Michigan Resident Shelton Issues Public Comment on Federal Crop Insurance Corporation Proposed Rule

WASHINGTON, April 15 -- Joseph Shelton of Niles, Michigan, has issued a public comment on the Federal Crop Insurance Corporation proposed rule entitled "Common Crop Insurance Regulations: Apple Crop Insurance Provisions". The comment was written on April 7, 2022, and posted on April 11, 2022:

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I am writing you today to urge USDA to reconsider its proposed changes to the apple crop insurance policy and make improvements prior to implementation.

Michigan apple farmers have taken many steps and significant investments to mitigate potential natural risks such as weather, pest, disease, etc. The current USDA Risk Management Agency apple insurance policy is an important component as it helps to protect farms in circumstances beyond our control. The apple crop insurance program is one of the tools used for risk mitigation. Specifically, we are concerned with the following changes:

The Apple Supplemental Report does not adequately define acceptable, verifiable records. The definitions are not consistent, are unclear of what the detailed report will be or what records would be required to substantiate data in the report. Depending on what is ultimately defined, the records may not be available. Because the report is months after the grower is required to elect their coverage level, it would be impossible to quote accurate premium & coverage levels.

The Recommended Cultural Practices provision is supposed to provide flexibility; however, it would not be recommended but be required for acreage to meet the definition of fresh apple production. Additionally, practices vary by growing region and therefore should be prevailing in the area before they become part of a requirement. These practices should be reviewed by regional University experts and should never be brought in to devalue an indemnity when a farm experiences a loss due to a weather event.

RMA has determined that 65% loss the value of the crop would be zero. Although there would be a loss for selling in the fresh market, the apples would still be able to be utilized in the processing market. The new proposal states that the loss would only be paid if the insured doesn't sell a single apple. This would directly impact our processed apple products such as slices, applesauce and apple juice of which are so highly desired by consumers and USDA.

Overall, the proposed changes have little improvement in coverage, is more restrictive and complex, add more administrative requirements, lack transparency, and would be more burdensome for producers. The proposed rule would greatly reduce the benefits to growers where it would become questionable if producers would participate.

Thank you for your consideration.

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The proposed rule can be viewed at: https://www.regulations.gov/document/FCIC-21-0007-0024

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