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Agriculture
Reference:

Mechanism of Legal Regulation of Agricultural Production Insurance as a Way to Ensure Food Security of the Country

Isakov Aleksandr Nikolaevich

Doctor of Agriculture

Professor, Department of Agronomy, Kaluga Branch of the Russian State Agricultural Academy named after K.A. Timiryazev

248007, Russia, Kaluga region, Kaluga, Vishnevsky str., 27

rogneda60@mail.ru

DOI:

10.7256/2453-8809.2022.4.39424

EDN:

TSLMDX

Received:

16-12-2022


Published:

29-12-2022


Abstract: The article talks about the importance of agricultural insurance for ensuring the financial well-being of agricultural producers and food security of the country. The main regulatory documents regulating insurance in the agricultural sector of the economy are indicated. The positive aspects achieved during the validity period of Federal Law No. 260 are noted: the possibility of choosing the most significant risks for production and the exclusion of unlikely ones; the ability to establish a real level of coverage; the threshold for the death of the crop yield and the harvest of perennial plantings has been abolished and the introduction of a criterion - a decrease in the actual harvest compared to the planned and loss of viability of perennial plantings as a result of the occurrence of events provided for by law; it is possible to take into account the specifics of the economy when assigning insurance amounts; the range of deductibles has been expanded; it is now possible to conclude an insurance contract for at least 70% of the cost crop yields, plantings of perennial plantings, or animals; the possibility of using space monitoring data to confirm the facts of the occurrence of an insured event. Production insurance has been introduced in case of natural emergencies. A number of issues requiring additional legal regulation in connection with the occurrence of natural emergencies are considered. The analysis of the law enforcement practice on agricultural insurance in the country is given.


Keywords:

insurance, emergency situations, natural character, agriculture, farm animals, risk insurance, agricultural producer, law, natural phenomena, insurance case

This article is automatically translated.

Most civilized countries of the world use a number of mechanisms to create favorable working conditions in agriculture that reduce the impact of adverse factors on the results of their economic activities. In the Russian Federation, one of the main mechanisms for protecting the property interests of agricultural producers from the negative impact of natural phenomena is production insurance. This ensures a certain financial stability and stability of economic entities and, undoubtedly, makes it possible to increase the country's food security.

An indisputable fact is an increase in the probability of the occurrence of insurance events as a result of adverse natural phenomena, which primarily negatively affects the functioning of agricultural enterprises and, especially, in the crop industry. The concept of the term "risky farming zone" has crossed the regional level and concerns most of the territories of Russia. This circumstance strengthens the responsibility of the state as a guarantor of ensuring food security of the population of the country.

The insurance protection of agricultural producers from adverse natural phenomena is carried out on the basis of the voluntary insurance mechanism stipulated in Federal Law No. 260-FZ dated 25.07.2011 "On State support in the field of agricultural insurance and on Amendments to the Federal Law "On the Development of Agriculture" (Collection of Legislation of the Russian Federation dated August 1, 2011 No. 31, Article 4700) (further-Federal Law No. 260).Property interests are subject to insurance in the event of loss or reduction of the yield of a legally defined list of agricultural crops, planting of perennial plantings, farm animals and aquaculture facilities.

Insurance protection is carried out on the basis of agricultural insurance contracts with state support, in which 50% of insurance premiums are paid by the agricultural producer. Insurance is carried out on the basis of uniform standard rules for each insurance program.

It should be noted that during the validity of Federal Law No. 260, many provisions of the law have changed. In the latest editions of Federal Law No. 260 (ed. dated 27.12.2018 No. 563-FZ, as amended. dated 12/30/2021 No. 475-FZ) largely takes into account the interests of the agricultural producer and provides:

- the ability to choose the most significant risks for production and the exclusion of unlikely ones, which significantly reduces the cost of insurance costs. This has reduced the criticism of researchers who pointed to the problem of differentiation of insurance tariffs, hindering the development of not only insurance, but also regional agricultural policy [1, 2].

