WASHINGTON, May 29, 2014 - Socrates said, “The secret of change is to focus all of your energy, not on fighting the old, but on building the new.” Change can be painful and takes a good amount of time and energy. Never is that more true than in government. Often, innovations in science and technology take place long before government has a chance to respond and adapt. Even though agriculture is a dynamic industry, constantly innovating and changing, there is always a lag time between innovation and policy.
There’s nothing new about cover crops – during the Roman Empire, farmers used legumes to improve soil in vineyards – but cover crop policy is very new and still going through some growing pains. Agriculture risk management policy took root in modern agriculture, after synthetic fertilizers had replaced cover crops for enhancing soil fertility. And when cover crops made a comeback over the last decade, USDA’s Risk Management Agency (RMA) policies lagged behind innovation.
Adding to the confusion, RMA is still reeling from the crop insurance abuse in the 1990s when many farmers were caught planting as many as three doomed crops a year during a drought and claiming losses on each one. To prevent further fraud, The Agriculture Risk Protection Act of 2000 created the first crop/second crop rule, stipulating that only the first crop could be insured. Even though cover crops are a practice and not an insured crop, they still bring back bad memories for RMA.
Good vs. bad farming practice
The federal crop insurance program does not cover losses due to negligence or failure to follow what they consider Good Farming Practices. Yet, if you ask USDA for a list of Good Farming Practices, you’ll come away empty handed, because they are defined more by what they are not instead of what they are. For instance, not using enough seed or fertilizer would be considered bad farming practice and render your crop uninsurable. And sometimes, new and innovative practices – like cover crops – can be mistaken for bad farming practice because many agricultural experts do not yet know about them.
RMA’s micro-management of cover crops is based on fears that cover crops could potentially have a negative impact on the yields of the subsequent insured crops. What if the cover crop uses too much water and nutrients or invites weeds and pests? What if the cover crop prevents the producer from planting the cash crop within the acceptable timeframe?So to limit losses, RMA has enacted guidelines on cover crops. In just the past three years, RMA has enacted numerous rules and changes to the rules, directing specifically how farmers use cover crops before, during or after, the production of an insured commodity crop. In the 2013 cropping year alone, RMA promulgated two changes to cover crop guidance.
While there is potential for farmers to experience yield declines with cover crops, the overwhelming experience and farm yield data shows cover crops improve yields of the subsequent insured crops. In a 2012 survey, the Conservation Technology Information Center (CTIC) found that corn following cover crops had a 9.6 percent yield increase and soy improved 11.6 percent after cover crops.
Why just cover crops?
And when put into the larger context of crop insurance and farming, it becomes quite clear RMA is uniquely applying this skepticism only to cover crops. There are at least 74 practices farmers can implement that might have a negative impact on crop yields, yet RMA has not enacted a single rule or regulation on any of these practices:
- Amount of fall applied nitrogen.
- Timing of fall applied nitrogen.
- Form of fall applied nitrogen.
- Ignoring subsurface compaction.
- Ignoring surface compaction.
- Allowing excessive sheet erosion.
- Allowing excessive rill erosion.
- Excess tillage leading to increases in soil bulk density.
- Excess tillage leading to lost soil organic matter, which holds water and nutrients for crops.
- Excess tillage leading to reduced soil porosity and water infiltration.
- Excess tillage leading to delayed planting due to slow soil warm up with the need for excess passes across the field.
- If tilling, leaving numerous soil clods resulting in poor seed to soil contact or uneven seeding depth.
- Not removing rocks from the soil surface, which tend to accumulate at the surface with tillage, resulting in uneven planting depth and reduced plant populations.
- Planting a seed variety not well adapted for the climate.
- Planting a seed variety not well suited for the soil type.
- Planting a seed variety not well suited for the plant population.
- Not maintaining a level planter.
- Worn opener disks on the planter.
- Poor singulation by the planter.
- Worn seed firmers on the planter.
- Worn bearings on the closing wheels on the planter.
- Worn closing wheels on the planter.
- Inadequate down pressure on the closing wheels for the specific conditions.
- Excessive down pressure on the closing wheels for the specific conditions.
- Wrong type of closing wheels on the planter.
- Coulter set deeper than the opening discs.
- Planting depth set too deep.
- Planting depth set too shallow.
- Using worn/uneven gauge wheels, resulting in inconsistent planting depth.
- Applying too much fertilizer in-row.
- Applying too little fertilizer in-row.
- Sidedressing too much fertilizer.
- Inadequate sidedress of fertilizer.
- Form of in-row fertilizer used.
- Form of sidedress fertilizer used.
- Planting too fast, leading to poor seed placement.
- Running tractor/planter wheels over planted seed rows, leading to surface compaction.
- Planting into excessively tilled soil, resulting in surface crusting.
