June 28, 1995 BULLETIN NO.: MGR-95-029 TO: All Reinsured Companies CFSA Texas State Office All Risk Management Field Offices FROM: Kenneth D. Ackerman Acting Deputy Administrator SUBJECT: 1995 Loss Adjustment Deviation Approval for South Texas Cotton BACKGROUND: Producers in South Texas are in the midst of a drought that has severely impacted agricultural production. Although most of the corn and grain sorghum will be carried to harvest, cotton acreage that has failed or partially failed may be better put to another use prior to harvest. Risk Management has reviewed conditions in four South Texas counties to assess the request that the Consolidated Farm Service Agency approve an immediate appraisal deviation for the 1995 crop year. In addition to the drought there has also been a dramatic increase in damaging insects this year, requiring additional applications of insecticide, and significantly raising the cost of continuing production. In a "normal" crop year, appraisals would be made via the stand reduction method until around July 15. The stand reduction method uses a plant count to determine potential production; however, this method would result in an appraisal far above the actual potential of this South Texas cotton crop. Although the cotton plants appear healthy in many of the fields, non-irrigated plants are shorter than usual and boll size and count on irrigated and non-irrigated cotton has been significantly reduced. ACTION: Effective immediately, insurance providers are authorized to use the boll count appraisal method for cotton in Cameron, Hidalgo, Starr, and Willacy Counties Texas. In recognition of the reduced boll size due to drought, green bolls will be counted at 500 per pound instead of the currently approved 250. Include: 1) only immature green and unopened bolls that will contribute to the ultimate yield at the time of harvest; and 2) only harvestable bolls that can be mechanically harvested by the intended method of harvesting, picker or stripper. Open bolls will be counted according to existing procedure. This deviation is effective for the 1995 crop year only. During the review of crop conditions in the four county area, several cotton fields were noted with heavy weed infestations in contrast to most of the acreage inspected. Producers who failed to care for their crop in accordance with the policy should be assessed for poor farming practices using approved procedures. Specific instructions for adjusters: 1. Verify that insurable causes have contributed totally to the reduced boll size and the reduced number of bolls to count. Otherwise, uninsured causes are to be applied. 2. Refer to this Bulletin number in the "Remarks" section of the appraisal worksheet for authorization to use this deviation. 3. Apply this deviation for appraisal from the effective date through the end of the crop year for the four counties. Insurance providers are reminded to exercise close supervisory controls over the application of this deviation. As a reminder, "drought" can not be the cause for reduced boll size and numbers to count when the cotton is irrigated.