Attachment A WYOMING DEPARTMENT OF WORKFORCE SERVICES INTEGRATED WORKFORCE PLAN PROGRAM YEAR 2013 Modification Summary of Annual Agricultural Outreach Plan Requirements The Agricultural Outreach Plan (AOP) portion of the State Plan must describe plans for providing services to the agricultural community, both for agricultural employers and Migrant and Seasonal Farmworkers (MSFWs), as described in Wagner-Peyser (W-P) regulations at 20 CFR 653.107, the Workforce Investment Act (WIA) Title I final regulations at 20 CFR 652.107(b)(1), the WIA/W-P Act Integrated Workforce Planning Guidance, and the Unified Planning Guidance. This attachment provides detail of states that must be included in the AOP section of the State Plan. A. Assessment of Need. The assessment of need must include: (i) A review of the previous year’s agricultural activity in the state. Wyoming’s land is very diverse. This is the region where the Rocky Mountains meet the Great Plains. At 6,700 feet above sea level, Wyoming has the second highest mean elevation in the United States. As such, cold winters and hot dry summers are typical in the state. Although more than 91 percent of land in the state is classified as rural, the high elevations contribute to short growing seasons in those areas of the state. The frost-free period ranges from 60 days (central and western Wyoming) to 140 days (eastern Wyoming). While agricultural productivity in the state may be limited by the short growing seasons, still there is significant crop production that occurs in Wyoming. Also, the makeup of the state makes it a good location for livestock. Rainfall varies from west to east and across the mountain ranges. Statewide, Wyoming averages 15 inches of moisture per year. In the rain shadows created by the mountains, average rainfall is much less than that although, ironically, some of the more productive agricultural areas in the state are found there. Those areas thrive on irrigation from Wyoming’s river systems. The following information, regarding Wyoming agriculture, was provided by Wyoming Farm Bureau, based upon 2012 preliminary data from the U.S. Department of Agriculture. Private ownership of Wyoming land: Land used for agricultural production in the state: Estimated value of Wyoming’s agricultural production: Number of Wyoming farms and ranches: Average size of Wyoming farms and ranches: Wyoming’s national agriculture rankings o Alfalfa hay production: o Barley production: 42 percent 30,169 million acres $1 billion 11,069 2,745 acres (no. 1 in the U.S.) 17th 8th o o o o o o Pinto beans production: Dry beans production: Number of beef cattle: Sheep and lamb production: Marketed sheep and lambs: Wool production: 3rd 8th 15th 4th 4th 4th Identify each major labor-intensive crop activity in the previous year, indicating the months of heavy activity and the geographic area of prime activity. Most major crops in Wyoming are no longer considered labor-intensive. The uses of herbicides and machinery have considerably reduced the need for manual labor in the planting, tending, and harvesting processes. With the exception of winter wheat, which is typically planted in September and early October, most Wyoming crop cycles begin in the spring and end in the fall, to coincide with favorable growing temperatures. This is based on information provided by USDA. Alfalfa, barley, oats, and spring wheat are planted in March and April. Sugarbeets are typically planted in April. Corn planting occurs toward the end of the month and into May. Dry beans are also planted in May. If moisture is adequate during the spring and summer, farmers may get as many as three alfalfa cuttings during the season, ending in September. Winter wheat is harvested in the summer. Barley, oats, beans, and corn are harvested in late summer and early fall, while sugarbeets are harvested in October and early November. With regard to livestock, lambing and calving begin in late March and extend into early May. Sheep and cattle, with their offspring, are moved to summer pastures typically by early June. Wyoming’s crop production in 2012 compared favorably to 2011 output, but was generally lower than in 2010. The following data, also from USDA, describes individual outputs and the methods used to work the crops. Wyoming’s barley production in 2012, at 5,340,000 bushels harvested, was down 13 percent compared to 2011 and 12 percent compared to 2010, although the same amount of acreage was planted. Primary locations for barley production in 2012 remained Park County (1,825,000 bushels), Big Horn County (1,375,000 bushels), and Washakie County (1,225,000 bushels), in the Big Horn Basin of northwest Wyoming. Wyoming counties outside of the Big Horn Basin totaled only 205,000 bushels in 2012. Barley production