Can unobserved heterogeneity in farmer ability explain the inverse relationship between farm size and productivity

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Fact or artefact : the impact of measurement errors on the farm size - productivity relationship (2011, background): “Assunçao and Ghatak (2003) demonstrate how theoretically unobserved heterogeneity in farmer quality may explain the observed differences in productivity.”
Land productivity and plot size : is measurement error driving the inverse relationship ? (2017, unknown): “…intuitive, explanation for the farm-size IR is missing land, labor, credit, or insurance markets; missing markets have been found to explain differences in land productivity between households (Assunção and Ghatak, 2003; Barrett, 1996; Carter and Wiebe, 1990; Eswaran and Kotwal, 1986; Feder, 1985).”