Almond Assessment Increase Comment Period Reopened

Comment Period Reopened for Almond Assessment Increase Through October 12.

 

Julie Adams, vice president global, technical, and regulatory affairs with the Almond Board of California, commented in an exclusive interview with California Ag Today on the proposed additional one cent almond assessment increase from 3 cents to 4 cents a pound by the Board of Directors to use in marketing the anticipated crop increases over the next three years, starting this season.

The proposed rule change was first published in the Federal Register on July 18, 2016. The comment period was reopened on Sept. 12 with an announcement in the Federal Register. The comment period is open for 30 days, ending Oct. 12, 2016, at midnight, Pacific Standard Time (PST).

California Ag Today (CAT): Where do almond growers go to make comments about the increased almond assessment?

Adams: Growers can go to www. regulations.gov and search for almonds.

Click here for the direct link to the Assessment entitled, Almonds Grown in California: Increased Assessment Rate.

CAT: The first comment period in August was only two weeks. How long will this one last?almond assessment increase

Adams: The new comment period is now open and will be stay open until Oct. 12. We have also sent out notifications to handlers and we’ve included it in our communication to growers. 

CAT: Why did the comment period reopen?

Adams: Basically this discussion has been going on for quite some time, actually, and started with planning and strategic meetings within the production and environmental research committees. Some of this discussion also started back a year ago when we were talking about all of the challenges facing the industry related to environmental issues, water requirements, and sustainability issues. And then, of course, with the anticipated increase in crop size, what was that going to mean in terms of keeping demand growing ahead of supply?

Discussions at strategic planning meetings underway and within our global market development committees, started feeding up to the Board recommendations that we really needed to get ready both for the challenges facing growers as well as building that [market] demand. It was at that time that the Board started talking about an increase in the assessment for a specific period of time.

We recognized that crops were increasing, and to get us through this period, we really needed to accelerate our activities. The increased assessment was approved by the Board several months ago and was published in the Federal Register. It was, at that point, a two-week comment period. While there had been a lot of communication out to the industry, the comment notification had not been sent out in a timely fashion as it needed to be since it was such a short comment period.

Based on that, as you’ll see from the reopened comment period, USDA determined that they would go ahead and reopen the period for 30 additional days. That’s the process we’re in right now.

Almond Board of California CAT: One argument against the assessment is that the almond industry is heading into big record crop, and the 150,000 to 200,000 non-bearing acreage will soon be bearing—and that alone is sure to increase the Almond Board’s marketing budget.

Adams: It does. What we have found throughout our programs is that the more we can start building consumer awareness and demand for the product, it’s going to be ready as those crop sizes increase. We really want to be ahead of that supply situation so that we’re not trying to chase the opportunities in the market. We want to make sure there’s a strong foundation. As crops are more available, customers are ready to take in that product, really ready to put more on the shelf for consumers, and hopefully [meet] increased demand from consumers.

I think the other part of this assessment increase is about what’s happening on the production side. Research takes time and growers are facing more challenges now in terms of water availability, water quality, production issues, and environmental concerns. There’s more pressure on growers now than ever before. Part of this assessment increase for this three-year period is really to accelerate a lot of the research and work that’s underway on irrigation practices and harvesting practices, and to ramp up our food safety education. We’ve got the Food Safety Modernization Act (FSMA) coming on board now—a  requirement starting to put additional burdens on the industry.

With all of that happening, the concern is that we really need to get in front of all of this. The idea is to do that with some additional funding, so while we’re keeping up our ongoing programs, accelerating some of this research over the next three years will put us in a position, when we do come into those larger crops, where we will already have a lot of those programs in place and we will have accelerated the research so we can continue to meet a very demanding market.

California AlmondsCAT: We can see the need to increase our momentum in research and marketing. Of course, the vast majority of the Almond Board’s budget is for marketing right? Will the vast majority of this extra assessment go toward global marketing?

Adams: The global marketing demand portion of the budget is over 70%. That includes more than just market development. It includes a lot of consumer research, attitudes and awareness research It also includes a lot of the investment we’ve made lately on reputation management—how consumers really perceive almonds and how we need to best communicate back to consumers about what our industry is doing.

CAT: Obviously there is not going to be a vote on the added assessment. There is going to be a comment period, and if the USDA approves the assessment, it will go forward.

Adams: It was a unanimous recommendation coming forward from the Board of Directors and from a number of committees that included industry members that made recommendations to the Board of Directors. Obviously the Board is responding to the strategies and recommendations coming through the committee process. That’s what the Board unanimously endorsed and put forward in a recommendation to the Agricultural Marketing Service (AMS), and USDA. Now based on the comments that start to come forward through this period, then USDA will assess all of that and publish a final rule, a final determination, after the comment period closes.

CAT: If the added assessment is for this season, the USDA will have to turn it around very quickly?

Adams: They would. Obviously the USDA is monitoring this comment period and will respond to the comments and the issues expressed by individuals who are commenting on the rule. They will reflect their thinking as they come forward.

CAT: If there is a big mixture of No and Yes comments, is it possible that the comment period will stay open past the 30 days to get a consensus?

