source: Minnesota Farm Nutrient Management Assessment Program; 
Application or sales: Application; 
Pesticides or fertilizers: Pesticides and fertilizers; 
U.S. geographic coverage: Select watersheds or regions within 
Minnesota; 
Level of geographic detail: Watershed and region; 
Crop and livestock coverage and detail: Has covered at least 8 crops, 
not disseminated by livestock species; 
Cost: Free; 
Restrictions on data use: No. 

Data source: Minnesota Pesticide Sales Information; 
Application or sales: Sales; 
Pesticides or fertilizers: Pesticides; 
U.S. geographic coverage: Minnesota; 
Level of geographic detail: State; 
Crop and livestock coverage and detail: Not disseminated by crop or 
livestock species[B]; 
Cost: Free; 
Restrictions on data use: No. 

Data source: New Jersey Pesticide Control Program; 
Application or sales: Application; 
Pesticides or fertilizers: Pesticides; 
U.S. geographic coverage: New Jersey; 
Level of geographic detail: State, county, watershed, and township; 
Crop and livestock coverage and detail: 32 crops, not disseminated by 
livestock species; 
Cost: Free; 
Restrictions on data use: No. 

Data source: New York Pesticide Reporting Program; 
Application or sales: Application and sales; 
Pesticides or fertilizers: Pesticides; 
U.S. geographic coverage: New York; 
Level of geographic detail: State, county, and zip code; 
Crop and livestock coverage and detail: Not disseminated by crop or 
livestock species; 
Cost: Free; 
Restrictions on data use: No. 

Data source: Washington Pesticide Use Project; 
Application or sales: Application and sales; 
Pesticides or fertilizers: Pesticides and fertilizers; 
U.S. geographic coverage: Washington; 
Level of geographic detail: State; 
Crop and livestock coverage and detail: Not disseminated by crop or 
livestock species; 
Cost: Free; 
Restrictions on data use: No. 

Data source: CDMS; 
Application or sales: Application and sales; 
Pesticides or fertilizers: Pesticides and fertilizers; 
U.S. geographic coverage: Multiple U.S. states; 
Level of geographic detail: State, county, watershed, farm, field, and 
custom; 
Crop and livestock coverage and detail: Over 100 crop categories, not 
disseminated by livestock species; 
Cost: Priced; 
Restrictions on data use: Yes. 

Data source: GfK Kynetec Syndicated U.S. Studies; 
Application or sales: Application and sales; 
Pesticides or fertilizers: Pesticides; 
U.S. geographic coverage: Multiple U.S. states; 
Level of geographic detail: State, agricultural statistics district, 
county, and U.S. national; 
Crop and livestock coverage and detail: 61 crops, 7 livestock 
species[C]; 
Cost: Priced; 
Restrictions on data use: Yes. 

Data source: Mike Buckley and Associates; 
Application or sales: Application and sales; 
Pesticides or fertilizers: Pesticides; 
U.S. geographic coverage: All U.S. states; 
Level of geographic detail: State; 
Crop and livestock coverage and detail: 32 crops, not disseminated by 
livestock species; 
Cost: Priced; 
Restrictions on data use: Yes. 

Data source: AAPFCO; 
Application or sales: Sales; 
Pesticides or fertilizers: Fertilizers; 
U.S. geographic coverage: All U.S. states; 
Level of geographic detail: State and county; 
Crop and livestock coverage and detail: Not disseminated by crop or 
livestock species; 
Cost: Priced; 
Restrictions on data use: No. 

Data source: EPA Pesticides Industry Sales and Usage reports; 
Application or sales: Application and sales; 
Pesticides or fertilizers: Pesticides; 
U.S. geographic coverage: All U.S. states; 
Level of geographic detail: World and U.S. national; 
Crop and livestock coverage and detail: Not disseminated by crop or 
livestock species; 
Cost: Free; 
Restrictions on data use: No. 

Sources: GAO analysis of information from these data sources. 

[A] Iowa's data have been disseminated by crop when researchers 
matched them with NASS's ACU data to determine which pesticides are 
used on which crops. 

[B] Minnesota's sales data have been reported by crop when a pesticide 
is used only on one crop. 

[C] GfK Kynetec also reformats and sells California's data, covering 
216 crops. 

[End of table] 

Many ACU data users that we interviewed said they also use state, 
private, or other sources of agricultural chemical usage data, but 
nearly all users emphasized that other sources do not replace NASS's 
data.[Footnote 23] Nearly all ACU data users said, and we found, that 
NASS is the only source of publicly available data reflecting the 
actual application of agricultural pesticides and fertilizers on a 
wide array of crops on a national scale. EPA and USGS purchase private 
data, and all three organizations representing chemical manufacturers 
that we interviewed said that chemical manufacturers purchase private 
data. For example, as discussed, EPA relies on pesticide usage data 
from both NASS and private sources to evaluate the safety of 
pesticides. EPA officials stated that one private source that they use 
provides somewhat different crop coverage and geographic detail, 
generally more data elements, and releases data a few months prior to 
NASS. EPA officials attested that this private data source meets EPA's 
methodological and transparency standards under its information 
quality guidelines and that EPA's use of these data is consistent with 
the Information Quality Act.[Footnote 24] However, as discussed, EPA 
officials said the agency still needs ACU data from NASS as well, in 
part because proprietary restrictions on the use of the private sector 
data conflict with the agency's desire to publish data used in risk 
assessments to increase transparency. 

Although some ACU data users reported finding private data useful, 
these data are not accessible to others due to cost. Officials from 
seven state agencies or their national representative organizations, 
representatives from two commodity groups and three public interest 
organizations, and two academics that we interviewed said that private 
data are cost-prohibitive. For example, private data can cost more 
than $500,000 per year, an amount that some ACU data users indicated 
would exceed their entire annual budget. Furthermore, officials from 
the American Nursery and Landscape Association and the Society of 
American Florists indicated that private sources of agricultural 
chemical usage data are not useful for them because these sources do 
not produce data on nursery and floriculture crops. Several ACU data 
users also said they prefer not to use, or rely exclusively on, 
private data because proprietary restrictions would limit their 
ability to use or publish the data. In addition, many ACU data users 
noted that they use state data in addition to NASS's data, but several 
users said they could not rely exclusively on state data as they need 
a nationwide picture of agricultural chemical use, or one state's data 
do not necessarily apply to another state. For example, the Center for 
Food Safety uses California's publicly accessible data, but since this 
organization looks at national pesticide usage trends, it must use ACU 
data as well. Many users said that state data sources do not replace 
NASS's data because they cannot be extrapolated to the nation as a 
whole, as pest pressures, weather patterns, and crops differ 
geographically, and therefore pesticide use can vary significantly 
from one state to another. 

Furthermore, several users said they use state, private, or other 
sources in conjunction with NASS's data so that they can compare or 
verify data sources. For example, chemical manufacturer members of the 
American Phytopathological Society whom we interviewed, as well as EPA 
and USGS--said that they rely on both NASS's and GfK Kynetec's data 
because they are more confident in the data's accuracy if the data can 
be checked against another source. Similarly, Iowa Department of 
Agriculture and Land Stewardship officials said they use NASS's data 
to validate their own pesticide sales data, which are collected from 
pesticide dealers, since the state agency does not have the authority 
to audit pesticide dealers to validate their data. Moreover, several 
ACU data users said that agricultural chemical sales data are not an 
adequate substitute for application data. For example, the Director of 
the North Central Integrated Pest Management Center said that sales 
data are not sufficient to gauge the impact of pest management 
practices because sales and application may not be equivalent. When 
soybean rust was identified in the United States in 2004, for 
instance, she said that farmers proactively purchased fungicides to 
defend against this outbreak, although they did not necessarily apply 
the fungicides. 

