THE COMMODITY CREDIT CORPORATION DAVID FIKE GODFREY INTRODUCTION No factor other than the weather probably effects agricultural prices more than the policies of the Commodity Credit Corporation. The various loan policies of the CCC generally set a stable floor under the world market price of a commodity and add some degree-'of consistency to the gamble of farming. Through manipulation of storage stocks and the exports program the CCC can effectively influence the supply of a given commodity which will be available in the market place at a given time. By either holding commodities or dumping them on the market the CCC can either depress or increase the price which the processor, retailer and housewife will have to pay for the commodity in question. The operations of the CCC are big business. In 1974 there were $449,000,000 worth of commodities pledged for loans and the CCC had an inventory of $89,000,000 worth of commodities to which it held title. In Texas alone the Corporation made loans on: 595,000 bales of cotton at a dollar value of $52,267,000; 6,011,000 pounds of grain sorgham for a value $6,045,000; and 2,801,000 pounds of wheat for a loan value of $3,423,000. They also made loans on other commodities such as barley, corn, honey, oats, peanuts, rice, and soybeans. This paper will attempt to present a broad overview of all 2 of the different operations of the Commodity Credit Corporation. It will not attempt to explore in depth anyone phase of CCC operations. However a more detailed study of the cotton loan pro- gram will be made as a representative of all loan programs. This paper will also attempt to present some of the various mechanical problems which will be encountered by the farmer, rancher, or lawyer in dealing with the daily operations of the CCC. HISTORICAL PERSPECTIVE The idea for the Commodity Credit Corporation had its origin in the Federal Farm Board created under the Agriculture Adjustment Act of 1933. The Farm Board attempted to regulate prices by direct controls on acreage and production. l In United States ~. Butler the Supreme Court struck down the Agriculture Adjustment Act as an unconstitutional regulation of agriculture within the states. The court held that it was both an invasion of the reserved powers of the states and a case of improper delegation of authority.2 With the AAA and Federal Farm Board dead, the United States Department of Agriculture had to formulate a new method of regulating agricultural prices. In October 1933, Jesse Jones, a Texas banker, set up the Commodity Credit Corporation to lend money to farmers who agreed to take land out of production the following year.3 The CCC was set up as an independent agency of the Federal Government, though it obtained its financing from and was managed in close 3 affiliation with the Reconstruction Finance corporation. 4 since the loans were at a figure higher than t he market price, they served as an ingenious form of price support. loan dealt only with cotton. ~ The original The loan rate on cotton was lO¢ per pound and the average market price was about 8¢ or 9¢. rate quickly set a floor on the domestic market. The loan The terms of the loan required that all of the cotton placed in the loan would be held for security. The government thus effectively acquired control of almost the entire supply of domestic cotton. This cotton was held off the market and its absence tended to relieve the depressing effect of a market surplus. 6 In 1935 the USDA came up with a new program based on the Soil Conservation Act of 1935. The plan of the new program was to pay farmers for taking land out of soil depleting crops and putting it J into soil conserving crops. Since the soil depleting crops (whea t, corn, cotton, and tobacco) were also the leading surp lus crops, such an approach could achieve indirectly s omewhat the same effects in controlling production and increasing farm income that the AAA had achieved directly. Sinc~ farmers received their benefit payments not for curtailing production but for restoring soil fertility, the criticisrnslcveled against the AAA were not directed at the new program. 