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many nursery crops may either be dormant at the time a disaster 

 strikes or may minimally survive under stress for a period of 

 time before finally succumbing. At best, a nursery farmer loses 

 income for up to several years because recovery for these plants 

 or trees may need such time before they ever reach the point 

 where they are ready again for harvest and sale. At worst, when 

 there are no prospects for salvageability of injured, scarred or 

 stunted plants, a nursery farmer's income is totally lost — even 

 if there has been an investment of up to ten years or more in 

 producing that species. 



While the rules governing the Tree Assistance Program provide for 

 disaster benefits if a crop's market value has been significantly 

 reduced, such a provision is not incorporated into the crop loss 

 disaster assistance program. Moreover, the application filing 

 deadlines for disaster assistance are often premature with 

 respect to nursery crops, particularly in the northern climes, 

 where plant dormancy persists longer into the spring. In such 

 instances, it may be difficult — if not impossible — to 

 determine actual crop losses in the first six months of the year. 



AAN urges Congress and USDA to amend the crop loss rules to allow 

 for disaster assistance to cover injured, scarred or stunted 

 plants whose market value is lost or substantially delayed. AAN 

 also urges Congress and USDA to adjust application filing 

 deadlines to reflect late dormancy periods for nursery crops, 

 particularly in northern regions. 



USE OF GROWER'S PREVIOUS THREE-YEAR SALES RECORDS AS BASIS FOR 



ELIGIBILITY DETERMINATION IS RESTRICTIVE 



In determining eligibility for crop loss disaster assistance, 

 USDA apparently reviews a grower's sales records for the past 

 three years. While this makes initial sense, there are several 

 drawbacks with respect to nursery crop production. Using 

 year-to-year varietal production values is unfair due to the 

 inconsistency of a nursery farmer's sales volumes. 



First, many growers do not sell the same volume of a plant 

 variety from year to year. It is entirely possible that a 

 nursery farmer may decide to forego selling his "crop" of 

 azaleas, for example, in a particular year if demand is not 

 present. Second, let's say a nursery farmer purchases additional 

 land, puts this new acreage into production, and is ready to 

 harvest from it for the first time when the disaster strikes. 

 How does USDA factor in such crop values when no production sales 

 records exist for this new acreage? Third, what happens if a 

 nursery farm has only been in business for one or two years prior 

 to the disaster? Would such a nursery grower be eligible at all? 