NASS May Not Be Fully Leveraging Resources or Minimizing Overlap Due 
to Limited Knowledge of Other Publicly Available Data: 

Although NASS cited the availability of other data sources as one of 
its criteria for cutting the ACU program in fiscal year 2007, NASS 
officials said they never systematically identified and assessed those 
data sources before or after making this decision. Furthermore, while 
agency officials said that NASS field staff work closely with state 
departments of agriculture to coordinate data collection efforts 
between federal and state entities, we found that NASS has not 
comprehensively monitored state agricultural chemical usage data 
sources. As a result, NASS does not know the extent to which ACU data 
might overlap with other publicly available sources and cannot be 
certain that it is fully leveraging limited government resources to 
maximize the data's usefulness and minimize cost. Similarly, a NASS 
official said that the agency is not certain whether other NASS data 
programs have overlap with other publicly available data. OMB guidance 
directs federal agencies to (1) seek to satisfy new information needs 
through intergovernmental sharing of information, or through 
commercial sources, where appropriate; (2) only collect or create 
information that is both necessary for the proper performance of 
agency functions and which has practical utility; and (3) disseminate 
information in a manner that balances the goals of maximizing the 
information's usefulness and minimizing cost.[Footnote 25] In 
addition, USDA's strategic plan declares that success depends on 
working cooperatively at all government levels and directing resources 
to where they are used most effectively.[Footnote 26] NASS's strategic 
plan also specifies that, through its field offices, the agency is 
intended to eliminate duplication of effort with state departments of 
agriculture and minimize overall costs to federal and state 
governments in meeting agricultural data needs at both the federal and 
state levels. 

A NASS official said the agency complies with OMB's guidance by 
seeking to utilize all available resources, including other data 
series, in order to provide the most timely, accurate, and useful 
statistics on agriculture. We found that NASS has taken measures to 
reduce overlap and leverage resources with California, where a state 
agency already collects and disseminates free, detailed pesticide 
application data. Specifically, NASS officials said that NASS reduces 
the cost and burden on farmer respondents associated with its ACU data 
program by collecting some of California's data from county 
agricultural commissioners to supplement NASS's own data collection 
activities. Additionally, NASS reduces overlap with Arizona by 
obtaining some pesticide data from that state's department of 
agriculture, which collects data on restricted-use pesticide usage 
from pesticide managers. However, NASS enumerators still survey 
farmers in that state to collect ACU data on nonrestricted pesticide 
usage, as well as fertilizer usage. Otherwise, because ACU data cover 
only chemical application, rather than sales, NASS officials said that 
state sources of pesticide and fertilizer sales data do not overlap 
with NASS's program because the agency does not consider sales to be 
comparable to application. 

However, NASS officials said that they were not familiar with all 
state-initiated efforts to collect and disseminate agricultural 
chemical application data. For example, NASS officials said they were 
not aware that New York has collected and disseminated pesticide 
application and sales data, which include names of active ingredients, 
pesticide product name, and total amount applied, since 1998. In 
addition, we found that New Jersey has collected and disseminated 
pesticide application data, including names of active ingredients and 
total amount applied, since 1985. NASS officials said they were aware 
of this program but hadn't assessed whether these data overlap with 
ACU data or explored whether coordination between NASS and New Jersey 
would be appropriate, in part because they did not know whether the 
state's sample size would meet NASS's statistical standards. While 
NASS officials acknowledged that one of the agency's goals is to 
reduce overlap, costs, and respondent burden, we found that the agency 
does not have a process in place to ensure all field offices are 
monitoring agricultural chemical usage data sources in their states. 
Consequently, without information on all state and other publicly 
available agricultural chemical usage data sources, NASS does not have 
assurance that the agency is fully leveraging limited government 
resources, maximizing efficiencies, and minimizing potential overlap 
in its ACU data collection. 

Conclusions: 

In the 20 years since its inception, NASS's ACU program has supported 
many federal and state government efforts, including monitoring water 
pollution under the Clean Water Act and measuring the success of 
integrated pest management efforts. As Congress debates greenhouse gas 
regulation, reliable data on pesticide and fertilizer usage could also 
provide critical information on agriculture's role in climate change. 
Users also rely on ACU data to support a variety of U.S. business 
needs, including research and development of new agricultural 
pesticide and fertilizer products and access to foreign agricultural 
markets. Furthermore, because consumers are increasingly interested in 
information about the food and products they consume and how those 
items are produced, ACU data are likely to become even more relevant 
in the future. Without ACU data, regulators, legislators, industry, 
consumers, and researchers alike would be uncertain about the extent 
of pesticide and fertilizer use--which, in turn, would deny 
policymakers important information needed to make decisions on 
protecting food safety and the environment. 

Because NASS cut the ACU program in fiscal year 2007 without 
consulting users, it discovered only through the subsequent outpouring 
of support for the program how critical ACU data are to a wide array 
of public, private, and nonprofit entities. Without an effective, 
formal mechanism to identify users and seek their feedback, the agency 
is unable to assess whether the data meet users' informational needs 
or make fully informed decisions considering the effects of potential 
program changes on users, while weighing the costs and benefits of 
such changes. In addition, without a mechanism to gather and evaluate 
input from users on an ongoing basis, NASS cannot be assured that ACU 
data continue to be relevant as new regulatory and public needs for 
information arise. Furthermore, we and several data users had 
difficulty locating ACU reports, data tools, and related ACU resources 
on NASS's Web site, which, in combination with incomplete data tools, 
limits the visibility and user-friendliness of the ACU program. In an 
increasingly technology-driven world, it is important for users to 
easily access and use information electronically. 

Moreover, as federal and state government agencies are faced with 
budget constraints, it is important to reduce unnecessary overlap in 
government programs and to maximize the public benefit while 
minimizing cost. However, NASS may be missing opportunities to better 
leverage federal and state resources. First, because NASS has not 
widely communicated its ability to enter into cooperative agreements 
with state agencies, it may be missing opportunities to be reimbursed 
by states for the costs associated with collecting additional 
information that ACU data users have said would enhance the data's 
usefulness. Second, although NASS has collected some information on 
other publicly available data sources and has coordinated with 
California and Arizona to reduce overlap, the agency has not 
systematically identified and evaluated whether other publicly 
available data on agricultural pesticide and fertilizer usage exist. 
Without a process in place to ensure that all field offices are 
monitoring other publicly available information sources, NASS does not 
have assurance that the agency has maximized efficiencies and 
minimized potential overlap with its ACU data collection. 

Recommendations for Executive Action: 

To improve NASS's ability to manage the ACU data program effectively 
and ensure that it continues to meet users' needs, we recommend that 
the Secretary of Agriculture direct the Administrator of NASS to take 
the following four actions: 

* Establish a formal mechanism to identify and consult ACU data users 
on an ongoing basis to ensure ACU data continue to meet users' 
informational needs and to consider the effects of potential program 
changes on users, weighing the costs and benefits of those changes. 

* Strengthen outreach to state agencies regarding NASS's ability to 
enter into reimbursable cooperative agreements that would maximize 
state and federal resources, minimize costs, and enhance ACU data's 
usefulness to state officials. 

* Improve users' ability to access and use ACU data on NASS's Web site 
by making it easier to find ACU reports, data tools, and related 
resources, and by updating ACU data tools on a timely basis. 