7 4 PURPOSE AND POWERS The Commodity Credit Corporation was created for: the purpose of stabilizing, supporting, and protecting farm income and prices, of assisting in the maintenance of balanced and adequate supplies of agricultural commodities, products thereof, foods, feeds, and fibers (hereinafter collectively referred to as "agricultural commodities"), and of facilitating the orderly distribution of agricultural commodities •••• e The CCC may sue or be sued but no attachment, injunction, garnishment, or other similar process may be issued against the Corporat1on or its property. 9 Original jurisdiction for any suit involving the Corporation is in the federal district courts without regard to the amount in controversy. 10 The CCC has a right of intervention in any suit, action, or proceeding in which it has an interest. There is a six year statute of limitations running from the time the action accrued, for all actions against the CCC except in· cases where there is a disability which tolls the statute. In such instances the limitation period is three years from the time the disability is removed. are tried ·without a jury.12 ll All actions against the Corporation The Corporation has all rights, privileges, and immunities of the United States with respect to priority of payments regarding debts due from insolvent, deceased, or bankrupt debtors. ll Contracts by the CCC are not subject to state and local regulatory laws to the extent that such contracts provide otherwise or to the ~xtent that such contracts are inconsistent with the local 5 or state laws or rules'. 1.4 The CCC may acquire its own storage warehouses in areas in which it determines that the privately . owned warehouses are inadequate to meet the needs of the Corporat10n. l~ The Corporation may borrow money to finance its operations but at no time may the borrowed money exceed $14,500,000,000. 16 The Corporation is empowered to accept strategic and critical materials .produced abroad in exchange for commodities held by the CCC. These materials are transferred to the department of defense and the CCC is reimbursed by the Secretary of the Treasury for the value of these materials. 17 The Corporation is specifically empowered to: (1) support the prices of agricultural commodities through loans, purchases, payments, and other operations, (2) make available materials and facilities required in connection with the production and marketing of agricultural commodities, (3) procure agricultural commodities for sale to other governmental agencies, foreign governments, and domestic, foreign, or international relief agencies, and to meet domestic agreements, (4) remove and dispose of or aid in the removal or disposition of surplus agricultural commodities, (5) increase the domestic consumption of agricultural commodities by expanding or aiding in the expansion of domestic markets or by developing or aiding in the development of new and additional markets, marketing facilities, and uses for such commodities, and 6 (6) aid in the development of foreign markets for agricultural commodities. 1S OPERATIONS IN GENERAL The eee is currently operating under the Agriculture and Consumer Protection Act of 1973 the Act). 19 (hereinafter referred to as Under this act .t he Secretary of Agriculture has broad discretion in determininqhow to attain the general objective of pr~ce support. In U.S. v. Swift & Co., 20 a case interpreting the Agriculture Act of 1949,21 the predecessor to the Agriculture and Consumer Protection Act of 1973, a price support program for milk and butter fat which had as its main objective the support of prices received by farmers and producers was upheld even though incidental benefits accrued to processors and manufacturers. 22 The CCC could not justify any program which was not calculated to accomplish the general objective of the statute 23 and the means chosen had to be reasonable calculated to achieve those ends. 24 The Secretary has authority, without notice, hearing, or approval of commodity producers to require identification of a co~~odity erations. in a particular way as a condition of price support op25 Different grades, varieties and types of a commodity must usually be identified prior to receipt of a loan. The Secretary also has the authority to reduce support rates for a particular commodity or for different grades within the commodity group. This 7 is permissible even though the reduced support rate results in an increased support rate for another variety of the commodity so long as the average