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SURE
Calculator (New Standing Disaster Aid)
Farmers have been writing to say the FSA SURE
calculator shows no SURE payments if they are insured with revenue
insurance. If one reads the disclaimer, the FSA SURE calculator is not
complete. While it is possible the final FSA rules will create an
economic incentive not to buy revenue insurance, but until those FSA rules
are published, it is too early to jump to that conclusion. However, CAT
insured farmers and farms that are highly diversified with crops, hay,
pasture, cattle, etc. will find little protection in SURE. Remember one can
also be diversified by distance because SURE is a whole farm revenue
guarantee that crosses county and state lines for the first time. SURE
favors farmers with a single enterprise with all production in a single
county and in counties with high production risk.
The Missouri Farm Service Agency (FSA) office and other
State FSA offices have posted a SURE calculator to estimate the SURE
payments under the new disaster program. Please note the following
disclaimer by the FSA office.
The calculator and instructions linked below are for
informational purposes only. This calculator in no way binds FSA to
potential payments under SURE and should not be relied on to make management
decisions. This is a tool that producers and others may use in familiarizing
themselves with SURE calculations and allows them to run various scenarios
based on basic levels of insurance coverage versus buy up levels of
insurance coverage. It is important to note that this calculator only
addresses yield based crops and does not address value loss crops or those
plans of insurance that are revenue based, including but not limited to, AGR
or AGR Lite. It does not include calculations for situations such as
prevented planting, first crop-second crop, and several other scenarios. The
calculator does not test for production loss.
The link to the FSA SURE calculator is:
http://www.fsa.usda.gov/Internet/FSA_File/sure_calculator.xls
One will note the calculator is not for revenue
based products; therefore one would assume this includes, Group Risk
Income Protection (GRIP), Crop Revenue Coverage (CRC), and Revenue Assurance
(RA). So while this program will help producers with some of their
decisions it does not provide answers to the most important questions that
are necessary for farmers to make informed decisions on the type and level
of crop insurance coverage to purchase on their winter wheat. It is
extremely unlikely that FSA will provide any official answers before the
sales closing date for winter wheat crop insurance. There are many
questions but these are some of the more important questions:
- How will the “expected price” used to set the SURE
guarantee and the 90% cap on SURE payment be defined for farmers insured
under Crop Revenue Coverage (CRC) and Revenue Assurance with Harvest
Price Option (RA-HPO) be set? Will FSA use the price guarantee in the
RA/CRC policy that is the higher of the planting price or the harvest
price or will all SURE coverages be based on the APH
price, irregardless of the type of insurance purchased?
- There are uninsurable acres when neither crop
insurance nor NAP is available. For example if a farmer’s crop is
hailed out and the claim is settled but the farmer decides to replant
those failed crop acres after the final planting date, then those acres
will not be covered by crop insurance. The question is will those
uninsured acres violate the SURE requirement that all acres must be
insured or is there some definition of a “ghost crop”? If no, then will
the revenue from those uninsurable acres count against the SURE
guarantee?
- The Law appears to state that any yield in
farmers’ historical aph that were replaced with a “plug yield” (60% of
T) will receive an adjusted SURE aph by dropped all of the plug yields
from the yield history and average the remaining actual yields for the
years with yields greater than 60% of T. Is that correct?
- Will the net or gross crop insurance indemnity
payment count against the SURE guarantee?
- Will SURE make any adjustment for prevented
planting or late planting? Under prevented planting the crop insurance
coverage is reduced to 60% of the guarantee. There is also a 1%
reduction in the insurance guarantee for each day insured farmers plant
after the final planting date.
- If farmers plant wheat in the fall and do not
insure it but destroy the wheat in the spring before harvest and replant
to soybeans, will they regain their eligibility for SURE? If yes, would
these same farmers be ineligible if they graze the wheat in the fall or
spring before replanting to soybeans?
- Will farmers who farm in two separate counties
need a Secretary’s disaster declaration in both counties to be eligible
for SURE? If yes, then this means farmers will need to meet the 50%
farm level yield loss across both counties to be eligible for SURE. Is
that correct?
- Is brome grass growing on a few acres in a water
way a “crop” and therefore requires NAP fees? If farmers hay or graze
the brome grass is it then a “crop”, i.e. no allowance for a de minimis
crop?
- How will FSA set the SURE coverage level for
farmers insured with GRIP/GRP, or forage insured under Pasture,
Rangeland, Forage Vegetative Index (PRF-VI) or the Pasture, Rangeland,
Forage Rainfall Index (PRF-RI)? How will FSA do farm level SURE loss
adjustment for farms that are insured under the area plans? How will
FSA set SURE coverage and complete farm level loss adjusting for farmers
insured under Adjusted Gross Revenue (AGR) and AGR-Lite that are based
on income tax records?
- Will the 07/08 MYA NASS price and the 08/09 MYA
NASS price be used to set the strike price in the 2009 ACRE program? If
so will FSA provide an estimate for the 2009 SURE guarantee to farmers
at signup.
The first two questions are the most important for
winter wheat producers making crop insurance decisions. If the APH price is
used that will lower the value of revenue insurance. There were also a
large number of wheat farmers that planted soybeans or grain sorghum on
wheat acres after harvest. Will those “double” crops that are uninsurable
acres in most Kansas counties count against the SURE payments?