is done by machines. Few agricultural workers are involved in the process. Corn production for grain, at 105,000 acres in 2012, was the same as 2011, both of which were nearly 17 percent higher than in 2010. The yield also increased substantially in 2011 (9,100,000 compared to 6,050,000 in 2010), but decreased in 2012 by 6.4 percent to 8,520,000 bushels. Highest production occurred in Goshen (4,332,000 bushels) and Laramie (1,088,000) in the southeast part of the state. Other sections of the state accounted for 2,233,000 bushels of corn. Corn production occurs primarily by machine work. Herbicides are used to retard weed development. Total dry bean production increased in 2012, compared to 2011, but was still 1.7 percent below 2010 output. The 2012 yield was 1,007,000 bushels, compared to 726,000 in 2011 and 1,024,000 in 2010. Acreage planted in 2012 was 45,000 (up 28.6 percent) compared to 2011, at 35,000, and 49,000 in 2010. The heaviest output of dry beans occurred in the Big Horn Basin, where Big Horn County (287,000 cwt.) led the way, followed by Park County (238,000 cwt.). Other districts outside of the Basin only totaled 323,000 cwt. Dry bean production is machine facilitated. Herbicides have been used in the production of dry beans in Wyoming, limiting the need for workers. The number of Wyoming acres producing hay (all types), at 875,000 in 2012, decreased from the 2011 level by nearly 22.0 percent, and was 26.5 percent lower than in 2010. Hay production continued to occur throughout Wyoming in 2012. Top producing counties were Fremont (84,200 tons), Sublette (66,800 tons), Lincoln (61,500 tons), and Uinta (46,700 tons), in western Wyoming, followed by Platte (39,800 tons) in the southeast part of the state. Most of the hay produced was alfalfa. Hay farming has evolved to the point where most individual harvests are completed by one or two workers, using machinery that produces and hauls very large bales. Few operations still rely on workers to haul 60–80 pound bales, and fewer still free-stack their hay without baling it. As a result, the traditional need in this area for workers has greatly diminished over time. The number of acres producing oats, at 30,000, remained the same as in 2011, but was still nearly 12 percent below 2010. Also, this was only 14.1 percent of the historic high that occurred in 1930. Oat harvest figures dropped substantially (62.2 percent) from the bushel output achieved in 2011, and was 60.3 percent below that of 2010. Production figures, by county, were not available. Oats are machine produced in Wyoming. Winter wheat acreage remained constant in 2012 at 150,000, compared to 2011, but was still 9.1 percent below 2010. However, production in 2012 (3,000,000 bushels), dropped 32.2 percent, compared to 2011 (4,420,000 bushels), and was 35.4 percent below the 2010 level (4,640,000 bushels). Figures for individual Wyoming counties were not available. Most wheat farming is done by machines. Sugarbeet acreage in 2012 (31,800) increased 2.6 percent, compared to 2011 (31,000), and was 4.1 percent higher than in 2010 (30,500). Production was also up in 2012 (895,000 tons compared to 859,000 in 2011 and 821,000 in 2010). Major sugar beet producing counties were Park (305,000 tons), Big Horn (250,000 tons), Washakie (204,000 tons), Platte (43,900 tons), Goshen (40,900 tons) and Fremont (38,000 tons). Ironically, Goshen County and the City of Torrington – where sugar processing occurs – have a lesser involvement in the production of sugarbeets. Sugarbeet production was a reliable source of employment for MSFWs until about 2010. Producers began using herbicides to control weeds, which limited the work that had been available to the workers. As a result, employer feedback, through the outreach program, indicated there was a dwindling need for the workers seasonally. Those conditions have continued since the 2010–2011 time period. (ii) A review of the previous year’s MSFW activity in the state. Estimate the agricultural labor employed in each of the crops identified in item (i) above. Estimate the number of MSFWs involved in each, and indicate crop areas that experienced labor shortages. Again in PY 2013, DWS checked a number of sources, in an effort to obtain data about labor involvement and labor shortages in Wyoming agriculture. These included the U.S. Department of Agriculture (USDA), Wyoming Farm Bureau, the Wyoming Department of Agriculture, county Agricultural Extension Offices, Motivation Education and Training (MET) – the WIA Section 167 NFJP grantee in the state, and DWS’ own Research and Planning Division, which produces data for the Bureau of Labor Statistics, etc. No data were found that would enable DWS to reliably estimate labor involvement, on the basis of crop types, for