Programs Submission Response: ARC/PLC

ARC-CO physical vs. admin county provisions are limited to 2014 & 2015.

If we have a payment system that can calculate a 14 and 15 payment based on physical location—why would producers be forced to change their administrative county to receive this payment for 16 and further years? Previously those producers have chosen an administrative office based on their residences and trade areas. Now we are forcing them to choose between administrative offices that provide convenience or that provide more relevant coverage benefits.  

Can the option to request benefits be based on physical county versus admin county be available each year of the program?

There are other programs that have eligibility based on physical county without changing the admin county (CREP is an example). Additionally, this would likely only affect a small number of farms.

Administrative county waivers are for 2014 and 2015 only. Because the regulation was crafted using administrative county as the source of revenue loss at the beginning of the farm bill, DAFP pursued the physically located waiver for 2014 and 2015 but could not change from the administrative county position. Base reallocation, yield updates, and election decisions were made with the knowledge that revenue losses were based on an administrative county.