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1 RIN2070

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AJ22_EO12866_AgWPS_FRM_EA AppendixA_2015

- 07

- 13.docx



## Draft document as submitted for review under EO 12866



## ECONOMIC ANALYSIS OF

FINAL REVISIONS TO

THE WORKER PROTECTIO N STANDARD

APPENDIX A

Estimating Farms and Workers Covered by the WPS

Table of Contents

A.1. Farms

................................ ................................ ................................ ................................ . 1

A.2. Employees

................................ ................................ ................................ ......................... 10

A.3. Comparison of Estimates

................................ ................................ ................................ .... 15



### A critical component in the estimation of costs and benefits of the WPS is the number of entities 1



### affected by revisions to the rule. The WPS is designed to provide protection to workers and 2



### handlers on agricultural establishments that use pesticides. To estimate the impacts of proposed 3



### revisions to the WPS

, E P A obtained a special tabulation, based on the 2007 Census of 4



### Agriculture, which identified the number of farms, by type and economic category, that used 5



### pesticides and/or hired la b o r, along with the number of employees. This special tabulation also 6



### provided information about different farm structure, particularly the number of employees per 7



### farm , which var ies by type and economic class

. 8

9



### The 2012 Census of U.S . Agriculture was pub lished in May 2014, as EPA began work on the 10



### final revisions to the WPS. This appendix describes the methods and results for estimating the 11



### number of farms and employees based on publicly available information from the 2012 Census

, 12



### given the information f rom the special tabulation conducted in 2008

. In May 2015, more 13



### detailed data from the 2012 Census of Agriculture was provided to EPA, which allows us to 14



### confirm the validity of these estimates. 15

16



## A.1. Farms 17

18



### Table A .1

- 1 presents d ata on farm numbers from the special tabulation for all farms in the U.S. 19



### based on the 2007 Census of Agriculture (NASS, 2008)

. The data are organized by economic 20



### category and by primary production or NAICS category. The economic categories are based on 21



### the Small Business Admin istration definition of a small farm, which is an entity with revenue 22



### less than $750,000 per year ($2,500,000 for feedlots). OPP developed additional categories 23



### within the SBA definitions to better understand the distribution of impacts since over 95% of 24



### U.S. farms meet the definition of a small business. NAICS category indicate the main source of 25



### farm revenue, but not the exclusive source of revenue. Oilseed and grain farms are in NAICS 26*** EO 12866 Review Draft

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2 

### 1111; vegetable, fruit, and nut are in NAICS 1112 and 1113; nurseri es and greenhouses are in 27



### NAICS 1114, where greenhouses are categorized as NAICS 11141; cotton and tobacco farming 28



### are in NAICS 11192 and 11191; other crop farms are in NAICS 11193, 11194, and 11199; 29



### bovine, ovine, and swine establishments are classified i n NAICS 112111 (beef cattle), 11212 30



### (dairy), 1124 (sheep and goat), and 1122 (hog and pig); poultry production is in NAICS 1123; 31



### other livestock comprises NAICS 1125 and 1129; and feedlots are NAICS 112112. 32

33



### Table A .1

- 1. All Farms, by economic category an d primary production , 2007

. 34

Farm Type Size (defined by gross revenue )

Total < $10,000 $10

– 100,000 $100

- $750,000 > $750,000

Grain and Oilseed 48,982 129,688 135,492 24,075 338,237

Vegetable, Fruit,

and Nut 60,078 53,233 18,215 7,344 138,870

Nursery 22,759 17,566 9,050 3,470 52,845

Greenhouses 472 1,079 319 174 2,044

Cotton and

Tobacco 2,703 7,477 7,133 2,281 19,594

Other Crop Farms 395,948 88,302 12,798 3,251 500,299

Bovine, Ovine,

Swine 475,086 234,056 82,524 19,927 811,593

Poultry 37,348 2,114 10,273 14,835 64,570

Other Livestock 214,860 24,019 5,324 1,472 245,675

< $50,000 $50

– 500,000 $500,000

- $2,500,000 > $2,500,000

Feedlots 20,620 6,172 2,957 1,316 31,065

Total 1,278,856 563,706 284,085 78,145 2,204,792

Source: 2007 Census of U.S. Agriculture (NASS, 200 8) , special tabulation

. 35

36



### Table A .1

- 2 presents data on the number of farms that hire d labor in 2007 , in contrast to 37



### operations that use d family labor. Overall, about 22% of farms hire labor, but that varies by type 38



### of production and economic size , denoted as ‘small

- small’ for farms with revenue less than 39



### $10,000 and feedlots with revenue less than $50,000, ‘medium

- small’ for farms with re venue 40



### between $10,000 and $100,000 and feedlots with revenue between $50,000 and $500,000, 41



### ‘large

- small’ for farms with revenue between $100,000 and $750,000 and feedlots with revenue 42



### between $500,000 and $1,000,000, and ‘large’ for farms with revenue grea ter than $750,000 and 43



### feedlots with revenue greater than $1,000,000 . Only about 10% of small

- small entities hire d 44



### labor while almost 80% of large entities do so. Across farm type s , the proportion of farms hiring 45



### labor ranges from about 11% for other farm ing to over 55% of cotton and tobacco farms. 46

47*** EO 12866 Review Draft

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### Table A .1

- 2 . Farms that hire labor , by economic category and primary production , 2007

. 48

Farm Type Size (defined by gross revenue )

Total small

- small medium

- small large

- small large

Grain and Oilseed 3,792 22,775 58,684 18,502 103,753

Vegetable, Fruit,

and Nut 10,436 18,959 13,794 6,746 49,935

Nursery 3,866 7,087 8,357 3,426 22,736

Greenhouses 78 341 286 174 879

Cotton and

Tobacco 1,001 3,312 4,639 1,970 10,922

Other Crop Farms 27,006 16,140 7,365 2,948 53,459

Bovine, Ovine,

Swine 53,144 61,632 45,748 16,272 176,796

Poultry 3,097 565 4,197 8,829 16,688

Other Livestock 25,696 7,335 3,199 1,216 37,446

Feedlots 3,342 2,705 2,269 1,256 9,572

Total 131,458 140,851 148,538 61,339 482,186

Source: 2007 Census of U.S. Agriculture (NASS, 200 8), special tabulation

. 49

50



### The WPS only covers workers in crop production. Table A .1

- 3 presents the number of farms 51



### hiring labor that produce d crops in 2007

. This excludes many livestock operations. While over 52



### 70% of animal farms (beef cattle, dairy, swine, sheep, and goat) also produce crops, less than 53



### 30% of other livestock operations ( e.g. , aquaculture facilities) do so. 54

55



### Table A .1

- 3

. Crop

- producing f arms that hire labor

, 2007

. 56

Farm Type Size (defined by gross revenue )

