2016 LSC Agricultural Worker Population Estimation Methodology

In 2016, LSC updated the estimation methodology and the estimate of the LSC Agricultural Worker Population for the first time in over twenty years.  The estimates reflected input LSC received during three public comment periods from January 2015 through July 2016.  

The 2016 estimation methodology is set forth in three documents:

• January 2015 initial population estimate methodology.
  • Memorandum from ETA to LSC with estimates of LSC-eligible agricultural worker population and explanation of estimation methodology (January 21, 2015).
  • The methodology was provided with the initial estimates reported to the LSC Board in January 2015.
• February 2016 methodology for estimate of additional non-U.S. citizens who are victims of violence or crime.
  • Estimate of the Population of Agricultural Workers Eligible for LSC-Funded Services Pursuant to 45 C.F.R. § 1626.4—Anti-Abuse Laws provided to the LSC Board (January 2016)
• August 2016 adjustments to the methodology based on public comments.
  • Memorandum from ETA to LSC adopting three adjustments to the methodology (July 2016).
  • The August adjustments were provided in conjunction with the Final Estimates–Tables I–VI (Excel), which the Board adopted in August of 2016

Past Notices and Public Comments

August 2016—Final Estimates Adopted by LSC for 2017–2018 Implementation

• Final Notice—Adoption of Estimates of Agricultural Workers (August 8, 2016)
  • Appendix A—July 2016 ETA and JBS Memorandum
  • Final Estimates–Tables I–VI (Excel) 

July 2016–Final Revised Estimates for Consideration by the LSC Board

• 2016 Ag Worker Data Final Order–LSC Board DRAFT–July-14-2016
  • Table of Contents Agricultural Worker Population Update
  • Appendix A
  • Appendix B
  • Appendix C
  • Updated Estimates–Tables for Publication I–VI (Excel) 

April 2016 Notice—Revisions to the Michigan Estimate

LSC published in the April 4, 2016 Federal Register a notice for comment on alternative estimates of the LSC-eligible agricultural worker population in Michigan.  Those estimates, which appear below, were submitted by the Michigan Advocacy Program in the comments to the February 2016 notice.

• Federal Register | Agricultural Worker Population Estimates for Basic Field-Migrant Grants
• Comments
  • Mich-Adv-Proj—Comment—Ag-Wrkr-Estmts—May-19–2016

February 2016 Notice—Revised Estimates

LSC published materials for comment in the February 5, 2016 Federal Register.  Comments were due March 21, 2016.  The materials and comments appear below.  Please direct any questions to  Mark Freedman, Senior Associate General Counsel, at mfreedman@lsc.gov. 

• Federal Register Notice: Request for Comments—Agricultural Worker Population Data for Basic Field–Migrant Grants
  • Appendix A: Estimate of the Population of Agricultural Workers Eligible for LSC-Funded Services Pursuant to 45 C.F.R. § 1626.4—Anti-Abuse Laws
  • Tables I–VII (Excel Document)
    • Table I—Updated Estimates of the Size and Geographic Distribution of The LSC-Eligible Agricultural Worker Population and the Sources and Calculations Used to Develop Those Estimates.
    • Table II—National and State Estimates of the LSC-Eligible Agricultural Worker Population—Summary Table.
    • Table III—Percentages of Agricultural Workers by National Agricultural Worker Survey (NAWS) Region and State Who Are Authorized and in Poverty.
    • Table IV—Average Numbers of Dependents per Farmworker by National Agricultural Worker Survey (NAWS) Region and State.
    • Table V—Number and Percentage of LSC-Eligible Agricultural Workers in Each State Who Are Crop, Livestock, and Forestry Workers.
    • Table VI—Number of Unauthorized and Below-Poverty Farmworkers Eligible for LSC-Funded Services Pursuant to Anti-Abuse Provisions of 45 CFR § 1626.4(3).
    • Table VII—LSC-Eligible Agricultural Worker Population by State: Comparison of Current Population Estimates and Updated January 2016 Department of Labor, Employment and Training Administration (ETA) Estimates.

• Comments
  • NLADA—Comment—Ag-Wrkr-Estmts—March-21–2016
  • Mich-Adv-Proj—Comment—Ag-Wrkr-Estmts—March-21–2016
  • Mich-Adv-Proj—Appendix—Ag-Wrkr-Estmts—March-21–2016
  • Puerto-Rico-Leg-Svcs—Comment—Ag-Wrkr-Estmts—March-21–2016
  • Puerto-Rico-Leg-Svcs—Appendix—Ag-Wrkr-Estmts—March-21–2016

February 2015 Notice—Initial Estimates

On February 3, 2015, LSC posted in the Federal Register a request for comments regarding updating the Basic Field—Migrant grants based on new data from the Department of Labor regarding agricultural workers and their dependents.  Written comments were due by April 20, 2015.  On July 27, 2015, LSC posted in the Federal Register a statement that it will make public additional information underlying the new data, contract with the Department of Labor for assistance addressing issues raised in the comments, consider development of revised data, and seek public comment on any revised data and a revised implementation plan. Implementation would begin January 2017

• Federal Register Notice Seeking Public Comment  (written comments due by April 20, 2015)
• Federal Register Notice of Extension of Comment Period to April 20, 2015 (March 19, 2015)
• Federal Register Notice Regarding Further Actions in 2016 (July 27, 2015)
  • LSC Memorandum to the Operations and Regulations Committee (January 21, 2015)
  • LSC Management Report on Agricultural Worker Population Estimate Update (updated January 30, 2015)
  • LSC Management Report Appendices (updated January 30, 2015)
  • LSC Management Report with Appendices as a single document (updated January 30, 2015)

• Public Comments on February 2015 Agricultural Worker Population Estimate Update
  • Comments of Marciel Buelna (March 17, 2015)
  • Comments of Anonymous (March 19, 2015)
  • Comments of Legal Action of Wisconsin (April 16, 2015)
  • Comments of the American Bar Association (April 16, 2015)
  • Comments of the National Legal Aid and Defender Association, Farmworker Section, Agricultural Worker Project Group (April 20, 2015)
  • Comments of the National Legal Aid and Defender Association (April 20, 2015)
  • Comments of Southern Minnesota Regional Legal Services (April 20, 2015)
  • Comments of Iowa Legal Aid (April 20, 2015)
  • Comments of Florida Legal Services (April 20, 2015)
  • Comments of Michigan Advocacy Program (April 20, 2015)
  • Comments of Georgia Legal Services (April 20, 2015)