either MSFWs or non-MSFWs. USDA, in its 5-year census, does provide data showing the number of MSFWs working in each county. Possibly, that data could be used to extrapolate outcomes, such as the two that are requested here. However, the most recent available census data is still only 2007. Since then, the state has experienced a reduced need for labor in the production of Wyoming crops, making those data questionable for the current time period. The 2012 census data won’t be available until later in 2014. USDA survey results do indicate the level of workers hired in jobs that are 150 days or more, and 149 days or less, by major region. Also, these results are available for recent time periods. Wyoming is in the Mountain 1 Region, along with Idaho and Montana. Results for the 149-daysor-less group consistently show between 5,000 and 10,000 workers, over recent years, for the entire region and depending on the time of year. Wyoming’s use of temporary agricultural workers is a smaller portion of this pie. In PY 2012, Wyoming job orders totaled 242, for 696 positions. A total of 1,896 people applied for the openings. Thus far in PY 2013, there have been 172 job orders for 572 positions. A total of 655 people have applied for those positions. DWS will continue to seek meaningful data that would enable the agency to accurately identify MSFW worker numbers in Wyoming and enable agency representatives to understand the workers’ needs. The State of Wyoming is not designated by ETA as a Significant State, for MSFW purposes. Also, none of Wyoming’s local One-Stop centers are designated as Significant Local Offices. Estimates of the number of migrant and seasonal farmworkers (MSFW) in the state have been consistently low. (iii) A projected level of agricultural activity in the state for the coming year. Identify any changes from last year's crop activities as described in item (ii) above. DWS receives requests from employers to post temporary agricultural job orders. In PY 2010 through PY 2012, the agency respectively received 193, 238, and 242 such job orders from Wyoming employers, of which 38, 67, and 48 respectively were related to crop activity. Thus far in PY 2013, job orders, are down 11.1 percent, compared to this time period in PY 2012. However, crop-related job orders are up by 19.4 percent (37 compared to 31). For the coming year DWS does not expect that agricultural activity will change much from what it has been in recent years. PY 2013 has been a better year for moisture in Wyoming. However, it is anticipated that agricultural employers will continue using herbicides to control weeds, and will continue to utilize agricultural machinery in their operations, which will negatively affect opportunities for MSFWs. With regard to long-term forecasts, the Research and Planning Division of the Wyoming Department of Workforce Services estimates continuing job reductions in the category of Farmworkers and Laborers, Crop, Nursery, and Greenhouse workers, over the 10 year period between 2012 and 2022. The percent change from 2012 to 2014 is projected to be -18.1 percent, while from 2012 to 2022, the change is projected to be -90.6 percent. On the other hand, Farmworkers, Farm and Ranch Animal positions are expected to increase by 28.0 percent over the ten-year period. This may seem impressive, but the actual numbers are small. (iv) A projected number of MSFWs in the state for the coming year, which must take into account data supplied by WIA Section 167 National Farmworker Jobs Program (NFJP) grantees, other MSFW organizations, employer organizations and federal and/or state agency data sources such as the U.S. Department of Agriculture and the Employment and Training Administration. MSFW data and outcomes are compiled by DWS’ Wyoming at Work System into a Migrant Indicators of Compliance (MIC) report. Because the MIC data come from the Wyoming at Work system, which is the same data source that is used to compile the Wagner-Peyser (W-P) reports, the MIC figures are the same as those that would be reported in the ETA 9002 series reports to the Employment and Training Administration. The Wyoming at Work system reports that there were 53 migrant farm workers, 2 migrant food processing workers, and 184 seasonal workers who registered in the system between July 2012 and June 2013. The Wyoming at Work labor management system is known to have a reporting issue involving its identification of MSFWs who used the system. As a result, user counts have been inflated and are not considered reliable. The data gathering questions in the system are in the process of being redesigned and it is anticipated that they will be more accurate in PY 2014. The State Monitor Advocate contacted the field office of Wyoming’s WIA 167 NFJP