ND Department of Agriculture Comments,
Speeches and Testimony

October 27, 1998

Tim Hoffman, Director
Product Development Division
Federal Crop Insurance Corporation
United States Department of Agriculture
9435 Holmes Road
Kansas City, MO 64131

Dear Mr. Hoffman:

The North Dakota Department of Agriculture (NDDA) supports the development of a pilot program for crop insurance that addresses scab problems in the Northern Plains. For several years, scab has been severely impacting the yields and quality of wheat and barley in North Dakota.

As indicated under the SUPPLEMENTARY INFORMATION of the Request for Comments, "The current small grains provision crop insurance provisions, 7 CFR 457. 101, section 11 (b) allow for quality adjustment of barley and wheat only when barley or wheat production grades U.S. No. 5 or worse. In some instances, barley and wheat damaged by scab do not meet this threshold, yet some price reduction is incurred by the producer in the marketing of such grain."

Scab has also been a primary cause of declining Actual Production Histories (APH) for wheat and barley producers. Many areas of the Northern Plains have suffered scab-related losses for several consecutive years, lowering their insurable yields.

The NDDA would recommend that quality discounts directly attributable to scab be indemnified. It is also recommended that a system be developed to mitigate the adverse affects on APH yields occurring from consecutive years of disease and/or insect infestation.

Incentives to raise alternative crops in areas impacted by scab should also be a priority for the Federal Crop Insurance Corporation (FCIC). Insurability of alternative and specialty crops through pilot programs, cost of production insurance, and expedited crop insurance development would provide producers with the means to grow alternatives to wheat and barley in areas of scab infestation.

The NDDA commends the FCIC for addressing this very severe problem for North Dakota wheat and barley producers. The opportunity to provide comments on this pilot program is also appreciated.

Sincerely,



Roger Johnson
Commissioner

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