Total small

- small medium

- small large

- small large

Grain and Oilseed 3,792 22,775 58,684 18,502 103,753

Vegetable, Fruit,

and Nut 10,436 18,959 13,794 6,746 49,935

Nursery 3,866 7,087 8,357 3,426 22,736

Greenhouses 78 341 286 174 879

Cotton and

Tobacco 1,001 3,312 4,639 1,970 10,922

Other Crop Farms 27,006 16,140 7,365 2,948 53,459

Bovine, Ovine,

Swine 25,474 47,530 40,590 13,564 127,158

Poultry 1,045 255 2,261 5,482 9,043

Other Livestock 6,129 2,868 1,310 629 10,936

Feedlots 1,082 1,956 1,951 848 5,837

Total 79,909 121,223 139,237 54,289 394,658

Source: 2007 Census of U.S. Agriculture (NASS, 200 8), special tabulation

. 57

58



### Thus, OPP estimated that 394,658 farms and feedlots would be impacted by revisions to the 59



### WPS, referred to as ‘WPS farms

, ’ given 2007 data. Most provisions of the WPS, however, are 60



### only triggered if the entity uses pesticides and often only if workers are physically present. 61



### Table A .1

- 4 prese nts the number of crop producing farms that hire labor that also use d pesticides 62*** EO 12866 Review Draft

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4 

### sometime during the course of 2007 . Given these data, we can see that pesticide use varies by 63



### economic size and production type. Just over half the small

- small WPS farms use d pesticides 64



### while about 90% of large WPS farms do so. Across production type s , the proportion of W PS 65



### farms using pesticides varied from 53% of other livestock operations to 97% of cotton and 66



### tobacco farms. 67

68



### Table A .1

- 4

. Crop

- producing f arms that hire la bor and use pesticides

, 2007

. 69

Farm Type Size (defined by gross revenue )

Total small

- small medium

- small large

- small large

Grain and Oilseed 2,905 20,817 56,266 17,476 97,464

Vegetable, Fruit,

and Nut 7,591 16,760 13,465 6,710 44,526

Nursery 2,685 5,697 6,702 2,956 18,040

Greenhouses 29 191 169 130 519

Cotton and

Tobacco 867 3,134 4,631 1,969 10,601

Other Crop Farms 11,292 9,757 6,566 2,799 30,414

Bovine, Ovine,

Swine 11,656 29,753 32,913 11,431 85,753

Poultry 434 123 1,611 4,236 6,404

Other Livestock 2,695 1,607 986 539 5,827

Feedlots 726 1,720 1,651 703 4,800

Total 40,880 89,559 124,960 48,949 304,348

Source: 2007 Census of U.S. Agriculture (NASS, 200 8), special tabulation

. 70

71



### In order to estimate the number of farms across economic categories and production types as in 72



### Tables A.1

- 3 and 4 .1

- for 2012, we rely on publicly available data and the observed proportions 73



### of farms in 2007 as described below. Table A .1

- 5 presents the nu mber of all U.S. farms, by 74



### economic category and type from the 2012 Census. Note that the same information is available 75



### for the 2007 Census. Compared to 2007, the total number of farms in the U.S. has declined 76



### about 4% with considerable variation across different farms types and sizes. The number of 77



### feedlots has fallen over 50% and livestock operations in general are down as are cotton and 78



### tobacco farms. The number of farms whose primary income is derived from grains and oilseed, 79



### however, has increased about 9%. By economic size, the number of small

- small farms and 80



### feedlots has decreased about 10%, the number of those in the medium

- small category is 81



### essentially unchanged, and the number of farms , excluding feedlots, with revenues over 82



### $1,000,000 has inc reased over 40%. 83

84*** EO 12866 Review Draft

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5 

### Table A .1

- 5 . All Farms, by economic category and primary production , 2012

. 85

Farm Type Size (defined by gross revenue )

Total < $10,000 $10

–

100,000 $100

-

5 0 0,000 $500,000

-

$1,000,000 >

$1,00 0,000

Grain and

Oilseed 43,993 130,819 118,839 42,150 33,531 369,332

Vegetable,

Fruit, and

Nut 60,165 49,483 15,506 4,119 6,768 136,041

Nursery and

Greenhouses 20,467 21,233 6,903 1,718 2,456 52,777

Cotton and

Tobacco 741 4,918 4,826 2,061 1,501 14,047

Other Crop

Farms 361,302 100,622 13,565 3,537 3,764 482,790

Bovine, Ovine,

Swine 439,843 221,905 66,485 14,628 17,275 760,136

Poultry 27,561 1,984 3,575 7,092 12,637 52,849

Other

Livestock 190,787 30,497 4,407 813 1,093 227,597

< $50,000 $50

–

500,000 $500,000

-

$2,500,000 > $2,500,000

Feedlots 4,601 5,054 2,737 1,342 13,734

Total 1,149,460 566,515 236,843 76,118 80,367 2, 109,303

Source: 2012 Census of U.S. Agriculture (NASS, 2014)