grantee, Motivation, Education, and Training (MET), Migrant Health of Wyoming, the DWS Powell Workforce Center, Torrington Workforce Center, and the U.S. Department of Agriculture regarding the number of MSFWs who were in Wyoming during 2013. The Monitor Advocate attempted also to obtain input from the Torrington Middle School, which runs a summer program for MSFW children. However, those attempts were not successful as of the time this plan was drafted. USDA census data from 2007 showed a total of 257 MSFWs throughout the state. However, the number of MSFWs has been confirmed to be decreasing since Wyoming employers began using herbicide-protected crops in about 2010. Estimates of MSFWs served in the Big Horn Basin, by both DWS and MET, indicate that less than 50 have been served, thus far, in PY 2013. MET’s MSFW definitions differ from those used by DWS. Met is allowed to consider a two-year period when determining if a worker qualifies as a MSFW, so actual counts may differ somewhat. DWS will continue to work with MET to identify MSFWs and to provide needed services to them. The Park County School District no longer has a summer school program for MSFW families. Therefore, that district was not contacted for information about workers in the area. The Torrington Middle School, in Goshen County, did not respond to DWS’ request for information for the PY 2014 plan. However, the Torrington Workforce Center and the State Monitor Advocate will continue to coordinate with the school, for the purpose of identifying MSFWs and providing needed assistance. The school has held a yearly summer school program for MSFW children, which are defined as such by the Wyoming Department of Education. In Calendar Year 2013, Wyoming’s Migrant Health Program served a total of 118 households belonging to MSFWs. Of these, 70 were classified as Seasonal Worker households and 41 were Migrant Worker households. The other seven households were unexplained. A total of 495 individuals, including men, women, and children, were served by the Migrant Health Program during the year. Some of the individuals served by the Migrant Health Program may not be actively participating as Migrant Workers or Seasonal Workers, per se. Small children are among those served. Nevertheless, this association with Migrant Health represents a good opportunity for DWS to potentially identify workers through referrals and other means. DWS will work to strengthen this cooperative effort in PY 2014. Based on the data from these combined sources, DWS projects MSFW numbers for PY 2014 to range between 100 and 200 workers – most of whom will be in the Big Horn Basin; the location of the Cody, Powell, and Worland Workforce Centers. The Powell Center, which is near the local offices for both MET and the Migrant Health Program, will be the key contact point. MSFW numbers are expected to be affected again by farmers’ use of herbicides and machinery in the production of their crops. B. Outreach Activities. The local offices outreach activities must be designed to meet the needs of MSFWs in the state and to locate and contact MSFWs who are not being reached through normal intake activities. The plan for the proposed outreach activities must include: (i) The goals for the number of MSFWs who will be contacted during the program year by W-P staff. The plan should also include the number of MSFWs who will be contacted during the year by other agencies under cooperative arrangements. These numerical goals must be based on the number of MSFWs estimated to be in the state in the coming year, taking into account the varying concentration of MSFWs during the seasons in each geographic area, the range of services needed in each area and the number of W-P and/or cooperating agency staff who will conduct outreach.1 DWS does not retain a full-time agricultural outreach worker, due to the lack of MSFWs who are believed to be in the state, even during summer crop-growing months. The Agency stopped doing that in 2011, when it was realized that significant numbers of workers were no longer coming to Wyoming. Agricultural outreach is now done from Wyoming’s workforce centers (American Job Center Network and One-Stop centers), by assigned workforce specialists, as part of their overall duties. As mentioned earlier in this plan, it is felt that Wyoming at Work system reports of MSFW are probably overstating the population. Efforts are being undertaken to improve the accuracy of the reports. The Department recognizes there is still a trickle of MSFWs who come into the state seeking employment and training opportunities. Therefore, DWS will utilize a memorandum of understanding with MET, the NFJP grantee, to facilitate information sharing and coordination of services to MSFWs. Also, the Department will