NAWG submitted comments this week addressing a number of concerns with a pending interim final rule on 2008 Farm Bill program payment limits and eligibility requirements.
The rule was released in late 2008 including a number of discretionary changes that went beyond the intent of Congress. Though USDA has said the rule’s provisions will be applied for the 2009 crop year, NAWG recommended a number of changes for 2010 crop years and beyond.
Comments touched on actively engaged qualifications, spousal qualifications, adjusted gross income (AGI) certification procedures and confidentiality. Major NAWG recommendations included:
• removing requirements of “separate and distinct” and “identifiable and documentable” contributions to farm activity for the purposes of determining active engagement. These requirements go beyond what was required by the 2008 Farm Bill and would be overly onerous on farm operations.
• formalizing a previous clarification that the spouse of an actively engaged producer is considered actively engaged for payment eligibility purposes regardless of operation structure.
• reevaluating some intrusive questions on sign-up forms relating to land rental rates and capital sources.
• clarifying options for certifying compliance with AGI limits.
The comments also addressed financing arrangements, application timing, incomplete enrollments and landowner paperwork burdens.
Calling the timing associated with the rule “less than ideal,” the comments also addressed the fact that because the rule was issued so late in 2008, producers will almost certainly be required to comply with three different sets of rules for the 2008, 2009 and 2010 crop years.
Growers are also encouraged to submit individual comments or experiences signing up for 2008 Farm Bill programs before the commenting deadline of April 6.
To read NAWG’s full comments and learn how to comment individually, please visit www.wheatworld.org/issues/farmpolicy