* Develop a process to systematically identify and evaluate other 
agricultural pesticide and fertilizer usage data sources that are 
publicly available on an ongoing basis to better leverage resources 
and reduce areas of potential overlap with ACU data collection. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to USDA for review and comment. In 
written comments, which are included in appendix III, USDA agreed with 
the recommendations and stated that the report and recommendations 
will be used to further strengthen NASS and its management of the ACU 
program. Regarding the first recommendation, USDA indicated that NASS 
will (1) include ACU data as an agenda item at an annual data users 
meeting where all statistical data series are open for discussion; (2) 
convene a special data users meeting during 2011 to focus specifically 
on the ACU data series; and (3) conduct a comprehensive market 
research effort to enable it to better understand its 
customers/audience and their information needs. Regarding the second 
recommendation, USDA stated that NASS will leverage its ongoing 
relationship with NASDA to reach outside the agriculture community 
into other sectors of local and state government with responsibilities 
for pesticide regulations and oversight. In addition, USDA said an 
inventory of available agricultural chemical use data collections will 
be made and monitored to minimize duplicative efforts. Regarding the 
third recommendation, USDA indicated that NASS is actively working to 
improve its online database, Quick Stats, for the presentation of all 
NASS data series, including ACU data, and that an internal NASS team 
has been chartered to review data user comments aimed at improving 
functionality and ease of use for all data users. Regarding the fourth 
recommendation, USDA stated that NASS headquarters personnel with ACU 
responsibility will (1) annually review known public sources of 
fertilizer and pesticide information for updated and expanded data 
items and (2) coordinate with NASS field office personnel to identify 
new data series available at local levels. According to USDA, these 
efforts will build off of the results from the agency's response to 
the second recommendation. USDA did not provide any suggested 
technical corrections. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies of this report 
to the appropriate congressional committees, the Secretary of 
Agriculture, and other interested parties. The report also will be 
available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staff members have any questions about this report, 
please contact me at (202) 512-3841 or shamesl@gao.gov. Contact points 
for our Offices of Congressional Relations and Public Affairs may be 
found on the last page of this report. GAO staff who made key 
contributions to this report are listed in appendix IV. 

Signed by: 

Lisa Shames: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Our objectives were to determine (1) the factors that the U.S. 
Department of Agriculture's (USDA) National Agricultural Statistics 
Service (NASS) considered in reducing the Agricultural Chemical Usage 
(ACU) program in fiscal years 2007 through 2009; (2) how ACU data 
users were affected by the temporary cutback, and their views on the 
quality and usefulness of the data; and (3) the extent to which 
agricultural pesticide and fertilizer usage data are available from 
sources other than NASS. 

To address all three objectives, we reviewed relevant NASS documents, 
as well as USDA strategic and performance plans. We also reviewed 
Office of Management and Budget (OMB) guidance to federal agencies on 
managing information resources; promoting transparency, public 
participation, and collaboration in government; and improving Web 
sites to better serve users and customers. To understand how and why 
the Environmental Protection Agency (EPA) and other federal agencies 
use ACU data, we also reviewed relevant documents from those agencies. 
In addition, to determine other USDA agencies' roles in using ACU 
data, we spoke with officials from the Economic Research Service, the 
Farm Service Agency, the Natural Resources Conservation Service, the 
Agricultural Research Service's Office of Pest Management Policy, the 
Agricultural Marketing Service, and the Animal and Plant Health 
Inspection Service. To describe NASS's authority to collect 
agricultural statistics data and, more specifically, pesticide use 
data, and to describe federal and state responsibilities in 
implementing certain laws to protect human health and the environment, 
we reviewed relevant federal laws. In addition, we reviewed our prior 
reports that were appropriate for this review, such as those relating 
to the origins of the ACU data program, challenges faced by federal 
agencies operating under continuing resolutions, and the importance of 
ensuring that information on federal agency Web sites is accessible 
and user-friendly. We also reviewed the annual reports containing 
findings and recommendations made by the NASS Advisory Committee on 
Agricultural Statistics from 2003 through 2009 and, in particular, the 
reports related to its 2006 Subcommittee on Pesticide Use Data. We 
also interviewed key NASS headquarters officials knowledgeable about 
the ACU program and reviewed NASS's internal controls for the 
information system that stores ACU data. However, we did not review 
other agricultural pesticide or fertilizer usage data sources' 
internal controls. Furthermore, because we are not using NASS's or 
other sources' data in this report, we did not assess the reliability 
of ACU or other sources' data. For the section on cooperative 
agreements, we converted all cooperative agreement amounts to constant 
2010 dollars to calculate the total across multiple years. We adjusted 
the cooperative agreement amounts for inflation using the gross 
domestic product price index from the U.S. Bureau of Economic Analysis 
and the Congressional Budget Office's inflation projection for the 
year 2010. 

To obtain ACU data users' views for all three objectives, we 
interviewed and reviewed documents from a nongeneralizable sample of 
25 ACU data users. We selected these users from a variety of sectors, 
including federal, state, private, nonprofit, and academic, in order 
to provide a broad range of perspectives on the use of ACU data. 
Specifically, we interviewed ACU data users from federal agencies 
other than USDA, state agencies and their representative associations, 
industry groups representing chemical manufacturers, commodity groups, 
public interest organizations, and academic researchers. Because NASS 
does not maintain a list of ACU data users, we initially identified 
users in all categories through (1) letters written by users urging 
USDA to restore the ACU program, (2) news articles about the ACU 
program's cutback, and (3) interviews with NASS officials and others. 
Using a snowball sampling technique, at each interview, we solicited 
additional ACU data user names and contact information until we had 
coverage from users across all sectors. To further assist in 
identifying academics, we conducted a literature search for peer- 
reviewed articles citing ACU data since 2005. From among the list of 
ACU data users we identified through this process, we selected at 
least three users from each category. When possible, we selected 
national organizations that represent state agencies, chemical 
manufacturers, and commodity groups--such as the National Association 
of State Departments of Agriculture, CropLife America/CropLife 
Foundation, The Fertilizer Institute, and the Minor Crop Farmer 
Alliance--because of their breadth of members across the country. In 
addition, three of the users we interviewed were also members of the 
2006 NASS Advisory Subcommittee on Pesticide Use Data: officials from 
the CropLife Foundation and EPA's Office of Pesticide Programs, as 
well as a researcher from the Michigan State University Department of 
Etymology. We selected these subcommittee members, in part, because of 
their firsthand knowledge of the subcommittee's findings and 
recommendations to NASS regarding ACU data and because NASS cited the 
subcommittee's work in the agency's decision to cut the ACU program in 
fiscal year 2007. 

In conjunction with the methods identified above, we used additional 
selection criteria for certain categories of ACU data users. For 
example, we selected: 

* states to ensure diversity in agricultural production and geographic 
location and, in one case, on the basis of a state's entering into a 
cooperative agreement with NASS; 

* commodity groups to ensure diversity of crop representation; 

* three public interest organizations who were among the four major 
signatories on letters to USDA in support of the ACU program; and: 

* academics through a variety of methods. One academic was identified 
through referral and selected based on his membership in the 2006 NASS 
Advisory Subcommittee on Pesticide Use Data. Another academic was 
identified through the literature search and selected because he was 
the only author we found who had published multiple articles citing 
ACU data since 2005, was employed by a U.S. university, and was not a 
graduate student. The third academic was identified through referral 
and selected because she was quoted in a media article discussing the 
ACU data cutback. 

For all ACU data user categories, information from our 
nongeneralizable sample cannot be used to make inferences about the 
entire ACU data user population. In addition, we did not assess the 
extent to which the users access or use ACU data (i.e., lightly, 
moderately, or heavily) as part of our selection criteria. Table 3 
lists the ACU data users we interviewed. 

Table 3: ACU Data Users Selected for Interview, by Type: 

Type: Federal agencies; 
User: EPA Office of Pesticide Programs; EPA Office of Water; U.S. Fish 
and Wildlife Service, Department of the Interior; U.S. Geological 
Survey, Department of the Interior; National Marine Fisheries Service, 
Department of Commerce. 

Type: State agencies and representative associations; 
User: California Department of Food and Agriculture; Florida 
Department of Agriculture and Consumer Services; Iowa Department of 
Agriculture and Land Stewardship; Michigan Department of Agriculture; 
Texas Department of Agriculture; Washington State Department of 
Agriculture; Association of American Pesticide Control Officials; 
National Association of State Departments of Agriculture. 

Type: Chemical manufacturer industry groups; 
User: American Phytopathological Society Public Policy Board industry 
members, representing pesticide manufacturers; CropLife 
America/CropLife Foundation, representing pesticide manufacturers; The 
Fertilizer Institute, representing fertilizer manufacturers. 

Type: Commodity groups; 
User: Minor Crop Farmer Alliance, representing fruit, vegetable, nut, 
and other minor crop growers; National Corn Growers Association; 
Society of American Florists and the American Nursery & Landscape 
Association, interviewed together. 

