NCC Urges APH Adjustment Implementation

In a letter to Risk Management Agency Administrator Brandon Willis, the NCC urged the RMA to make every effort to implement for the '15 cotton crop the farm bill provision allowing a producer to adjust their APH insurance yield. The letter is based on an American Cotton Producers resolution subsequently approved by the NCC Board.

Published: September 12, 2014
Updated: September 12, 2014

September 11, 2014

Mr. Brandon Willis
Administrator, Risk Management Agency
United States Department of Agriculture
USDA/RMA/Stop 0801, Room 6092-South
1400 Independence Ave., SW
Washington, DC 20250

Dear Administrator Willis:

The National Cotton Council (NCC) would like to extend our appreciation for the efforts of you and your staff in implementing the Stacked Income Protection Plan (STAX) for the 2015 crop. Your staff has maintained an open dialogue with the NCC throughout the implementation process, and we believe that serves to enhance the product that will be an important risk management tool for cotton producers. STAX is the NCC's top priority among the new insurance provisions, and we remain impressed with the commitment and energy that RMA has devoted to this new product.

In addition, we are pleased that upland cotton farmers will have a choice between STAX and the Supplemental Coverage Option (SCO). Also, many of our producers will find the new provisions for enterprise unit coverage and coverage levels by practice to be beneficial in managing their risks.

The NCC also would like to convey our thanks to you for addressing the meeting of the American Cotton Producers (ACP) in Savannah in August. At the close of that meeting, the ACP discussed the importance of the new farm bill provision that will allow producers to adjust their Actual Production History (APH) yields. This provision is especially important for portions of the Cotton Belt who have recently incurred several years of historic drought conditions. The ACP subsequently approved and brought before the NCC Board a resolution urging RMA to make every effort to implement the APH adjustment for cotton for the 2015 crop. That resolution was adopted by the NCC Board, and this letter also conveys the industry's request that RMA move forward with that implementation for the 2015 cotton crop.

Thank you for consideration of this request. We understand the tremendous workload and calendar constraints that you and your staff face. Let me reiterate our appreciation for your continued good work.


Mark Lange
President and CEO