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Because turfgrass sod is typically not considered a traditional "food or fiber" 

 agricultural commodity, it is important for the Subcommittee to understand that turfgrass 

 production is in fact a traditional agricultural activity. It is produced, cultivated and 

 harvested in much the same manner as other traditional agricultural commodities. For 

 example, its production requires careful selection of quality grass seeds free from 

 contaminants. Turfgrass sod must be produced in a specially prepared field and provided 

 with high levels of day-to-day management to yield a high-quality end product. The 

 harvesting methods require specialized techniques to prepare the product for market. These 

 steps involve a high degree of intensive management. As a result, ASPA believes that 

 turfgrass sod farmers should have the same access to federal disaster relief benefits that other 

 agricultural producers are currently eligible to receive. 



Turfgrass sod has in the past been excluded by USDA from eligibility for disaster 

 assistance relief under its various programs. This was in part because turfgrass sod was not 

 considered "food or fiber," - more traditional agricultural concepts. This reflects the general 

 difficulty USDA has had in trying to properly establish the eligibility of our farms for 

 assistance. Part of the problem was the lack of specific legislative language or regulatory 

 guidelines which would enable USDA officials to make timely decisions affecting turfgrass 

 sod producers. 



Section 2244 of P.L. 101-624 (1990 Farm Bill) took an important step in trying to 

 resolve the uncertainty in the context of disaster relief. It included turf among the non - 

 "food or fiber" crops determined to be eligible for disaster crop loss assistance. The 1993 

 disaster relief provisions necessitated by the floods in the midwestem U.S. also adopted this 

 definition. 



Because turfgrass was only recently included within the definition of crops eligible for 

 disaster assistance, USDA officials are having difficulty implementing treatment under its 

 disaster relief programs. The recent midwestern floods illustrate the problem. Two of the 

 major problems that ASCS officials have in processing claims for disaster assistance are in 

 determining when there is a crop loss and secondly in assessing the value of the crop loss. 

 While ASCS officials can readily determine when a field of corn or soybeans has been 

 damaged or destroyed and they can readily determine the average value of such commodity 

 during preceding years, this process is more difficult for perennial crops such as turfgrass 

 sod. 



they convert wetlands into cropland after 1985. In defining what is prior converted cropland 

 for purposes of the Clean Water Act, the Army Corps of Engineers borrowed the 

 Swampbuster definition of "agriculture" which is limited to annual crops governed by the 

 Swampbuster program. As a perennial crop, turfgrass sod, along with all other perennials, 

 was arbitrarily denied prior converted cropland status. This was not the result of a rational 

 policy decision or activity. It was a result of confusion and lack of knowledge by the Corps 

 of Engineers about the scope of the definition of agriculture. 



