Comment Text:
I support the evaluation of storage costs and the attempt to address non-convergence, but the timing involved with the evaluation of storage and the extended delay in implementation may not truly address the issue. A more dynamic approach via an annual review process would be a better alternative. This would let conditions at the time determine the appropriate rate and support convergence. The lack of convergence is a key industry issue that needs to be addressed in a more dynamic manner. As a producer, non-convergence has the potential to reduce crop indemnity payments because they are based off of futures prices.
