From owner-vgin-sa@virginiainteractive.org Fri Jul 25 13:08:55 2008
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Date: Fri, 25 Jul 2008 13:10:07 -0400
From: "Karl Huber" <Karl.Huber@dcr.virginia.gov>
To: <vgin-sa@virginiainteractive.org>
Subject: VGIN_State-Agencies_Listserv: FSA CLU
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Contrary to the recent ruling which denied the FSA FOIA protection for
their Common Land Unit (CLU) boundaries and identifiers, and which many
of us in Virginia have been discussing of late, recent guidance from
within the USDA FSA appears to effectively reverse that opinion.  It
halts any of our attempts to obtain the FSA Farm, Tract, and Field
identifiers in a manner that allows them to be associated with the CLU
boundaries.

I pulled the following from the guidance where it applies to this issue:
*-----
General Prohibition Defined:  Section 1619, "Information Gathering" of the Food, Conservation, and Energy Act of 2008 (2008 Farm Bill) enacted on May 22, 2008 and reenacted on June 18, 2008 to include the Title III, "Trade."  This law prohibits public disclosure of information that meets the following criteria:

(1) Provided to U.S. Department of Agriculture (USDA) by an agricultural producer or owner of agricultural land in order to participate in a USDA program, and concerning the agricultural operation (including production and marketing of agricultural commodities and livestock), farming or conservation practices, or the land itself; 
or,
(2) Contained in any type of USDA geospatial information system (GIS) with producer- provided information about agricultural land or operations.

Calculations based on producer-provided information and inspection reports or other records derived from visual, on-site inspection of the producer's or owner's land are prohibited from release as USDA derives such information directly from the producer- or owner-provided information.  Contract, farm, field, and tract numbers are releasable, except when these data elements appear on maps relating to a specific data gathering site.  The prohibitions in Section 1619 apply both to participating and "non-participating" producers (e.g., those producers and land owners who provide information to USDA to aid USDA in the administration of programs).   See "Conservation, 'Transition,' Section 2903," below for special conservation program exceptions.   

The National Aerial Imagery Program (NAIP) maps themselves are releasable as this imagery is derived from airspace above the producer's and owner's land.  The common land unit (CLU) designations and attributes that may be shown on NAIP maps are not releasable in response to a Freedom of Information Act (FOIA) request or public inquiry.  CLU designations shall be released to USDA cooperators and contractors, in compliance with Section 1619 and as identified in permissible routine uses under the Privacy Act (PA).
*----

The FSA seems to consider these identifiers to be too closely associated with the producer-provided
information in aims to keep from the public when used to graphically identify a specific land area.


Karl Huber
GIS/Data Management Manager
Virginia DCR - DSWC
203 Governor St, Suite 206
Richmond, VA  23219-2094
(804) 371-7484
karl.huber@dcr.virginia.gov

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