60-day FRN Summary of Comments

Summary of Comments

Rural Investment to Protect Our Environment

• Better data on and understanding of costs of practice adoption are necessary

• Complexity of application processes, eligibility, and lack of flexibility limit enrollment in addition to inadequate payment rates

National Corn Growers Association

• Encourages consultation of technical and programming experts in addition to growers

• Suggests inclusion of multiple data sources on cover crop adoption

IL Corn Growers Association

• Suggest consideration of the following issues when finalizing questionnaire and sampling strategy:

  • Land ownership, as tenant farmers may face challenges if contracts require the landowner to be a signatory

  • Crop rotation, since cover crop management can be very different depending on the cash crop that follows

  • Program usage, as eligibility standards and other application related burdens decrease interest in programs

  • Technical assistance, particularly the role of the private sector in providing technical assistance in areas with limited local resources

  • Encourage inclusion of all farmers in the study, not only program participants to ensure multiple perspectives

Midwest Cover Crops Council

• Research into motivation of cover crop adoption and assessment of barriers would aid organizations in reaching non-adopters

• Recommend looking at a range of federal programs, including models of incentives similar to the Pandemic Cover Crop Program offered by the Risk Management Agency (RMA)

• Suggest assessing barriers through crop insurance as well as farmer preferences for incentives such as premium reductions and subsidies

AGree Coalition

• Encourage gathering information on the following topics:

  • Incentive payment structure, including payment amounts, ease of applying, and payment providers

  • Maintenance of practices after program participation, such as crop insurance premium reductions, flexibility related to haying/grazing for forage and availability of technical assistance

  • Farmer perceptions of crop insurance policy and interactions with adoption of conservation practices

  • Ease of application to programs

  • Requirements for seeding mixes, rates, and timing restrictions

Center for Rural Affairs

• Suggest distributing the survey outside the planting season

• Asking farmers about non-federal programs and localized models may provide useful information about cover crop adoption

• Recommend asking farmers about the Pandemic Cover Crop Program and other crop insurance programs

• Consider factors beyond costs and technical assistance that may motivate adoption

American Farmland Trust, National Wildlife Federation, and Natural Resources Defense Council

• Recommendations:

  • Asking farmers’ knowledge and use of the Pandemic Cover Crop Program and perceptions related to interactions between crop insurance and conservation programs

  • Explore personal experience and attitude related barriers as well as financial/technical barriers to adoption

  • Include questions about a variety of programs, including state programs

  • Include questions about technical assistance

  • Ensure utility of all survey questions

  • Consider the use of an incentive for completion of the survey