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selection to their customers. These crops are sold in their own 

 stands at the higher retail prices. A grower may be earning a 

 living off of seven acres by selling his crops at retail prices 

 while it may take 25 or more acres at wholesale prices to realize 

 the same income. For example, a grower would rarely, if ever, 

 receive less than 50 cent6 per pound on tomatoes through direct 

 market sales. Yet, the ASCS has set assistance payments based on 

 the Chicago Terminal Market, which reflect the lowest wholesale 

 price in the country. Also, the grower must suffer a 40% crop 

 loss before the grower could even qualify since federal crop 

 insurance is not available for these crops in Iowa. This means 

 that the grower would receive payment on only 60% of his total 

 crop at a small fraction of the price that he would have realized 

 had the disaster not occurred. The USDA must be more responsive 

 to realistic payment for crop losses. 



We fear that nursery and Christmas tree growers may face the same 

 situation, as most of these produce for their own retail sales, 

 as well. 



Accordingly, we request that the DSDA acknowledge and utilize 

 direct-to-consumer or retail marketing prices, when applicable, 

 on all horticultural products. 



ISSUE 3: The March 4, 1994 filing deadline is premature with 

 respect to perennial crops in northern regions. Believe me when 

 I say the weather in Iowa in early March is unpredictable! I 

 cannot remember ever seeing plants showing any growth that early 

 in spring in Iowa. To have March 4th as a filing deadline is 

 unrealistic. Plants are still very dormant at that time. Even 

 extending the date to later in the spring of 1994 is 

 unsatisfactory for determining plant viability. Many plants may 

 minimally survive under stress for a period of time following 

 exposure to adverse conditions like flooding. However, these 

 plants may very well succumb to death or be, at the very least, 

 severely damaged to the point of being unmarketable. Moreover, 

 plants under stress are very susceptible to disease, insect, and 

 related stress problems in the future. 



Nursery growers who had their fields flooded to the extent that 

 any plants were lost, would practically be forced to consider all 

 the plants lost until they prove otherwise. These growers have 

 their business reputations at stake and cannot risk selling plant 

 material that is not completely healthy and may not live. To ask 

 them to do otherwise would certainly be unethical and unfair to 

 their customers. 



Since it may take a minimum of two years to determine the true 

 extent of damage, we ask the DSDA to extend the filing deadline 

 for perennial plants until at least July 1, 1995. 



