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Responding to Assistant Secretary Arun Venkataraman’s

Public Comments by:

Martha Montoya, CEO

Agtools, Inc.

8502 E. Chapman Ave - #137

Orange, California - 92869

Responding to Assistant Secretary Arun Venkataraman’s

July 7th, 2023, request for public input with respect to improving.

DOC/ITA programs to increase small business

participation in foreign trade.

Provided to: Laura Barmby

District Export Council Program Manager

Lack of Participation - According to the US Department of Commerce (DOC), there are some 27 million small businesses in the United States (U.S.) Of that number, less than 1% sell their products in foreign markets. Moreover, by not selling their products in foreign markets, U.S. small businesses are missing 95% of the world market of customers that live outside the United States.

These circumstances are what Secretary Venkataraman is trying to address in his outreach for ideas on how to better serve the small business community to facilitate their participation in international trade. This is crucial and we appreciate the opportunity to comment and provide suggestions.

Well-Known Barriers - The main barriers to small business participation in foreign trade are well known and have been extensively studied and documented by government agencies, such as the U.S. Small Business Administration (SBA), the US DOC’s International Trade Administration (ITA), the World Trade Organization (WTO), and other such entities. The barriers to small business participation in foreign trade can be readily summarized as follows:

1. Lack of data and knowledge as to which countries buy their products.

2. Lack of data and knowledge as to how to identify and contact in-country buyers.

3. Prohibitive tariffs on the products they sell

4. Quotas limiting the quantity of goods that can be sold in certain foreign countries

5. Lack of data and knowledge about financing international business transactions

6. Lack of data and knowledge to access capital needed to finance the sale of products internationally.

7. Lack of information and understanding of foreign countries’ import rules and regulations.

Lack of Data – We believe access to accurate, consistent, and usable data is the major barrier to small business participation in foreign trade that is not very well coordinated or provided by the government. While our focus will be on the agriculture sector, the reader should bear in mind that this lack of data affects all areas of commerce and industry, not just agriculture.

Data Tracking – A number of US government agencies capture and maintain data on US agriculture products sold overseas, and the products from overseas that are sold in the US (USDA, Census, Customs, DOT Maritime Administration, etc.). The collecting agencies gather data in their own way, for their own purposes. There is no uniform method of collecting and managing data; or consistent method of providing data to small business owners. Even for a sophisticated data science company like Agtools, it is very difficult to determine which agencies gather the data, and to access data from them. Small businesses need clear direct access to this data.

Playing Pin-Ball - There is no thought about the data being shared to a central repository so that it can be available to users of all sorts, including small businesses trying to figure out how to participate in overseas commerce. Trying to gather data from the US government agencies is a bit like playing the pin-ball machine, with the ball bouncing wildly all over the board. There should be an interagency council or designated agency to ensure data is available to small businesses from the federal government.

Lack of Updating - The data collected is often spotty and dated. For example, the most recent data that Agtools was able to garner from the US Department of Transportation was from 2017 – dated and, therefore, not very helpful. Very often, data from the agencies is far older and even less useful. There is no uniformity in the manner in which data is updated - it appears that data typically gets updated mostly when an agency needs to generate a report of some sort. Collecting and ensuring data is timely is critical to ensuring small businesses can use the data to make short- and long-term business decisions.

Difficult to Access - Information about agriculture products brought into the US by ship, truck, or plane is kept by different agencies, and is not available at a central location. Sometimes, access to agency data by individuals and small businesses is actually blocked as a matter of policy. To access US Customs Data, for example, a business must fill out and submit paperwork requesting the desired data. The agency response informs the requester that the data is only available to customs brokers, not to individual small businesses.

Example: Data-Blind Tomato Farmers – To export tomatoes to France, a US farmer would need to know what varieties of tomatoes are grown in France, during which seasons, the quantities grown, and the price histories for tomatoes sold in local, national, and international markets. Unfortunately, that data is not available to US farmers from US agencies. Therefore, US farmers trying to sell tomatoes to France are totally blind to the market. The data they need to make decisions and plans about exporting product to France is unavailable.

Data-Blind Farmers - The situation is the same with respect to the lack of access to data, not just about one country (France, in this example), but about all 100 countries of the world. That is compounded by the fact that data is not just unavailable for US tomato farmers, it is also unavailable for the thousands of US growers of the other 500 specialty crops grown in the US. Nor is data available to growers/ranchers in the US beyond specialty crops, such as for row crops and cattle. Or to other sectors of the economy, such as electronics and auto parts.

Use of Big Data – In recent years, several data analytics companies in the agricultural sector are using Big Data to develop extensive databases on almost every crop grown, including row crops (primarily grains), and specialty crops (primarily fruits and vegetables). These data bases cover crops grown, not only in the US, but in every major growing region of the world. This needs to be available to all businesses.

Many Variables Covered - These databases cover a wide range of variables such as: production volumes, crop prices, transportation costs, border closures and labor disputes affecting deliveries, weather patterns in the areas where the crops are grown, and so forth. Usually, the data covers a span of many years, ranging from 25 years for most crops. At least one such company has assembled 50 years of weather data for all major growing areas of the world.

Commercially Available - This data is commercially available for private use. Training on how to access and use the data is normally provided to enable users to fully understand how to access and use the information to improve their marketing decision-making. Access to such data bases is key for understanding domestic and international food markets.

Recommendations – Below are our main recommendations for Secretary Venkataraman with respect to the importance of data for improving the participation of US small farmers and related small businesses in the agriculture sector in international trade. These recommendations will be relevant to all other areas of the U.S. economy.

1. Recognize that the lack of access to data is a largely unseen and underappreciated barrier to small business participation in international trade.

2. Recognize that access to detailed data on what crops are grown around the world is a key element in farmers reaching a better understanding of where they can sell their crops in international markets.

3. The Department of Commerce/ITA needs to prioritize the importance of access to data by small farmers to facilitate international trade.

4. The Department of Commerce/ITA needs to help small farmers gain access to data that is captured and maintained by government agencies.

5. The Department of Commerce/ITA needs to identify ways to help small farmers gain access to, and utilize, commercially available data bases (accessing these data bases is typically prohibitively expensive for small farmers).

6. An extremely important factor is to make data available to small businesses in a manner that is easy to access and use (through “User-friendly Dashboards”) to enhance their decision-making about what international markets to try to access.

Reorientation - The US needs a complete change of orientation with respect to the importance of data in international commerce. The countries that capture data, and make it readily accessible to their businesses, will be the future leaders in international trade.

We appreciate the opportunity to respond and are available to answer any questions. Washington, D.C. Contact: Scott Carter –


Agtools, Inc. is a data science and analytics company headquartered in

Orange, California. Its Founder and CEO, Martha Montoya,

has sourced virtually every type of fresh produce for international

markets from growing areas all over the world for over 25 years.

Agtools accesses data from many government and private sources worldwide.

The objective is to provide information on over 500 specialty crops from

growing regions throughout the world to farmers,

producers, processors, shippers, brokers, buyers, and retailers

to enable them to make better decisions in their day-to-day operations.

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