rate of support continues to be the percentage of parity provided for in the applicable act. 26 Stroud v. Benson 27 dealt with discount varieties of tobacco. The loan program and parity percentage were originally based on high quality varieties of tobacco which were very much in demand in the export trade. Producers began growing inferior varieties of tobacco which could not be recognized by sight from the superior brands. The influx of these inferior varieties into CCC stocks, the increase in loaned funds connected with these brands, and general complaints from the export trade prompted the Secretary of Agriculture to require identification of these inferior varieties. The loan rate for these inferior varieties was subsequently cut to one-half that of the better quality variety. Producers sought to enjoin the Secretary from identifying the varieties of tobacco in question and sought an injunction requiring him to maintain the price support at 90\ of parity. The court held that the Secretary had the authority to require identification of the discount varieties of tobacco as a condition of price support 28 and that he had the authority to reduce . f er10r ' " t h e support rates f or t h ese 1n var1et1es 0 f to b acco. 29 The Secretary may also designate which privately owned warehouses are approved for storage of commodities covered by 'the loan. 30 8 Except in instances specifically covered by the code (which will be discussed later) no commodity will be eligible for the loan unless it is stored in a government approved warehouse. In order to obtain approval of the Secretary of Agriculture a warehouseman must submit a financial statement which was prepared within 90 days of the date of application and continue submission of statements annually after approval. (1) (2) (3) He must have : a license to store the commodity in question, a net worth of at least $10,000, sufficient operating funds to meet daily requirements, (4) corrected any deficiencies owed to the government, and (5) provided any bonds which are required by the Secretary of Agriculture' 3l These bonds are to equal a value of not less than 5\ of the value of the estimated quantity of processed commodities in the warehouse. The bond cannot be less than $5,000 nor need it be greater than $100,000. 32 In some instances where the farmer has adequate storage facilities located on the farm the Secretary will allow the farmer to store the commodity for the government. Convenience and ease of administration are taken into consideration in determining if the farmer will be allowed to store his own commodities. Govern- ment loans are provided to some farmers, to enable them to build---_ their own storage facilities when the existance of such facilities would be advantageous to the government. 33 9 Another condition for receipt of the loan, which was previously applicable was compliance with acreage allotments • 34 . . · A producer was entitled to aid by price support if he was a "co-operator." A co- operator was a producer on whose farm the acreage planted to the commodity did not knowingly exceed the farm acreage allotment. 35 Today a producer is not required to comply with any acreage allotments in order to be eligible for the loan. He can enter his entire crop of any given commodity into the loan without fear of a penalty for surplus production. 36 One who receives cash rent for land is not a "producer" of the commodity grown on t.....e fore not eligible for a cotton loan under it. land, and is thereA landlord who tried to get a loan on cotton that he had bought from his tenants was found guilty of mail fraud in Richardson v. U.S. 37 .The landlord bought the cotton from his tenants and then had samples of the cotton graded at a marketing association that he controlled. The grades on the various samples were raised one or two grade levels above their true value. The landlord then sent the graded samples to the COC for determination of the loan value. He was convicted of mail fraud because he fraudulently represented the cotton to be his own produce and because he sent the fraudulently graded samples to the CCC via the mail. The courts have no right to question the acts of the designated agencies in administering the policies of the CCC, in absence of charges of fraud or bad faith, provided the agencies acted within 10 the framework of the Act and did not abuse their discretion. 