. 86

87



### The publicly available data poses two problems. First, the Census publicly reports an economic 88



### category encompassing revenue between $500,000 and $1,000,000 while OPP, following the 89



### Small Business Administration definition of a small farm

, distinguishes categories at the 90



### $750,000 threshold ($2,500,000 for feedlots) . Second, the Census publicly combines the NAICS 91



### codes for Nurseries and Greenhouses while OPP in interested in separating the two types of 92



### production because indoor production (greenhouse) is subject to somewhat different posting and 93



### notification requirements than is outdoor production. Given the 2007 special tabulation, we can 94



### calculate that 65% of farms with revenue between $500,000 and $1,000,000 have revenue below 95



### the $750,000 SBA

- defined. Poultry farms are most evenly split, with 55% having revenue below 96



### $750,00 0 and 45% above $750,000, while oilseed and grain farms are least evenly distributed 97



### with 66% having revenue below $750,000. To estimate the number of farms in the OPP 98



### categories, we apply these proportions to the 2012 data. We can similarly estimate the 99



### proportion of greenhouses within the nursery and greenhouse from the 2007 data, which indicate 100



### that about 4% are greenhouses. The results of this estimation is shown in Table A .1

- 6. 101

102*** EO 12866 Review Draft

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6 

### Table A .1

- 6 . All Farms, by economic category and primary production

, 2012

. 103

Farm Type Size (defined by gross revenue )

Total small

- small medium

- small large

- small large

Grain and Oilseed 43,993 130,819 146,795 47,725 369,332

Vegetable, Fruit,

and Nut 60,165 49,483 18,060 8,333 136,041

Nursery 20,031 20,004 7,727 2,932 50,694

Greenhouses 436 1,229 272 146 2,083

Cotton and

Tobacco 741 4,918 6,105 2,283 14,047

Other Crop Farms 361,302 100,622 15,806 5,060 482,790

Bovine, Ovine,

Swine 439,843 221,905 75,887 22,501 760,136

Poultry 27,561 1,984 7,452 15,852 52,849

Other Livestock 190,787 30,497 4,935 1,378 227,597

Feedlots 4,601 5,054 2,737 1,342 13,734

Total 1,149,460 566,515 285,776 107,552 2, 109,303

Source: Census of U.S. Agriculture (NASS

, 201 4 and 200 8) , special tabulation (NASS, 200 8)

. 104

105



### Publicly available data from the 2012 Census provide the number of farms hiring labor by 106



### economic class or by production type, but not both. To estimate the number of farms hiring 107



### labor across both categories, we use a two

- step procedure. First, we calculate the number of 108



### farms hiring labor in 2012 based on the proportio n of farms with hired labor to total farms in 109



### each economic/production category in 2007. Second, we adjust th es e initial estimates so that 110



### totals in each economic class and production type equal t he number of farms hiring labor from 111



### the 2012 Census. 112

113



### In the first step, we calculate the proportion of farms with hired labor to total farms in 2007 from 114



### Tables A.1

- 1 and A.1

- 2. For example, there were 3,792 grain and oilseed farms with revenue 115



### less tha n $10,000 hiring labor in 2007 out of 48,982 farms in that category, or 7.7%. Given 116



### 43,993 farms in that category in 2012, we calculate that there would be 3,406 of those farms 117



### hiring labor. Other categories are calculated the same way. Results of this step are presented in 118



### Table A .1

- 7. Table A.1

- 7 also shows the sum of farms, by production type and economic size, 119



### along with the total observed in the 2012 Census. Note that we had to estimate the number of 120



### farms with hired labor in the $500,000 to $1,000,000 size category between the two neighboring 121



### size categories as was done with the total number of farms in Table A .1

- 6. We also had to adjust 122



### the number of farms in each size category to account for the fact that feedlot categories are 123



### different from farms, in keeping with the SBA definition. Thus, the number of entities in the 124



### small

- small and medium

- small categories is larger than provided by the Census for entit ies with 125



### revenues of less than $100,000 while there are fewer entities in the two larger size categories 126



### than shown in the Census for entities with revenue greater than $100,000. 127

128*** EO 12866 Review Draft

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### Table A .1

- 7

. Initial estimates of f arms hiring labor

, 2012

. 129

Farm Type Size (defined by gross revenue )

Sum Total small

small medium

small large

- small large

Grain and

Oilseed 3,406 22,974 63,579 36,678 126,636 133,209

Vegetable,

Fruit, and Nut 10,451 17,623 13,676 7,655 49,406 55,497

Nursery 3,406 8,071 7,135 2,894 21,506 24,485

Greenhouses 69 388 244 147 848 947

Cotton and

Tobacco 274 2,178 3,971 1,971 8,395 8,979

Other Crop

Farms 24,643 18,392 9,096 4,588 56,719 89,449

Bovine, Ovine,

Swine 49,202 58,432 42,069 18,373 168,076 178,337

Poultry 2,285 530 3,044 9,434 15,294 18,959

Other Livestock 22,817 9,313 2,965 1,138 36,234 50,718

Feedlots 746 2,215 2,100 1,281 6,342 5,889

Sum 117,299 140,117 147,880 84,160 489,457 566,469

Total 173,337 154,615 150,028 88,489 566,469

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS

, 2014)

. 130

131



### As seen in Table A .1

- 7, we have underestimated the number of farms hiring labor in 2012 in all 132



### sizes and types, with the exception of feedlots. Indeed, while the total number of farms has 133



### declined slightly si nce 2007, the number hiring labor has increased 17.5%. To adjust the 134



### estimated number of farms hiring labor, we use an iterative process. To begin, we take the ratio 135



### of observed values for each farm type to the sum of the calculated value. For example, 133,209 136



### grain and oilseed farms are observed to hire labor while we initially calculated that 126,636 137



### farms hired labor . The ratio of observed to calculated is 1.052, implying that we need to increase 138



### our estimate of farms of this type about 5%. We multi ply our initial estimates for each farm type 139



### by these ratios to obtain the values shown in Table A .1

- 8 , with three exceptions

. The number of 140



### large nurseries, greenhouses, and other crop farms are not adjusted upward and the numbers of 141



### small farms of those types are increased instead. Otherwise, we end with more large farms of 142



### these types than are observed in the data. The sum for each farm type now equates to the 143



### observed number of farms hiring labor. 144

145*** EO 12866 Review Draft

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8 

### Table A .1

- 8

. First iteration, estimates of f arms hiring labor

, 2012

. 146

Farm Type Size (defined by gross revenue )

