PCG Position on Dryland Insurability Gains Support on Capitol Hill

A letter co-signed by House Agriculture Chairman Frank Lucas (R-OK) Representatives Randy Neugebauer (R-TX), Mike Conaway (R-TX), Mac Thornberry (R-TX) has been sent to USDA Risk Management Agency (RMA) Administrator William Murphy supporting the request of Lubbock-based Plains Cotton Growers that RMA reiterate the applicability of procedures in the 2011 Upland Cotton Loss Adjustment Standards Handbook.

PCG’s request does not ask RMA to alter any of its current procedures.

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Instead, PCG is asking the Agency to clarify for both growers and crop insurance providers that there are procedures in the 2011 Upland Cotton Loss Adjustment Standards Handbook that address the insurability of non-irrigated cotton planted into a terminated small grain cover crop under a conservation tillage practice when dry conditions make it difficult to fully terminate the small grain crop before heading.

A copy of PCG’s letter, as well as a copy of the letter sent by Chairman Lucas and Representatives Neugebauer, Conaway, Thornberry are available for review on the PCG website: http://www.plainscotton.org.

As of the time of this article, efforts to resolve the issue with USDA officials were ongoing by PCG and the Congressmen whose districts are being directly impacted by the situation and are supporting PCG’s request.

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In addition to the conservation-tillage question, PCG also is working toward a resolution on the treatment of volunteer wheat or other small grains in a field. At this time, volunteer wheat is being judged with the same zero-tolerance standard that small grain crops planted in the same calendar year are under the Upland Cotton Special Provisions for counties in Texas, Oklahoma and New Mexico.

Further, it appears that insurance providers are being told that there is no room for common sense to prevail when it comes to the presence of volunteer small grain plants in a field, even when their presence is not representative of the rest of the field.

The Conservation Tillage procedure, which has been in the Cotton Loss Adjustment Standards Handbook for at least a decade, instructs insurance providers to consider a small grain cover crop as “not headed out” when a conservation tillage practice is present and the grower attempted to kill the small grain cover crop in a manner which, under normal growing conditions, would result in the termination of the small grain prior to heading.
 

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