All farmers remember with deep sadness the damage caused by Hurricane Maria, after its passage through Puerto Rico on September 20, 2017. This Category 4 hurricane, bordering on Category 5, with sustained winds of 155 mph and gusts reaching 180 mph, according to NOAA exceeded $100 billion in damage in Puerto Rico alone. Of that $100 trillion, about $2 trillion was estimated losses in agriculture.
In response to these losses caused in agriculture by Hurricane Maria, the U.S. Congress authorized compensation under the Wildfire and Hurricane Indemnity Program (WHIP). This Ad Hoc Program replaced the Noninsured Crop Disaster Assistance Program (NAP) for this event. The WHIP was administered by the Farm Service Agency (FSA). FSA adopted the WHIP Manual (1-WHIP) for determining compensation for agricultural losses. This manual essentially lists the steps to be taken to approximate crop or crop losses, apply the prevailing price per crop or per tree, adjust any other compensation received, and set factors per crop harvested or for having had agricultural insurance. In the case of Puerto Rico, the 1-WHIP established special conditions, indicating that only the average harvest by county («county expected yield» or CEY), tree count («damage factor») and average prices per county would be used, instead of the historical one of each farmer.
The National Crop Table
FSA maintains a database on crops from across the United States, known as the National Crop Table (NCT). In the case of compensations for damages from Hurricane Maria, FSA used the 2017 NCT (See Appendix A). The content of the 2017 NCT includes: 1) county (FSA office); 2) cultivation; 3) crop code; 4) variety; 5) crop intended use; 6) practice (I=irrigated/N=non-irrigated); 7) unit of measurement; 8) equivalence in pounds; 9) average expected harvest per county (CEY); 10) expected average harvest after disaster by county (CDY); 11) percent CDY over CEY; 12) average price for cultivation by county; 13) unharvested factor. In some cases, as reflected in the NCT 2018 (See Appendix D), additional information is included such as: a) time between sowing and harvesting; (b) duration of cultivation in the field; (c) planting season; (d) harvest period; (e) planting distances; and (f) plant density per acre.
According to 1-WHIP, the CEY should reflect the average production potential for the county, based on practices and intended use (which can be fresh or brewed). These averages must adopt the acceptable sources of production set forth in the Non-Insurable Crop Disaster Assistance Program Manual (1-NAP). According to the 1-NAP, data may be obtained from entities such as the Department of Agriculture, knowledge of county committees, the National Agricultural Statistics Service (NASS), crop insurance, or other reliable sources such as universities. The 1-NAP also provides that an Olympic average will be used to estimate the data. This Olympic average consists of obtaining
the previous 5 years of production data, removing the highest and lowest, and averaging the remaining 3 (some exceptions apply). The 1-NAP
provides that to determine the price, the Olympic average will also be used. As for the CDY, 1-WHIP says it is defined as the average yield per acre per county in the year of the disaster, intended to reflect the output a participant would have had based on eligible disaster conditions. It will only be used when there is no other production data. The CDY will not be «0» unless no acre of the crop has been harvested in the county and all field ratings reflect «0». In case a participant has not insured, it was determined in 1-WHIP the application of a payment factor of 65%.
Based on information obtained through a Freedom of Information Act (FOIA); see Appendix B), the alleged source of data used by FSA to nourish the NCT is the Puerto Rico Agricultural Gross Income Report (IBA for its Spanish acronym) issued by the Division of Agricultural Statistics of the Puerto Rico Department of Agriculture (PRDA). When comparing the data provided in the NCT (See Appendix C) with the IBA report (Appendix B), the units of measurement are not the same. This prompted another FOIA request to learn what conversion factors FSA adopted (See Appendix E). Data found in the NCT for several select crops are explored below.
Citrus
The 2017 NCT (Appendix A) reflected data for oranges such as mandarins («MND»), Navel («NAV»), Valencia («VLN»), Creole («SWT») and lemons. Surprisingly, when comparing the NCT data (Appendix C) with the IBA report (Appendix B), the latter does not make distinctions by variety in the case of the Chinese ones. How is it then that FSA manages to arrange different prices between mandarins and Navel, Valencia, or Creole Oranges? In addition, the IBA report (Appendix B) measures in «thousands» the oranges, while the NCT, 2012-2017, (Appendix C) measures oranges in 45-pound boxes. On the other hand, in the conversion sheet provided by FSA (Appendix E, p. 13), the measure for oranges is based on 40-pound boxes.