38 The Corporation may in the exercise of its discretion refuse to adminiater a program through the warehouses of a particular person. £££~. Worthington 39 In the CCC refused'to deal with a warehouseman who had previously managed a tobacco warehouse that had been suspended ~y the CCC. Other farmers and tobacco buyers had had difficulty in dealing with the warehouseman and his reputation showed a general lack of integrity. The court held that the CCC did not abuse its discretion in refusing to extend price supports to tobacco sold to any tobacco auction warehouse or tobacco auction business in which '1 " d • 40 the wareh ouseman actLve y partLcLpate The CCC has authority to recover any purchases or payments improperly made by the corporation. 41 The Corporation is also authorized to withhold payments when there is: (1) a serious breach of contract or a violation of the individual program requirements, (2) - evidence of criminal or civil fraud, (3) prior difficulty in collecting payments due the CCC, (4) doubt that the debtor will be able to pay the CCC on an outstanding judgment, (5) a judgment obtained, and (6) a request by the Justice Department for withholding of payment. 42 . The CCC can also stop payment in any of the above Lnstances. The CCC also has a right of set off against all debts owed to the CCC or any other agency of the Federal Government. priority of claims in a set off situation is: (1) the Commodity Credit Corporation, 44 The 43 11 (2) Agriculture Stabilization and Conservation Service, (3) all other agencies of the United states . Departrnent of Agriculture (in order of filing) , (4) Internal Revenue Service, and (5) other Federal Government agencies (in order of filing) .45 In these set off situations a prior assignment of the producer's claim to another party is disregarded and the claim is set off Just as if the producer still held the claim. 46 Under eB14p a buyer in the ordinary course of business takes free of any claim by the CCC, based on want of authority in the seller to sell such goods, provided he gave value, was a good faith - purchaser, and there was no notice of defective title in the seller. The buyer must assert an affirmative defense and establish by a preponderance of the evidence each of the facts necessary to attain relief. 47' -- - In U.s. v. Kerr Gifford and Co. 4B the court held that this section "manifested a congressional intent to protect the purchaser who has parted with his money and received the goods without knowledge of any defect in the seller's authority to sell. 49 Section 714M provides for a $10,000 fine or five years ~n prison or both for any false statement in connection with an act or influencing any action of the CCC. This provision covers any overvaluation of a commodity, embezzlement, theft, or conversion. LOAN PROGRAM The CCC currently makes non-recourse loans on cotton, 50 . gra~ns, 51 12 peanuts, 52 honey, · 58 and moh a1r. 53 wool, 54 naval st6res, 55 oil seeds, 56 tobacco, 57 Generally the provisions and mechanics of each loan program are somewhat similar. The cotton loan program is represent- ative of all loan programs and will be set forth in detail below. Application for a loan on cotton must be filed in the county ASCS office where the cotton is grown. 59 The ASCS will then require documents showing proof of ownership of the cotton On which the loan is sought. Typically loans are advanced on warehouse receipts for warehouse storage loans and bills of lading for bills of lading loans. After these documents are produced several other requirements must be met before the loan is advanced: (1) 60 The cotton must have been produced by a cooperator as defined in the Agricultural Act of 1949 and this cooperator must be in compliance with all acreage allotments and set aside requirements applicable at that time. 61 (2) The cotton must be of a grade and length which is specified for the loan. Ii? The CCC will not accept cotton for the loan unless it is specifically within a designated grade for which loans are made. (3) The cotton cannot be falsely packed, water packed, mix-packed, reginned, or repacked. (4) 63 The cotton must in fact be in existance and in good cond~t~on. Damaged cotton is not accepted to the loan. (5) The person seeking the loan must have a legal right to pledge 64 13 the cotton 65 and ' in conjunction with this requirement, the cotton cannot be cotton which ha's been purchased by the prospective debtor 66 or cotton which was previously in the loan program and' has been redeemed. 