Adams: I think the USDA will look at the issues and the context of the comments. If the comments are more about clarifications and they feel what has been proposed will deal with those concerns or areas of focus, then they will look at that and make a determination. I really couldn’t say whether they would go forward with an additional comment period.

CAT: And the additional assessment will automatically sunset in crop year 2018/2019?

 Adams: Exactly, and it would go back to the current 3 cent assessment. Really nothing has to be done for that to happen and that’s why the industry put in that sunset period. The Board does not have to vote on it; there does not have to be any further consultation. It will automatically go back to the 3 cent assessment.


 

CULTIVATING COMMON GROUND: Almond Board on Assessment Increase

Almond Board’s Response on Assessment Increase

 

Editor’s note: We thank Mike Mason for his contribution to California Ag Today’s CULTIVATING COMMON GROUND, in response to the letter submitted by John Harris.

By Mike Mason, chairman of the Board of Directors, Almond Board of California

 

Over the history of this [almond] marketing order, assessments have risen and fallen to meet changing business conditions. This increase was voted on by the Board of Directors after much input from growers and handlers.  After the vote, the industry had an opportunity to weigh in again during a USDA-administered comment period.  They will get another chance during a second comment period.

Only after growers have had all of these opportunities to voice their opinions will the USDA make a final decision on the assessment.

The Almond Board of Directors welcomes your feedback and is available to discuss any questions you may have about the critical investments and justification for this assessment increase.

Below you will see a memo I sent to the industry, dated April 14 2016.  It covers why and how the assessment is needed and will be used.

Sincerely,

Mike Mason                                                                                                               


Mike Mason is a first generation almond farmer and partner of Supreme Almonds of California, a family owned and operated almond handling operation in Shafter. He is also the Chairman of the Board of Directors of the Almond Board of California.


CA Almond Board Header

 

 

 

 

 

 

 

To: Almond Handlers and Growers

From: Mike Mason, Chairman of the Board of Directors, and

Kent Stenderup, Vice Chairman of the Board of Directors

Re: Almond Board of California FY 16/17 Budget and Assessment Increase

Date: April 14, 2016

On April 12, the Board of Directors met to review the program and budget recommendations coming forward as a result of the extensive strategic planning efforts which have taken place over the past year.

The Board unanimously agreed to recommend a budget for FY 16/17 with an increase of the assessment from 3 cents per pound to 4 cents for a three year period. The increase is limited to three years due to the expectation that almond production will increase significantly during that time period thereby providing additional funding. This decision was made after extensive dialog among Board members as well as outreach between Board members and Handlers and Growers in the almond community.

There are three principal reasons the Board determined an assessment increase was needed. They are:

  1. 30% increase in production anticipated by 2020. This estimated 600 million pound increase needs to be planned for now, to invest in global demand prior to the production hitting the market.

This substantial volume increase is nearly as much as our largest market currently consumes, and is more than the consumption of our four largest export markets combined. This will require doing more of what has been working, as well as implementing innovative new marketing programs.

  1. Strain on agricultural resources has never been higher. Almonds are currently California’s highest value agricultural crop and soon will be its largest acreage crop. With this leadership comes responsibility. Additional investment will allow us to take a leadership role by investing in and accelerating research which will enable us to address concerns, such as:
    • our changing water supply and quality system,
    • air quality as it relates to harvesting, pesticide and energy use,
    • bee health, which is critical to our success
  2. Transformation of the consumer landscape. The environment in which we are growing and marketing almonds is quickly changing. Consumers are more interested in where and how their food is made. In response to this, the industry needs to take a leading role in the world of sustainable farming, as we have done for so long in the world of nutrition, by transparent communications regarding our meaningful and measured sustainable improvements.

To plan for and address these challenges, your Board of Directors has worked across the Environmental, Production Research, Almond Quality, Technical and Regulatory, and Global Market Development Committees to develop a plan of action. This plan is a two pronged approach including investment in research, via the Accelerated Innovation Management or AIM program (launched at our annual conference), and global marketing:

  • AIM Program: Expand and Accelerate sustainability and production research in 9 areas:
  1. Irrigation and nutrient management
  2. Orchard and rootstock development
  3. Harvesting innovations
  4. Pest management tool development
  5. Pollination research and management practices
  6. Bio-mass and by-product innovation
  7. Food safety leadership
  8. Soil health research
  9. Energy Innovation
  • Global Marketing: Expand our programs to address production growth & changing consumer needs by:
  1. Accelerating programs and results in current markets
  2. Considering additional markets for investment
  3. Increasing communication transparency and trust
  4. Ensuring confidence in our sustainability efforts

Your Board of Directors welcomes your feedback and is available to discuss questions you may have about the critical investments and justification for this assessment increase. The assessment increase will be reviewed by the USDA and an opportunity for public comment will be provided before any change is implemented.

 

1150 Ninth St., Ste. 1500  *  Modesto, CA  95354  USA

T: +1.209.549.8262  *  F: +1.209.549.8267


To read the original post to which the Almond Board is responding, go to: CULTIVATING COMMON GROUND: Almond Growers on Assessment Increase, by John Harris.


