NFFC comments on FNS Information Collection Needs due to COVID-19


Washington D.C. January 18, 2022

Maureen Lydon and Jamia Franklin 
Food and Nutrition Service, U.S. Department of Agriculture 

FNS Information Collection Needs due to COVID-19. OMB Number: 0584-0654.

Dear Ms. Lyndon and Ms. Franklin, 

On behalf of the members of the National Family Farm Coalition, we thank you for the opportunity to  submit comments to the Food and Nutrition Services (FNS) on its intent to ask the Office of  Management and Budget (OMB) to extend approval of the information collection under OMB approval  #0584-0654 from January 31, 2022, to August 27, 2023 (OMB Number: 0584-0654). 

The National Family Farm Coalition (NFFC) is an alliance of grassroots farmer- and advocate-led  groups across 42 states, representing the rights and interests of independent family farmers, ranchers,  and fisherfolk in Washington, DC. NFFC’s 32 state, national, and regional farm and rural organizations  are bound by a common belief that communities have the right to determine how their food is grown and harvested; that everyone in the food system should receive fair prices or wages; that all producers  have equitable access to credit, land, seeds, water, markets, and other resources; and, that our food  and agriculture policies must support sustainable farming, ranching, and fishing practices. 

While the proposed extension of waivers and reporting requirements do not directly affect our  members, we are compelled to highlight our primary concerns about them based on the fact that the  COVID-19 pandemic and related emergencies persist, providing merit to the extension. Our first  concern is that, in the rush to provide service, some important norms may be overlooked by State officials; our second concern relates to the final use of the data collected. 

For many years, NFFC has advocated various programs, including the ones described in the proposed  regulations, to ensure that USDA dollars are directed to small farmers and producers, but the process  has not always been fair or clear (NFFC, 2021). We know that many school districts, particularly in  rural areas, receive fresh produce from local family farmers, thanks to the waivers and to the  recognition of our food system’s vulnerability. 

Finding the right balance between safety norms, local market supports, and healthy food access, while  addressing the social inequalities of our food system, will require more than temporary waivers and  increased reporting. We support data collection, particularly if such data provides useful information.  Very often, USDA collects data that is not easily accessible, and serves no known purpose aside from reporting the use of funds because there has been no follow-up discussion with farmers, providers,  and consumers about the data or its implications. 

In short, we ask for: a) equal opportunities for family local farmers, food procurement agencies, and  beneficiaries; and b) transparency about the data collected, particularly regarding the option to analyze  the data in way can help to redefine and improve our unsustainable food system. For example, data  available at USDA Agricultural Research Services and at the Agricultural Collaborative Research  Outcomes System (AgCROS) is limited; in the first case data tend to be outdated and in the second case access is limited if not in an academic institution – which for the most part tend to side with agro-industrial interests.  

Thank you, again, for the opportunity to provide these comments. 

Antonio Tovar PhD 
Policy Associate 
National Family Farm Coalition 
110 Maryland Ave. Suite 307 
Washington D.C. 20002 


National Family Farm Coalition (NFFC) 2021. Comments to USDA on Buy-American