continue to contact other organizations that are known to serve MSFWs, including the Migrant Health Program, English as a Second Language (ESL) organization, and Wyoming’s school districts and schools. DWS will work with these organizations as much as possible, to identify MSFWs and reach out to the workers. The workforce specialists who are assigned to conduct MSFW outreach will, along with the State Monitor Advocate, be the individuals who will work with MET and other MSFW service providers. It is difficult to set numerical goals for the number of MSFWs who will be contacted during the year, due to the circumstances mentioned in this plan. However, DWS feels that a goal of 50 – 100 is reasonable in PY 2014, for the Department. (ii) An assessment of the resources available for outreach that includes: 1. The number of SWA staff positions the state will assign to outreach activities. The assessment must indicate the full-time equivalent positions for each local office to which staff must be assigned, and the number of staff assigned to the state office for this purpose. The Department of Workforce Services does not plan to assign full-time agricultural outreach positions to any of its Workforce Centers, due to limited anticipated MSFWs in the state and planned budget cuts for the state fiscal year, beginning July 2014. 2. Where the number of SWA staff positions assigned to outreach activities is less than in the prior year, please provide an explanation for the reduction and the expected effect of the reduction on direct outreach activities, as indicated in 20 CFR 653.107(h)(3)(i). The number of SWA staff positions assigned to outreach activities has not changed since before PY 2012. DWS does not plan to have a full-time or seasonal outreach worker in PY 2014. 3. The resources to be made available through existing cooperative agreements with public and private community service agencies and MSFW groups. (States are encouraged to initiate cooperative agreements with WIA Section 167 NFJP grantees for outreach position.) The Department of Workforce Services will coordinate with the WIA Section 167 NFJP grantee, MET, to identify MSFW needs, and to facilitate or provide intensive services and training services. This will be facilitated by a Memorandum of Understanding. Cooperative agreements are not anticipated with other public or private community service groups. Nevertheless, DWS does plan to engage other groups for the purpose of identifying and assisting MSFWs. (iii) The tools which will be used to conduct outreach contacts, including personal contact, printed matter, videotapes, slides, and/or cassette recordings. DWS will employ printed materials and personal contacts through community opportunity fairs, and migrant health fairs, etc. to conduct outreach with workers and their families. Efforts will also be made to visit identified workers at their work locations and to assist them using available technology. C. Services Provided to MSFWs through the American Job Center (AJC) Network. The plan must provide specific information on how core, intensive, and training services required under WIA Title I will be provided to MSFWs through the AJC network (previously referred to as the One-Stop Career Center system). States should provide information on how MSFWs will be provided staff-assisted services and how MSFWs will be served in an electronic environment in the AJCs and/or affiliate sites. States should consider how they will enable these AJC customers to advance their skills and be competitive in a local, regional and global economy. Core workforce services will continue to be offered to workers through the Wagner-Peyser (W-P) program. These may be received in person at the workforce centers. Also, W-P services are available electronically through the Wyoming at Work system. This system is available in Spanish. In-person services will include assistance in registering for work in the Wyoming at Work system, resume preparation and repository, job matching, labor market information, skills testing, and career planning. Consideration, on a need basis, will be given to the provision of services to workers in the workplace. Priority of service for Veterans, which is enforced through federal and state policies, will be provided to MSFW. Staff-assisted services, including WIA intensive services and training, are offered at the workforce centers. As needed, these will be taken to workers in their workplace too. The services are coordinated between programs, based on eligibility. Through the centers, workers will also have access to the full array of other services provided by DWS and its partners. Core, intensive, training, and supportive services are also provided by MET and it is anticipated that the grantee will