Letter to Ken Nagel, USDA Expressing Concerns About the USDA's Proposed Uniform Guidelines for Conducting Farm Service Agency (FSA) County Committee Elections

September 16, 2004

Ken Nagel
Administrative Management Specialist
Office of the Deputy Administrator for Field Operations
Department of Agriculture
Room 3092-S Mail Stop 0539
1400 Independence Ave SW
Washington, DC 20250-0539

RE: Proposed Uniform Guidelines for Conducting Farm Service Agency County Committee Elections (FR Doc. 04-18774)

Dear Mr. Nagel:

On August 17, 2004, Secretary Ann Veneman issued the Department of Agriculture's "Proposed Uniform Guidelines for Conducting Farm Service Agency (FSA) County Committee Elections."

The organizations listed below would first like to commend Secretary Veneman and the USDA for their work to advance the mandates of the 2002 farm bill as they relate to these issues and for their work to improve the democratic process for conducting FSA County Committee Elections.

Given our support for your endeavor, we must also explain that we are very concerned about some of these guidelines which we feel will further erode the effectiveness and authorities of our county committees and jeopardizes their abilities to manage the programs passed by Congress and administered by the FSA.

The key areas which we find problematic are;

I. County Committee Election Outreach and Communication Efforts

While we fully support this initiative and again commend your efforts, we feel that since this first phase is a year-long process, the implementation of the balance of the new guidelines should be postponed until this phase has had the requisite time to be successful. Therefore, we urge that the balance of the new guidelines, as amended following this comment period, be implemented for the December 2005 County Committee Elections.

II. County Committee Election Procedures

1. Slate of Candidates:
   1. We believe that there should never be less than two valid candidates on the ballot since that is the only way to ensure that an alternate will be available to serve should the need arise.
   2. We believe that discretionary appointment by the Secretary should be resorted to if, and only if, both the County and State committees, respectively, have been unable to complete the slate of nominees after a diligent search.
   3. We strongly oppose the nomination of any candidate by the Secretary after the nomination deadline has passed if the County Committee has completed a slate of nominees pursuant to item 1 of this subsection.
      
      
2. Term Limits: We are adamantly opposed to reducing term limits from three to two consecutive terms. This proposed guideline fails to recognize the difficulty in finding eligible producers who are willing to serve and the need for continuity on our county committees. It also ignores the significant costs associated with orientating and training new committee members that will result if terms are reduced.
   
   But most importantly, in the context of the main emphasis of these proposed guidelines, reducing the terms limits will severely hamper those member of the committee representing socially disadvantaged groups who have been nominated and voted on to become regular committee members. This provision is most likely counter to the intent of the proposed guidelines.

III. Additional Election Reform Efforts

1. While we are fully committed to the concept of fair representation on FSA county committees, we do not believe that centralization of the election process will further that goal. Local control of election processes is a mainstay of our democratic system. The problems experienced in the 2003 committee elections argue against any attempt to abandon that standard in favor of further centralization.
   
   We also oppose Secretarial appointment of any voting member to FSA county committees. We do favor modifying the existing procedures to allow for elected at-large and fully-privileged minority representatives. We believe that appointing voting members dilutes the accountability and credibility of our county committee system. Elected representation is the only way to achieve and sustain fair and equitable representation for all the producers we serve. The appointment of voting members of County Committees will inject politics into non-partisan committees.

IV. Implementation of Uniform Guidelines

1. As stated above, until the outreach and communications projects of this initiative are completed, the balance of these guidelines should not be implemented. We urge that the balance of the new guidelines, as amended following this comment period, be implemented for the December 2005 County Committee Elections.

Our last concern is one of the lack of inclusion by all stakeholders in drafting these important changes in procedure. Many, if not all, of the undersigned organizations were never consulted by FSA or the USDA on these issues. We therefore strongly suggest a thirty-day extension for remarks to these proposed changes in procedure. We also request the Secretary to direct the FSA to facilitate a stakeholders meeting prior to the conclusion of said thirty-day extension.

Thank you for this opportunity to respond.

Sincerely,

American Corn Growers Association
National Association of Wheat Growers
National Cotton Council
National Farmers Organization
National Grange
Women Involved in Farm Economics