Hybrid canola seed production is a process where seed companies contract with producers to plant and grow male and female parent plants which cross-pollinate to produce canola with specific and controlled traits. Hybrid canola seed has been grown in parts of Alberta, Saskatchewan, Washington and Idaho for the past 20 years and more recently in parts of Montana and North Dakota. Some 2013 estimates put the amount of U.S. acreage contracted at around 30,000 acres.
Section 8 (b) (5) in the Basic Provisions specifically states that canola grown for such purposes is not insurable except through written agreement:
(b) A crop which will NOT be insured will include, but will not be limited to, any crop: ***** (5) That is planted for the development or production of hybrid seed or for experimental purposes, unless permitted by the Crop Provisions or by written agreement to insure such crop;
Since hybrid canola seed has been determined to be a separate crop, Written Agreement Handbook Paragraphs 12 (3) and (4) apply:
(3) Requests for a WA will not be accepted for crops that do not have a policy for the crop.
(4) Requests for a WA will not be accepted when CP specifically prohibits WAs, or the WA would alter policy provisions not specifically designated for alteration by WA in the policy.
Additionally, while the Written Agreement Handbook technically allows a T/P written agreement for hybrid seed, T/P requirements make it unfeasible to approve a request for hybrid canola seed because there are no crop provisions or loss adjustment standards. Written Agreement Handbook Subparagraphs 84 C (1) (f) (i) and (iii) would apply:
(f) determine if all of the following conditions are met. If one or more of the conditions are not met, the request for a WA must be denied. The conditions that must be met are:
(i) quality adjustment, moisture adjustment or other special loss adjustment provisions can be applied consistently;
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(iii) all other policy terms are appropriate for insuring the unrated P/T and acreage;
Please circulate this memo to field offices as appropriate. If you have questions about insuring hybrid canola seed under a MPCI program, feel free to contact the Billings Regional Office by email at rsomt@rma.usda.gov or by telephone at 406-657-6447.
Cc: Tim Hoffman Pam Bollinger Bill Klein Bill Bing Topeka Regional Office St. Paul Regional Office Spokane Regional Office Northern Regional Compliance Office Montana, North Dakota and South Dakota State FSA Offices