67 The CCC will not accept any bales of cotton into the loan which weigh le~s than 325 pounds · 69 pac k ag1ng requ1rements. approved warehouse. 70 68 and all bales must meet specific All cotton'must be stored in a CCC No provision was made for on the farm storage of cotton bales. The value of the loan is computed on the basis of the weights shown on the warehouse receipts or the bills of lading. 7l The CCC will not make loans on the amount that any given bale exceeds 600 pounds. 72 The loan rete is set for one specific grade of cotton by order of the Secretary. The base grade is Strict Low Middling 1 1/16 and all other grades are either discounted or paid a premium dependent on their variation from the base grade. 73 The cotton must .be classified as to staple and micronaire in order to determine the grade. USDA Board of Cotton Examiners. The classification is done by the If two or more classes of cotton are submitted for the same loan, the loan is based on the 'lower of the two grades. 74 The interest rate on the loan is variable and' is published regularly . in the Federal Re9ister. is 9.35\.76 75 The current interest rate 14 In order for cotton to enter the loan program it must be free and clear of all leins. If there are leins attached to the cotton the producer must get a waiver from all lein holders, laborers, landlords, and mortgagees, or obtain a subordination agreement from them before the cotton will be accepted. 77 The loan matures automatically on the last day of the ninth month following the month in which the loan was advanced or it is payable upon demand at anytime prior to that date. 78 Upon maturity and non-payment the CCC can sell, transfer, and deliver the cotton or documents of title without notice to the producer or advertisement or notice of the sale to the public. 79 Any overage in the sale price ordinarily goes to the producer, however title rests in the CCC immediately upon default and they are not required to pay any overage if there is no sale. 80 The loan may be paid off at any time prior to the maturity date but not after the CCC acquires title to the collateral. 81 All approved warehouses are required to carr y insurance on the commodities stored. Liability for any damage or lo s s occurring during the time a commodity is in the loan program falls primarily on the warehouse. The CCC can file claims against any liable party for the amount of loss sustained. The CCC credits the producer's loan value (including interest and charges) with the value of any recovery. producer. Any excess recovered over the loan value goes to the 82 15 MISCELLANEOUS PROGRAMS The ccc administers several minor programs which are designed to help in attaining the major goal of price support.' These programs are not encountered by as large a segment of the agricultural population as are loan programs but they are significant for their OVerall effect on the economy. In 1973 there was ,a bumper crop of grain in the United States and approved storage facilities were not available for all of the crop. As a consequence the grain not in approved storage facilities was not eligible for the nOn-recourse loan. The CCC devised the Distress Grain Loan Program which provides recourse loans for grains stored in temporary facilities or on the ground. The CCC is not liable for any loss of quantity or quality under this program. 8~ The ! recourse loan can be liquidated at maturity by: (1) (2) (3) repayment of the loan with interest at maturity, transferring the grain into the non-recourse program when facilities become available, delivery of the grain to the CCC for credit at the market price. Since this is a recourse loan the producer is liable for any defiC1enC1es. 84 The CCC maintains several export programs to help maintain competition between products produced in the U.S. and the World Market. The products covered in the general export program are , 85 wheat and f 1 our, 86 fee d gra1ns, ' 87 and fl axsee d and l'1nseed r1ce, 16 AA oil. . Export ·payments are designe<l to. (1) assure that the commodity produce<l in the U.S. is generally competitive in world markets, (2) avoid description of the world market price, (3) aid the price support program by strengthenng the domestic market price, (4) re<luce the quantity of commodities which would otherwise be taken into CCC stocks under its price support program, (5) promote the orderly liquidation of CCC stocks, (6) fulfill the international obligations of the Unite<l states' 89 Under this· program payments are made to approved exporters 90 SO that they can afford to effectively compete with the world market prices either in open world market operations or in programs covered under Public Law 480. 