Sum Total small

small medium

small large

- small large

Grain and

Oilseed 3,583 24,166 66,879 38,581 133,209 133,209

Vegetable,

Fruit, and Nut 11,740 19,796 15,363 8,598 55,497 55,497

Nursery 3,956 9,373 7,992 3,165 24,485 24,485

Greenhouses 78 443 278 147 947 947

Cotton and

Tobacco 294 2,330 4,247 2,109 8,979 8,979

Other Crop

Farms 40,115 29,939 14,807 4,588 89,449 89,449

Bovine, Ovine,

Swine 52,205 61,999 44,637 19,495 178,337 178,337

Poultry 2,833 657 3,774 11,695 18,959 18,959

Other Livestock 31,938 13,036 4,151 1,593 50,718 50,718

Feedlots 692 2,057 1,950 1,189 5,889 5,889

Sum 147,433 163,797 164,079 91,161 566,469 566,469

Total 173,337 154,615 150,028 88,489 566,469

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS

, 2014)

. 147

148



### T he sum for each farm type now equates to the observed number of farms hiring labor

. By 149



### economic size, however, we now overestimate the number of farms hiring labor for by economic 150



### size, except for the small

- small farms. We now calculate the ratio of observed to calculated 151



### farms by economic size and use that ratio to adjust the number of farms within each class. We 152



### then continue to iterate between adjusting the estimates by type and by economic size until all 153



### sums equal the observed values. The final estimates for farms hiring labor in 2012 are presented 154



### in Table A .1

- 9. 155

156



### Table A .1

- 9

. Estimated number of f arms th at hire labor

, 2012

. 157

Farm Type Size (defined by gross revenue )

Total small

- small medium

- small large

- small large

Grain and Oilseed 4,745 24,879 64,427 39,158 133,209

Vegetable, Fruit,

and Nut 14,514 19,023 13,814 8,146 55,497

Nursery 4,972 9,158 7,307 3,048 24,485

Greenhouses 101 442 260 145 947

Cotton and

Tobacco 387 2,388 4,073 2,131 8,979

Other Crop Farms 46,198 26,800 12,403 4,049 89,449*** EO 12866 Review Draft

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9 Bovine, Ovine,

Swine 62,991 58,147 39,173 18,025 178,337

Poultry 3,569 644 3,458 11,289 18,959

Other Livestock 34,978 11,097 3,306 1,337 50,718

Feedlots 882 2,037 1,808 1,161 5,889

Total 173,337 154,615 150,028 88,489 566,469

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS

, 2014)

. Rows and columns may not sum due to 158

rounding. 159

160



### Table A .1

- 10 presents the estimated number of crop producing farms that hire labor in 2012. 161



### Publicly available data from the 2012 Census of Agriculture enumerates the number of farms 162



### with cropland out of the total number of farms, but not for f arms that hire labor. Therefore, we 163



### estimate the number of crop producing farms that hire labor in 2012 using the same proportion of 164



### such farms from 2007. For example, from Table A .1

- 3 , we know that, in 2007, 25,474 animal 165



### farms with revenue less than $1 0,000 hire labor and have crop land out of 53,144 similar animal 166



### fa rms that hire labor from Table 2 , or 48%. We therefore calcula t e that, in 2012, there are 167



### 30,194 animal farms with revenue less than $10,000 hire labor and have crop land out of 6 2,991 168



### sim ilar animal farms. In total, we estimate that there were 466, 579 crop producing farms hiring 169



### labor , or WPS farms, in 2012, an 18.2% increase over the number of WPS farms identified in 170



### 2007. 171

172



### Table A .1

- 10

. Estimated number of crop producing f arms that hire labor

, 2012

. 173

Farm Type Size (defined by gross revenue )

Total small

- small medium

- small large

- small large

Grain and Oilseed 4,745 24,879 64,427 39,158 133,209

Vegetable, Fruit,

and Nut 14,514 19,023 13,814 8,146 55,497

Nursery 4,972 9,158 7,307 3,048 24,485

Greenhouses 101 442 260 145 947

Cotton and

Tobacco 387 2,388 4,073 2,131 8,979

Other Crop Farms 46,198 26,800 12,403 4,049 89,449

Bovine, Ovine,

Swine 30,194 44,843 34,756 15,026 124,819

Poultry 1,204 290 1,863 7,009 10,367

Other Livestock 8,343 4,339 1,354 692 14,727

Feedlots 286 1,473 1,554 784 4,097

Sum 110,944 133,635 141,811 80,187 466,576

Source: OPP calculations

. Rows and columns may not sum due to rounding

. 174

175



### Finally, Table A .1

- 11 presents the estimated number of crop producing farms that hire labor and 176



### use pesticides in 2012. Again, publicly available data from the 2012 Census of Agriculture 177



### provides the number of farms that use pesticides out of the total number of farms, but not for 178



### farms that hire labor. Therefore, we estimate the number of crop producing farms that hire labor 179



### and use pesticides in 2012 using the same proportion of such farms from 2007. For example, 180



### from Table A.1

- 4, we know that, in 2007, 2,905 grain and o ilseed farms with revenue less than 181



### $10,000 and hired labor used pesticides out of 3,792 similar grain and oilseed farms that hire 182*** EO 12866 Review Draft

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10 

### labor from Table 3, or 76.6%. We therefore calculate that, in 2012, there are 3, 635 grain and 183



### oilseed farms with revenue les s than $10, 000 that hire labor out of 4,745 similar grain and 184



### oilseed farms. In total, we estimate that there were 35 4

, 220 WPS farms that used pesticides in 185



### 2012, a 16.5 % increase over the number of WPS farms using pesticides in 2007. Over all WPS 186



### farms, this implies that 76. 0 % use pesticides in any given year. 187

188



### Table A .1

- 1 1

. Estimated number of crop

- producing f arms that hire labor and use 189



### pesticides

, 2012

. 190

Farm Type Size (defined by gross revenue )

