Dodson said that while USDA's Risk Management Agency (RMA) has made some recent beneficial changes to crop insurance products, the U.S. cotton industry believes there are areas for improvement.

• RMA should continue to look for ways to move towards rate-setting procedures that recognize those investments a grower makes that reduce their individual risk such as improved irrigation practices and adoption of seed varieties that incorporate crop protection traits.

• Regarding RMA's proposed rule for Area Risk Protection Insurance, Dodson said cotton producers also are very supportive of the Federal Crop Insurance Corporation's (FCIC) efforts to expand the offering of area-wide insurance products covering revenue and yield losses. These will provide an important risk management tool. Producers also agreed with FCIC's decision to incorporate their own yield data, as well as other USDA sources – a move that should enhance the yield estimates' accuracy/reliability and ultimately program performance.

He expressed appreciation for RMA's efforts to improve the cotton quality loss adjustment provision, based on the Commodity Credit Corporation's Loan Premium and Discount schedule and said the industry is continuing to look at further enhancements in quality adjustments.

He urged the reauthorization in the new farm law of a pilot program aimed at encouraging producers to insure enterprise units — insuring all of their acres in a county under one policy. Many have been able to purchase higher coverage levels with lower premiums.

Dodson also talked about the cotton industry's new risk management program recommendation that would allow a producer to purchase a crop insurance product from their insurance agent that would sit on top of their current insurance — to address shallow revenue losses.

He said there are few options for producers who suffer from shallow losses, those up to 30 percent.

"As a producer, I understand the narrow margins we all are facing and 5 or 10 percent can make a huge difference to your operation's viability," Dodson stated.

"While this program would be an asset to cotton producers in all areas of the country, it would be especially important to young farmers as they work with their lenders."

He added that this program would best utilize budget resources; respond to public criticism by directing benefits to growers who suffer losses resulting from factors beyond their control, and build on existing crop insurance programs, thus ensuring there is no duplication and offering the potential for program simplification.