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qualify for disaster relief because the income from all the farms was consolidated so that it 

 exceeded $2 million gross sales eligibility threshold. Fairness dictates exceptions should exist 

 for such circumstances. 



Had the Missouri and Illinois farmers been eligible for assistance, they were informed by 

 ASCS that they would have had to sign an agreement to purchase crop insurance or never be 

 eligible for disaster relief again. The problem with this requirement is that to our knowledge, 

 crop insurance is not available for turfgrass sod. 



Because ASCS officials are unfamiliar with turfgrass sod farming and know little about 

 the business they must turn to manuals and regulations for guidance when confronted by an 

 unusual problem. If ASCS disaster eligibility manuals are silent or unclear about whether 

 turfgrass sod is entitled to the same benefits as other agricultural products, then farmers who 

 deserve disaster relief assistance may be unfairly excluded from help. 



As the Subcommittee examines the operation of USDA's disaster relief programs, we 

 request that it keep in mind the many similarities turfgrass sod has with traditional agricultural 

 crops, as well as the special characteristics that require the attention of USDA during natural 

 disasters that affect it. 



We ask that turfgrass sod farms be allowed to participate in federal disaster relief 

 assistance programs in the same fashion as other agricultural products and that USDA be given 

 the necessary guidance to achieve that end. 



Among the issues we hope the Subcommittee can direct the USDA to address regarding 

 turfgrass sod farm are the following: 



1. Guidance to USDA regarding the adverse effects of crop losses or harvesting delays 

 that subject turfgrass sod farmers to losses without requiring proof that the field is dead; 



2. Guidance regarding valuation of economic loss of turfgrass sod; 



3. Elimination of needless impediments to eligibility for disaster relief where economic 

 loss can be demonstrated; and 



4. Reconciliation of the conflicts between disaster eligibility rules and availability of 

 crop insurance for crops like turfgrass sod which are excluded from crop insurance 

 eligibility. 



None of these comments are intended to be critical of USDA. We recognize that the 

 Department has not had much experience dealing with turfgrass sod in natural disasters. 

 Generally, ASCS and other Department officials attempt to be helpful, they simply need further 

 guidance. We hope the Subcommittee, through these hearings, will be able to provide such 

 direction. 