Total < $10,000 $10

– 100,000 $100

- $750,000 > $750,000

Grain and Oilseed 3,635 22,740 61,772 36,772 12 4

, 919

Vegetable, Fruit,

and Nut 10,557 16,817 13,484 8,102 48,960

Nursery 3,453 7,362 5,860 2,630 19,305

Greenhouses 37 247 154 108 546

Cotton and

Tobacco 335 2,260 4,066 2,130 8,791

Other Crop Farms 19,317 16,201 11,057 3,844 50,419

Bovine, Ovine,

Swine 13,816 28,071 28,183 12,663 82,733

Poultry 500 140 1,327 5,416 7,383

Other Livestock 3,668 2,431 1,019 593 7,711

Feedlots

< $50,000 $50

– 500,000 $500,000

- $2,500,000 > $2,500,000

Feedlots 192 1,296 1,315 650 3,453

Total 55,510 97,565 128,237 72,908 354,220

Source: OPP calculations

. Rows and columns may not sum due to rounding

. 191

192

193



## A. 2

. Employees 194

195



### Table A.2

- 1 presents data on the number of people employed in agriculture from the special 196



### tabulation for all farms in the U.S. based on the 2007 Census of Agriculture. Like the number of 197



### farms, the data are organized by economic category and by primary production or NAICS 198



### category. 199

200*** EO 12866 Review Draft

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11 

### Table A.2

- 1. Agric ultural Employees , by economic category and primary production

, 201



### 2007

. 202

Farm Type Size (defined by gross revenue )

Total small

- small medium

- small large

- small large

Grain and Oilseed 7,996 51,743 150,231 89,328 299,298

Vegetable, Fruit,

and Nut 31,347 107,936 212,775 517,771 869,829

Nursery 11,384 31,778 76,721 206,344 326,227

Greenhouses 381 1,307 2,657 20,492 24,837

Cotton and

Tobacco 4,357 19,064 24,122 20,475 68,018

Other Crop Farms 64,586 45,347 33,366 53,592 196,891

Bovine, Ovine,

Swine 118,591 150,952 147,368 167,731 584,642

Poultry 7,953 2,016 13,069 61,974 85,012

Other Livestock 66,661 23,321 18,849 21,495 130,326

Feedlots 7,899 7,420 8,856 27,254 51,429

Total 321,155 440,884 688,014 1,186,456 2,636,509

Source: 2007 Census of U.S. Agriculture (NASS, 200 8), special tabulation

. 203

204



### Table A.2

- 2 presents the number of employee s on farms that produced crops in 2007; the WPS 205



### only covers workers in crop production activities, not those working solely with livestock. 206



### Similar to farm numbers, about 75% of employee s on animal farms (beef cattle, dairy, swine, 207



### sheep, and goat) are em ployed on farms that also produce crops while less than 30% of 208



### employees on other livestock operations (e.g., aquaculture facilities) are working on crop 209



### producing establishments. 210

211



### Table A.2

- 2

. Agricultural Employee s on crop

- producing f arms, 2007

. 212

Farm Ty pe Size (defined by gross revenue )

Total small

- small medium

- small large

- small large

Grain and Oilseed 7,996 51,743 150,231 89,328 299,298

Vegetable, Fruit,

and Nut 31,347 107,936 212,775 517,771 869,829

Nursery 11,384 31,778 76,721 206,344 326,227

Greenhouses 381 1,307 2,657 20,492 24,837

Cotton and

Tobacco 4,357 19,064 24,122 20,475 68,018

Other Crop Farms 64,586 45,347 33,366 53,592 196,891

Bovine, Ovine,

Swine 58,127 116,352 129,840 129,032 433,351

Poultry 2,614 884 7,074 7,328 12,675

Other Livestock 16,364 8,561 6,439 6,395 37,759

Feedlots 2,613 5,195 7,328 12,675 27,811

Total 199,769 388,167 650,533 1,084,121 2,322,610

Source: 2007 Census of U.S. Agriculture (NASS, 200 8), special tabulation

. 213

214*** EO 12866 Review Draft

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### Table A.2

- 3 presents the number of employees on crop producing farms that used pesticides 215



### sometime during the course of 2007. As with the number of farms

, the number of employees 216



### associated with pesticide use varies by economic size and production type. In general, however, 217



### farms that used pesticides appear to employ more labor than do similar farms that did not use 218



### pesticides. For example, j ust over half the small

- small WPS farms used pesticides while almost 219



### two

- thirds of the workers on small

- small WPS farms worke d on farms using pesticides. 220



### Similarly, about the 90% of large WPS farms that used pesticides employed 92% of the labor

. 221



### Across production types we see the same pattern

, where the proportion of employees on WPS 222



### farms using pesticides is greater than the proportion of farms using pesticides. The exceptions 223



### are cotton and tobacco farms, where the ratios are approximately equal, and feedlots, where 82% 224



### of feedlots use pesticides but those establishments employ 79% of the workers

. 225

226



### Table A.2

- 3

. Agricultural Employee s on crop

- producing f arms that use pesticides

, 2007

. 227

Farm Type Size (defined by gross revenue )

Total small

- small medium

- small large

- small large

Grain and Oilseed 6,424 47,355 143,504 58,065 282,166

Vegetable, Fruit,

and Nut 23,302 99,849 209,157 516,897 849,205

Nursery 8,325 26,363 62,703 186,387 283,778

Greenhouses 99 709 1,435 16,095 18,338

Cotton and

Tobacco 3,893 18,350 24,082 18,907 65,323

Other Crop Farms 52,876 28,996 28,992 29,079 139,943

Bovine, Ovine,

Swine 27,793 74,529 106,147 109,058 317,527

Poultry 1,101 375 4,925 22,585 28,986

Other Livestock 7,339 5,073 4,661 5,231 22,304

Feedlots 1,874 4,573 6,067 9,568 22,082

Total 132,844 306,172 591,673 998,872 2,029,561

Source: 2007 Census of U.S. Agriculture (NASS, 200 8), special tabulation

. 228

229



### To estimate the number of employees across farm type and economic category in 2012, we 230



### follow the same two

- step approach as used to determine the number of farms with hired labor. 231



### Publicly available data from the 2012 C ensus provide the number of employees by economic 232



### class of the farm or by production type, but not both. First, we calculate the number of 233



### employees on farms of each type and economic category based on the average employee per 234



### farm observed in 2007. Seco nd, we adjust these initial estimates so that totals in each economic 235



### class and production type equal the number of employees from the 2012 Census. 236

237



### In the first step, we calculate the average number of employees per farm by dividing the number 238



### of workers in Tables A.2

- 1 by the number of farms in Table A.1

- 2. For example, there were 239



### 7,996 employees employed on 3,792 small

- small grain and oilseed farms or 2.11 employees per 240



### farm in 2007 . Given an estimated 4, 745 farms in th is category in 2012, we calculate that there 241



### would be 10

, 006 employees employed on such farms. Other categories are calculated the same 242