Type: Public interest organizations; 
User: Center for Food Safety; Natural Resources Defense Council; The 
Organic Center. 

Type: Academic researchers; 
User: The Director of the North Central Integrated Pest Management 
Center at the University of Illinois, Urbana-Champaign; A research 
faculty member from the Biological and Agricultural Engineering 
Department at the University of Idaho; A professor from the Department 
of Etymology at Michigan State University. 

Source: GAO. 

[End of table] 

We used a standard set of questions to interview each of these users 
to ensure we consistently captured their views on various aspects of 
each of our objectives. We then analyzed the results of these 
interviews and related documents to identify the main themes and 
develop summary findings. Two GAO analysts separately conducted this 
analysis and placed users' responses into one or more categories, then 
compared these analyses. All initial disagreements regarding the 
categorizations of users' responses were discussed and reconciled. The 
analysts then tallied the number of responses in each category. To 
characterize ACU data users' views throughout this report, we defined 
modifiers (e.g., "nearly all") to quantify users' views as follows: 

* "nearly all" users represents 21 to 24 users, 

* "most" users represents 16 to 20 users, 

* "many" users represents 11 to 15 users, 

* "several" users represents 6 to 10 users, and: 

* "some" users represents 3 to 5 users. 

To determine the extent to which agricultural pesticide and fertilizer 
usage data are available from sources other than NASS, we developed 
and distributed a questionnaire to collect information from these data 
sources and used the responses to describe certain attributes of their 
data. To develop the questions, we analyzed NASS's ACU data 
documentation to identify the proper terminology used for agricultural 
chemical use data and to determine what characteristics of the other 
data sources were relevant to this review. Because there is no 
comprehensive list of sources of agricultural chemical use data, we 
identified as many other sources of agricultural chemical use data as 
possible through interviews, document review, and outreach to members 
of the Association of American Pesticide Control Officials. However, 
we cannot know whether we identified all sources and, therefore, we 
cannot know whether the results are generalizable to any other 
existing data sources. We contacted representatives of these sources 
by phone and e-mail to ensure that they met the following criteria: 
(1) they collect and disseminate data on the application, sale, or 
both of agricultural pesticides, fertilizers, or both on an ongoing 
basis; (2) they collected and disseminated such data in the last 5 
years; (3) they operate in the United States; and (4) they make their 
data available to users outside their organization. In addition, for 
data sources that disseminate agricultural chemical application data 
by crops, the data had to cover eight or more crops. 

Ultimately, we identified 12 state, private, and other data sources 
that met these criteria. Each data source selected an appropriate 
official to complete the questionnaire. To minimize errors that might 
occur from respondents interpreting our questions differently from our 
intended purpose, we pretested the questionnaire in-person or by phone 
with a federal government agency, a state government agency, a private 
company, and a nonprofit organization. During these pretests, we asked 
officials to complete the questionnaire as we observed the process. We 
then interviewed the respondents to ensure that (1) the questions were 
clear and unambiguous, (2) the terms used were precise, (3) the 
questionnaire did not place an undue burden on the officials 
completing it, and (4) the questionnaire was objective and unbiased. 
We also tested the functionality of the questionnaire and submitted it 
to review by a GAO questionnaire methodology expert and two external 
reviewers who were familiar with agricultural pesticide and fertilizer 
usage data and their use. We modified the questions based on feedback 
from the pretests and reviews, as appropriate. We then asked 
respondents to complete the questionnaire within an electronic form 
and return it as an e-mail attachment. 

Overall, there was a 100 percent response rate, as all 12 recipients 
and NASS completed questionnaires. Two of these data sources completed 
two questionnaires each, since these data sources collect and 
disseminate both sales and application data using different 
methodologies. We reviewed all questionnaire responses, and followed 
up by phone and e-mail to clarify the responses, as appropriate. In 
order to categorize and summarize these responses, we performed a 
systematic content analysis. The responses were coded, entered into a 
spreadsheet, independently checked for accuracy, and analyzed to count 
how many data sources have various attributes. We also sent the 
descriptive summaries to each data source other than NASS to review 
for accuracy and, in some cases, to provide further clarification, and 
we incorporated their comments as appropriate. We did not 
independently verify the information provided by these data sources. 

We conducted this performance audit from October 2009 to November 
2010, in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Other Sources of Agricultural Chemical Usage Data: 

As part of our review, we identified and collected information on 
sources of agricultural chemical usage data other than the U.S. 
Department of Agriculture's (USDA) National Agricultural Statistics 
Service (NASS). As of September 2010, we found seven states, three 
companies, one nonprofit organization, and one other federal agency 
that collect and disseminate agricultural chemical usage data in the 
United States. This appendix describes the information that each of 
these sources provides. We collected this information using a 
questionnaire that we distributed to officials from the agencies, 
companies, and organizations that produce these data. Table 4 shows 
how language from the questionnaire is used in this appendix. 

Table 4: Terms Used in This Appendix and Questionnaire Definitions: 

Term: Application rate; 
Definition from Questionnaire: Average amount per area per application 
(rate per application). 

Term: By mail; 
Definition from Questionnaire: CD-ROM, DVD, or paper by mail. 

Term: Chemical dealers; 
Definition from Questionnaire: Pesticide and/or fertilizer 
distributors and/or dealers, wholesale or retail. 

Term: Chemical manufacturers; 
Definition from Questionnaire: Pesticide and/or fertilizer 
manufacturers or their representative trade organizations. 

Term: Commodity groups; 
Definition from Questionnaire: Commodity or producer 
groups/associations. 

Term: Conferences; 
Definition from Questionnaire: Conferences and/or seminars. 

Term: Data Center; 
Definition from Questionnaire: In-person visit to data 
center/laboratory. 

Term: Document review; 
Definition from Questionnaire: Document/record review, such as farm 
record or sales receipts. 

Term: Farmers; 
Definition from Questionnaire: Farmers, farm owners/operators, 
employees, or contractors, such as bookkeepers, custom/licensed 
applicators, or pest control managers. 

Term: Federal requirements; 
Definition from Questionnaire: Federal laws or regulations. 

Term: Foreign governments; 
Definition from Questionnaire: Foreign government or international 
governing bodies, such as the United Nations. 

Term: Lawyers; 
Definition from Questionnaire: Lawyers or law firms. 

Term: Online tool; 
Definition from Questionnaire: Web-based comment box or pop-up survey. 

Term: Presentation; 
Definition from Questionnaire: In-person presentation. 

Term: Reports from other entities; 
Definition from Questionnaire: Reports from other entities that 
collect data, including but not limited to state or local government. 

Term: Sales by chemical dealers to users; 
Definition from Questionnaire: Sales by dealers/distributors to end 
users. 

Term: Sales by chemical manufacturers to dealers; 
Definition from Questionnaire: Sales by pesticide and/or fertilizer 
manufacturers to dealers/distributors. 

Term: Sales by chemical manufacturers to users; 
Definition from Questionnaire: Sales by pesticide and/or fertilizer 
manufacturers to end users. 

Term: State requirements; 
Definition from Questionnaire: State laws or regulations. 

Term: Telephone calls and e-mails; 
Definition from Questionnaire: E- mails and/or phone calls from users. 

Term: Timing of application with respect to planting or seeding; 
Definition from Questionnaire: Whether pesticides and/or fertilizers 
were applied before, at, or after planting/seeding. 

Source: GAO. 

[End of table] 

Attributes of the state, private, and other data sources that we 
identified, as reported by officials from the relevant agency, 
company, or organization, are described below. Unless otherwise 
stated, all information from these sources in this appendix has not 
been independently verified by GAO. 

State Data Sources: 

As of September 2010, we found seven states that have ongoing programs 
to collect and disseminate data on the use of agricultural pesticides, 
fertilizers, or both: Arizona, California, Iowa, Minnesota, New 
Jersey, New York, and Washington. 