91 The CCC also provides financing for impo:r~ing nations under Public Law 480. 92 The CCC has one other export plan designed to encourage the importation of quality breeding stock by underdeveloped countries. In this program exporters sell hogs, beef and dairy cattle, and sheep to the underdeveloped countries on a deferred payment plan. CCC then purchases the exporters accounts receivable. The Bree<ling animals sold under this plan must meet certain specifications as to size, age, and quality. 93 The CCC has an emergency feed program which is de s ~gne<l to provide fee<l grain at beneficial prices in designate<l areas where there is a shortage of feed due to flood, drought, fire, hurricane, storm, tornado, earthquake, disease, infestation or other catastrophe. 94 17 In order to be eligible to participate in the program the disaster must have caused a serious loss of feed, including hay, pasture, or range which normally would have been available to the owner's livestock. This loss must be one which causes an undue financial burden upon the owner and requires him to purchase a quantity of feed substantially more than he usually produces. Individuals who have a reputation of being wealthy as measured by local standards are automatically excluded from the program. Once a producer qualifies for the program he must repay all principal and interest due on any feed grain that he has in the loan program. After these obligations are repayed, the CCC releases those feed grains which are stored within a reasonable hauling distance of the producer's livestock operation to him. his livestock. He is free to feed these grains to After this grain is exhausted the producer may pur- chase grain upon which the CCC holds title. If the producer wants to buy processed feeds from a feed dealer he may do so. The CCC will issue warrants to the grain dealer for the replacement of the gra1n contained in the processed feed. 95 Finally the CCC administers a barter program in which exports of U.S. agricultural commodities are used to finance procurement of materials, equipment, goods and services required from foreign sourceS by U.S. Government agencies and foreign procurement of strategic and other materials for stockpiling. 18 Th", objectives of the program are: (1) to develop and expand foreign markets for U.S. farm products, (2) to improve the (3) to procure strategic materials to meet stockpiling goals, (4) to procure strategic materials in excess of stockpiling u. s. balance of payments position, goals where this is in the best interest of the u.s. when measured against other alternatives such as taking foreign currencies in payment. 96 APPENDIX PARITY PRICING Each loan rate for a commodity is based on a percentage of parity which is set by statute or regulations. A parity price is one that will buy the same quantity of other products as it would during some specified base period. Parity prices provide a yard- stick designed to represent a fair price for the commodities which farmers produce in relation to the price of the commodities which they buy. Parity prices are determined by first computing the "parity index." This is an index number with the period 1910-1914 as a base which includes the following cost items: the general level of prices for articles and services that farmers buy, wages of hired farm labor, interest on farm indebtedness secured by farm real estate and taxes on farm real estate. index includes 335 items. This part of the parity This index is computed monthly by the Bureau of Agricultural Economics and is published in the monthly report entitled Agricultural Prices. Next an index number of prices received by farmers is computed for all agricultural commodities. subsidy