### way. Results of this step are presented in Table A.2

- 4 . Table A.2

- 4 also shows the sum of 243



### employees , by p roduction type and economic size of the farm , along with the total observed in 244



### the 2012 Census. Again, we had to allocate the number of employees in the $500,000 to 245*** EO 12866 Review Draft

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13 

### $1,000,000 size category between the two neighboring size categories as was done with the 246



### number of farms for Table A.1

- 6. From the 2007 Census and special tabulation, we calculated 247



### that 41.4% of the employees on farms in this category were employed on farms making less than 248



### $750,000 gross revenue and 58.6% were employed on farms making $750,0 00 or more gross 249



### revenue. We also adjust the number of employees in each size category to account for the fact 250



### that feedlot categories are different from farms, in keeping with the SBA definition. 251

252



### Table A.2

- 4

. Initial estimates of agricultural employees

, by farm type and size

, 2012

. 253

Farm Type Size (defined by gross revenue )

Sum Total small

small medium

small large

- small large

Grain and

Oilseed 10,006 56,523 164,933 189,055 420,517 382,559

Vegetable,

Fruit, and Nut 43,596 108,302 213,082 625,219 990,199 904,400

Nursery 14,641 41,063 67,079 185,589 306,373 271,956

Greenhouses 491 1,693 2,414 17,045 51,644 20,705

Cotton and

Tobacco 1,685 13,746 21,180 22,144 58,755 48,709

Other Crop

Farms 110,484 75,297 56,189 73,605 315,574 281,726

Bovine, Ovine,

Swine 140,565 142,417 126,188 185,804 594,975 555,076

Poultry 9,164 2,296 10,767 79,242 101,469 81,373

Other Livestock 90,740 35,282 19,481 23,633 169,137 160,975

Feedlots 2,086 5,589 7,055 25,203 39,933 28,938

Sum 423,458 482,210 688,369 1,424,538 3,018,575

Total 417,260 445,776 583,120 1,290,261 2,736,417

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS

, 2014)

. 254

255



### The sums of employees across farm sizes and across farm types are larger than the observed 256



### totals for all categories. To refine the estimates, we follow the iterative procedure described 257



### above, where we estimate the number of farms hiring labor through Tables A.1

- 7, A.1

- 8, and 258



### A.1

- 9. Table A.2

- 5 presents the final estimates of labor employed by farms according to size 259



### and production type. 260

261*** EO 12866 Review Draft

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14 

### Table A.2

- 5

. Estimated number of employee s, by f arm type and s ize

, 2012

. 262

Farm Type Size (defined by gross revenue )

Total small

- small medium

- small large

- small large

Grain and Oilseed 10,178 53,625 142,791 175,965 382,559

Vegetable, Fruit,

and Nut 43,905 101,725 182,639 576,131 904,400

Nursery 14,322 37,464 55,847 164,232 271,956

Greenhouses 516 1,658 2,157 16,374 20,705

Cotton and

Tobacco 1,554 11,829 16,632 18,694 48,709

Other Crop Farms 105,199 66,867 45,534 64,127 281,726

Bovine, Ovine,

Swine 141,657 133,858 108,232 171,330 555,076

Poultry 8,021 1,875 8,020 63,458 81,373

Other Livestock 90,249 32,728 16,491 21,507 160,975

Feedlots 1,660 4,148 4,779 18,352 28,938

Total 417,260 445,776 583,120 1,290,261 2,736,417

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS

, 2014)

. Rows and columns may not sum due to 263

rounding. 264

265



### To estimate the number of employees on farms producing crops in 2012

, we follow the same 266



### procedure as for estimating the number of farms producing crops. That is, we calculate the 267



### proportion of employees on farms producing crops (Table A.2

- 2 ) out of all employees (Table 268



### A.2

- 1) in 2007, by farm type and size. For example, 46.5% of employees of large feedlots (more 269



### than $2.5 million in revenue) worked on feedlots that also produced crops in 2007 (12,675 270



### workers out of 27,254). We then multiply that proportion by the estimated numbe r of employees 271



### in 2012 (Table A.2

- 5 ). We estimate that large feedlots employ 18,352 employees in 2012 , of 272



### which 8, 5 3 5 (46.5%) are employed on feedlots that also produce crops. Results for all farm 273



### types and sizes are shown in Table A.2

- 6

. We estimate that there are 2,40 8

, 452 employees 274



### potentially covered by the WPS because they work on farms that produce cr ops. This is an 275



### increase of 3.7 % over the number of employees in 2007. We estimate there are 466, 576 crop

276



### producing farms that hire labor, implying an average of 4.8 employees per farm. 277

278



### Table A.2

- 6

. Estimated number of employee s on crop

- producing farms, 2012

. 279

Farm Type Size (defined by gross revenue )

Total small

- small medium

- small large

- small large

Grain and Oilseed 10,178 53,625 142,791 175,965 382,559

Vegetable, Fruit,

and Nut 43,905 101,725 182,639 576,131 904,400

Nursery 14,322 37,464 55,847 164,323 271,956

Greenhouses 516 1,658 2,157 16,374 20,705

Cotton and

Tobacco 1,554 11,829 16,632 18,694 48,709

Other Crop Farms 105,199 66,867 45,534 64,127 281,726*** EO 12866 Review Draft

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15 Farm Type Size (defined by gross revenue )

Total

small

- small medium

- small large

- small large

Bovine, Ovine,

Swine 69,432 103,176 95,358 131,801 399,768

Poultry 2,636 822 4,641 28,688 36,487

Other Livestock 22,154 12,014 5,633 6,399 46,201

Feedlots 549 2,904 3,954 8,535 15,942

Total 270,447 392,084 554,886 1,191,036 2,408,452

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS

, 2014)

