Source: RURAL COALITION submitted to NRP
IT`S OUR FARM BILL: LET`S USE IT
Sponsoring Institution
National Institute of Food and Agriculture
Project Status
COMPLETE
Funding Source
Reporting Frequency
Annual
Accession No.
0219166
Grant No.
2009-39300-19986
Cumulative Award Amt.
$299,258.00
Proposal No.
2009-00741
Multistate No.
(N/A)
Project Start Date
Sep 1, 2009
Project End Date
Aug 31, 2012
Grant Year
2009
Program Code
[2501]- Outreach for Disadvantaged Farmers & Ranchers (OASDFR)
Recipient Organization
RURAL COALITION
1029 Vermont Ave, NW
WASHINGTON,DC 20005
Performing Department
(N/A)
Non Technical Summary
This project builds upon what RC and its partners have learned in our prior CSREES and USDA Risk Management Agency projects. In these, we have developed tools and training protocols to assist producers in maintaining adequate financial and other records and in obtaining the certifications they need to access new markets. Our member groups have shared with us that even the simple tools we have prepared are still complex to the producers whom our member groups serve. But they also felt that producers would be more willing to share information and complete training if they first could envision and benefit from the development of new markets. We also have prepared and continue to use tools to prepare for disasters, to access conservation programs, and to participate in the census of agriculture. These tools can be utilized a in each participating community to assure producers are well prepared and have the capacity to secure eligibility to new farm bill programs and services. We will share results. For example, we anticipate this project will increase the ability of SDFRs to benefit from the more than $400 million set aside in the EQIP program for SDFRsand Beginning Farmers and Ranchers.
Animal Health Component
100%
Research Effort Categories
Basic
(N/A)
Applied
100%
Developmental
(N/A)
Classification

Knowledge Area (KA)Subject of Investigation (SOI)Field of Science (FOS)Percent
60160303030100%
Goals / Objectives
The Rural Coalition and members the Farm and Food Policy Diversity Initiative secured more than 30 sections in the 2008 Farm Bill that address past inequities and provide new resources to serve the diverse group of socially disadvantaged farmers and ranchers (SDFRs). We will now provide information, outreach and technical assistance to groups in 10 states over a three-year period to assure SDFRs secure access to these new benefits. Activities, events and products are as follows: 1) Develop and disseminate outreach and informational tools on these programs to partners. We will collaborate with diverse participants to produce informational packages that address program needs from multiple regions. 2) Present 5 Farm Bill Program implementation workshops annually at events held by partners to keep producers apprised of farm bill opportunities and progress, reaching 1000 producers in each of 3 years. 3) Develop a team of 50-60 producers in five to six locations to test and identify and build capacity to access farm program opportunities and barriers. The producers will share in development of training programs and tools to assure farmers and ranchers are prepared to participate, and access programs. A core team of approximately 10 trainers, selected from each participating stakeholder group, will receive detailed training on each program. Once the trainer becomesproficient, he/she will be responsible for training an additional 10 producers to access USDA programs. They will be trained to utilize census, transparency and accountability data to assess access to programs in their counties and states. Findings will be reported to USDA. 4) Conduct in-depth information and feedback sessions annually over three years in each location, with special focus on conservation, specialty crops, energy et al. 5) Host a Farm Bill Implementation Network and Web Center "Its Our Farm Bill," to assist the producers in the non-program specialty crop sector with focus on new programs and a method for them to share their experiences in accessing programs, and identifying opportunities and their problems. By upgrading our communications technology, we can provide updates on new programs, status of implementation whereby farmers can share their experiences. There will be a quarterly video conference and a monthly call in the out months, tailored to the needs of the SDFRs. The website will include Feedback Central - which will allow producers to provide, share and receive immediate feedback on what is and/or is not working well, if producers are accessing programs, etc., whether program design and /or delivery is working. We will hire a website developer. The website will include: (a) articles on program requirements and prerequisites, (b) programs participation challenges, (c)success in program participation, (d) data revealing increases in program participation, and (e) articles and tips on successful marketing strategies. 5) Project leaders from each location will convene for an annual knowledge sharing institute to share ideas and tools developed and to track progress.
Project Methods
This new project grows directly from the Rural Coalition's recent work with and data collected from socially disadvantaged farmers and ranchers. The activities under this project focusing on analysis, evaluation and interpretation will include the following: Forming a project team with staff of partner groups and with them designing evaluation tools to be completed by participating organizations and producers at the beginning and end of the grant period; Hold farm bill workshops in up to six participating communities each year; Track progress and develop materials to address problems; Using the annual knowledge sharing institute at University of the District of Columbia to track progress and discuss in depth all the issues that arise, focusing on the collective findings on accessibility of new farm programs, During quarterly video conferences at UDC, engage our communities and extension professionals and to review progress with implementation and access in each priority area of USDA programs; Use information shared by producers in communities and at the website to document successes and challenges in accessing programs, and analyze transparency and accountability findings from USDA as directed under section 14006 of the 2008 Farm Bill. Track participation rates to the county level and work in the field site to analyze results. Report at least annually to USDA on the findings. Develop and regularly update the website as a central information source on farm bill programs and an analysis of accessibility in various regions, Develop a network to provide a regular flow of information to producers and hold calls as needed and to revised training materials and disseminate results to member groups of the Rural Coalition working with small and socially disadvantaged farmers. Community trainings will emphasize a horizontal learning process with teachers and students learning from one another. The trainers, who are also farmers, consciously value the knowledge and experience of the farmers, and create a level of trust within the learning community. The train-the-trainers model of data collection and analysis turns socially disadvantaged farmers into active participants in a shared learning process rather than passive bystanders. By the end of the project, those trained should have the capacity to use county level participation data to establish goals for their outreach work, to track progress, and to identify and solve problems with access to USDA. Training and self-evaluation will be an empowering process, designed to help the participants identify their own reality and also imagine that reality's untapped possibilities. By valuing the knowledge and experience of participants and engaging them in the educational process, participants become empowered to independently seek and undertake new activities. These same popular education techniques will be used to develop the components of marketing materials and package development curriculum. Focusing on farmers aged 18-40 will likely introduce new perspectives to the product development and marketing plans.