Arizona: 

According to officials from the Arizona Pest Management Center (APMC) 
at the University of Arizona, the center analyzes and publishes 
agricultural pesticide application data collected by the Arizona 
Department of Agriculture (ADA) for that state. ADA is required by law 
to collect some pesticide use data from farmers, pest control 
advisors, and custom pesticide applicators within the state. As of 
September 2010, APMC had archived 20 years of historical data from ADA 
and was building an historical database of Arizona pesticide use data, 
which it periodically updates with newly reported data from ADA. APMC 
also makes this data available through published reports. Data 
elements in published reports vary, but they often include names of 
active ingredients in applied pesticides, pesticide product names, 
acres treated, number of applications, application rate, total amount 
applied, cost information, and dates of application. The data are 
presented at both state and county levels and generally cover the 
state of Arizona. The data are disseminated by crop: APMC historical 
pesticide use database has information on over 150 crops, and 
published reports cover over 24 crops. The data are not disseminated 
by livestock species. APMC collects and disseminates these data to 
fulfill mission- related responsibilities and to evaluate integrated 
pest management programs. It has disseminated these data routinely 
since 2006, though ADA has collected the data since at least the early 
1990s. The data are disseminated through Web downloads, e-mail, phone, 
and presentations.[Footnote 27] There is no regular dissemination 
schedule. Published reports are available for free, with no 
restrictions on their use. Data users include farmers, academics, 
chemical manufacturers, commodity groups, public interest 
organizations, lawyers, news media, the federal government, state 
government, and local government. APMC identifies these users through 
user requests for data and citations in published articles. APMC 
gathers feedback two to three times per year through an advisory 
committee, as well as on an ad hoc basis through user group meetings 
and phone calls and e-mails from users. 

California: 

According to California Department of Pesticide Regulation (CDPR) 
officials, the agency produces free pesticide application data and 
pesticide sales data in separate reports--California Pesticide Use and 
Annual Pounds of Pesticides Sold in California--and in other 
specialized reports by request for a fee. Both reports cover the 
entire state of California and provide data at the state, county, 
watershed, farm, and field levels, while the California Pesticide Use 
report also presents data at the square mile level. Both reports 
disseminate data by crop, covering more than 200 crops, and by 
livestock species, covering 12 species. 

CDPR's application data elements include the names of active 
ingredients in applied pesticides, pesticide product names, 
application method, number of planted acres, area applied, number of 
applications, application rate, total amount applied, dates of 
application, geographic location, and grower identification number. 
Meanwhile, CDPR's sales data include the names of active ingredients 
in pesticides sold, amounts of pesticides sold, sales by chemical 
manufacturers to chemical dealers, and sales by chemical dealers to 
users. 

CDPR's purposes for collecting and disseminating both application and 
sales data are to support state requirements and mission-related 
responsibilities, as well as business purposes and research by 
environmental groups and other government agencies. CDPR collects the 
application and sales data continuously from farmers, academics, 
federal government agencies, state government agencies, and local 
government agencies. Pesticide users in California must report 
applications to CDPR, excluding household pesticide use. Pest control 
businesses are required to report applications to their county 
agricultural commissioner within 1 week of use, and farmers must 
report by the tenth day of the following month. County agricultural 
commissioners then submit the data to CDPR. The application and sales 
data were first disseminated in 1950. Both data sets are disseminated 
through Web downloads, e-mail, fax, mail, telephone, presentations, 
and computer laboratories. The application and sales data are 
published once per year, though users may request the data or access 
them on CDPR's Web site at any time. There are no restrictions on the 
use of the data. Application and sales data users include farmers, 
academics, chemical manufacturers, commodity groups, public interest 
organizations, academics, lawyers, news media, the federal government, 
and foreign governments, while application data users also include 
state and local governments. CDPR identifies these data users through 
data requests and citations in published articles. The agency gathers 
feedback from them on an ad hoc basis through individual and group 
meetings, online tools, conferences, telephone calls, and e-mails. 

Iowa: 

According to Iowa Department of Agriculture and Land Stewardship 
(IDALS) officials, the agency collects and disseminates pesticide 
sales data covering that state. These data show pesticide sales at the 
state, county, and watershed levels. The data contain the names of 
active ingredients in pesticides and amounts of pesticides sold. They 
are not released by pesticide product sales amount because Iowa law 
generally prohibits the release of certain information IDALS collects. 
Consequently, IDALS converts this information to approximate pounds of 
active ingredient or a statewide dollar amount by active ingredient 
before it releases the data. Although sales information cannot 
generally be tied to specific crops, Iowa's pesticide sales data can 
be disseminated by crop when matched with the NASS's Agricultural 
Chemical Usage (ACU) data; according to IDALS, researchers compare the 
two data sets to determine where pesticides were used on certain crops 
within Iowa. The data are not disseminated by livestock species. IDALS 
collects and disseminates these data to provide information to 
pesticide, water quality, and public health researchers. The data are 
collected from licensed pesticide dealers, who must report all sales 
of pesticide products with at least $3,000 in sales to IDALS at the 
time of their annual license renewal. IDALS first disseminated these 
data in 2004, though its database contains historical information 
going back to 1989. The data are disseminated through e-mail and other 
electronic methods to the Iowa Department of Natural Resources, which 
provides interactive maps based on the data. So far this information 
has not been widely distributed to the public at large--it is 
available by request and is used by academic researchers, academics, 
the federal government, and state government. However, IDALS plans to 
make this information publicly available on the Iowa Department of 
Natural Resources' Web site, which, as of August 2010, contained a 
pilot version of the interactive maps and database. There is no 
established schedule for data dissemination. IDALS generally 
disseminates the data to users free of charge, and the pilot version 
of the interactive maps and database on the Iowa Department of Natural 
Resources' Web site is available for free, but IDALS provides data to 
entities other than state and federal agency partners for a fee. IDALS 
does not restrict how the data may be used, though it cautions users 
about the data's flaws and limitations, such as the lack of 
statistical validity and statutory limitations on reporting 
thresholds. IDALS receives feedback from data users on an ad hoc basis 
through meetings with individual data users, conferences, telephone 
calls, and e-mails. 

Minnesota: 

According to Minnesota Department of Agriculture (MDA) officials, the 
agency produces pesticide and fertilizer application data through the 
Minnesota Farm Nutrient Management Assessment Program reports and 
pesticide sales data through Minnesota Pesticide Sales Information 
reports. The purpose of these reports is to fulfill state requirements 
and mission-related responsibilities. The Farm Nutrient Management 
Assessment Program reports cover select watersheds or regions within 
Minnesota, while the pesticide sales information covers the entire 
state of Minnesota. Both reports are available to users free of 
charge, without restrictions on their use. Data users include farmers, 
academics, chemical manufacturers, commodity groups, public interest 
organizations, academics, lawyers, news media, state government, and 
local government. MDA obtains feedback from data users annually 
through the state's Pesticide Management Plan Committee, and on an ad 
hoc basis through user group meetings, meetings with individual data 
users, conferences, telephone calls, e-mails, and agency committees. 

The Farm Nutrient Management Assessment Program data were first 
disseminated in 1992. These data are available at the level of 
specific watersheds and regions. Data elements for the majority of 
such data collection efforts include names of active ingredients in 
applied pesticides and nutrients in applied fertilizers, pesticide 
product names, application methods, number of planted acres, area 
applied, number of applications, application rates, total amount 
applied, and timing of application with respect to planting or 
seeding. The data are disseminated by crop and have covered at least 
eight crops. The data are not disseminated by livestock species. MDA 
collects these data via face-to-face interviews with farmers, based on 
an identified agency need or at the request of an interested third 
party, such as a local watershed group, commodity group, academic 
researcher, or other state agency interested in nutrient and pesticide 
data. There is no set schedule for collecting or disseminating these 
data. Dissemination methods include Web download, mail, e-mail, and 
presentations. 