. Rows and columns may not sum due to 280

rounding. 281

282



### Finally, the number of employees on crop producing farms that used pesticides in 2012 is 283



### estimated using the same method. The proportion of workers on crop

- producing farms that used 284



### pesticides in 2007, from Table A.2

- 3 , out of all employees on crop

- producing farms from Table 285



### A.2

- 2 , is mu ltiplied by the estimated employees on crop

- producing farms in 2012 (Table A.2

- 6 ). 286



### Results are presented in Table A.2

- 7

. We estimate a total of 2,0 9 8

, 272 people are employed on 287



### crop

- producing farms that use pesticides. This is a 3.0% increase over the n umber of employees 288



### in 2007. Given an estimated 354,775 crop

- producing farms using pesticides in 2012, the overall 289



### average workforce is 5.9 employees per farm. 290

291



### Table A.2

- 7

. Estimated number of employee s on crop

- producing farms that use pesticides, 292



### 2012

. 293

Farm Type Size (defined by gross revenue )

Total small

- small medium

- small large

- small large

Grain and Oilseed 7,945 49,077 136,397 167,568 360,987

Vegetable, Fruit,

and Nut 32,367 94,104 179,533 575,159 881,432

Nursery 10,474 31,080 45,643 148,430 235,627

Greenhouses 134 899 1,165 12,860 15,059

Cotton and

Tobacco 1,389 11,386 16,604 17,263 46,641

Other Crop Farms 86,125 42,756 39,565 34,795 203,241

Bovine, Ovine,

Swine 33,199 66,089 77,958 111,398 288,644

Poultry 1,110 349 3,022 23,126 27,607

Other Livestock 9,936 7,119 4,078 5,234 26,367

Feedlots 394 2,556 3,274 6,443 12,667

Total 183,343 305,416 507,238 1,102,275 2,098,272

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS

, 2014)

. Rows and columns may not sum due to 294

rounding. 295

296

297



## A. 3

. Comparison of Estimates 298

299



### In May 2015, EPA obtained results of a special tabulation of data collected for the 2012 Census 300



### of Agriculture. The tabulation aggregates farms more than was done with data from the 2007 301



### Census. In t he more recent tabulation

, vegetable, fruit, and nut farms were combined with 302*** EO 12866 Review Draft

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16 

### nurseries to form a ‘specialty crop’ category that is relatively labor intensive. Greenho uses 303



### remained separated and all other crop production (oilseed and grains, cotton and tobacco, and 304



### other crops) were combined into a ‘field crop’ category. Feedlots also remained as a separate 305



### category, but all other livestock operations were aggregated. 306

307



### Table A.3

- 1 presents a comparison of the estimated number of crop producing farms that hire 308



### labor in 2012 with the actual number from the Census of Agriculture. In total, EPA’s approach 309



### overestimated the number of farms by over 45,000 farms or about 10 p ercent of the true number. 310



### Small farms were significantly overestimated while large farms were slightly (three percent) 311



### underestimated. Farms that primarily produce field crops and livestock operations were 312



### overestimated by 15 and 12 percent. The approa ch came within one percent of estimating the 313



### number of specialty crop establishments. The number of greenhouses and feedlots with crop 314



### production that hire workers is underestimated and, for these farm, especially underestimated for 315



### small economic classes

. 316

317



### Table A

. 3

- 1

. Estimated and actual number of crop producing f arms that hire labor

, 2012

. 318

Farm Type Size (defined by gross revenue )

Total small

- small medium

- small large

- small large

Field Crops 1 est. 51,330 54,067 80,903 45,338 231,638

actual 32,131 47,686 74,664 47,501 201,982

Specialty Crops 2 19,486 28,181 21,121 11,194 79,982

actual 17,856 29,346 21,815 10,676 79,693

Greenhouses est. 101 442 260 145 947

actual 240 567 248 176 1,231

Livestock 3 est. 39,741 49,472 37,973 22,727 149,913

actual 28,772 42,881 38,528 23,320 133,501

Feedlots est. 286 1,473 1,554 784 4,097

actual 732 1,508 1,623 956 4,819

Sum est. 110,944 133,635 141,811 80,187 466,576

actual 7 9,731 1 21,988 1 36,878 82,629 421,226

Source: E P A calculations; 2012 Census of Agriculture, Special Tabulation

. Rows and columns may not sum due to 319

rounding

. 320

1 Includes farms producing oilseeds and grains, cotton and tobacco, and other crop farms. 321

2 Includes vegetable, fruit, and nut farms an d nurseries. 322

3 Includes bovine, ovine, and swine operations, poultry farms, and other livestock operations. 323

324



### Table A.3

- 2 compares the estimated and actual number of crop

- producing farms that hire labor 325



### and use pesticides in 2012. The number of these farms is a primary driver of the total cost of the 326



### WPS revisions. The total estimated number is about eight percent higher than the actual number. 327



### As with the number of crop

- producing farms that hire labor, EPA estimated larger numbers of 328



### small farms hiring l abor and using pesticides and slightly underestimated the number of large 329



### farms , although for greenhouses and feedlots, the pattern was largely reversed

. 330

331*** EO 12866 Review Draft

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17 

### Table A

. 3

- 2

. Estimated and actual number of crop

- producing f arms that hire labor and 332



### use pesticides

, 2012

. 333

Farm Type Size (defined by gross revenue )

Total small

- small medium

- small large

- small large

Field Crops 1 est. 23,287 41,201 76,895 42,960 184,344

actual 12,175 36,490 73,085 47,309 169,059

Specialty Crops 2 14,010 24,179 19,344 10,732 68,266

actual 11,228 23,922 20,313 10,378 65,841

Greenhouses est. 37 247 154 108 547

actual 109 368 159 131 767

Livestock 3 est. 17,984 30,642 30,529 18,672 97,827

actual 12,294 25,697 30,721 20,312 89,024

Feedlots est. 192 1,296 1,315 650 3,453

actual 412 1,278 1,542 908 4,140

Sum est. 55,511 97,564 128,238 73,123 354,436

actual 36,218 87,755 125,820 79,038 328,831

Source: EPA calculations; 2012 Census of Agriculture, Special Tabulation

. Rows and columns may not sum due to 334

rounding

. 335

1 Includes farms producing oilseeds and grains, cotton and tobacco, and other crop farms. 336

2 Includes vegetable, fruit, and nut farms and nurseries. 337

3 Includes bovine, ovine, and swine operations, poultry farm s, and other livestock operations. 338

339



### The number of workers and handlers is another important driver in the estimation of total costs 340



### of the WPS revisions. Table A.3

- 3 compares the estimated number of employees to the number 341



### of employees reported in the Census for farms that produce crops and hire labor. As with farms, 342



### the approach yielded a slight overestimate, of about four percent, compared to the actual number 343



### of employees. The number of people employed on the small

- small farms is particularly 344



### overe stimated, while estimated numbers of employees in greenhouses and on feedlots is 345



### underestimated. 346

347



### Table A.3

- 3

. Estimated and actual number of employees on crop

- producing farms, 2012

. 348

Farm Type Size (defined by gross revenue )