Progress 09/01/09 to 08/31/12

Outputs
Target Audience:Target audiences included African American, Latino, Asian American, American Indian and other producers in all participating states. Audiences also included USDA leaders in those states, who were able to better meet the needs of their colleagues. Other audiences included our CBO and Extension partners with whom we communicated at many workshops. Changes/Problems: Nothing Reported What opportunities for training and professional development has the project provided?The partner organizations engaged in training and professional development through collaboration, utilizing existing networks and the expertise of agricultural producers and organizational liaisons to begin identifying and assessing the experiences and needs of socially disadvantaged producers with USDA programs, as well as innovative solutions for addressing myriad challenges associated with these issues. The research team and other project partners led in organizing and scheduling focus group meetings, disseminating written questionnaires to meeting participants, facilitating focus group discussions, and documenting discussions and activities associated with a mentor farm workshop, collaborative interagency meetings, and related organizational forums. The Institute faculty/staff are social scientists with a variety of qualitative and quantitative research experiences focusing on agriculture and rural communities.The partner organizations with which the research team worked included: the Mississippi Sustainable Agriculture Working Group (MS SAWG) and Delta Fresh Foods (Shelby, MS), Indian Springs Farmers Association (Petal, MS), the Oklahoma Black Historical Research Project, Inc. (Oklahoma City, OK), Hampton County Young Farmers Association (Hampton, SC), Florence Small Farmers Association (Florence, SC), Accokeek Foundation and partner farms (Accokeek, Maryland), an interagency collaboration of federal farm/rural program and university representatives (Annapolis and the Eastern Shore of MD), and several additional partners of the Rural Coalition at its 2011 summer National Rural Gathering (Shawnee, OK) and Winter Forum in Washington, D.C. How have the results been disseminated to communities of interest? National Rural Gathering Results were presented at the June 2011 National Rural Gathering was held in Shawnee, Oklahoma, with approximately 250 attendees (including males and females from several racial/ethnic groups). Much of the event involved activities for the Innovative Solutions project. Beyond general meeting discussions, a role-playing exercise at the Rural Coalition's National Rural Gathering involved diverse farm operators, farmworkers, organizational leaders, and U.S. Department of Agriculture staff. Together, they developed and performed a skit critiquing the traditional practices and structures resulting in socially disadvantaged producers being underserved. The actors followed this with a skit portraying a "new day" at the USDA where people are treated with respect and dignity. Using this as a framework, they identified immediate changes that could be made for the agency to better serve diverse producers. These involved language and interpretation, days/hours of operation, and support for new and innovative enterprises. Many of these issues were discussed again at the Rural Coalition's Winter Forum held in Washington, DC, during December 2011. Results from the Innovative Solutions project were shared, and this was followed by a general discussion of strategies for improving outreach and services for socially disadvantaged producers. Of the more than 70 participants in the meeting, there were farmers, ranchers, farm workers, organizational leaders, and USDA agency representatives. What do you plan to do during the next reporting period to accomplish the goals? Nothing Reported