- Planting into soils that are too cold, leading to slow/poor/uneven emergence.
- Planting into excessively wet soils, leading to seedling diseases.
- Planting up steep hills, leading to in row washout of seed/nutrients.
- Planting in low areas in wet years (for this practice and the next, while seemingly quite unfair in asking farmers to be able to predict the weather, these can nonetheless can impact yields, in addition to the fact that some RMA rules on cover crops essentially require farmers to be able predict the weather if using cover crops).
- Planting in drought-prone soil in dry years.
- Removing all residue from the prior crop allowing the soil and roots to get too hot.
- Leaving too much residue on the soil surface, causing poor soil drying and warm up.
- Applying correct herbicides too early.
- Applying correct herbicides too late.
- Not adjusting water pH in herbicide application for herbicide needs.
- Excess nozzle pressure on sprayer.
- Inadequate nozzle pressure on sprayer.
- Incorrect nozzle type on sprayer.
- Excess sprayer pass over-lap.
- Skipped areas during sprayer passes.
- Spraying herbicides in the evening/too late in the day.
- Spraying herbicides too early in the morning during heavy dew.
- Applying in-season fertilizer when not needed.
- Applying in-season fertilizer too close to the root.
- Applying in-season fertilizer too far from plants to reach.
- Using worn coulters or knives on the fertilizer applicator.
- Not addressing micro-nutrient needs
- Mixing some foliar fertilizers with some herbicides.
- Applying foliar fertilizers, herbicides, other chemical applications, right before a rain.
- Not using fungicide seed treatments (for seed treatments, most years will see little to no yield boost, but some years will see a significant yield advantage due to weather conditions causing disease or pest outbreaks).
- Not using insecticidal seed treatments.
- Applying fungicides too soon/late.
- Applying fungicides under poor conditions.
- Not maintaining combine head resulting in poor cutting of stalks/plants.
- Harvesting too fast, resulting in missed crops.
- Harvesting with combine sieves too close together for crop conditions, resulting in grain not getting captured.
- Harvesting with combines sieves too far apart for crop conditions, resulting in excess foreign matter in the grain resulting in dockage at the elevator or grain loss due to moisture.
- Harvesting with excessive combine cylinder speed for crop conditions, resulting in shattered grain.
- Harvesting with inadequate combine cylinder speed for crop conditions, resulting in grain remaining attached to cob/pod/head and being lost.
- Chaff spreader not spreading residue the width of the header, resulting in windrowed material, leading to uneven nutrients and planting conditions (for not till planting) for the following season.
- Not managing for weeds in prevented plant acres, resulting in significant long-term weed challenges for subsequent growing seasons.
Not only are there no rules on these potentially yield-impacting practices, but the decision to use or not use any one of these practices would likely not even come up in an insurance company analysis of whether a producer used Good Farming Practices. RMA would simply defer to the judgment of the producer and advice of local agronomic experts. The assumption is, the yield impacts of these 74 practices would feed into the Approved Production History (APH) and therefore, would eventually be reflected in the level of insurance coverage available to a producer. However, the availability and implementation of any of these practices can vary from year to year (just like cover crops) and their yield impacts will depend on the weather (just like cover crops).
Considering all of that variability and the time it takes to impact APH to reflect new practices, APH is a poor means of addressing – or in many cases ignoring – the risk of any one specific practice.
Additionally, RMA treats cover crops differently than other practices when it comes to weather and how it impacts the management or implementation of the practice. If a producer using cover crops experiences a weather caused delay, RMA rules still require them to obtain special guidance from NRCS or extension on approved cover crop termination. This requirement is not placed on any other practice, even though a weather delay or missed application of any practice could just as easily result in significant yield declines for the insured crop.
This is an important distinction by RMA. In the event bad weather causes farmers to delay or entirely miss one of the agronomic practices listed, all yield losses would be considered insured. However, if that delayed or omitted practice involves cover crops and a farmer did not get a note from NRCS or miss a specific RMA deadline by even one day, it is possible that farmer could lose his or her crop insurance coverage entirely.
Bring on the new
Yes, change is difficult and it will always take time for government to catch up with innovation. But it’s time that RMA embrace Socrates’ secret and focus building the new approach to cover crops and Good Farming Practices.
Because frankly, if RMA were to apply the same level of scrutiny to each of these 74 practices as they have for cover crops, if they had to design new rules and guidelines, articulating the proper use and implementation of each of these 74 practices, then changing, tweaking and updating them twice a year, they would have to triple their staff and work in shifts around the clock.
And if America’s producers had to endure the same level of oversight and micromanagement for each of these 74 practices, trying to keep up with changes in the rules and guidelines twice per year and were punished for failing to do so, the fields would soon be empty and the supermarket shelves bare.
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