The Pesticide Sales Information reports were first disseminated in 
1991. These reports present data at the state level only. Data 
elements include the names of active ingredients in pesticides sold 
and the amounts of pesticide sold. These data are not generally 
disseminated by crop, as crop type cannot always be discerned from 
sales information, but occasionally sales data associated with a 
single crop are reported when an agricultural pesticide is used only 
on that crop. The data are not disseminated by livestock species. MDA 
receives the sales data from pesticide registrants through mandatory 
sales reports; registrants must report pesticide product sales in the 
state, as well as the associated total dollar amount. MDA collects 
this information annually from chemical distributors and chemical 
manufacturers. The agency uses information reported by these entities 
to determine the amount of active ingredient sold. The Pesticide Sales 
Information reports are disseminated annually and are available 
through Web download, e-mail, and presentations by MDA officials at 
MDA meetings and education and outreach functions. 

New Jersey: 

According to New Jersey Department of Environmental Protection 
officials, the New Jersey Pesticide Control Program produces 
agricultural pesticide application data covering that state. The data 
cover both restricted use and general use pesticide products, and the 
data elements include the names of active ingredients in applied 
pesticides, application methods, and total amounts applied. Data are 
presented at the state, county, watershed, and township levels. They 
are disseminated by crop, and 32 crops are included. The data are not 
disseminated by livestock species. The purpose of this program is to 
fulfill federal requirements, state requirements, and mission-related 
responsibilities. State regulations mandate that pesticide applicators 
maintain records for a minimum of 3 years, and that they provide those 
records to the New Jersey Department of Environmental Protection upon 
request. The agency collects pesticide application data from licensed 
private pesticide applicators through document review, site 
inspection, and questionnaires. The New Jersey Pesticide Control 
Program develops reports from these data, which are disseminated once 
every 3 years through Web download, mail, e-mail, presentations, and a 
data center. The reports are disseminated free of charge, with no 
restrictions on their use. They were first disseminated in 1985. Data 
users include farmers, academics, commodity groups, public interest 
organizations, academics, lawyers, news media, the federal government, 
state government, and local government. Users are identified through 
data requests and citations in published articles. The agency does not 
gather feedback from data users on these data. 

New York: 

According to New York State Department of Environmental Conservation 
officials, the agency's Pesticide Reporting Program produces 
agricultural pesticide application and sales data covering that state. 
Data elements include names of active ingredients in pesticides 
applied and sold, pesticide product names, total amounts applied, 
amounts of pesticide sold, sales by chemical manufacturers to chemical 
dealers, and sales by chemical dealers to users. The data are 
presented at the state, county, and zip code levels. They are not 
disseminated by crop or livestock species. Applicators are required by 
a state environmental law to submit reports under the pesticide 
reporting program. The data are collected through prescribed annual 
report forms, submitted by chemical dealers, chemical manufacturers, 
and commercial pesticide applicators. In addition, the New York State 
Department of Environmental Conservation collects sales reports from 
commercial permit holders that detail the sales of pesticides used in 
agricultural crop production. The application and sales data have been 
disseminated annually since 1998 and are available through Web 
download and presentations. The data are provided free of charge, and 
there are no restrictions on their use. Data users include academics, 
public interest organizations, academics, and state government. Users 
are generally identified through data requests and, although the 
agency generally does not gather feedback from data users, it posted a 
user survey in 2002. 

Washington: 

According to Washington State Department of Agriculture (WSDA) 
officials, the agency's Pesticide Use Project produces agricultural 
pesticide application and fertilizer sales data covering the state of 
Washington. Data elements include names of active ingredients in 
applied pesticides, names of nutrients in applied fertilizers, number 
of planted acres, acres treated, number of applications, application 
rate, and total amount applied. The data are presented at the state 
level only and are not disseminated by crop or livestock species. WSDA 
first disseminated the data in 2003 to provide the U.S. Environmental 
Protection Agency (EPA) with information necessary to conduct risk 
assessments related to the Endangered Species Act (ESA). According to 
WSDA officials, the purpose of the Pesticide Use Project is to fulfill 
federal requirements, state requirements, and mission-related 
responsibilities. Specifically, WSDA uses the data for risk 
assessments related to EPA requirements and biological opinions 
related to ESA compliance. The data are collected through document 
review, questionnaires, reports from other entities, and cooperative 
agreements with NASS. WSDA collects the data once every 3 years from 
farmers, chemical dealers, commodity groups, and the federal 
government. The agency considers the data to be anecdotal, in part due 
to the small sample size of the data that it collects. The data are 
disseminated by mail, e-mail, telephone, and presentations. There is 
no established dissemination schedule. The data are available free of 
charge, and there are no restrictions on their use. Data users include 
academics, commodity groups, public interest organizations, the 
federal government, state government, and local government. WSDA 
identifies these users through requests for data and citations in 
published articles and, as of July 2010, the agency was implementing a 
log-in registration process. The agency does not gather feedback from 
data users. 

Private Data Sources: 

Three companies collect and disseminate data on the use of 
agricultural pesticides, fertilizers, or both: Crop Data Management 
Systems (CDMS), GfK Kynetec, and Mike Buckley & Associates. 

CDMS: 

According to CDMS officials, the company produces agricultural 
pesticide and fertilizer application and sales data covering multiple 
U.S. states. Data elements include the names of active ingredients in 
pesticides applied and sold, names of nutrients in fertilizers applied 
and sold, pesticide product names, fertilizer product names, 
application methods, number of planted acres, acres treated, number of 
applications, application rates, total amounts applied, cost 
information, dates of applications, timing of applications with 
respect to planting or seeding, who applied the chemicals, and amounts 
sold. The data are presented at the state, county, watershed, farm, 
and field levels, as well as custom areas that may be requested by a 
client. The data are disseminated by specific crops and crop 
categories, covering over 100 crop categories. The data are not 
disseminated by livestock species. CDMS uses software to collect the 
data. The company collects the data from chemical dealers, chemical 
manufacturers, commodity groups, chemical applicators, and farmers. 
Data are collected annually, quarterly, monthly, daily, and in real 
time. CDMS has disseminated the data since 1994, and dissemination 
methods include Web download, mail, e-mail, fax, telephone, 
presentations, and other electronic options. Data are disseminated 
annually, quarterly, monthly, weekly, daily, and in real time, 
depending on the client's needs. Users pay a fee for the data, and 
there are restrictions on how the data may be used, based on 
individual agreements with each client. Data users include farmers, 
academics, chemical manufacturers, commodity groups, crop consultants, 
chemical applicators, academics, the federal government, and state 
governments. Users are identified through log-in registration, online 
tools, subscription-based user information, and data requests. CDMS 
gathers feedback from users regularly and on an ad hoc basis, through 
user group meetings, meetings with individual data users, online 
tools, conferences, telephone calls, and e-mails. 

GfK Kynetec: 

According to GfK Kynetec officials, since acquiring Doane Market 
Research in January 2010, the company has produced agricultural 
pesticide application and sales data covering multiple U.S. states in 
its Syndicated U.S. Studies. Prior to the acquisition, Doane Market 
Research had produced these data since 1954. Data elements include the 
names of active ingredients in pesticides applied and sold, pesticide 
product names, application methods, number of planted acres, acres 
treated, number of applications, application rates, total amounts 
applied, cost information, timing of applications with respect to 
planting or seeding, who applied the chemicals, crop stages of 
application, sales by chemical dealers to users, amounts sold, target 
weeds or pests, pesticide application sequence, tank mixing partners, 
seed treatments, and seed trait of target crop.[Footnote 28] The data 
are presented nationwide and by state, agricultural statistics 
district, and county. GfK Kynetec disseminates data by crop and 
livestock species; the company's own data collection covers 61 crops 
and 7 livestock species, and it also reformats and sells some of 
CDPR's data, covering 216 crops. 