The opinions, beliefs and viewpoints expressed by the various participants on CaliforniaAgToday.com do not necessarily reflect the opinions, beliefs, viewpoints or official policies of the California Ag Today, Inc.

CULTIVATING COMMON GROUND: Almond Growers on Assessment Increase

Almond Growers Want Justification and Vote on Almond Board’s Assessment Increase

 

Editor’s note: We thank John Harris for his contribution to California Ag Today’s CULTIVATING COMMON GROUND. The Almond Board’s Response can be read at Almond Board’s Response on Assessment Increase.

By John Harris, owner, Harris Ranch

 

Marketing orders give agriculture a great tool to collect fees from producers to promote products and/or conduct research projects.  The concept is great, and increasing demand is always good. To be successful, the plan needs to be affordable and explained so it is understood and backed by a big majority of the producers.  I am concerned the Almond Board’s recent assessment increase from 3 to 4 cents a pound—in the absence of an almond producer vote—is unwise.

Harris Farms Fresh LogoAt the current rate of 3 cents per pound, money raised will increase as production increases, which seem fairly certain.  Plus, the fund receives significant help from a government program to encourage exports.  A year or so ago, almond growers were doing really well, when many sales were exceeded $4 a pound.  But last fall prices dropped significantly, in some cases to the $2 range. This loss in revenue made it tougher for almond growers to break even. A grower producing 2,500 pounds per acre is now paying $75 per acre in assessments; under the new plan it would increase to $100 per acre.

To get feedback from growers, the USDA published a request for comments. The comment period opened on July 18 and closed on August 2. But the industry was not notified until July 27. I commented at the time that I was not in favor of the assessment without full knowledge of the purpose of the extra money. I am certain many growers have an opinion on this, but only five comments were submitted. I think most growers did not realize both the assessment increase was under discussion and a producer vote would not be forthcoming.

The time frame for comments was alarmingly short; however, the USDA has decided to reopen the comment period for 10 days.  The reopening of the comment period is expected to be announced within the next two weeks and will be communicated immediately to the industry once it is published in the Federal Register.

I urge all producers to take a good look at the proposal and voice your opinions.

This link will take you to the almond assessment comment page: https://www.regulations.gov/docket?D=AMS-SC-16-0045.

There should be more of a democratic process. I think this proposed assessment increase needs to go to a vote among the growers affected by it and should require strong approval by at least 51 percent of the growers representing 60 percent of the production. We don’t want to micromanage the Board’s process, but large changes like this assessment increase should demand some form of referendum.

I also think everyone would like to know how the millions of extra dollars collected would be used.

And, of course I think the industry deserves more awareness of this proposed increase in assessment. I do not hear people talking about it; many growers may not even learn about the extra assessment until they get their check from their handler next year. I think all almond growers need to know this is happening now and not be surprised next year.

If I asked my boss for a 33% raise, I believe the onus would be on me to sell the idea and win support, rather than just push it through providing little information to the guy who would be paying me.

If the Almond Board is increasing their budget by 33%, shouldn’t the burden be placed on the Board to win the support of growers?  I would think they would communicate a clear plan on how to spend the enormous increase—a strong and strategic plan—they would be eager and proud to share with growers and handlers.

To increase any tax/assessment, the logical thought process should be, “No, unless proven to be needed, supported, and affordable,” instead of defaulting to, “Increase the tax unless we get stopped.”


The Almond Board’s Response can be read at Almond Board’s Response on Assessment Increase.


Harris Ranch and Allied Companies


The Harris Family’s commitment to agriculture spans over 100 years, four generations, and four states, from Mississippi, to Texas, to Arizona, and eventually into California.

J. A. Harris and his wife, Kate, arrived in California’s Imperial Valley in 1916 to start one of California’s first cotton gins and cotton seed oil mills. They later moved to the San Joaquin Valley and began farming there.

In 1937, their only son, Jack, and his wife Teresa, began what is now known as Harris Ranch, starting with a previously unfarmed 320 acres of desert land on the Valley’s Western edge. With vision and determination, Harris Ranch has grown into the most integrated, diversified, and one of the largest agribusinesses in the United States.

Beginning with cotton and grain, Harris Ranch now produces over thirty-three crops annually, including lettuce, tomatoes, garlic, onions, melons, oranges, lemons, almonds, pistachios, walnuts and winegrapes, all backed by their commitment to superior quality and satisfaction. Harris Farms thoroughbreds are raised and trained to compete internationally. Harris Feeding Company, California’s largest cattle raising operation, and Harris Ranch Beef Company produce and market a premium line of packaged and fully-cooked beef products, including Harris Ranch Restaurant Reserve™ beef. All Harris products are served and sold at the internationally acclaimed Harris Ranch Restaurant and Inn.


The opinions, beliefs and viewpoints expressed by the various participants on CaliforniaAgToday.com do not necessarily reflect the opinions, beliefs, viewpoints or official policies of the California Ag Today, Inc.