- the ability to set the real level of coverage, which reduces the cost of the insurance contract;

- the threshold for the death of the crop of agricultural crops and the harvest of perennial plantings, in which the case was recognized as insured, has been canceled. Federal Law No. 260 (as amended. from 12/22/2014 N 424-FZ) since 2016, insurance protection with state support has been provided only for the risks of loss and death of the crop harvest, or with a decrease in the actual harvest by 20% or more compared to the planned one and the loss of long-term plantings viability by more than 30% of planting areas. At the same time, the high limits of risk recognition reduced insurance payments to almost zero. Federal Law No. 260 (as amended. dated 27.12.2018 N 563-FZ) under the loss (death) of the crop has already provided for a reduction in the actual harvest compared to the planned loss of long-term plantings viability as a result of the occurrence of events stipulated by law. These criteria for the occurrence of insurance events increased the probability of receiving payments by agricultural producers.

- it became possible to make payments for any losses and on any area. The current version of Federal Law No. 260 in paragraph 13 of Article 2 provides for payments as a result of the loss (death) of the crop of agricultural crops, including the harvest of perennial plantations, as a result of a decrease in the actual crop of agricultural crops, including the harvest of perennial plantations compared with the planned harvest

on a land plot or part thereof as a result of the occurrence of all, several or one of the events provided for by law. Thus, the policyholder is dealing with multi-risk insurance;

- an expanded list of insurance natural phenomena leading to crop loss is provided. The current version of Federal Law No. 260 provides for insurance of the risks of loss (death) of the crop of agricultural crops, including the harvest of perennial plantings, loss (death) of plantings of perennial plantings from 26 types of natural phenomena and natural disasters, from the penetration and (or) spread of harmful organisms, if such events are epiphytotic in nature. The provisions of the first edition of Federal Law No. 260 applied to 21 types of natural phenomena and natural disasters;

- when insuring animals, an extended range of compensation for losses is provided in case of forced slaughter of all insured animals when an epizootic outbreak is detected;

- it is possible to take into account the specifics of the economy when assigning insurance amounts, the range of deductibles has been expanded (up to 50% of the insured amount);

- it became possible to conclude an insurance contract for at least 70% of the value of the crop yield, planting of perennial plantings, or animals;

- the possibility of using space monitoring data to confirm the facts of the occurrence of an insured event.

All this has simplified the ways to protect the interests of the agricultural producer.

In the first years of the Federal Law No. 260, villagers quite often faced a delay in the subsidies allocated to insure their production due to the inertia of federal and regional officials, excessive bureaucratization of the executive system, due to poor awareness of agricultural producers about the insurance program itself with state support.

Currently, the severity of the problems concerning the procedure for subsidizing agricultural producers and the mechanism of state support has weakened.

As the analysis of judicial practice in agricultural insurance shows, in most cases the courts take the side of the policyholder, however, it is not uncommon for insurers to fail to fulfill their obligations in the event of insured events, including as a result of intentional inclusion of unfavorable conditions for policyholders in contracts [3].

Agricultural producers are not clearly oriented in the details of the insurance mechanism, which imposes a certain responsibility on the authorized body of the subject of the Russian Federation, whose duties should be not only to launch the insurance mechanism with state support, but also to train the peasant in the main aspects of the insurance procedure, and further supervise this process.

This has led to the fact that the current level of the insurance system still does not allow us to talk about the use of agricultural insurance as a systemic institution for the development of agriculture. For example, in 2020, only 7% of agricultural crops were insured, instead of 20% planned by the Ministry of Agriculture.

It is obvious that the low coverage of agricultural crop insurance is not determined by the unwillingness of agricultural producers to participate in this process. This is due to a complex of problems in the agricultural sector, the main of which, in our opinion, are:

- the difficult financial situation of agricultural producers;

- lack of funds to pay 50% of the insurance premium, even taking into account government subsidies;

- high level of creditworthiness of the agricultural sector.

Some researchers still note the presence of "gray" schemes in the agricultural insurance industry, due to the lack of an accurate regulatory framework and insurance rules [4, 5].

To break the financial impasse, comprehensive support for the agricultural industry is required by implementing many directions: establishing price parity between the cost of agricultural products and industrial means of production used in the agro-industrial complex, a well-thought-out system of measures to support the agricultural sector, etc.

Another burden for the state is the need to compensate for losses from natural emergencies that have become more frequent on the territory of the country (hereinafter referred to as natural emergencies). The state, trying to get away from the sole compensation of farmers' losses as a result of the occurrence of a natural emergency, includes agricultural producers in this process.

Federal Law No. 260 (as amended. dated 11.06.2021 No. 177-FZ) (hereinafter - FZ No. 177) from July 1, 2021 expanded the list of insurance risks, Clause 4 was added to Article 8, which provides for the possibility of insuring the risks of loss of crop yield and harvest of perennial plantings in case of an emergency of a natural nature.

