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ISSUE 4: Trees must b.e totally dead to be eligible for crop loss 

 assistance. In the ASCS Handbook , Tree Assistance Program 1-TAP 

 (•Revision 1) , it states, "A live tree that has been significantly 

 damaged to the extent that its market value has been 

 significantly reduced ie considered lost and thus eligible for 

 TAP and should be included in the total mortality rate." TAP 

 covers only orchard trees and Christmas and forest tree 

 seedlings. However, under the crop loss program that covers 

 nursery trees produced for horticultural purposes, trees must be 

 completely dead to be considered a loss. This is obviously a 

 double standard. 



It is important to point out that trees grown for horticultural 

 or landscaping purposes and are in any way scarred, damaged, or 

 stunted have significantly lessened or totally lost their market 

 price. No customer is willing to pay for a weak, damaged, 

 stunted, or half dead tree. Our business practices will not 

 allow us to offer damaged plant material for sale. Therefore, 

 those plants are a total loss to the nursery grower, but not to 

 the USDA. However, forest tree seedlings that are planted for 

 harvest twenty years or more in the future for lumber or pulp are 

 considered lost by the USDA if they have been damaged or stunted. 



As such, we ask for uniform definitions in determining mortality. 

 The TAP definition should transcend to the crop loss program. 



ISSUE 5: A perennial that is itself the end product 

 ( i .e. .shrubs) or one in which a crop is to be harvested (i.e.. 

 strawberries) that is damaged by a natural disaster is not 

 eligible for replacement assistance. The loss of a perennial 

 plant means the loss of the initial price of the young liner and 

 the years of labor invested growing the plant, as well as, loss 

 of future income generated from the plant at harvest time. The 

 very nature of perennial plants involves production over multiple 

 years. This is very important and needs to be recognized. 



A grower may easily have two or three years invested in producing 

 a shrub, and certainly longer in producing specimen trees or 

 conifers, only to have the plant destroyed by a disaster. A 

 grower's income for the harvested year is lost but, just as 

 important, it will take a substantial investment to replant and 

 at least two, three, or more years of time to get the plant back 

 to the same stage of development as it was before the disaster. 



For example, an asparagus grower may receive assistance on the 

 crop that the grower was unable to harvest due to the flooding 

 last summer, but if the grower's plants were damaged or destroyed 

 to the extent they will not bear a crop, the grower's future 

 income is lost for next year and ensuing years . 



The policy is already established for one of our crop areas. 

 Apple producers receive crop loss assistance and also qualify for 

 TAP to replant their lost trees. Without help to replant 



