National Alfalfa & Forage Alliance Issues Public Comment on Federal Crop Insurance Rule

WASHINGTON, May 23 -- Beth C.W. Nelson, president of the National Alfalfa and Forage Alliance, St. Paul, Minnesota, has issued a public comment on the Federal Crop Insurance Corp.'s rule entitled "Common Crop Insurance Regulations: Forage Production Crop Insurance Provisions and Forage Seeding Crop Insurance Provisions". The comment was written on May 20, 2020, and posted on May 21, 2020:

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As President of the National Alfalfa & Forage Alliance, I appreciate the opportunity to comment on the Federal Crop Insurance Corporation's amendments to the Forage Production and Forage Seeding Crop Insurance Provisions. We believe strongly the proposed changes are sensible, prudent, and universally supported by forage farmers across the United States.

As you know, NAFA's Crop Insurance Advisory Committee has worked closely with Risk Management Agency representatives to address issues the industry felt were priorities in improving both the Forage Production and the Forage Seeding Crop Insurance Provisions. We believe the proposed changes are clear improvements to these programs and begin to address the industry's most important concerns.

A few of the most critical changes NAFA supports are:

* Establishing coverage of forage seeding for producers in 161 additional counties nationwide.

* Expanding coverage to fall-planted forage and aligning forage seeding cancellation and termination dates with the dates for other fall-planted crops in each state.

* Revising loss-adjustment procedures to rely upon the number of live alfalfa stems rather than the number of live plants for making loss determinations for forage containing more than 60 percent alfalfa.

NAFA has always maintained expansion of forage seeding coverage is one of the most critical needs of the alfalfa/forage industry in the U.S. Currently, many areas of the country still do not have access to forage seeding coverage, limiting the ability of forage farmers to mitigate risk against losses in the critical establishment phase of production. Expanding the program, as is proposed, will enhance alfalfa/forage production in those areas by limiting risk in the all-important first year of production.

Also included in the proposed amendments are revisions to loss-adjustment procedures to rely on the use of stems/ft.2 instead of plants/ft.2 for the purposes of determining in the spring whether a stand was established. We believe strongly, as do forage agronomists, stems/ft.2 are a much better predictor of potential yield than plants/ft.2

While expanding forage seeding coverage to an additional 161 counties is needed and welcomed, many of the country's most productive forage-producing areas in AZ, CA, NV, and UT remain uncovered. Further expansion of the program in these areas remains a critical need.

Additionally, proposed improvements to RMA's Forage Production coverage are beneficial. However, more needs to be done with this product to address a farmer's inability to insure against losses in quality and revenue (available to most other major crops). Unless more is done to improve this product, the Forage Production program will remain a seldom-used, inadequate risk management tool.

Thank you for the opportunity to provide comments during the process of amending the Forage Production and Forage Seeding Crop Insurance Provisions. We support the changes and look forward to their implementation.

If you should have any questions, please do not hesitate in contacting us.

Sincerely,

Beth C. W. Nelson, President

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The rule can be viewed at: https://www.regulations.gov/document?D=FCIC-20-0003-0001

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