Comment on FR Doc # 2011-17781

Please see attached file for full comments, which exceed the 2000 character limit of this space. Below are highlights. I do not support non-AIP affiliated individuals or entities (FSA?) be allowed sell this product, should my interpretation of the proposed rule be correct. The (Burden Statement) requirement to submit production information removes one of the advantages of GRP (at least for my clients with GRP Forage Production)...simplification! While it may improve the accuracy of the program, it adds an undue and unprecedented burden on the insured and agent. This entails more work for the agent and at only about half of the A&O for an APH crop. The penalty for not reporting yields is excessive and unjust (the insured's trigger yield is changed to the expected county yield). Isn't the intent of collecting production for program integrity, not an individual's insurability? If such data is needed for ARPI program integrity, then it may indicate the ARPI coverage should not be offered (Note: per the 10/1/10 Summary of Business, GRP/GRIP only accounted for 5.38% of total liability of all coverage plans)! If this data is indeed needed for program integrity and improvement, then make it voluntary and without penalties. Like NASS surveys, the request for yield data should come from directly from RMA or NASS for each policy holder. Also, isn't RMA already collecting enough info for most crops via an APH/YP/RP policy that the need for ARPI yield data should be minimal, or in fact unnecessary? If RMA is not collecting enough yield data via non-ARPI crop coverage, then improvements first need to be made for those crops via the non-ARPI plans noted. ARPI is not being purchased by my clients as an effective and reliable risk management plan. Only .06% of our total premium is generated from ARPI type coverage. Greg Wheelock, owner/agent Crop Insurance Services (An equal opportunity provider) 1230 South Victory Drive, Mankato, MN 56001-5308