90 



ISSUE 1: The practice of using a producer's historical records 

 to establish a cap on total eligible yield for a given crop is 

 un.iustly restrictive. Historical records certainly assist in 

 determining prospective yields for future crops on the same 

 acreage, if the same crops are planted and the same production 

 methods are used. However, past marketed quantities should not 

 be the only factor utilized and should never be used solely to 

 reflect the total eligible yield. This practice ignores the 

 total crop loss. For example, growers may have put new acreage 

 into production several years ago and are now ready to harvest 

 from the new field. While this new field may have no historical 

 record of ever producing a marketed crop, this would certainly 

 reflect a crop loss if destroyed. The USDA fails to recognize 

 this new increased crop simply because there are no historical 

 records to substantiate the crop. This, in effect, penalizes a 

 grower who increases production. Yet, this increased crop would 

 represent a market value and would reflect increased dollars for 

 the grower had it not been destroyed by the disaster. 



The following is the example that I U6ed with our state ASCS. 

 Suppose my nursery business had been retailing 100 three foot 

 white pines for the past five years. Several years ago I decided 

 to plant and grow my own instead of buying them from another 

 grower. This year the pines were large enough to harvest. 

 Before I could dig them, the rains came. The pines were flooded 

 and killed. So I went back to my wholesale grower, bought 100 

 pines from them again and sold them all, just as I had done in 

 the past. Now I have sold 100 pines this year and had historical 

 records of selling 100 pines each year. Therefore, according to 

 ASCS I have no loss; meaning the 100 dead pines in my field do 

 not exist. So in order to access any assistance, I needed to 

 lose my crop in the field and then close my doors to my 

 customers. I would be penalized for buying in plants to service 

 my customers and continuing to try to earn an income. 



In determining crop loss , we ask that the USDA recognize all 

 acres in production or designated for production and harvest that 

 were damaged by the natural disaster. 



ISSUE 2: The price differential between marketing channels on 

 fruits and vegetables is not afforded the producer in determining 

 eligible assistance. Although the Disaster Assistance Bill 

 specifies that appropriate marketing channels be considered in 

 determining the rates to calculate .crop loss payments, this is 

 not happening. Instead, only the processing market and wholesale 

 fresh market are being recognized. 



The major marketing channel for most Iowa fruit and vegetable 

 growers is the direct sale to the consumer or retail market. The 

 vast majority of our producers sell direct through farmers' 

 markets, roadside stands, or on-farm markets. These growers 

 split their production to produce smaller quantities of many 

 varieties of fruits and vegetables in order to offer a wide 



