Source: NATIONAL SUSTAINABLE AGRICULTURE COALITION, 11/4/14


On Wednesday, October 29, the Natural Resource Conservation Service (NRCS) issued a second revision to the Cover Crop Termination Guidelines document that was first issued in June of 2013.
This second revision modifies the rules for grazing a cover crop, adds a definition of a cover crop, and defines when a cover crop is considered terminated.

• Grazing Consideration—Cover Crop Grazing or Forage Harvest – Cover crops may be grazed or harvested as hay or silage, unless prohibited by a specific RMA crop insurance policy provision. Cover crops cannot be harvested for grain or seed.
• Definition of Cover Crop—Crops, including grasses, legumes, and forbs, for seasonal cover and other conservation purposes. Cover crops are primarily used for erosion control, soil health improvement, and water quality improvement. A cover crop managed and terminated according to these guidelines is not considered a “crop” for crop insurance purposes. The cover crop may be terminated by natural causes such as frost, or intentionally terminated through chemical application, crimping, rolling, tillage, or cutting.
• Definition of Termination—Termination means growth has ended.

It also adds a clarifying consideration for the use of Summerfallow Practice crop insurance.

Consideration #13: RMAs Summerfallow Practice.—If a crop, or a cover crop, is planted on summerfallow acreage in a fallow year, the following planted crop will not meet the RMA “Summerfallow Practice” definition until the acres lie fallow for a full crop year.  For the 2015 crop year, if a cover crop was planted during the fallow year, the acreage may be insured under the “continuous cropping practice” (if available in your county), or by written agreement (if continuous cropping is not available in your county).  For the 2016 and succeeding crop years, if a cover crop is planted during the fallow year, the acreage may be insured under the “continuous cropping practice” (if available in your county), or by written agreement (if continuous cropping is not available in your county) provided the cover crop is terminated at least 90 days prior to planting for summer and fall seeded crops.  For early spring seeded crops, terminate the cover crop in the fall or as early as possible in the spring.  Please contact your crop insurance agent for more information.

In a summerfallow system a farmer leaves a field fallow for an entire year between cash crops in order to allow soil moisture to recover.  This practice is used in low rainfall areas across the Western United States.  Farmers utilizing this system insure their crops under the RMA’s “summerfallow practice” as opposed to its “continuous cropping practice,” which has a different rate structure.  In some counties where summerfallow is used, “continuous cropping practice” insurance may not be available except by written agreement.

This new clarification indicates that a farmer cannot plant a cover crop on summerfallow acres within a year of planting a cash crop on those acres and insure it under the RMA’s “summerfallow practice.”  In order to utilize a cover crop on summer fallow acres and be able to insure the following cash crop they will have to insure it using RMA’s “continuous cropping practice.”  Shifting from insuring under summerfallow to a continuous cropping practice policy means that that farmer using cover crops will have to re-establish an actual production history under the continuous cropping practice, creating an unfortunate, continuing barrier to the adoption of cover crops in these counties.
The complete final version of “Cover Crops Termination Guidelines” can be found on the RMA website.

The first revision of the “Cover Crop Termination Guidelines” document was released in in December 2013.  That revision brought uniformity and clarity to the guidelines issued in June of that year.
NSAC and the National Center for Appropriate Technology (NCAT) partnered with the Risk Management Agency to host a webinar to explain the guidelines in January 2014.

The need for revised guidelines arose out of a concern that farmers planting cover crops could lose their eligibility for crop insurance coverage of the following crop.  USDA’s previous calendar date specific guidelines were very rigid whereas the new guidelines are tied to the planting dates of the cash crop.  An interagency taskforce developed the new Cover Crop Termination Guidelines document that addresses this concern, using science-based cover crop management guidelines developed and approved across USDA.