Comment Text:
I support the implementation of the increase in base storage rates due to the lack of convergence in the markets.
Implementing a VSR program would be the solution to the lack of convergence. We should lok at the possibility of a hybrid approach to the VSR program that would have an observation period each year rather than each delivery period. A review period every three years would not be sufficient enough to keep up with the changes in the market year on year. Given the S&D report today it appears that we will not see convergence in the 2018/2019 crop year and we should be able to react to such changes on an annual basis. However, we would want to be able to back off if we see an increase in demand that would warrant a reduction in storage rates the following year.
We need to find a solution to create convergence in an ever changing market.
