Michigan resident Shelton issues public comments on Federal Crop Insurance Corporation’s proposed rule – InsuranceNewsNet
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I am writing to you today to ask you
Apple’s supplemental report does not adequately define acceptable and verifiable records. The definitions are not consistent, do not specify what the detailed report will be or what records would be needed to substantiate the data in the report. Depending on what is finally set, recordings may not be available. Since the report comes months after the producer is required to choose their level of coverage, it would be impossible to quote specific premium and coverage levels.
The provision on recommended cultural practices is supposed to provide some flexibility; however, this would not be recommended but required for the acreage to meet the definition of fresh apple production. Additionally, practices vary by growing region and should therefore prevail in the region before becoming a requirement. These practices should be reviewed by regional academic experts and should never be used to devalue an indemnity when a farm suffers a loss due to a weather event.
RMA determined that a loss of 65% of the crop value would be nil. Even if there would be a loss for sale in the fresh market, the apples could still be used in the processing market. The new proposal stipulates that the loss would only be paid if the insured did not sell a single apple. This would have a direct impact on our processed apple products, such as apple slices, applesauce and apple juice, which are so sought after by consumers and
Overall, the proposed changes do little to improve coverage, are more restrictive and complex, add more administrative requirements, lack transparency and would be more burdensome for producers. The proposed rule would significantly reduce benefits to producers where it would become questionable whether producers would participate.
Thanks 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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