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The provision requiring the use of production sales records for 

 the three previous years as the basis for determining eligibility 

 is unfair and restrictive to nursery farmers. AAN urges Congress 

 and USDA to use total acreage in production as a more accurate 

 factor in eligibility determinations. 



TREE ASSISTANCE PROGRAM IS INCONSISTENT 



The Tree Assistance Program (TAP) is a cost-share program that 

 covers the costs of replanting, reseeding and repairing the 

 commercial production of seedlings and trees. In the aftermath 

 of Hurricane Andrew last year, TAP was expanded to also include 

 orchard and nursery crops, including those in containers and 

 those requiring several years of production prior to harvest or 

 sale. Last year's availability of the TAP program was critical 

 to nursery growers devastated by Hurricane Andrew. 



Much to our consternation, AAN understands that nursery farmers 

 devastated by the Midwest floods this year are ineligible to 

 participate in TAP's cost share program. AAN urges Congress and 

 USDA to eliminate this inconsistency by permanently extending the 

 TAP program to cover field and container-grown nursery crops 

 damaged by disasters. 



GUIDELINES FOR ASSESSING VALUES OF NURSERY CROP LOSSES NEED TO BE 

 CLARIFIED 



It is not surprising that USDA has found it difficult at times to 

 assess true values of nursery crop losses. First, many nursery 

 crops require multi-year production periods, and these periods 

 vary widely according to species, variety, growing conditions, 

 management practices, and climate. 



Second, there are literally tens of thousands of varieties of 

 plants and trees. In fact, there are more than two thousand 

 varieties of roses alone! The value of landscape specimen shade 

 trees or evergreens have considerably higher market values than 

 similar trees grown for forestry purposes. While we understand 

 USDA has made attempts to group plants with like characteristics, 

 we question whether such groupings truly reflect the diversity of 

 nursery crops and lead to accurate valuations. 



Third, as noted above, previous sales records may prove to be an 

 inadequate basis for determining eligibility. Lastly, USDA has 

 little experience with nursery crops, particularly with respect 

 to crop loss disaster assistance. 



All of these difficulties may lead to easily undervaluing the 



