FAQs On Cover Crops And NRCS Guidelines
Q. I was prevented from planting my insured crop, and I would like to establish a cover crop on the prevented planted acreage. My crop insurance agent explained that the NRCS Guidelines will not apply to this cover crop, and I need to be cognizant of the haying and grazing restrictions. Why is that?
A: The NRCS Guidelines are applicable in determining the insurability of a crop that follows a cover crop. According to the Special Provisions statement in the actuarial documents, insurance shall attach to the crop following a cover crop if among the three conditions stated in question 6 above, the cover crop, is managed and terminated according to the NRCS Guidelines.
Once the insurability criteria in the Special Provisions statement has been established, the crop is insurable. For cover crops that follow a prevented planting determination on an insurable crop, rules and regulations in the Prevented Planting Loss Adjustment Standards Handbook will apply. Generally, once you receive a prevented planting payment you can later plant a cover crop on the prevented planting acreage but YOU CANNOT hay or graze that cover crop before November 1, (and cannot otherwise harvest anytime), or you will impact your prevented planting payment.
Q. I was prevented from planting my insured crop, and the prevented planting was not caused by the cover crop. I would like to establish a new cover crop to replace the terminated cover crop after the later of the final planting date or the late planting period (when applicable). Do I still qualify for full prevented planting coverage for my insured crop?
A: It depends. If the new cover crop (the one planted on prevented planting acreage) is not hayed or grazed prior to November 1, or is not otherwise harvested at any time, the full prevented planting payment may be available. The rules and regulations associated with haying, grazing and harvesting of cover crops planted on prevented planted acreage are specified in the Prevented Planting Loss Adjustment Standards Handbook.
Q. Can I graze or harvest hay or silage from my cover crop prior to termination?
A: It depends. 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, which states: cover crops can be grazed but not hayed. If they are hayed, or harvested for grain or seed, etc., double crop restrictions may be applicable which may adversely affect the insurability of the following crop.
For the 2014 crop year, crops with a November 30th contract change date, the December 2013 version is to be used, which states: In all areas of the country and for all crops, except for crops insured under the RMA summerfallow practice in Zones 1, 2 and 3 (see below for more information summerfallow practice), cover crops may be grazed or harvested as hay or silage as long as the planned amount of biomass is available at the time of termination to meet the conservation purpose. A cover crop harvested for grain or seed will not be considered to have been planted for conservation purposes and will be considered a “crop”.
For the RMA designated summerfallow practice for crops with an 11/30 contract change date, cover crops cannot be hayed or grazed, or otherwise harvested. If the cover crop is hayed, grazed or otherwise harvested in any manner, or is not terminated in accordance with NRCS termination guidelines, it will be considered a crop and the acreage will not be eligible for the summerfallow practice until the acreage lies fallow for a full crop year.
Q. In My farm is in a Zone 4 county. The NRCS Guidelines state that I must terminate my cover crop at or within 5 days after planting, but before crop emergence. Can I terminate my cover crop prior to planting (e.g. several weeks prior) and still be in compliance with the NRCS Guidelines?
A: Yes. You can terminate the cover crop prior to planting your insured crop. The intent of the termination language for Zone 4 was to give the latest time periods to terminate. For Zone 4, the latest you can terminate the cover crop is before your insured crop emerges.
Q. My farm is in zone 2 and I will be planting non-irrigated soybeans. I plan to terminate my cover crop 15 days prior to planting. However, the weather and planting conditions this spring allows earlier than normal planting. I terminated the cover crop 5 days ago, but seedbed conditions and temperatures are right to plant now. Can I plant after 5 days, or must I wait 15 days?
A: In this case, with favorable weather and soil conditions, the good farming practice would be to plant under the ideal planting conditions. It is not necessary to wait 15 days. However, for crop insurance purposes, you must document the weather and soil conditions that support the earlier than normal planting conditions.
Q. My fields and the crops I planted are susceptible to wind erosion abrasion. My typical practice is to plant a cover crop of spring oats prior to or during planting of my insured susceptible crop. I then terminate the oat cover crop once the insured susceptible crop is established and the soil is protected from wind erosion. This does not fit any of the cover crop management zones. Can I insure my crop?
A: Yes. This is a special consideration within the cover crop termination guidelines to allow growing a protective cover crop during the establishment of a wind erosion susceptible crop, which would be considered a good farming practice.
Q. Will over-seeding/interseeding a conservation cover crop into an insured grain crop affect insurability?
A: No, as long as the cover crop is seeded near physiological maturity of the insured crop and the practice does not interfere with harvest, of the insured crop. If there was any damage caused by over-seeding the cover crop (although unlikely), uninsured cause of loss appraisals would be applied to the insured crop.
Q. Will interplanting a conservation cover crop into an insured grain crop affect insurability?
A: No, not if the cover crop and a cash crop are planted in a way that permits separate agronomic maintenance or management, then RMA will insure the cash crop. However, RMA will not insure the cash crop if the cover crop that is interplanted into a cash crop interferes with the agronomic management and the harvest of the cash crop.
Q. RMA has stated for some crops that have a summerfallow practice, RMA will allow cover crops to be planted during the fallow period without jeopardizing eligibility for the summerfallow practice. For other crops, cover crops cannot be planted during the fallow period. Please explain the reason.
A: For the 2014 crop year, crops with June 30th contract change date, the June 2013 version of the NRCS Guidelines is to be used. For those crops, which include winter wheat, and most spring wheat and barley, cover crops cannot be planted during the fallow period without jeopardizing eligibility for the summerfallow practice the following crop year. RMA is currently developing 2015 crop year provisions for these crops that will be released in June 2014.
For 2014 crop year crops with a November 30th contract change date, which includes some spring wheat, spring barley and other spring planted small grains, the December 2013 guidelines are applicable. For these crops, producers can plant cover crops during the fallow period provided they are managed and terminated according to the NRCS Guidelines (December 2013 version). There is no impact on summerfallow eligibility for the next crop year (provided the cover crops are not hayed, grazed or otherwise harvested).
Source: USDA Risk Management Agency