Impacts
What was accomplished under these goals? Project activities utilized a community-based research framework to collaboratively collect and analyze data with people at the grassroots level, as a catalyst for broader social change (see: Chambers 2009; Pretty 1995; Reason and Bradbury 2001; Selener 1997; Stoecker 2005; Stringer 2007). At least one partner organization sponsored or co-sponsored each focus group meeting. The overriding purpose of the focus group meetings for this project was to obtain information regarding people's experiences with accessing and receiving services through USDA farm programs. Additional community-based activities involved a mentor farm workshop and farmer training session, interagency meetings and related individual interviews, additional inter- organizational collaboration at the National Rural Gathering and Winter Forum, and producer needs assessments. Mentor farm workshops and related farmer training activities for beginning and existing farmers served as hands-on learning opportunities for understanding different ways a farmer can be a successful producer and steward of the land. Interagency meetings and related forums and interviews with public sector stakeholder groups and community-based organizations have also been valuable for building collaboration between programs and organizations, as well as for increasing their understanding of the needs of disadvantaged producers and building agency capacity for addressing these needs. Ongoing updates from this project were shared and discussed at the National Rural Gathering and Winter Forum. Focus Group Results Six focus group meetings were conducted from February to August 2011 and included a total of 77 adult participants (18 years of age or more). They included 48 male and 29 female participants, and represented white and minority racial/ethnic groups; a majority of the participants self-identified as Black/African American. The meetings were held in the communities of Shelby and Petal, Mississippi (with participants from Coahoma, Bolivar, and Forrest Counties), Oklahoma City, Oklahoma (with participants from Caddo and Okfuskee Counties), Hampton and Florence, South Carolina (with participants from Hampton and Florence County, respectively), and in Accokeek, Maryland (with participants from Charles County) (see Table 3). Mentor Farm Workshop and Farmer Training As an innovative activity for knowledge-sharing and training for beginning farmers, a mentor farm workshop hosted by the Accokeek Farm was conducted in April 2011. There were 45 people in attendance. Participants discussed several mentor models utilized to promote sustainable production, one of which is CRAFT (Collaborative Regional Alliance for Farmer Training). The Chesapeake CRAFT program coordinates and facilitates learning opportunities for farm apprentices, interns, and workers in Virginia and Maryland (see: Accokeek Foundation 2011). Other useful mentoring programs discussed were cooperatives, popular education approaches, demonstration projects, apprenticeships, and land trust and tenure models. Meeting participants discussed the benefits and challenges of mentor farm programs. They viewed these programs as important for nurturing relationships, empowering farmers and consumers, building community, promoting economic and environmental sustainability, creating jobs, developing opportunities for future generations of farmers, and developing appropriate farm policy at all levels. As one presenter noted in regard to learning from the mentoring process, "People usually start growing the stuff they like to eat; then they start to grow what other people want." The mentoring models were also viewed as excellent tools for capacity- development, knowledge-transfer, diversity-awareness, transforming the farm and food system, promoting nutrition and health, and supporting the long-term survival of small-scale sustainable producers. Participants discussed challenges associated with land loss due to urban growth, land fertility, global and corporate farm competition, institutionalized racism, social backlash from some people in the community, and federal farm programs excluding mentor farm needs and access. Details from this mentor farm workshop are outlined in Appendix Table 11. An additional forum for discussing innovative programs and goals was a farmer training session and coordination meeting involving fourteen community-based organizations and representatives from government agencies held in December 2011 in Baltimore, Maryland. Several of these groups are involved in new farmer training, education, and support activities, such as immigrant farming initiatives, internship/apprenticeship programs, incubator programs, farm-to-school programs, sustainable and organic farming, university-based technical assistance programs, and "connectivity" efforts linking other issues and groups to agriculture (e.g. land access, zoning, veterans, ex-offenders). Interagency and Stakeholder Meetings and Interviews One of the primary areas of focus for the Innovative Solutions project was to gather input from agency partners and other stakeholder groups and organizations involved with and advocating for disadvantaged producers, on exclusions to farm programs and on innovative solutions for addressing these exclusions and related programmatic deficiencies. At least four of these collaborative meetings were held during 2010-2011 in the Maryland/Virginia region. At these gatherings, Rural Coalition staff and partner organizations reported on farmer activities and research conducted to date, while agency staff provided feedback on the research and updates on their programs. Agencies frequently represented have included USDA in general, the National Agricultural Statistics Service (NASS), Farm Service Agency (FSA), Animal and Plant Health Inspection Service (APHIS), Rural Development, and regional universities involved in agricultural education and programs. The collaborative group has been commonly referred to as the "Maryland MOU" group (Maryland Memorandum of Understanding). Producer Needs Assessments Additional input from producers was sought through ten interviews conducted by project partner organizations. Participants were asked to interview producers with varying levels of interaction with USDA. Basic information about their farm operation was collected, as well as descriptions of their experiences with USDA and other organizations in regard to marketing, programs and services, and interactions with staff.