continue to provide these services to MSFW during the PY 2014. MET has coordinated training services at Northwest College in Powell, Wyoming, and truck driver training with Sage Technical Services. MET also has its clients register in Wyoming at Work, and refers the workers to DWS, according to the needs of the workers. DWS will coordinate with MET in the provision of services. D. Services Provided to Agricultural Employers through the AJC Network. The plan must describe efforts that will be taken to provide services to agricultural employers in states with an adequate supply of U.S. workers and in those states where a shortage of workers is anticipated. The services provided to agricultural employers can be incorporated into the section of the WIA/W-P plan on serving employers in general. The Department’s workforce centers have contact with agricultural employers and provide services to them, including job order preparation, job matching, and employer seminars. Although it is anticipated that there will continue to be a reduced demand for MSFWs in Wyoming, DWS will work with crop growers to ascertain and fulfill their needs for workers. Employers who participate in the H-2A Temporary Agricultural Program also have direct contact with DWS and the State Monitor Advocate, or else through their agents. It is anticipated that this contact will continue through the PY 2014 plan period. E. Data Analysis. (i) Previous year’s history (based on Program Year (PY) 2012 data): Number of agricultural job orders and openings received, In PY 2012, DWS processed 387 agricultural job orders, of which 149 were for interstate employers. A total of 216 were posted in connection with the H-2A program. The combined positions offered through H-2A and non-H-2A job orders were 1,010 and 1,991 applications were received. Only 264 applicants applied for 216 H-2A job orders. Total H-2A positions to be filled were 674. Number of agricultural job orders filled, A total of 74 applicants were reported by staff as being hired during PY 2012. It is probable that other, non-reported, applicants were also hired. Also, some of the positions that were filled could have been for job orders that were posted prior to PY 2012. Percent to be filled, Approximately 7.0 percent of vacancies were filled in PY 2012 (74 of 1,010 openings.) Number of interstate clearance orders received, and A total of 149 interstate job orders were received from other states and processed in the Wyoming at Work system, during PY 2012. Of that number, 129 were H-2A. Number of interstate clearance orders initiated. All but one H-2A job order initiated in Wyoming, during PY 2012, were also sent to labor supply states for entry into their systems, for a total of 86. The job order that was not sent was totally filled in Wyoming. It is believed that no non-H-2A agricultural job orders were sent to other states for recruitment. (ii) Plan for upcoming year (based on estimated data): Number of agricultural job orders expected to be received, DWS anticipates that agricultural demand for workers will remain constant in PY 2014, with possibly even a small amount of growth, even though the long-term demand for crop workers is expected to decrease. Demand should still exist for sheepherders, as well as other livestock workers, and equipment operators, etc. Therefore, the Department anticipates it will process approximately 465 agricultural job orders in PY 2014. This number includes orders from other states. Number of agricultural job orders projected to be filled, DWS will seek to increase the number of agricultural job orders for which a placement occurs in PY 2014. It is currently working with Geographic Solutions regarding reporting capabilities in the Wyoming at Work System, which will enable the Department to better track performance for this outcome. Also, better utilization of local and intrastate recruitment, as a part of the state’s Agricultural Recruitment System, are expected to help. The Department understands that this will be challenging to accomplish, especially given the high number of H-2A job orders in the mix. H-2A employers have exhibited a strong tendency to want to employ foreign workers who have worked for them in past years. Because of this, low wages, and required experience levels, the number of workers applying for the H-2A positions is decreasing. The ratio of applicants to each open H-2A position, for the years PY 2010, PY 2011, PY 2012, and so far in PY 2013 are shown below. Program Year 2010 2011 2012 2103 Interstate H-2A Applicant Ratio 0.16 0.12 0.24 0.13 Wyoming H-2A Applicant Ratio 1.02 0.81 0.51 0.25 Total H-2A Applicant Ratio 0.72 0.57 0.39 0.22 DWS is aware of this situation and is working with employers, their agents, and job applicants to assure