GfK Kynetec collects the data annually, quarterly, monthly, and 
weekly, through questionnaires and reports from other entities. The 
company collects data from farmers, chemical dealers, chemical 
manufacturers, commodity groups, academics, state government, and 
local government. It disseminates the data annually on a regular 
schedule, and dissemination methods include Web download, mail, e-
mail, and presentations. Users pay a fee for the data, and there are 
restrictions on how the data may be used; for example, the data cannot 
be released to the public or put in the public record. Users of GfK 
Kynetec's data include academics, chemical manufacturers, commodity 
groups, lawyers, and the federal government. The company identifies 
users through log-in registration, subscription-based user 
information, and data requests. It gathers feedback from data users 
once per year and also gathers feedback on an ad hoc basis. Feedback 
mechanisms include user group meetings, telephone calls, and e-mails. 

Mike Buckley & Associates: 

According to the company's president, Mike Buckley & Associates 
collects and disseminates agricultural pesticide application and sales 
data covering all U.S. states, as well as Canada and Mexico. Data 
elements include names of active ingredients in pesticides applied and 
sold, pesticide product names, application methods, number of planted 
acres, areas applied, cost information, dates of application, timing 
of application with respect to planting or seeding, season of 
application, amounts of pesticide sold, cost information, and sales by 
chemical manufacturers to users. The company disseminates data by 
crop, but not livestock species. Its agricultural chemical usage 
studies cover 32 crops, and it also undertakes seed treatment studies, 
which cover 16 crops. The data are presented at the state level only. 
The company collects data annually from farmers, chemical dealers, 
pesticide manufacturers, commodity groups, academics, state 
government, and local government. The data are collected through 
document reviews, site inspections, questionnaires, and reports from 
other entities. Mike Buckley & Associates first disseminated the data 
in 1990. The data are disseminated annually through the mail and 
presentations. Users pay a fee for the data, and there are 
restrictions on how the data may be used. Specifically, the company 
maintains ownership of all data produced in multiclient studies; 
subscribing clients generally purchase the rights to access the data 
for internal use only, but exceptions may be granted to support 
regulatory and legal filings. Data users include chemical 
manufacturers, commodity groups, public interest organizations, 
federal government, foreign governments, and consulting firms. The 
company identifies its data users through subscription-based user 
information, data requests, and citations in public articles. It 
gathers feedback from users regularly and on an ad hoc basis through 
user group meetings, meetings with individual data users, conferences, 
telephone calls, and e-mails. Regularly scheduled feedback is gathered 
quarterly and annually. 

Other Data Sources: 

We also found one nonprofit organization, the Association of American 
Plant Food Control Officials (AAPFCO) that collects and disseminates 
agricultural fertilizer usage data, and one federal agency other than 
NASS, EPA, that collects and disseminates agricultural pesticide usage 
data. 

AAPFCO: 

According to an AAPFCO official, the organization produces 
agricultural fertilizer sales data covering all U.S. states. The 
organization collects data through reports from its members, who 
include state fertilizer control officials. Additionally, AAPFCO 
estimates the fertilizer sales information for a few states that do 
not collect such information based on sales in surrounding states. 
Data elements include the names of nutrients in fertilizers applied 
and sold, fertilizer product names, amounts of fertilizer sold, sales 
by chemical manufacturers to chemical dealers, sales by chemical 
dealers to users, and sales by chemical manufacturers to users. 
However, data elements vary from state to state due to differences in 
the information that AAPFCO receives from state agencies. The data are 
presented at both state and county levels but are not disseminated by 
crop or livestock species. The organization collects and disseminates 
fertilizer sales data for business purposes and mission-related 
responsibilities. AAPFCO first disseminated these data in 1995, when 
it began this effort as a joint project with The Fertilizer Institute--
an organization representing fertilizer manufacturers--after the 
Tennessee Valley Authority, which had disseminated the data since 
1985, discontinued managing the data program. AAPFCO disseminates the 
data annually and upon request, by mail, e-mail, and fax. Most of 
AAPFCO's data are disseminated at a cost; both printed reports and 
electronic data sets are provided to users at what the organization 
considers to be a nominal fee. However, there are no restrictions on 
how the data may be used. Data users include academics, chemical 
manufacturers, commodity groups, public interest organizations, 
lawyers, and the federal government. AAPFCO identifies these users 
through data requests and does not gather feedback from its data users. 

EPA: 

According to EPA officials, the agency produces Pesticides Industry 
Sales and Usage reports, which present global data on agricultural and 
nonagricultural pesticide active ingredient pounds applied and sold, 
including all U.S. states. Regarding agricultural pesticides 
specifically, data elements included in these reports include the 
names of the top active ingredients applied and sold, total amounts 
applied, and sales by chemical dealers to users. The reports do not 
present data by crop or livestock species. The data are summarized at 
the world and U.S. national levels. The purpose of these reports is to 
provide general information to the public on pesticide active 
ingredients applied and sold. EPA does not collect primary data for 
these reports and instead relies on other sources. As previously 
discussed, the 2010 report will use U.S. agricultural chemical usage 
data from NASS and GfK Kynetec, as well as other sources for non-U.S. 
and nonagricultural pesticide usage data. The agency generally 
collects data for these reports once per year, although some sources' 
data are available less often. EPA first disseminated these reports in 
1979. They are not disseminated every year; the most recent report was 
published in 2004, showing new data for pesticide usage in 2000-2001. 
According to EPA officials, the reports were subsequently discontinued 
due to resource and time constraints, but resources are now available 
to resume the reports, most likely on a biannual basis. The 2010 
report will present new data for 2002 through 2007 and historical data 
for previous years. The reports are disseminated via Web download, and 
there is no established dissemination schedule. The reports are 
available for free, with no restrictions on their use. Users include 
academics, commodity groups, public interest organizations, news 
media, the federal government, and state governments. EPA identifies 
these users through data requests and citations in published articles, 
and the agency gathers feedback from data users on an ad hoc basis 
through e-mails and telephone calls. 

[End of section] 

Appendix III: Comments from the U.S. Department of Agriculture: 

USDA: 
United States Department of Agriculture: 
Research, Education, Economics: 
Office of the Under Secretary
Room 216W: 
Jamie L. Whitten Building: 
Washington, DC 20250-0110: 

October 25, 2010: 

Ms. Lisa Shames: 
Director, Natural Resources and Environment: 
U.S. Government Accountability Office: 
Washington, D.C. 20548: 

Dear Ms. Shames: 

This is in response to the draft Government Accountability Office 
(GAO) report on Agricultural Chemicals: USDA Could Enhance Pesticide 
and Fertilizer Usage Data, Improve Outreach and Better Leverage 
Resources (GAO-11-37). The National Agricultural Statistics Service 
(NASS) appreciates the detail and professionalism exhibited by the GAO 
auditors throughout this review. The draft report and recommendations 
are insightful and will be used to further strengthen NASS and its 
management of the Agricultural Chemical Use Program. 

For clarity, the NASS comments have been organized under each of the 
four recommendations in the report. 

1. Establish a formal mechanism to identify and consult ACU data users 
on an ongoing basis to ensure ACU data continue to meet users' 
informational needs and to consider the effects of potential program 
changes on users, weighing the costs and benefits of those Changes. 

The Department of Agriculture (USDA) agrees with this recommendation. 
NASS holds an annual data users meeting where all statistical data 
series are open for discussion. The ACU data will be included as an 
agenda item. Additionally, NASS will convene a special data users 
meeting during 2011 to focus specifically on the ACU data series. The 
invitation list to this meeting will be drawn from known ACU data 
users with an emphasis on individuals and entities who submitted 
comments to the Department during the period when the ACU program was 
reduced. 

NASS will also conduct a comprehensive market research effort to 
enable it to better understand its customers/audience and their 
information needs. A statement of work has already been issued to seek 
the assistance of a qualified public affairs consulting firm to 
conduct this independent assessment. The research findings will be 
used to guide the development and implementation of a multi-year, 
multi-faceted, strategic communications plan that will identify 
strategies, tactics, practices, products, and action steps to ensure 
all NASS data series meet users' informational needs. 

2. Strengthen outreach to state agencies regarding NASS's ability to 
enter into reimbursable cooperative agreements that would maximize 
state and federal resources, minimize costs, and enhance ACU data's 
usefulness to state officials. 