Publications

  • Type: Conference Papers and Presentations Status: Accepted Year Published: 2012 Citation: Exploring Innovative Solutions to Root Causes of USDA Exclusions: Analysis from an Action Research Initiative A Working Paper prepared by the Institute for Community Based Research Anna M. Kleiner, Southeastern Louisiana University John J. Green, The University of Mississippi Lynn C. Woo, The University of Mississippi with Lorette Picciano, Tracy McCurty, Angela Adrar, Bryn Bird, Elliot Meador, and Thomas Moncrief in partnership with the Delta State University Center for Community and Economic Development on behalf of the Rural Coalition/Coalici�n Rural and the individuals and organizations involved in the project Innovative Solutions to Root Causes of USDA Exclusions
  • Type: Journal Articles Status: Published Year Published: 2012 Citation: Green, J. 2012. Who Counts Reality and Why it Counts: Searching for a Community-Based Approach to Quantitative Inquiry. Journal of Rural Social Sciences 27(2):137-149. http://journalofruralsocialsciences.org/pages/TOCs/JRSS%20vol27-2.htm
  • Type: Websites Status: Published Year Published: 2010 Citation: Rural Coalition/Coalici�n Rural and Federation of Southern Cooperatives/Land Assistance Fund. 2010. A Time to Change: A Report by the Assessment Conversations Team (ACT Report). Authors.
  • Type: Journal Articles Status: Published Year Published: 2015 Citation: Picciano, L. 2015. Critical Needs of Small Farmers and Ranchers. Small Farm Digest 17(Fall): 3-8.


Progress 09/01/10 to 08/31/11

Outputs
OUTPUTS: *Project team formed with staff of partner groups. *Farm Bill Web Center Developed. *"Seat at the Table" and other informational materials developed, including a flyer on how to sign up at Farm Service Agency (in Spanish also). *Materials tested at January 2010 2-day workshop at Epes, AL Annual Project Meetings held on Dec. 2009 with 60 people, Dec. 2010 with 120 people and June 2011 with 250, including 70 youth leaders. Social media was added in 2011. *More than 2500 people have been reached in education and training events in the first 2 years PARTICIPANTS: The Rural Coalition conducted this project in partnership with its members, including Rural Advancement Fund (SC), Operation Spring Plant (NC), Oklahoma Black Historical Research Project (OK), Land Loss Prevention Project (NC), National Hmong American Farmers, Inc. (CA), National Latino Farmers and Ranchers Trade Association (DC) and others to provide information, outreach and technical assistance to socially disadvantaged producers in each respective State over a three-year period, with a focus on critical needs and skills such as accessing credit, conservation and risk management. RC, its staff, and its partners also worked to assure the voice of the producers represented were heard as USDA developed its response to the Farm Bill Debate for 2012. TARGET AUDIENCES: Target audiences included American Indian, African American, Asian American and Latino Farmers and Ranchers, and farmworkers becoming farmers. PROJECT MODIFICATIONS: There were no major changes to the project.

