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Comment for Industry Filing 18-001

  • From: Nick Fitzgerald
    Organization(s):
    Advance Trading Inc

    Comment No: 61723
    Date: 8/10/2018

    Comment Text:

    I do agree with implementing an increase in base storage rates (if not going the VSR route), however feel there needs to be a review period as many have mentioned on this comment list. There has been a lack of convergence as everyone knows, especially in soybeans this year--and whose to say corn isn't next 5 years from now? Lack of convergence has challenged producers & country elevators over the past several years, and the bottom line is the market place has to have cash convergence to work. Grain storage has been inefficient vs. cheap cash and also that same cheap cash could penalize the producer as his crop insurance indemnity assumes a converging market (could result in a lower indemnity because of the amt. of non convergence)! After waiting 3 years for a change to storage rates, something proactive has to be in place bi-yearly or at least yearly as a review on top of the fixed rate increase for the market to stay elastic and to improve the ability for corn/soybeans to converge. I am concerned that only having the fixed increase on its own does not offer the flexibility to adjust to the ever changing environment in world ag supply/demand dynamics.

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