FAQs On Cover Crops And NRCS Guidelines

The USDA’s Risk Management Agency (RMA) released Frequently Asked Questions (FAQs) on cover crop management and the Natural Resources Conservation Service (NRCS) Cover Crop Termination Guidelines.

“These questions and answers provide valuable information for producers who want to take advantage of the conservation benefits cover crops provide while remaining in compliance with federal crop insurance rules,” said Brian Frieden, director of RMA’s Springfield Regional Office.

Questions & Answers

The following are Frequently Asked Questions concerning cover crops, the NRCS Guidelines, and crop insurance for the 2014 crop year:

Q. What are cover crops?
A: A crop generally recognized by agricultural experts as agronomically sound for the area for erosion control or other purposes related to conservation or soil improvement. Cover crops include grasses, legumes and forbs for seasonal cover and other conservation purposes. A cover crop, if managed and terminated according to the NRCS Guidelines, is not considered a “crop”.

According to the NRCS Guidelines, cover crops must achieve conservation purposes while minimizing the risks of reducing yields to the following crop due to soil water use. Conservation purpose includes reducing soil erosion, improving soil’s physical and biological properties, supplying of nutrients, and suppressing weeds. Please see your local NRCS office for a listing of appropriate cover crop species, seeding rates, expected growth rates and biomass, and other pertinent information necessary for your locale.

Q. Why were the cover crop guidelines developed, and who was involved?
A: With the increased use of cover crops among agricultural producers, questions and misunderstandings across USDA agencies arose. NRCS, RMA, and FSA united to develop cover crop termination guidelines to address these issues. More than 100 published articles, USDA crop growth models, the Precipitation Effectiveness Index (PEI), and regional and national crop experts contributed to the guidelines developed.

Q. Two different versions of the Cover Crop Termination Guidelines have been released – the first version in June 2013, and the second version in December 2013. Which version should I use?
A: For the 2014 crop year, crops with a June 30th, August 31st, and September 30th contract change date, the June 2013 version of the NRCS Guidelines are to be used. For the 2014 crop year, crops with November 30th or later contract change date, the December 2013 version is to be used.

The contract change date is the calendar date by which changes to the policy, if any, will be made available to the public. To find the contract change date for the insured crop in your county, visit our Actuarial Information Browser. Select the appropriate Reinsurance Year, complete the Crop information, and then click on the “Dates” tab. A contract change date of “June 30, 2013” is referred to as a June 30th contract change date (for the 2014 crop year).

Q. What does ‘Termination’ mean?
A: Termination means growth has ended for 100% of the cover crops, and it is the producer’s responsibility to ensure it is terminated according to the NRCS Guidelines.

Q. Can grazing be used as a form of terminating the crop?
A: A cover crop can be terminated by any means. However, termination means growth has ended for 100% of the cover crop. While grazing in some cases can terminate a cover crop, there is no definitive way to assure growth has ended which will vary based on weather, soil and the type of cover crop utilized. Moreover, grazing could use soil water needed by the insured crop. Regardless of termination method, it is the producer’s responsibility to ensure that 100% of the cover crop is terminated according to the NRCS Guidelines. If you have any question regarding which method is best for ensuring your cover crops is terminated, please consult your local Extension or NRCS office for guidance.

Q. In the Special Provisions statement that addresses the insurability of a crop following a cover crop, it states; “If growing conditions warrant a deviation from the guidelines, producers should contact either Extension or the local NRCS for management guidance”. What do I need to do to get an acceptable deviation from the NRCS Guidelines?
A: To receive a deviation from the NRCS Guidelines, you will need signed, written support from at least two agricultural experts indicating that the requested cover crop management utilized will not adversely affect the yields or quality of the insured crop and allow it to make normal progress toward maturity and produce at least the expected yield.

See Manager’s Bulletin MGR-05-010 for a list of approved agricultural experts.

Q. For my crop that follows a cover crop, what will happen if I do not follow the NRCS Guidelines in the management and termination of my cover crop?
A: Insurance will not attach to the crop following a cover crop not timely or properly terminated in accordance with the NRCS Guidelines. The Special Provisions statement specifies that insurability is dependent on three criteria: the cover crop 1) meets the definition provided in the Basic Provisions; 2) was planted in the last 12 months; and 3) was managed and terminated according the NRCS Guidelines. In the absence of receiving a deviation from following the NRCS Guidelines, failure to meet any one of the three criteria means insurance will not attach to the crop that follows the cover crop.

Q. I disagree with the zone to which my farm is assigned. Can I have my farm assigned to a different cover crop termination/management zone?
A: It is possible to have a different termination management practice approved for your farm, but you would remain in the same zone. If the county has unique topographical or geographic features which result in multiple climate zones within the county, a farm may be authorized different termination management practices compatible with the local climate and/or topographic location. To be authorized a different termination management practice, contact your local County Extension office or local NRCS office for specific cover crop management guidance for your farm. If this guidance results in a different cover crop termination time than your assigned zone, provide copies of the recommendation to your crop insurance agent. However, it should be noted that even under the different termination management practice, cover crops must be terminated no later than emergence of the insured crop.

Q. My insured crop will be irrigated. When do I need to terminate my cover crop?
A: According to the NRCS Guidelines, cover crops in an irrigated cropping system should be terminated based on the crop system and conservation purpose, but before the insured crop emerges.

Q. I live in Kansas in a county that is in Zone 2, and plan to plant non-irrigated corn. According to the guidelines, corn is an early spring seeded crop. Does this mean I can terminate my cover crop at planting instead of 15 days prior to planting?
A: Yes. For early spring seeded crops, such as corn, cover crops will have limited growth in the spring prior to seeding the ‘early’ spring crop, and therefore the cover crop may be terminated at or just prior to planting.

Q. I’m in zone 2, and will plant non-irrigated soybeans. The guidelines state I should terminate my cover crop at least 15 days before planting any insured crop. However, I started a new cover crop strategy on my farm over three years ago which does not impact soybean yields. Can I still insure my soybeans if I terminate the cover crop at planting time?
A: Yes, you can obtain authorization for a different termination management practice if you have adequate records. Generally you will need at least three years of production records from the cash crop that demonstrates the yield is not impacted by a later cover crop termination and you have written support of the later termination from two approved agricultural experts (see Manager’s Bulletin MGR-05-010 for a list of approved agricultural experts). However, it should be noted that even under an approved different termination management practice, cover crops must be terminated no later than crop emergence.

Q. My farm is in a zone 4 county, and I will plant non-irrigated soybeans. There are two non-irrigated crop insurance practices available in this county – FAC (i.e., Following Another Crop) and NFAC (i.e., Not Following Another Crop). If I do not follow the NRCS Guidelines in the management and termination of my cover crop, will my soybeans be considered FAC?
A: No. If you did not follow the NRCS Guidelines, your soybeans will not be insurable. The Special Provisions statement specifies that insurability is dependent on three criteria: the cover crop 1) meets the definition provided in the Basic Provisions; 2) was planted in the last 12 months; and 3) was managed and terminated according the NRCS Guidelines. In the absence of receiving a deviation from following the NRCS Guidelines, failure to meet any one of the three criteria means insurance will not attach to the crop that follows the cover crop. Also, for RMA purposes a cover crop is not considered a “crop”.

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