After a brief review, the FSA calculator apparently
doesn’t adjust the SURE aph yields for any yield “plugs” that allows farmers
to replace a low yield with 60% of T in their aph. The elimination of plug
yields is in the Law, so one would assume the adjustment to aph will be
required by FSA. Also the FSA calculator uses the APH (MPCI) price for the
SURE guarantee. However that doesn’t necessarily mean the APH price will be
used for the revenue insured farmers too. If the APH price only is used by
FSA, then the rule will lower SURE payments to revenue insured farmers and
create an incentive not to pay the higher premiums for revenue insurance.
This is the only calculator I have seen for SURE but
with so many undefined parameters one should not run though the calculator
assuming the calculated results will be the payment under SURE. The most
critical decision that will need to be made is; will SURE guarantees be
based on the higher of the planting price or harvest price for farmers who
paid the higher premium costs for RA-HPO and CRC? The other major
factor is the dropping of the “plug” yields (60% of T) in the aph. This
model does not make the aph adjustment for low yields replaced with 60% of
T, but it does appear the Law requires the adjustment. Therefore, if
farmers run the FSA SURE calculator and it generates no SURE payments for
their farm, this is not the final answer. Until FSA defines price and yield
in SURE one will not know the expected value of the SURE coverage.
What should farmers do about 2008 Losses?
This lack of information is a major problem for farmers trying to make
informed decisions before paying 2008 NAP fees and any required CAT fees to
be eligible for SURE payments on 2008 crop losses. Therefore, if farmers
have 2008 losses they can pay the $100 CAT and NAP fees on any 2008
uninsured crop, until September 16. That will make the farmer eligible for
SURE but they cannot collect from 2008 CAT or NAP if they did not pay the
fee before the 2008 sales closing date. This will give a low level of
coverage under SURE, but it may not pay at that low level. The FSA SURE
calculator may help with this question if all of the insurance is CAT or
APH. However, if FSA defines the price and yield for SURE based on APH
price and makes no adjustment to the aph, it is likely many revenue insured
farmers will receive no SURE payments. Currently the FSA calculator makes
no adjustment for the SURE aph yield or the revenue prices.
In Kansas crops are not crops until they are in the
bin. Therefore, growers with 2008 wheat losses or if they have a large
number fall crop acres, then the best suggestion is pay the $100 NAP fees on
pasture and other uninsured crops. One should check with the FSA office to
make sure of the crops that will need the 2008 NAP or CAT fees to maintain
eligibility for fall crops. Clearly there are still weather perils that
could destroy fall harvested crops and the SURE payment would be helpful.
So is it worth the risk to save a couple of $100 on large farm even if we
assume FSA makes decisions that are not favorable to farmers?
What is the optimal level and type of insurance
for winter wheat? This lack of information on SURE is also a
problem for farmers making winter wheat insurance decisions too. If buying
revenue insurance eliminates any SURE payments, some farmers may want to cut
their coverage level and save premium. Because there are still so many
unknowns and one will likely not have answers before September 30, the best
suggestion is to buy the level and type of crop insurance you planned to
buy on wheat without considering SURE. The one exception is farmers who
have been buying CAT insurance so they will be eligible for ad hoc disaster
with a 65% yield trigger. This is no longer a good strategy. Cat insured
farmers will have their SURE coverage based on 50% coverage at 55% of the
price. There is little effective coverage under either program, so those
farmers may want to consider buyup at the 65% or 70% level.
One complicating factor is farmers with high risk
ground who are allowed to insure at the CAT level and then purchase buyup
(65% for example) on the rest of their acres. One would assume those acres
would be based on CAT for the SURE program too. The reason those farmers
are buying CAT is that in some cases the premium rate can exceed 100%.
Don’t forget the pasture. Farmers will
need to pay NAP fees for pasture and hay to maintain eligibility for 2009
SURE. In many cases those fees are not due until December 1, so it is
possible that more information will be available on SURE rules. Farmers
should check with their FSA office for the final NAP payment dates on all of
their uninsurable “crops”. The NAP fee has been increased from $100 to $250
for 2009 crops.
Do base acres adjust SURE? I was asked
this question in a meeting and I agreed with the question but after more
reflection I don’t think that is correct. ACRE is only available on base
acres but SURE is available on all crops including crops that have no base.
In fact farmers are required to insure or pay NAP fees on all crops to be
eligible for SURE. So I think the correct answer is ACRE is only on base
acres, but SURE is on all acres, even for farmers with no base.
New entities? This farm bill creates
major incentives to create new entities. It would be a clear advantage if
one corporation or LLC was farming and another corporation or LLC was cash
renting pasture and hay. FSA will likely challenge new entities that are
created, therefore if ones cow herd is a small part of the operation it may
make sense to sell the cows and cash rent the pasture or sell the pasture.
One would also expect that Kansas Farmers my drop one
or more crops out of their rotation. This “free” SURE coverage is improved
with less diversification therefore, many Kansas farmers may drop dryland
grain sorghum out of their rotation and replace those acres with dryland
corn. Likely many Corn Belt farmers will drop wheat out of their rotation.
SURE may also cause farmers in low hail risk areas to
change from optional units to higher coverage enterprise crop insurance and
at the same time increase their SURE coverage. For example change from 75%
optional units to 80% enterprise unit under crop insurance and increase
their SURE revenue coverage to 80% also. If the farm has only one
enterprise, for example 100% wheat, then their crop insurance and SURE
coverage would have the same unit structure. One could then self insure for
hail or buy private hail insurance. Indemnity payments from private
insurance contracts do not count against the SURE guarantee.
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