Impacts
*More than 60 Farm and Ranch Team increased their knowledge on the Farm Bill. *Team members and project partners contributed their wisdom to the completion of numerous sets of comments on USDA regulations. *More than 100 producers learned about FSA for the first time. *USDA was made more aware of the specific concerns, needs and ideas of socially disadvantaged producers in the comments prepared. *More than 1000 people increased their awareness of federal farm program resources for socially disadvantaged producers and farmworkers in workshops and dialogue held. * Working relationships were built or enhanced with USDA leaders in at least 7 states, and the mutual knowledge of how to best match producer needs with USDA programs was increased, resulting in greater trust and program participation. *More than 60 Farm and Ranch Team members participated in events and conference calls, and began using new farm bill tools, with at least 40 farmers in participating groups being accepted for high tunnels and other practives. The team members contributed their wisdom to the completion of numerous sets of comments on USDA regulations. *More than 100 producers signed up at FSA for the first time. *USDA-NRCS approved high tunnels as a conservation practice and many socially disadvantaged producers learned how to apply for, adopt and use this practice, with 4500 High tunnels funded by USDA through late 2011. *USDA was made more aware of the specific concerns, needs and ideas of socially disadvantaged producers in the comments prepared. More sociallly disadvantaged producers are going to USDA offices, with better results in most, but not all places. USDA programs still do not match the needs of diverse producers of specialty crop and livestock, and risk protection needs improvement. However, where programs do match needs, participation and capacity to participate is increasing. There are many more areas that need attention to meet producers needs, but progress is being made.

Publications

  • *"Seat at the Table" published in 2010, *Act Report Published in Late 2009 Other informational materials developed, including a flyer on how to sign up at Farm Service Agency (in Spanish also).


Progress 09/01/09 to 08/31/10

Outputs
OUTPUTS: Objective One: Farm Bill Program Implementation Workshops: Project team formed consisting of 10 leaders from our partner organizations and conducted and made presentations in 30 workshops, including more than 700 people, designed to inform farmers themselves and those who train them about what is in the farm bill, the status of the program and policy implementation, how they can get involved, and what they need to do to use these programs. A report and power point presentation with summary of provisions for more than 30 provisions for socially disadvantaged and beginning farmers in the farm bill were widely circulated with educational materials that were shared during these meetings, over half held in partnership with organizations serving socially disadvantaged producers. In our January 2010 workshop in Epes, Alabama, our 2-hour presentation turned into a one and a half day intensive dialogue and training session for farmers, trainers and USDA staff with review of regulations and other policies in order to ensure all parties had common information and understanding of the content of the provisions as implemented. Project leaders participated in our annual knowledge-sharing institute in December 2009 where training materials were reviewed and shared. Objective Two- Addressing Farm Bill Opportunities and Barriers - During our events and field visits, and in phone consultations, we conducted on-going in-depth tracking of program participation and implementation in consultation with our 10 trainers, selected from each participating stakeholder group. We also conducted another 8 trainings in collaboration with our members, reaching approximately 250 producers on how to access and benefit from the targeted USDA programs with special focus on conservation, specialty crops and energy and other farm bill programs of special interest. We also educated the trainer-leaders on how to utilize agriculture census data, and have worked with USDA on speeding the implementation of the release of transparency and accountability data so trainers can more readily assess access to programs in their counties and states. We tracked barriers encountered and regularly called these to the attention of USDA officials. Similarly, we informed them of programs farmers and ranchers have found especially useful. We are also investigating training approaches that work especially well. We also organized and communicated to approximately 40 Farm team members to keep them informed of program deadlines and training materials. Objective 3: Farm Bill Implementation Network and Web Center - We worked throughout the year on updating our training materials, hiring a contractor, and upgrading our website with information on new programs. We conducted a Webinar while at University of the District of Columbia in December 2009, but participants decided that the technology was not accessible to them form the field and they preferred phone calls, meetings and other methods of communication. Training materials were prepared tailored to the target producers. needs of socially disadvantaged and beginning farmers and ranchers. PARTICIPANTS: Partner Organizations for the project include Rural Advancement Fund, Orangeburg, SC, Operation Spring Plant, NC, Federation of Southern Cooperatives, Epes, Alabama, Flats Mentor Farms, Lancaster, Massachusetts, National Latino Farmers and Ranchers Trade Association Washington, DC, Land Loss Prevention Project, NC, Farmworker Association of Florida, and others. All of the participants advanced their understanding of USDA programs. TARGET AUDIENCES: Target audiences included African American, Latino, Asian American, American Indian and other producers in all participating states. Audiences also included USDA leaders in those states, who were able to better meet the needs of their colleagues. Other audiences included our CBO and Extension partners with whom we communicated at many workshops. PROJECT MODIFICATIONS: Nothing significant to report during this reporting period.

