Two counterfactual analyses investigate the new ACRE program. Had ACRE existed instead of the programs authorized during 1996-2006 for corn, soybeans, and wheat, farm program spending would have totaled less. Estimated ACRE revenue payments increase 78 percent when calculated by applying the annual 1996-2006 percentage variations to USDA forecast average 2009-2012 acres, prices, and yields. Traditional marketing loan and counter-cyclical payments are estimated near zero. Policy design issues concern the merit of revenue versus price protection, fixed support targets versus support adjusting with lagged market revenue, and the economic dislocation and WTO compliance from alternative policy instruments.