For FSA, the average 45-pound boxes, produced by acre for oranges, is 137 boxes (6,165 lb. or 3,085 tons). This average remains the same since 2013. It’s unclear where that average of 6,165 pounds per acre comes from. The closest data seems to be one that refers to the average production of a 5-year-old orchard, since for that age corresponds the approximate production of 6,600 pounds per acre (Again, see Annex D, p. 13). However, the information itself in the hands of FSA (Appendix D) provides that a 7-year-old tree produces 56,075 fruits per acre (57,750 fruits per “cuerda”). In that case, the equivalence to pounds would be approximately 22,400 or 497 boxes of 45 pounds. Therefore, those farmers with citrus orchards older than 5 years, did not necessarily obtain a reasonable compensation, since everything seems to indicate that FSA arbitrarily determined that the average production per acre in Puerto Rico will be that of a 5-year citrus orchard, instead of obtaining the production averages taken in the field. How much additional money could orange growers (except mandarins) have received if the average production per acre had been adequately reflected in the production in the field instead of the 6,165 pounds adopted by FSA?
According to the IBA report (Appendix B) the prices of oranges have been as follows: in 2010, $73.84/thousand; in 2011, 83.87/thousand; in 2012, $85.15/thousand; in 2013, $89.97/thousand; in 2014, $97.85/thousand; in 2015, $88.84/thousand; in 2016, $148.17; and in 2017, $151.56. FSA says that the conversion factor (Appendix D) for oranges is that 1,000 fruits weigh 400 pounds: 2.5 fruits per pound. Therefore, a thousand equals 4 quintals or 8.88 boxes of 45 pounds. In the case of mandarins, 1,000 fruits equal 166 lb. or 3.68 boxes of 45 lbs. For its part, the NCT 2012 states that a box of 45 lb. had an average (Olympic) price of $7.75 (excluding mandarins). This equates to $68.82 per thousand. The 2013 NCT reflects a 45-pound per box of oranges with a price of $9.90, equivalent to $87.91 per thousand. The 2014NCT has $8.70 per box, equivalent to $77.26 per thousand. In 2015, 2016 and 2018, the average price was $10.14 per 45-pound box, equivalent to $90/thousand. In the year of the hurricane, 2017, the NCT reflected an average price of $10.06 per 45-pound box of oranges (except mandarins), equivalent to $89.33. This contrasts sharply with the price in the IBA report for 2017 of $151.56 per thousand. Following the Olympic average rule, if the 5-year data of the IBA report for oranges, prior to 2017 (2012-2016) are used, eliminating the highest and lowest value, the resulting average is $92.22/thousand fruits or $10.38/box of 45-pounds: $0.32 less for each box. Note that from the data of the 2017 NCT (Appendix A), taking into consideration that one pound of oranges consists of 2.5 fruits, the price per fruit is $0.09.
Based on FSA conversion factors (Appendix E, p. 13), in the case of lemons, 1,000 fruits equal 80 pounds: 12.5 fruits per pound. In the information made public by FSA, it appears that one acre of Tahiti limes produces 825 25-pound boxes or 20,625 pounds (458 45-pound boxes) This is for a 5-year-old lime/lemon orchard, according to FSA conversion data (Appendix E, p. 18). However, in the NCT, it appears that one acre of limes/lemons produces 92 boxes of 45 pounds; this equates to 4,140 pounds per acre. In the 2017 NCT (Appendix A) limes/lemons appear with a CDY of 32.2 with a percent compared to the CEY of 35%. Where did the remaining 128.1 boxes of 45 pounds of lemons go?
In the case of limes and lemons, between 2012 and 2014, there has been a substantial increase in the average price per box of 45 pounds, according to NCT (Appendix C) of $59.46 and $73.15 respectively; $96.75 from 2015 to 2018. As a thousand limes/lemons equals 80 pounds, it can be deduced that it also equals 1.77 boxes of 45 pounds. Therefore, the price per box of lemons in the NCT is equivalent to $105.24/thousand (2012), $139.48/thousand (2014), and $171.25/thousand (2015 to 2018). These numbers should be compared with the IBA report (Appendix B) which reflects: 2010, $143.48/thousand; 2011, $171.92/thousand; 2012, $92.34/thousand; 2013, $88.68/thousand; 2014, $93.32/thousand; 2015, $103.93/thousand; 2016 $143.25/thousand; and 2017, $151.92/thousand. If FSA has been using data from the Department of Agriculture, how is it possible that its Olympic averages are above the dataset numbers? Note that from the 2017 NCT data (Appendix A), considering that a pound of limes or lemons consists of 12.5 fruits, the average price per fruit on that date was $0.17.
