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  • From: "Nan Johnson" <nan AT olemiss.edu>
  • To: "Market Farming" <market-farming AT franklin.oit.unc.edu>
  • Subject: act re: crop insurance for sust. ag practices - (very long)
  • Date: Tue, 5 Nov 2002 09:30:43 -0800

Dear MF friends.......here is an action alert from national sustainble ag groups regarding crop insurance legislation........[for future reference, is it better to offer long items in body of email, or send on as an attachment...I want to be careful for those who find long items too expensive or cumbersome to download......thanks, nan at dancing goats farm, north mississippi
 
Sent: Monday, November 04, 2002 2:17 PM
Subject: Crop Insurance Proposed Rule for Organic and Sustainable Agriculture

Please respond to this Action Alert from the Sustainable Agriculture Coalition  (202) 547-5754:

ACTION NEEDED TODAY:

SUBMIT COMMENTS ON NEW CROP INSURANCE PROPOSED RULE WITH RESPECT TO SUSTAINABLE AND ORGANIC AGRICULTURE
DEADLINE IS NOVEMBER 12, 2002

Background in Brief:  In the Agricultural Risk Protection Act of 2000, Congress recognized the importance of sustainable and organic farming practices to American farmers. Utilizing sustainable and organic farming practices as part of an overall farm operating and marketing plan continue to be an important route to economic viability for many small and moderate sized family farms. But crop insurance rules have historically offered fewer and less favorable risk management options to these farmers.  Congress acted to end the second-class status of these practices by indicating that “scientifically sound sustainable and organic farming practices” are indeed “good farming practices” for crop insurance purposes. (ARPA, Section 123).  This provision was originally proposed by the Sustainable Agriculture Coalition.

The proposed rule, which is long and involved and includes many, many issues in addition to the sustainable and organic portions, was issued on September 18 with a 30 day comment period ending October 18.  However, after the closing date, the deadline was extended to November 12 allowing a few short days for more groups to submit comments to help get needed changes.  (The Sustainable Agriculture Coalition, Northern Plains Sustainable Agriculture Society, National Family Farm Coalition, and the National Campaign for Sustainable Agriculture Organic Committee among others, submitted detailed comments on the rules which are available upon request.)

The proposed rule does address sustainable and organic farming, as required by ARPA, but it is seriously deficient in several respects.  Even brief comments to the Risk Management Agency from farmers and organizations could help force needed improvements.  We suggest you make some or all of the following points.  The letter need not be long or involved.


1.  Begin by naming your organization (or farm) and saying you are responding to proposed rule making revisions to the Basic Provisions for crop insurance policies to implement the Agricultural Risk Protection Act of 2000 and make other changes.
 
2.  Recommend that the definition of “good farming practices” and all regulatory references to “good farming practices” be revised in the final rule.  Recommend that the final rule:
·       address both sustainable and organic farming practices in each reference to good farming practices;
·       clearly place sustainable and organic practices on an equal footing with conventional practices;
·       include a strong statement of non-discrimination against sustainable and organic practices and systems; and
·       not require sustainable or organic farming systems to be commonly in use in a given geographic area in order for producers using those systems to be eligible.
3.  Recommend the final rule add a  review process for “good farming practices” determinations to require that the producer be given an opportunity to review and respond to the evidence available to or
considered by the agency staff person who made the original adverse determination.

4. Recommend the addition of a clear statement that organic crop insurance coverage (a) will not include insurance premium surcharges and (b) will include full recognition of organic price premiums when making indemnity payments.

5.  Recommend a waiver be instituted with respect to multiyear record requirements in the case of farmers transitioning to organic and for new, beginning farmers so that they are not precluded from obtaining insurance.

6.  Express strong support for the proposal to eliminate the mandatory arbitration requirement in
disputes between producers and the government and disputes between producers and insurance companies.  (Mandatory arbitration can be quite costly to the producer and eliminates access to any other form of dispute resolution.)

7.  Sign the letter and submit it by the close of business on November 12th.


Mail, email, or fax comments, by November 12, to:

Mr. Tim Hoffmann
Director, Product Development Division
Risk Management Agency
U.S. Department of Agriculture
6501 Beacon Drive
Stop 0812, Room 421
Kansas City, MO 64133-4676

or
DirectorPDD AT rm.fcic.usda.gov

or
Fax: 816-926-1803

National Campaign For Sustainable Agriculture
P.O. Box 396
Pine Bush, New York 12566
Phone: 845-744-8448 Fax: 845-744-8477
e-mail: sheilah AT sustainableagriculture.net
www.SustainableAgriculture.net
If you would like to join our * free * Action Alert Network, please e-mail us your name, address, phone, fax, and e-mail. Please let us know if your contact information changes



  • act re: crop insurance for sust. ag practices - (very long), Nan Johnson, 11/05/2002

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