It remains unclear whether the mechanism for providing subsidies to agricultural producers in case of natural emergencies will remain without concluding agricultural insurance contracts with state support?

According to the National Union of Agricultural insurers, at the cost of a multi-risk policy of 200-900 rubles per hectare, a natural emergency policy will cost 2-3.5 times cheaper, which is attractive for small farms. Given that a policy against natural disasters is able to compensate producers for only 35-50% of the cost of possible crop losses in crop production, multi-risk contracts are likely to be more profitable for large farms.

Analysis of the provisions of paragraph 19 of Article 2 of Federal Law No. 177 and the provisions of Federal Law No. 68- FZ of December 21, 1994 "On the Protection of the Population and Territories from Natural and Man-made Emergencies (Collection of Legislation of the Russian Federation of December 26, 1994, No. 35, Article 3648) (hereinafter - the Emergency Law)allows the concept of insurance risk "emergency of a natural nature" to be characterized as follows. As a result of a natural emergency, an emergency regime should be introduced. An event of a natural nature must at least meet the criteria of a dangerous natural phenomenon. Thus, it should develop according to the scheme: the fact occurred as a result of a natural event – this event should lead to crop loss - a federal, interregional or regional emergency regime has been declared. However, insurance contracts with state support in accordance with Federal Law No. 177 provide for covering the costs of natural disaster losses in a specific territory, in a separate farm, i.e. at the local level. This does not correspond to the concept of insurance risk "natural emergency" defined by the Emergency Law.

According to the Law on Emergencies, in order to determine the death of an agricultural crop from a natural emergency, the commissions for the prevention and elimination of emergencies are guided by the criterion of the economic feasibility of further cultivation of the crop. To date, it is unknown exactly what criteria will be established in the by-laws to determine the loss of crop yield, planting of perennial plantings for the risk of natural emergencies. Federal Law No. 260 imposes only the following requirements for determining the loss (death) of an agricultural crop " ... is established by the commission for the prevention and liquidation of emergency situations ... with the participation of the head of an agricultural organization, representatives of local self-government bodies; the loss is confirmed by an act drawn up by the policyholder and the insurer, or by the insurer based on the results of monitoring conducted using aviation and space facilities".

According to K. Svintsova [6] in recent years, in agricultural insurance, the judicial practice of applying conclusions on the fact of confirming the occurrence of insurance events according to remote sensing data has been formed. Whereas there are cases when, on the basis of the acts of the emergency commissions, the complete death of the insurance object was recorded, but upon careful study it turned out that the crops were unharmed or there was no loss of the planned harvest (The Decision of the Ninth Arbitration Court of Appeal of 27.09.2017 in the case N A40-168831/2016; The Decision of the Arbitration Court of the Moscow District of 10.09.2018 N F05-19087/2017 in the case N A40-204088/2016)(date of application:26.11.22)).When insuring crop production facilities and assessing their condition during the survey by the emergency commission, it is necessary to detail the territory of the farm with the indication of field numbers and links to geographical points.

This is necessary already at the stage of concluding insurance contracts.

The law enforcement practice on agricultural insurance still has facts when insurers unreasonably declare the occurrence of insured events and a decrease in the actual harvest of agricultural crops or the harvest of perennial plantings in comparison with the planned harvest. Along with an erroneous understanding of the insurance rules, criteria for the occurrence of insurance events, policyholders, in connection with the introduction of the insurance condition - a decrease in the actual harvest compared to the planned one, began to commit violations when calculating the level of the lost harvest. For example, the decision of the Arbitration Court denied the policyholder claiming to receive insurance payments for the risk of crop shortage due to the provision of inaccurate statistical reporting on the volume of harvested crops. This information was filled in by the policyholder himself without proper verification, including by the statistical authorities (the Decision of the Arbitration Court of the City of Moscow dated 14.06.2017 in case N A40-168831/2016) (date of appeal: 25.11.22)).Often the courts agree with the arguments of insurers about the need to apply contractual criteria for the occurrence of insured events, and not the criteria of Roshydromet.