payments. This index includes any The ratio of these two index numbers is referred to as the "parity ratio." It represents the per cent which agri- 20 cultural prices in general are of parity. The next requirement is the computation of an "adjusted base price." · This equals the average price received for a particular commodity for the lO-year period ending on the thirty-first of December prior to the date of computation divided by the average index number of prices received by farmers for all commodities for the same lO year period. The parity price for the particular com- modity is then obtained by multiplying the adjusted base price by the parity index. This formula is designed to keep the same ratio between prices received by farmers for all commodities and prices paid by farmers as in the period 19l0-l9l4, but to permit price relationships between individual commodities to be as they were in the most recent lO years. Parity prices for major items are published by the Bureau of Agricultural Economics in the monthly issue of Agricultural Prices. An· example of parity computed on egg prices is set forth below. Average price received, ·Jan 1940 - Dec ·l949 ~ Average index of prices received by farmers, Jan 1940 - Dec 1949 ~ 36.6¢ per doz 202% of 19l019l4 base period 250% of 19l019l4 average 21 Adjusted Base price - Average Price Received - Index of prices Received 18.1 ¢ Parity price of 45.2¢ .• EggS - 2.02 36.6 Adjusted Base ·Price X parity Index 18.1 X 2.50 Source:' Agricultural Pricing, Thomsen and Foote, 1952, McGraw-Hill Book Company, Inc. FOOTNOTES 1 Thomsen & Foote, Agricultural ·Pricing 355 (2nd ed. 1952 ) 2297 U.S. 1 (1936) 3 Leuchtenburg,Franklin D. Roosevelt 4 the New ~ Thomsen & Foote, supra note 1 at 357. 5 Leuchtenburg, supra note 3 6schlesinger, The Coming ~~~ ~ 155 (1958) 7Schlesinger, The Politics 8 9 ~ 2f Upheaval 504 (1966) 15 U.S.C •. § 714a (1964) 15 U. S . C. i 714b(c) (1964) 10 I d • llId. 12 I d • 13 15 U.S.C. Ii 714b (d) 14 15 (1964) 15 U.S.C. Ii 714b (g) {1964) 15 U.S.C. 16 17 15 U.S.C. 19 21 714b(b) (1964) 15 U.S.C . Ii 714b (i) (1964) 18 20 § § 714b(b) (1964) 15 U.S.C. § 714c (1964) 7 U.S.C. § 1331 (1970) 152 F. Supp 738 (D.C. Md 1957) 7 U.S.C. E: 612(c) (1964) 74 (1963) 23 22 U.S. v. Swift & Co., 152 F. Supp. 738 (D.C. Md. 1957) 23 Id • at 752 24 Id • 25 Stroud v. Benson, 155 F. Supp. 482 (D.C. N.C. 1957) 26 Id • 27155 F. Supp. 482 (D.C. N.C. 1957) 28 Id. at 492 29 Id • at 491 30 31 32 . Richardson v. U.S., 150 F.2d 58 (C.C.A. Tenn 1945) 7 C.F.R. I 14 2 3.2 ( 1974 ) 7 C.F.R. § 1423.3 (1974) 33 7 C.F.R. § 1424 (1974) 34u• S • v. Appling, 239 F. Supp. 185 (D.C. 1965) 35 Id • at 191 36 37 Interv1ew w1th Walter Well, Manager Lubbock A.S.C.S. 150 F.2d 58 (C.C.A. Tenn 1945) 38 CCC v. Worthington, 263 F.2d 178 (C.A.N.C. 1959) 39 Id. at 180 40 Id. 41 U.S. v. Swift & Co. 152 F. Supp. 738 (D.C. Md. 1957) 42 7 C.F.R. § 1408.5 (1974) 43 7 C.F.R. Ai 1408.6 (1974) 44 7 .C.F.R. 6 1408.1 (1974) 45 7 C.F.R. § 1408.52 (1974) 24 46 47 7 C.F.R. § 1408.14 15 U.S.C. § 714 48 15 U.S.C. 3714 M (1964) 50 7 C.F.R. 11 1427 (1974) 51 7 C.F .R. 11 1421 (1974) 52 7 C.F.R. 53 55 !l 1422 (1974) 7 C.F.R. § 1434 (1974) 7 C.F.R. § 1472 (1974) s 7 C.F. R. s 1438 (1974) 56 57 (1964) 136 F. Supp 771 (D.C. Idaho 1956) 49 54 o (1974) 7 C.F.R. § 1443 (1974) 7 C.F.R. § 1464 (1974) 58 59 60 61 62 63 64 65 66 7 C.F.R. !l 1468 (1974) 7 C.F.R. § 1427.3 (1974) 7 C.F. R. § 1427.6 (1974) 7 C.F.R. !l 1427 . 7 (1974) 7 C.F.R. !l 1427.6 (e) (1974) 7 C.F.R. § 1427.6 (d) (1974) 7 C.F.R. ii 1427.6 (e) (1974) 7 C.F.R. § 1427.6 (g) (1974) 7 C.F.R. ~ 1427.6 (h) (1974) 67 . Id. 68 69 7 C. F. R. § 1427.6 (j ) (1974) 7 C.F.R. § 1427.6 (k) (1974) 25 7°7 C.F.R. II 1427.8 (1974) 71 7 C.F.R. II 1427.9 (1974) 72 Id. 73 Id. 74 7 c. F. R. 1i 75 7 C.F.R. 76 ' § 1427.16 (1974) 1427.17 (1974) Interview with Walter Wells, Manager Lubbock A.S . C. S . 77 7 C.F .R. § 1427.14 (1974) 78 7 C.F.R. § 1427.18 (1974) 79 Id. 80 Id. 81 7 C.F.R. 82 83 7 C.F.R. § 1473 (1974) 85 86 87 88 89 91 92 93 1427.25 (1974) 7 C.F.R. § 1427.24 (1974) 84 90 § 7 C.F.R. § 1481 (1974) 7 C.F.R. § 1483 (1974) 7x C.F.R. Ii 1483 (1974) 7 C.F.R. . § 1484 (1974) 7 c. F. R. Ii 1486 (1974) 7 C.F.R. § 1481 (1974) 7 C.F.R. § 1483.110 (1974) 7 C.F.R. 5 1483.130 (1974) Id. 7 C.F.R. § 1488 (1974) 26 94 7 C.F.R. § 1475 (1974) 95 Id • 967 C.F.R. i 1495 (1974)