that domestic workers have opportunity to be employed. Inasmuch as the number of positions available for each job order is not a one-to-one ratio, it is difficult to project how many actual job orders will be filled. A single job order may request workers for dozens of positions. There are no known data in Wyoming that measure the number of job orders where every position is completely filled. However, DWS will seek to improve on the percentage of applicants placed, which is measured. Percent to be filled, The Wyoming at Work system is showing a placement rate, thus far, of 8.9 percent in PY 2013, which is an improvement over PY 2012. However, the percentage is for all placements; not just agricultural placements. As mentioned earlier in this plan, the system has used inflated numbers in calculating MSFWs. With the introduction of new policies and procedures this spring and increased outreach to MSFWs, DWS anticipates that placements will be higher. DWS proposes to monitor referral outcomes more closely, as well as increase coordination with employers in the recruitment of workers, to facilitate accomplishment of the goal. Estimated number of interstate clearance orders the state will receive, and Nearly all of the interstate clearance orders, which Wyoming receives from other states, are H-2A requests. As in previous years, the majority of PY 2013 clearance orders have come from Montana. A few orders have also been received from Washington, Utah, Colorado, Nebraska, and Oregon. Based on recent activity, Wyoming estimates that it will receive about 244 of these orders during PY 2013, of which approximately 200 have already been received. PY 2014’s counts are expected to be about the same. Estimated number of interstate clearance orders the state will initiate. DWS is in the process of writing Agricultural Recruitment System policies and procedures that are expected to result in more interstate clearance orders, as well as better utilization of local and intrastate recruitment. The rules will prescribe interstate recruitment as the course of action to take, when local and intrastate recruitment do not furnish enough workers to satisfy the needs of employers. DWS estimates that a high percentage of intrastate job orders could need to be posted with other labor supply states, because of the fact that less than 10 percent of all PY 2012 job orders were filled locally or through intrastate recruitment. Inasmuch as locally created non-H-2A job orders numbered 155 in PY 2012, it is estimated that Wyoming could expect the need to recruit interstate for at least 100–150 of its Wyoming-originated job orders, even with improved performance in PY 2014. The number of PY 2013 H-2A interstate job orders, from Wyoming to other labor supply states, thus far is 0.03 percent higher than at the same time in PY 2012. H-2A employers have a tendency to repeat participation each program year. A few employers will opt out of participation, while others will start for the first time. As of the beginning of March 2013 (PY 2012), Wyoming’s interstate H2A job orders totaled 84. For the same period in PY 2013 the total is 87. The tally for PY 2014 is expected to be similar, possibly a little bit higher. F. Other Requirements. (i) State Monitor Advocate. The plan must contain a statement that indicates that the State Monitor Advocate has been afforded the opportunity to review and comment on the PY 2014 AOP. The State Monitor Advocate position resides in the Employment and Training Division of the Wyoming Department of Workforce Services. This Agricultural Outreach Plan was prepared for the Department by the Monitor Advocate. (ii) Review and Public Comment. The plan must provide information indicating that WIA Section 167 NFJP grantees, other appropriate MSFW groups, public agencies, agricultural employer organizations and other interested employer organizations, have been given an opportunity to comment on the state AOP. Include the list of organizations from which information and suggestions were solicited, any comments received, and state responses to those comments. The Wyoming Department of Workforce Services is observing the requirement to make the proposed plan available to the NFJP Grantee, public agencies, agricultural employer organizations, and other organizations expressing an interest in the plan. This is being done, as required, at least 45 days prior to the expected submission date of the plan to the Region IV Administrator, Employment and Training Administration, U.S. Department of Labor. A 30-day comment period is being provided to these parties. 1 The numerical goals that must be included in the agricultural outreach plan are in reference only to the proposed outreach activities and are not negotiated performance targets.