At the same time, as it is often noted, the expert's conclusion cannot confirm the fact that the event meets the criteria established by the insurance contract, because the expert cannot influence the terms of the insurance contract, as well as the meteorological results (Resolution of the Arbitration Court of the North Caucasus District of 17.05.2017 N F08-2593/2017 in case N A53-1320/2016., Definition of the Supreme Courts of the Russian Federation dated 12.10.2015 N 308-ES15-12587) (date of appeal: 25.11.22)).It should be noted that the Ministry of Agriculture, being the main state body responsible for the country's Food security, is taking certain steps to stimulate insurance.

In particular, based on the Decree of the Government of the Russian Federation No. 118 of February 6, 2021, an additional coefficient of payments of increased rates per ton of manufactured products to agricultural producers who insured the harvest is introduced in 2023 (http://ivo.garant.ru/#/document/404520374/paragraph/1/doclist/2607 /) (accessed: 12/24/12)). In animal husbandry, the subsidy for 1 kg of sold milk for insured livestock is increased.

Thus, in conditions of increasing natural and climatic instability in the field of agricultural production, it is difficult to find an alternative to the insurance system to create a certain financial guarantee for producers and food security of the country. Legal regulation of the mechanism of the insurance system aimed at expanding insurance products, insurance of the most likely risks, increasing the responsibility of the authorized body of the subject of the Russian Federation for informational, advisory and legal support of contracts will contribute to the expansion of agricultural insurance in the country.

References
1. Efimov O.N. Content of the concepts "agricultural producer" and "beneficiary" as subjects of the agricultural insurance market with state support // Insurance business.– 2016.– No. 5.– pp. 47-55.
2. Shestakova M.V., Shestakova N.N. Agricultural insurance in the system of state support of agriculture: monograph — Krasnoyarsk: KrasGAU, 2018. — 146 p.
3. Eliseev V.S. Problems of protecting the property interest of agricultural subjects in contractual obligations (on the example of Russian and Belarusian legislation) // Civil law. 2009. N 4. pp. 31-35.
4. Yureneva T.G., Golubeva S.G., Barinova O.I. Assessment of the current state of agricultural insurance in the Vologda oblast / Management accounting. – 2019. – No. 4. –pp. 52-60.
5. Barinova O.I., Yureneva T.G., Golubeva S.G. Analysis of the agricultural insurance market in the Vologda oblast / Insurance in the information society – place, tasks, prospects: proceedings of the XX International Scientific and Practical Conference. In 2 volumes. Ed. P.N. Zakharov, E.V. Zlobin.-2019. – pp. 124-130.
6. Svintsova K. Emergency agricultural insurance "Modern insurance technologies", 2021, N 4.

First Peer Review

Peer reviewers' evaluations remain confidential and are not disclosed to the public. Only external reviews, authorized for publication by the article's author(s), are made public. Typically, these final reviews are conducted after the manuscript's revision. Adhering to our double-blind review policy, the reviewer's identity is kept confidential.
The list of publisher reviewers can be found here.

