FOIA request draft — LFP county boundaries data update (2026)

USDA Component: Farm Service Agency (FSA) Request Type: FOIA Requester Category: Educational Institution Delivery Method: PAL Date Range for Record Search: 01/01/2008 to 12/31/2026 Amount Willing to Pay: $25 | Fee Waiver: Yes

Description of Records Request

This is a data-update to request 2025-FSA-08431-F. Data in the format delivered in response to that request — an Esri file geodatabase of the National Drought Mitigation Center’s (NDMC) county boundaries — is adequate and preferred. I am not requesting producer- or field-level data.

I am requesting the geospatial county boundaries used to determine eligibility for the Livestock Forage Disaster Program (LFP) for program years 2008–2026. Each week, eligibility for the LFP is determined for each county in the United States by the intersection of county boundaries, the United States Drought Monitor (USDM) weekly drought assessment, and the normal grazing period for each type of grazing land in each county (FSA Guidance 1-LFP Amend. 6, ¶ 23A). Because LFP eligibility is triggered when “any area of the county” falls within certain drought classes, the precise county boundaries used in each determination are essential records.

The Final Response to 2025-FSA-08431-F, dated September 4, 2025, stated that the NDMC maintains these boundaries, that revisions have been made over time (a 2019 county name and FIPS change in South Dakota and a 2021 Alaska boundary change), and that “the next anticipated changes that will be required are in Connecticut due to a redraw and renaming of their county level jurisdictions that were initiated at the state level.” The USDM state pages now display Connecticut’s new planning-region jurisdictions, indicating that this revision has since been implemented. I am therefore requesting the current NDMC county boundary geodatabase, reflecting the Connecticut update and any other boundary revisions made since the September 2025 release.

To the extent such records exist, I also request:

  1. Documentation of each revision made to this boundary dataset, including the date each revision took effect and which USDM release weeks each version of the boundaries was used for; and
  2. Any computer scripts or written protocols used by the NDMC to update these boundaries and to tabulate USDM statistics by county. (These were referenced in the response to 2025-FSA-08431-F but were not included in the released files.)

Thank you for your consideration.

Reason for Waiver Request

The University of Montana is an institution of higher education, and this request is for academic research purposes. The disclosure of the requested information is in the public interest as a means of quantifying discrepancies between county eligibility and FSA program subscription, ultimately to improve administration of FSA programs and enhance the security of the Nation’s food system. The disclosure of the information is not primarily in the commercial interest of myself or the University of Montana.