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NASS Wheat Price Cap and Disaster Aid
Payment Reductions for Non-Harvest
USDA has made a
decision to use the National Agricultural Statistic Service (NASS) “all
wheat price” of $3.60 for the payment cap rather than the winter wheat
price of $3.45. Because
NASS’s “all wheat price” of $3.60 will be used to set the payment
cap, it is very unlikely any insured Kansas wheat growers will exceed the
per acre payment cap based on combined crop insurance and disaster
payments for 2002 wheat losses. Senator
Roberts and Congressman Moran both sent comments to USDA, suggesting the
“all wheat price” was the appropriate number for per acre payment
limits.
Disaster
aid payment reductions for non-harvest.
As reported in a previous paper, USDA will reduce the disaster
payment if the crop was not mechanically harvested.
This most likely will occur on dryland corn in western
Kansas
but also applies to other crops too.
When corn yields are low, farmers often chop the remaining stalks
for livestock feed. While this
may provide poor quality forage, given the drought situation in 2002 any
livestock feed became very valuable. If
the crop was not mechanically harvested then corn producers will suffer a
12 percent reduction in their disaster payment (table 1).
On the surface this seems like a very straight forward rule with a
yes or no answer, but several questions have been e-mailed to me with
other scenarios that are not clear cut.
Scenario
1.
The remaining failed corn crop is salvaged simply by harvesting any
yield using a combine. Under
this scenario the grower would be paid the full calculated disaster
payment based on the yield used to settle the crop insurance claim.
Of course, this assumes the grower did not exceed the combined
disaster and crop insurance per acre payment limit.
Scenario
2. Grower
decides to salvage the remaining corn stalks by chopping it for feed.
The grower uses his\her own equipment to chop the corn stalks.
The grower then sells the feed to a livestock producer who feeds
the salvaged corn. This
scenario would also suggest the grower would be eligible for the full
disaster payment because the crop was mechanically harvested.
Scenario
3.
Grower chops the remaining corn stalks and retains it to feed
his\her livestock. This
scenario would also suggest the grower will be eligible for the full
disaster payment.
Scenario
4.
The grower custom hires a forage cutter to chop the remaining corn
stalks simply because he\she does not own the equipment.
The chopped forage is then stored on the farm and later fed to
his\her livestock. This
scenario would also suggest the grower will be eligible for the full
disaster payment.
Scenario
5.
The grower custom hires a forage cutter to chop the remaining corn
stalks but sells the chopped forage for cash to a neighbor for livestock
feed. Because the grower
incurred the harvest expense the assumption is the grower would be
eligible for a full disaster payment.
Scenario
6.
The grower has neither the equipment to chop the remaining corn
stalks or livestock to feed those stalks.
The grower simply sells the crop on the stump to a neighbor.
The neighbor then chops the forage and hauls the feed to his\her
farm for later feeding to his\her livestock.
It is unclear, if the grower would be eligible for the full
disaster payment because the grower did not incur any harvest expense.
However, if this same grower had hired that same neighbor to custom
chop the forage and then sold the forage to the same neighbor for feed,
the net would be the same as the grower would have received in the number
5 scenario. Therefore, because
the grower paid harvesting expenses it is assumed he\she would be paid the
full disaster payment. The
grower who paid a custom cutter and then sold the forage would have a
similar net position as the grower selling the remaining corn stalks on
the stump.
Scenario
7.
The grower turns his\her cows in to the field and allows the cows
to salvage any remaining forage from a failed crop.
Under this scenario, the grower would clearly be subject to the
discount for non-mechanically harvested acres (table 1).
There probably are
many other scenarios beyond the ones listed here but it is clear FSA will
need to interpret non-harvest rules to cover different crop salvage
methods. It is very likely
that different counties and county committees may interpret the rules
differently for some of these “gray area” scenarios. The really
“gray area” scenario is number 6 because if the Farm Service Agency
determines the grower is subject to the 12 percent reduction in disaster
payments for non-harvest, it is possible the grower is worse off by
selling the forage on the stump. If
the payment he\she received for the remaining corn stalks is less then the
reduction in disaster payments, then the grower clearly had a net loss.
It is also possible the grower sold the remaining corn stalks for
mechanical harvest for a price greater than the reduction in disaster
payments. Therefore even if
the grower does suffer a reduction in disaster payments he\she is clearly
better off by having sold the corn stalks.
Undoubtedly, this will
be another issue that will be viewed differently by one’s personal
situation. Those farmers who
sold the stalks rather than paying a custom cutter or harvesting those
stalks themselves will likely argue they should be paid the full disaster
payment because it was mechanically harvested.
That is certainly a valid argument because if one knew the rules
last fall, they could have easily circumvented the harvest rule by simply
paying someone to custom cut those stalks and then selling the feed as a
separate cash transaction. A
more liberal definition by FSA that simply requires the forage to be
mechanically harvested and makes no distinction how the proceeds were
distributed would make all of these scenarios non-issues.
Clearly, this could
apply to other crops too such as wheat.
For example, one might have salvaged remaining wheat by baling
straw.
Regardless of how FSA
interprets the mechanical harvest rule, farmers are clearly better off
receiving disaster payments. In
many cases disaster payments plus crop insurance will generate returns
approaching an average crop. Without
those disaster payments clearly many farmers would have suffered losses on
the 2002 crop. However one
must remember there was a significant delay from harvest time until
disaster aid payments were provided. Because
these payments will come in 2003 there may also be some income tax
implications but many growers with their tax adviser have been very
proficient managers of their tax liabilities.
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