A REVIEW of an article on the topic "The mechanism of legal regulation of agricultural production insurance as a way to ensure food security of the country". The subject of the study. The article proposed for review is devoted to topical issues of agricultural production insurance. The author provides examples from judicial practice, an attempt is made to generalize it. At the same time, the scientific component of the article is questionable, since there are actually no scientific approaches on the stated topic. The subject of the study was the norms of legislation and materials of judicial practice. Research methodology. The purpose of the study is not stated directly in the article. At the same time, it can be clearly understood from the title and content of the work. The goal can be designated as the consideration and resolution of certain problematic aspects of the issue of legal regulation of agricultural production insurance as a way to ensure the country's food security. Based on the set goals and objectives, the author has chosen the methodological basis of the study. In particular, the author uses a set of general scientific methods of cognition: analysis, synthesis, analogy, deduction, induction, and others. In particular, the methods of analysis and synthesis made it possible to draw specific conclusions from the materials of judicial practice. The most important role was played by special legal methods. In particular, the author actively applied the formal legal method, which made it possible to analyze and interpret the norms of current legislation (first of all, the norms of the legislation of the Russian Federation). For example, it is noted that "during the validity of Federal Law No. 260, many provisions of the law have changed. In the latest editions of Federal Law No. 260 (as amended. dated 12/27/2018 No.563-FZ, as amended. dated 12/30/2021 No. 475-FZ) (2, 3) the interests of the agricultural producer are largely taken into account and provided for: - the possibility of choosing the most significant risks for production and excluding unlikely ones, which significantly reduces the cost of insurance costs; - the ability to establish a real level of coverage, which reduces the cost of the insurance contract; - the threshold for the death of the crop and the harvest of perennial plantations, in which the case was recognized as insured, has been canceled." The possibilities of an empirical research method related to the study of judicial practice materials should be positively assessed. The author actively cites the opinions of various courts in the article, attempts are made to generalize judicial practice. At the same time, taking into account the research topic, the method of analysis and generalization of scientific literature on the research topic was clearly not fully implemented. At the same time, there are enough works on the problems stated by the author. Thus, the methodology chosen by the author is not fully adequate to the purpose of the study, does not allow to study all aspects of the topic in its entirety. Relevance. The relevance of the stated issues is beyond doubt. There are both theoretical and practical aspects of the significance of the proposed topic. From the point of view of theory, the topic of legal regulation of agricultural production insurance is complex and ambiguous. There are various scientific approaches to the essence of this phenomenon, discussions about the ratio of private and public in agricultural production insurance. It is a pity that the author has not fully consecrated this (scientific) aspect of the problem. From the point of view of practice, an analysis of business and law enforcement practice on the issue proposed by the author would be interesting and useful. Thus, scientific research in the proposed field should only be welcomed. Scientific novelty. The scientific novelty of the proposed article requires clarification, first of all, in relation to other points of view expressed in science. Firstly, it is expressed in the author's specific conclusions. Among them, for example, is the following conclusion: "in conditions of increasing natural and climatic instability in the field of agricultural production, it is difficult to find an alternative to the insurance system in order to create a certain financial guarantee for producers and food security of the country. The development of a well-coordinated mechanism of the insurance system is a rather complicated process, but its result is obvious for the agro-industrial complex industry." It is not fully clear what is new in this conclusion. In general, similar questions arise in the whole article. The author should clearly indicate what is new in the article he offers, as well as how his author's approach should be distinguished from existing approaches on the stated topic. Secondly, the authors have made generalizations of practice, including the practice of various courts. Specific conclusions should be drawn, in which the generalizations proposed by the author can be useful for the practical activities of lawyers. At the same time, the author's analysis itself, as it is, may be of interest after clarifying the author's position and "highlighting" a specific scientific novelty. Thus, the materials of the article may be of particular interest to the scientific community in terms of developing a contribution to the development of science, but after clarifying the author's position. Style, structure, content. The subject of the article corresponds to the specialization of the journal "Agriculture", as it is devoted to legal problems related to the insurance of agricultural production. The content of the article fully corresponds to the title, since the author considered the stated problems and achieved the research goal. The quality of the presentation of the study and its results should be recognized as fully positive. The subject, objectives, methodology and main results of the study follow directly from the text of the article. The design of the work generally meets the requirements for this kind of work. No significant violations of these requirements were found. At the same time, a number of design issues need to be clarified. In particular, links should be in square brackets, not round ones. Bibliography. It is impossible to assess the quality of the literature used. The author, as confirmed by the bibliographic list, used only one scientific source (author: K. Svintsova), which cannot be considered satisfactory for an article of this level and subject. Thus, the works in the bibliography do not have a sign of sufficiency, do not contribute to the disclosure of various aspects of the topic. Appeal to opponents. The author has not conducted a serious analysis of the current state of the problem under study. Conclusions, the interest of the readership. The conclusions are fully logical, as they are obtained using a generally accepted methodology. The article may be of interest to the readership in terms of the systematic positions of the author in relation to the stated problems after clarifying the author's position. Thus, the article can be recommended for publication, but only after eliminating the comments (clarifying the author's position, adding scientific literature, bringing an appeal to opponents, carrying out some editorial clarification on the design of the article). Based on the above, summing up all the positive and negative sides of the article, "I recommend sending it for revision"

Second Peer Review

Peer reviewers' evaluations remain confidential and are not disclosed to the public. Only external reviews, authorized for publication by the article's author(s), are made public. Typically, these final reviews are conducted after the manuscript's revision. Adhering to our double-blind review policy, the reviewer's identity is kept confidential.
The list of publisher reviewers can be found here.

