PCG Requests Clarification on Dryland Insurance Questions

Ongoing drought conditions in 2011 have been wrecking the best-laid plans of both irrigated and dryland cotton producers in the Texas, Oklahoma and New Mexico production regions.

Because of the extreme situation many growers find themselves in this year, a variety of questions have been raised regarding how these conditions will impact their risk management program, and specifically their ability to insure dryland cotton under the federal crop insurance program.

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While growing conditions are tough for everyone, dryland growers who utilize conservation tillage practices that incorporate small grain cover crops – like terminated wheat or rye – have a lot of questions and few, if any, definitive answers.

In order to bring clarity to the situation, Lubbock-based Plains Cotton Growers, Inc. (PCG) has sent a letter to USDA Risk Management Agency Administrator William Murphy requesting that he reinforce the applicability of procedures included in the Upland Cotton Loss Adjustment Standards Handbook regarding small grain crops utilized in a conservation tillage system.

Essentially PCG’s request involves asking the Agency to remind Approved Insurance Providers (AIPs) that the Upland Cotton Loss Adjustment Handbook recognizes that in certain situations a moisture stressed small grain cover crop can be difficult to terminate and will sometimes produce a few heads even after appropriate efforts, applied in a manner that would terminate the crop before heading occurs under normal growing conditions, are undertaken.
In these instances, the Upland Cotton Loss Adjustment Standards Handbook instructs the insurance provider to consider the small grain crop to have not headed out if the grower is practicing a conservation tillage program and also attempted to terminate the small grain crop before heading using recommended practices.

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In situations other than a conservation tillage practice, RMA’s Upland Cotton Special Provisions of insurance for counties in Texas, Oklahoma, and New Mexico has, since 2002, said that non-irrigated cotton is uninsurable following a small grain crop in the same calendar year if the small grain crop is: harvested or hayed; allowed to reach the headed stage (regardless of the percentage of small grain plants that reach the headed stage), or was grazed past March 15.

Both growers and the federal crop insurance program have long recognized the benefits to conservation tillage practices in dryland production systems. In light of those benefits, PCG has encouraged the Agency to recognize the applicability of the procedures addressing small grain cover crops utilized in a conservation tillage practice and prevent growers from inadvertently being denied coverage on non-irrigated cotton acres in 2011.
 

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