Total small

- small medium

- small large

- small large

Field Crops 1 est. 116,931 132,321 204,957 258,786 712,994

actual 75,069 120,729 201,440 246,723 643,961

Specialty Crops 2 58,227 139,189 238,486 740,454 1,176,356

actual 55,763 141,439 261,464 715,622 1,174,288

Greenhouses est. 516 1,658 2,157 16,374 20,705

actual 697 2,096 1,993 17,602 22,388*** EO 12866 Review Draft

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18 Farm Type Size (defined by gross revenue )

Total

small

- small medium

- small large

- small large

Livestock 3 est. 94,223 116,012 105,333 166,887 482,455

actual 67,511 99,608 109,838 173,400 450,357

Feedlots est. 549 2,904 3,954 8,535 15,942

actual 1,657 3,452 4,768 9,631 19,508

Sum est. 270,447 392,084 554,886 1,191,036 2,408,452

actual 200,697 367,324 579,503 1,162,978 2,310,502

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS

, 2014)

. Rows and columns may not sum due to 349

rounding. 350

1 Includes farms producing oilseeds and grains, cotton and tobacco, and other crop farms. 351

2 Includes vegetable, fruit, and nut farms and nurseries. 352

3 Includes bovine, ovine, and swine operations, poultry farms, and other livestock operations. 353

354



### Table A.3

- 4 presents the estimated and actual number of employees on crop

- producing farms 355



### that use pesticides. Overall, the estimate is about three percent greater than observed in the data. 356



### The estimated number of employees on small

- small farms is nearly double the observed number 357



### and about ten percent greater for medium

- small farms while we are six percent and two percent 358



### lower for large

- small and large farms, respectively. By farm type, we overestimate the numbe r 359



### of employees on farms producing field crops by almost 47,000 employees or about eight percent. 360



### We underestimate the number of employees in greenhouses and feedlots by a large percentage, 361



### but only by 3,000 to 4,000 total workers. 362

363



### Table A.3

- 4

. Estimated and actual number of employees on crop

- producing farms that use 364



### pesticides, 2012

. 365

Farm Type Size (defined by gross revenue )

Total small

- small medium

- small large

- small large

Field Crops 1 est. 95,459 103,219 192,566 219,625 610,870

actual 28,976 93,110 196,736 245,132 563,954

Specialty Crops 2 43,111 125,183 225,176 723,589 1,117,059

actual 37,071 120,987 249,600 699,250 1,106,908

Greenhouses est. 134 899 1,165 12,860 15,059

actual 324 1,459 1,376 14,940 18,099

Livestock 3 est. 44,245 73,557 85,058 139,758 342,618

actual 29,400 60,198 88,027 155,458 333,083

Feedlots est. 394 2,556 3,274 6,443 12,667

actual 940 2,923 4,511 8,583 16,957

Sum est. 183,343 305,416 507,238 1,102,275 2,098,272

actual 96,711 278,677 540,250 1,123,363 2,039,001

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS

, 2014)

. Rows and columns may not sum due to 366

rounding. 367

1 Includes farms producing oilseeds and grains, cotton and tobacco, and other crop farms. 368

2 Includes vegetable, fruit, and nut farms and nurseries. 369

3 Includes bovine, ovine, and swine operations, poultry farms, and other livestock operations. 370

371



### Overall, EPA has slightly overestimated the number of agricultural establishments and 372



### employees that wou ld be affected by revisions to the WPS. In estimating the total incremental 373



### impacts, EPA assumed that farms faced similar per

- establishment and per

- worker or handler 374*** EO 12866 Review Draft

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19 

### costs, so basing costs on the estimated number of crop

- producing farms and employees that hire 375



### labor and use pesticides will result in an overestimation of the total costs on the order of three to 376



### eight percent, which are the degree of overestimation of the number of employees and 377



### establishments, respectively. Within economic size categories, the cost estimates for small 378



### establishments, in aggregate, would be overestimated to a greater degree and the cost to large 379



### farms, in aggregate, would be underestimated. 380

381



### The number of workers per farm is an important factor in the estimation of total per

382



### establishment costs , which are key to understanding the distributional effects of the revisions to 383



### the WPS . According to the data from the special tabulation, crop

- producing farms that hire labor 384



### and use pesticides average 6.2 workers per farm, ranging f rom 2.7 workers per small

- small farm 385



### to 14.1 workers per large farm. EPA’s estimation results in an average of 5.9 workers per farm, 386



### a slight underestimation over all farms. The approach yields an estimate of 3.3 workers per 387



### small

- small farm, however, in dicating that total per

- establishment costs would be slightly 388



### overestimated. Similarly, EPA estimates 15.1 workers per large farm. EPA estimates 4.0 389



### workers per large

- small farm compared to an observed average of 4.3 workers per farm in that 390



### category. 391

392



### I n general, EPA concludes that the estimation is reasonably accurate or will lead to a slight 393



### overestimation of costs that are of most concern: total national incremental costs and per

394



### establishment costs to the smallest entities. Further, the estimation provides more disaggregate 395



### information about the types of farms affected, separating for example, cotton and tobacco farms 396



### from other field crops. Therefore, EPA bases the cost analysis of the final WPS rule on the 397



### estimated number of farms and employees rather than the more aggregate information obtained 398



### from the 2012 Census of Agriculture. 399

400