A REVIEW of an article on the topic "The mechanism of legal regulation of agricultural production insurance as a way to ensure food security of the country". The subject of the study. The article proposed for review is devoted to the mechanism of "... legal regulation of agricultural production insurance as a way to ensure the country's food security." The author has chosen a special subject of research: the proposed issues are investigated from the point of view of civil, agricultural and insurance law, while the author notes that "Most civilized countries of the world use a number of mechanisms to create favorable working conditions in agriculture that reduce the impact of adverse factors on the results of their economic activities." The NPA and judicial practice of Russia relevant to the purpose of the study are being studied. A certain not very large volume (6 titles) of scientific literature on the stated issues is also studied and summarized, analysis and discussion with these opposing authors are present. However, there are other authors who also study this problem and write about it, but for some reason the author did not mention them. At the same time, the author notes: "In the Russian Federation, one of the main mechanisms for protecting the property interests of agricultural producers from the negative effects of natural phenomena is production insurance. This ensures a certain financial stability and stability of economic entities and, undoubtedly, allows us to increase the country's food security." Research methodology. The purpose of the study is determined by the title and content of the work: "An undeniable fact is an increase in the probability of the risk of insurance events as a result of adverse natural phenomena, which primarily negatively affects the functioning of agricultural enterprises and, especially, in the crop industry", "Insurance protection is carried out on the basis of agricultural insurance contracts with state support, in which 50% insurance premiums are paid by the agricultural producer." They can be designated as the consideration and resolution of certain problematic aspects related to the above-mentioned issues and the use of certain experience. Based on the set goals and objectives, the author has chosen a certain methodological basis for the study. The author uses a set of general scientific, special legal methods of cognition. In particular, the methods of analysis and synthesis made it possible to generalize some approaches to the proposed topic and partially influenced the author's conclusions. The most important role was played by special legal methods. In particular, the author used a formal legal method, which allowed for the analysis and interpretation of the norms of current legislation and judicial practice. In particular, the following conclusions are drawn: "Currently, the severity of problems related to the procedure for subsidizing agricultural producers and the mechanism of state support has weakened," etc. Thus, the methodology chosen by the author is fully adequate to the purpose of the article, allows you to study many aspects of the topic. The relevance of the stated issues is beyond doubt. This topic is one of the most important in Russia, from a legal point of view, the work proposed by the author can be considered relevant, namely, he notes "The implementation of insurance protection of agricultural producers from adverse natural phenomena is carried out on the basis of the voluntary insurance mechanism enshrined in Federal Law No. 260-FZ dated 07/25/2011." And in fact, an analysis of the work of opponents and NPAs should follow here, and it follows and the author shows the ability to master the material. Thus, scientific research in the proposed field is only to be welcomed. Scientific novelty. The scientific novelty of the proposed article is beyond doubt. It is expressed in the specific scientific conclusions of the author. Among them, for example, is the following: "Legal regulation of the mechanism of the insurance system aimed at expanding insurance products, insurance of the most likely risks, increasing the responsibility of the authorized body of the subject of the Russian Federation for information, advisory and legal support of contracts will contribute to the expansion of agricultural insurance in the country." As can be seen, these and other "theoretical" conclusions can be used in further research. Thus, the materials of the article as presented may be of interest to the scientific community. Style, structure, content. The subject of the article corresponds to the specialization of the journal "Agriculture", as it is devoted to the mechanism of "... legal regulation of insurance of agricultural production as a way to ensure food security of the country." The article contains analytics on the scientific works of opponents in a limited number, so the author notes that a question close to this topic has already been raised and the author uses some of their materials, discusses with opponents. The content of the article corresponds to the title, as the author considered the stated problems and achieved the goal of his research. The quality of the presentation of the study and its results should be recognized as improved. The subject, objectives, methodology, research results, and scientific novelty directly follow from the text of the article. The design of the work meets the requirements for this kind of work. No significant violations of these requirements were found. Bibliography. The quality of the literature presented and used should be assessed. However, the presence of additional modern scientific literature would show even greater validity of the author's conclusions. The works of these authors correspond to the research topic, have a sign of sufficiency, and contribute to the disclosure of many aspects of the topic. Appeal to opponents. The author has analyzed the current state of the problem under study. The author describes the opponents' different points of view on the problem, argues for a more correct position in his opinion, based on the work of individual opponents, and offers solutions to individual problems. Conclusions, the interest of the readership. The conclusions are logical and specific "... in the context of increasing natural and climatic instability in the field of agricultural production, it is difficult to find an alternative to the insurance system to create a certain financial guarantee for producers and food security of the country." The article in this form may be of interest to the readership in terms of the systematic positions of the author in relation to the issues stated in the article. Based on the above, summing up all the positive and negative sides of the article, I recommend "publishing" taking into account the comments.