USDA agrees with this recommendation. NASS will leverage its on-going 
relationship with the National Association of State Departments of 
Agriculture to reach outside the agriculture community into other 
sectors of local and State government with responsibilities for 
pesticide regulations and oversight. An inventory of available 
agricultural chemical use data collections will be made and monitored 
to minimize duplicative efforts. This will allow NASS to maximize use 
of its appropriated funds. 

3. Improve user's ability to access and use ACU data on NASS's Web 
site by making it easier to find ACU reports, data tools, and related 
resources, and by updating ACU data tools on a timely basis. 

USDA agrees with this recommendation. NASS is actively working to 
improve its on-line database, QuickStats, for the presentation of all 
NASS data series including the ACU data. An internal NASS team has 
been chartered to review data user comments aimed at improving 
functionality and ease of use for all data users. 

4. Develop a process to systematically identify and evaluate other 
agricultural pesticide and fertilizer usage data sources that are 
publicly available on an ongoing basis to better leverage resources 
and reduce areas of potential overlap with ACU data collection. 

USDA agrees with this recommendation. NASS Headquarters personnel with 
ACU responsibility will annually review known public sources of 
fertilizer and pesticide information for updated and expanded data 
items. They also will coordinate with NASS Field Office personnel to 
identify new data series available at local levels. These efforts will 
build off of the results from the USDA response to the second 
recommendation addressed in this response. 

We appreciate the opportunity to review and provide comments on the 
draft report. 

Sincerely, 

Signed by: 

Catherine Woteki: 
Under Secretary: 
Chief Scientist, USDA: 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Lisa Shames, (202) 512-3841, or shamesl@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, James R. Jones, Jr., 
Assistant Director; Laurel Ball; Josey Ballenger; Kevin S. Bray; 
Ronald S. Fecso; Jacqueline M. Nowicki; Alison O'Neill; Shannin 
O'Neill; Valerie Pfeiffer; Rebecca Shea; and Michael Silver made key 
contributions to this report. 

[End of section] 

Footnotes: 

[1] Congress enacts continuing resolutions to allow federal agencies 
to continue operating when their regular appropriations bills have not 
been enacted prior to the start of the fiscal year. Under continuing 
resolutions, federal agencies generally allocate funds through funding 
formulas frequently referenced to the previous year's appropriations 
act or a bill that has passed either the House or Senate--instead of a 
specific amount. 

[2] A restricted-use pesticide is a pesticide that is available for 
purchase and use only by certified pesticide applicators or persons 
under their direct supervision, and only for the uses covered by the 
applicator's certification. 

[3] Integrated pest management is an agricultural strategy that 
combines the use of chemical pesticides with a wide range of 
nonchemical pest management practices, such as planting pest-resistant 
crop varieties and protecting beneficial organisms, thereby 
potentially reducing reliance on pesticides. 

[4] Emergency exemptions are granted to federal or state agencies by 
EPA and allow use of a pesticide in circumstances such as a disease 
outbreak that cannot be controlled by registered products, while 
special pesticide registrations are granted to state agencies by EPA 
and permit states to allow additional uses of a federally registered 
pesticide product to meet special local needs. 

[5] OMB Statistical Policy Directive Number 3, "Compilation, Release, 
and Evaluation of Principal Federal Economic Indicators," governs the 
release of principal economic indicators, which are statistical series 
that provide timely measures of economic activity and that are 
compiled and released by federal agencies. 50 Fed. Reg. 38,932 (Sept. 
25, 1985). 

[6] The 2006 subcommittee's objectives were to consider whether there 
was (1) interest in creating an integrated national system for 
pesticide use data collection and distribution combining public and 
private sources of data; (2) a compelling problem with pesticide use 
data availability or coverage that is currently unaddressed by 
available pesticide use data sources; and (3) a groundswell of support 
for a major increase in public funding for federal pesticide use data 
collection. 

[7] Office of Management and Budget, Executive Office of the 
President, OMB Cir. No. A-130, Transmittal Memorandum #4, Management 
of Federal Information (Nov. 28, 2000). 

[8] GAO, Continuing Resolutions: Uncertainty Limited Management 
Options and Increased Workload in Selected Agencies, [hyperlink, 
http://www.gao.gov/products/GAO-09-879] (Washington, D.C.: Sept. 24, 
2009). 

[9] U.S. Department of Agriculture, National Agricultural Statistics 
Service, Strategic Plan for 2006-2011 (Washington, D.C.: April 2007). 

[10] Although these were the most frequent suggestions made by users 
we interviewed, other suggestions to enhance the data's usefulness 
included adding more crops to ACU surveys, such as kale, garlic, and 
canola; adding data elements on acres planted with genetically 
modified versus conventional crops; and adding data elements on 
whether farmers use conventional or organic practices. 

[11] Methyl bromide is a fumigant used to control pests across a wide 
range of agricultural sectors. According to EPA, the amount of methyl 
bromide produced and imported in the United States was reduced 
incrementally until it was phased out in 2005 because it was found to 
deplete the stratospheric ozone layer. 

[12] OMB Cir. No. A-130. 

[13] Unless otherwise noted, all cooperative agreement amounts are in 
constant 2010 dollars. 

[14] OMB Cir. No. A-130. 

[15] GAO, Medicare: Communications to Beneficiaries on the 
Prescription Drug Benefit Could be Improved, [hyperlink, 
http://www.gao.gov/products/GAO-06-654] (Washington, D.C.: May 3, 
2006). 

[16] As of October 2010, NASS's "Environmental" page was located at 
[hyperlink, 
http://www.nass.usda.gov/Statistics_by_Subject/Environmental/index.asp].
 

[17] As of October 2010, the original version of Quick Stats, Quick 
Stats 1.0, could be found at [hyplerink, 
http://www.nass.usda.gov/Data_and_Statistics/Quick_Stats_1.0/index.asp],
 and a new version, Quick Stats 2.0, was located at [hyperlink, 
http://quickstats.nass.usda.gov]. Meanwhile, the ACU Database could be 
found at [hyperlink, http://www.pestmanagement.info/nass]. 

[18] As of October 2010, the "Agricultural Chemical Use Program" Web 
page was located at [hyperlink, 
http://www.nass.usda.gov/Surveys/Guide_to_NASS_Surveys/Chemical_Use]. 

[19] The USDA data user meetings cover data generated not only by NASS 
but also by USDA's World Agricultural Outlook Board, Economic Research 
Service, Agricultural Marketing Service, and Foreign Agricultural 
Service, as well as data generated by the U.S. Census Bureau. 

[20] OMB Cir. No. A-130. 

[21] According to NASS officials, the Program Planning Council is an 
ongoing team comprising NASS's 10 senior executives, 2 rotating branch 
chiefs, and 4 rotating field office directors, and usually meets once 
each spring and fall. 

[22] We developed and distributed a questionnaire to collect 
information from these data sources, the results of which are used to 
describe their data. Unless otherwise stated, we did not independently 
verify the questionnaire results. 

[23] We did not assess the reliability of other data sources and 
therefore cannot determine whether they, or any of their attributes, 
are comparable to NASS's ACU data or to each other. 

[24] The Information Quality Act requires OMB to issue guidelines for 
ensuring the quality, objectivity, utility, and integrity of 
information disseminated by federal agencies. OMB's guidelines direct 
agencies covered by the act to issue their own quality guidelines. 

[25] OMB Cir. No. A-130. 

[26] U.S. Department of Agriculture, Strategic Plan for FY 2010-2015. 

[27] As of September 2010, the full database was not available on the 
Web. However, the APMC publishes reports on the Arid Southwest IPM 
Network Web site and responds to information requests from 
researchers, companies, and other entities. 

[28] A pesticide application sequence is the sequence of products used 
on a given piece of land. A tank mix is an application of two or more 
products at once. Seed trait is an identifier for the type of 
genetically modified seeds. 

[End of section] 

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