Farmers have several general concerns about crop insurance voiced by national farm organizations representing a cross-section of American agriculture. The American Farm Bureau Federation (AFBF) and others would like USDA to address shallow losses, which occur when losses are significant for the farmer but not enough to trigger an indemnity. 31 Also, this group and others point out a need to address declines in actual production history (APH), which is used for determining the insurance guarantee. Some farmers are subject to a declining insurance guarantee because of recent repeated disasters. (The American Sugar Cane League has commented on the inadequacy of.