Impacts
Year One Outcomes/Impacts: We have worked with our partners and USDA in a number of states to advance shared understanding of new farm bill provisions as related to farmers. We have developed working relationships with USDA staff in Alabama, Florida, Mississippi, Oklahoma, North Carolina, Maryland, Massachusetts, New Mexico, Texas and South Carolina that have allowed us to get immediate assistance for producers to address any issues that arise. NRCS in Massachusetts agreed to offer the high tunnel pilot program to producers there and on April 6 announced that 8 producers at Flats Mentor Farm had been approved for $85,936 in funding to install seasonal high tunnels. Socially disadvantaged producers working with Mississippi Association of Cooperatives (20 producers) Oklahoma Black Historical Research Project 25 producers) and ALBA in California have all been approved for high tunnels. In Oklahoma, the high tunnels were also repaired by NRCS after snow and ice damage, based on our inquiries to the state and to Washington to clarify the provisions of the regulations. At the January 2010 workshop in Alabama, the producers, trainers and USDA leaders helped address various issues and clarify regulations. We trained leaders both there and in all subsequent trainings that the 90% cost share for socially disadvantaged producers for conservation practices such as high tunnels, means 90% of the average state cost, not of the total cost. As the costs for high tunnels and also wells and irrigation may exceed the state average costs, this clarification is vitally important in training in order to assure that expectations match deliverables. We continue to look at significant variations in average payments among various states. This new conservation initiative is bringing new producers through USDA's doors and expanding the use of conservation programs in these states and others. We also turned to expanding training to address the issue that many socially disadvantaged producers are not signed up for USDA programs. We produced a training material called "Doing Business with USDA" that detailed exactly what is needed to sign up at FSA, why signing up at FSA is necessary to participate in NRCS programs, and what the benefits will be. This material translated into Spanish and used it widely at each field visit to expand participation in USDA programs. This sign up was essential for the 8 Flats Mentor Farm Farmers who secured high tunnels, and has also been essential for producers in Florida who have had great difficulty in accessing disaster benefits, where at least 20 producers in Florida have signed up with USDA, and in SC, NC and Oklahoma, farmers have signed up and more than 30 more have applied for high tunnels. We are working to get better participation numbers from USDA to the county level to assist local and state offices and CBO groups in determining the impact of outreach efforts, the results in terms of farmer sign ups, and those barriers in regulation or service that still require improvement. We have also worked to develop better networks for farmers, finding email useful for some.

Publications

  • A TIME TO CHANGE: REPORT OF THE ASSESSMENT CONVERSATIONS TEAM (ACT), Rural Coalition, Washington, DC, September 22, 2009
  • RC Comments on the Natural Resources Conservation Service National Listening Sessions (September 30, 2009)
  • RC Comments concerning the interim final rule for the Conservation Stewardship Program as published at 74 Fed. Reg. 37499 (October 28, 2009)
  • Farm and Food Policy Diversity Initiative Issue Brief: Definitions of Socially Disadvantaged, Beginning Farmers and Ranchers and Limited Resources Farmers and Ranchers (Rural Coalition, Washington, DC January 2009)
  • A Seat at the Table: Report on the Farm and Food Policy Diversity Initiative - (Rural Coalition, Washington, DC Rev. March, 2010, 40 pp)
  • RC Press Story on Approval of EQIP Funding for Seasonal Greenhouses with Positive Access for Socially Disadvantaged Producers Highlighting the Flats Mentor Farms High Tunnels Success Story (April 7, 2010)
  • Letters to Risk Management Agency and to USDA Secretary Vilsack on the Standard Reinsurance Agreement with crop insurers, (June 15 and 18, 2010)
  • Letter to USDA Secretary Vilsack on the Standard Reinsurance Agreement and the reallocation of savings socially disadvantaged producers that are inadequately served by the Standard Reinsurance Agreement (July 1, 2010)