Coffee (Arabica)
The IBA report
(Appendix B) reflects an average price per CWT of Arabica coffee of $297.39 for 2017. In fact, since 2010, coffee has never reflected a price lower than $230.51/CWT, according to the information provided in the IBA report (Appendix
B). The 2017 NCT reports an average price of $220.50. How is it possible that the Olympic average for coffee falls below the numbers from the data set? From the IBA report (Appendix B) it can be calculated that the average per acre in 2015 was 3.87 CET, in 2016, 3.46 CWT and in 2017, 4.46 CWT. However, the average production per FSA, since 2013, has remained between 3.17 and 3.18 CWT per acre, in the case of Arabica coffee. Does FSA consider the fact that the price of coffee is regulated by the Department of Consumer Affairs? Price Order No. 8578 dictates a price of $0.52 per pound of ripe Arabica coffee and $0.35 for green-ripe Arabica coffee to be paid to farmers. To obtain a CWT of dry-base coffee, the conversion (see Appendix E, p. 9) is 616 pounds. Therefore, the price per CWT of Arabica coffee should be between $320.32 for ripe coffee and $215.60 for green-ripe coffee. How does FSA get to set the average price for ripe and green-ripe at $220.50?
Onions
The average price for onions
listed in the IBA report (Appendix B) for 2010 is $27.20/CWT, while in 2011 it is $28.43/CWT. In 2012, the price of onion is $24.85/CWT; in 2013, $24.90/CWT; in 2014, $27.68/CWT. In 2015, the IBA report (Appendix B) averages the price at $29.66/CWT, while in 2016, it is $27.94 and in 2017, $29.30 per CWT. If you take the IBA (Appendix B) price data from the 5 years prior to 2017 to calculate the Olympic average, this turns out to be $26.84/quintal. For its part, the NCT, for the
years 2012 to 2018 (Appendix C) provides the following prices per CWT respectively: $20.18; $28.43; $22.95; $25.49; $25.49; $25.27; and $25.49.
In the case of production per acre, the NCT (Appendix C) maintains in a sustained yield since 2013 of 154 CWT per acre without irrigation and 206 CWT per acre with irrigation. This figure contrasts sharply with the 302 CWT/ “cuerda” of onion produced in 2015, the 121.79 CWT/ “cuerda” produced in 2016, and the 150 CWT/ “cuerda” produced in 2017, obtained from the IBA report (Appendix B). Per acre productions are not static. The PRDA makes no distinction between irrigated and non-irrigated acres. Where do the averages adopted by FSA come from?
Sweet Potatoes
The sweet potato prices reflected in the IBA report (Appendix B) are as follows: 2010, $52.99/CWT; 2011, $31.77/CWT; 2012, $39.52/CWT; 2013, $33.49/CWT; 2014, $48.65/quintal; 2015, $43.54/CWT; 2016, $60.11/CWT; 2017, $55.22/CWT. The data from the IBA report also reflect that the averages harvested per “cuerda” for 2015, 2016 and 2017 are 77.9 CWT, 55 CWT and 66 CWT respectively. Prices per CWT in the 2012-2018 NCT (Appendix C) dropped between $44.93 in 2012 and $40.03 in 2018, while the CEY ranges from 80 to 82 CWT/acre. If the Olympic average is applied, the price in 2017 should have been $43.90 instead of $37.27. On the other hand, FSA’s CEY for sweet potato appears to be above the average production per “cuerda” compiled by the Puerto Rico Department of Agriculture.
conclusion
Farmers should pay close attention to how FSA set up the NCT, as such data has a substantial effect on compensation for agricultural losses caused by atmospheric events. They must also request the Department of Agriculture to annually issue its Gross Agricultural Income (IBA) report, for FSA to count on updated numbers, since everything seems to indicate that there was a delay between for 2014 and 2017 data, which were not available until the occurrence of Hurricane Maria. Permanent programs such as NAP and Ad Hoc programs such as WHIP use NCT. If there are mistakes in crop data, and they are not corrected, it is possible that Puerto Rico farmers will not be adequately compensated in future instances in which they experience natural disasters. All farmers and agronomists are invited to take a close look at the data collected by the Department of Agriculture and the one adopted by FSA. If you find discrepancies, please submit your comments, to expand the analysis provided here.
NOTE: This document was originally written in June 2021, as part of an investigation developed by the author, but had not been published, since the author concentrated mainly on the cultivation of plantains and the effect of NCT in WHIP compensation. A full post on plantain cultivation is coming out soon. If you want to see data related to plantains, see the contents of Appendix F. If anyone wishes to compare the data here presented with the values adopted by the Puerto Rico Crop insurance, check Appendix G.

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