Feasibility Report for Insuring Irrigation

Indefinite Delivery Indefinite Quantity Contract for 

Insuring Irrigation

Task Order 1: Limited Irrigation Analysis & Evaluation

Deliverable 2: Limited Irrigation Feasibility Report

Contract Number: D13PC00032

Order Number: D13PD00306

Submitted to:

USDA-RMA

COTR: Claire White

6501 Beacon Drive

Kansas City, Missouri 64133-4676

(816) 926-5131

Submitted by:

Watts and Associates, Inc.

4331 Hillcrest Road

Billings, Montana 59101

(406) 252-7776

twatts@wattsandassociates.com

Due Date: May 23, 2013

This document includes data that shall not be disclosed outside of the Government and shall not be duplicated, used, 

or disclosed, in whole or in part, for any purpose. The Government shall have the right to duplicate, use, or disclose 

the data to the extent provided in Contract D13PC00032. All pages of this document are subject to this restriction.
Feasibility Report for Insuring Irrigation

Use or disclosure of information or data Risk Management Agency

contained on this sheet is subject to the Order Number: D13PD00306

restrictions on the title page of this report.

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Table of Contents

Section I. Executive Summary........................................................................................................ 1

Section II. Introduction ................................................................................................................... 4

Section III. Data Availability and Applicability........................................................................... 19

Section IV. Analysis of the UNL Model ...................................................................................... 29

Section V. Analysis of the RMA Underwriting Draft .................................................................. 36

Section VI. Rating Approaches..................................................................................................... 39

Section VII. Stakeholder Input ..................................................................................................... 58

Section VIII. Impact of Implementation....................................................................................... 61

Section IX. Research Findings...................................................................................................... 66

Section X. Recommendations....................................................................................................... 74

List of Tables

Table 1. United States Specified Field and Row Crops by Extent of Irrigation 

on Individual Farms, 2007.............................................................................................. 20

Table 2. Total Irrigated Acreage in the Three Study States by Irrigation Type, 2008 ................. 21

Table 3. Total Number of Irrigated Farms in the Three Study States by Irrigation Type, 2008 .. 21

Table 4. Irrigated and Non-Irrigated Production of Corn and Soybeans 

in the Study States, 2008 ................................................................................................ 22

Table 5. Counties Reporting Corn Production to NASS, by Study State, 2008 ........................... 23

Table 6. Metadata on County-level Corn Yields (bushels/acre) in the Study States, 2008.......... 24

Table 7. Aggregate Annual Crop Year Precipitation (Inches) in Sheridan County, 

1972 through 2012.......................................................................................................... 26

Table 8. Correlations between Precipitation (inches) in Sheridan County and Crop Yields 

(Bu/Acre) by Irrigation Approach, 1972 through 2010.................................................. 27

Table 9. Relationship between Total Annual Crop Year Precipitation and Yield Boost 

from Full Irrigation......................................................................................................... 31

Table 10. Relationship between total Growing Season Precipitation and Yield Boost 

from Full Irrigation....................................................................................................... 31

Table 11. Yields and Actuarial Data for Corn for the 2011 Crop Year, 

Sherman County, KS and Perkins County, NE ............................................................ 40

Table 12. Reported Acres, Premium, Indemnity, and Liability for Ranges of 

Approved Yields, Sherman County, KS and Perkins County, 

NE for 2011 Crop Year ................................................................................................ 41

Table 13. UNL Yield Adjustment Table for Limited Irrigation, Sherman County, KS ............... 43

Table 14. Estimated Yield Levels, Premium Rates (65% Coverage Level), 

and Premiums per Acre for Corn, Sherman County, KS and 

Perkins County, NE with UNL Adjustment Factors Incorporated 

Using Non-irrigated Reference Yield as the Base (2011 Crop Year Parameters)........ 46

Table 15. Indicated Yields, Premium Rates, and Total Premiums Associated with Water 

Reductions Assuming Historical Use of 15 Inches of Water, 

Sherman County, KS and Perkins County, NE ............................................................ 48

Table 16. Policy Number Counts, Ranges of Approved Yields, and Increases 

in Approved Yields for Irrigated Practice for Policy Numbers with 

Both Irrigated and Non-irrigated Practice, Sherman County, KS and 

Perkins County, NE, 2011 Crop Year .......................................................................... 49
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Table 17. Average Difference of Irrigated Yield Relative to Non-irrigated Yield 

on Policies with Both Practices and Reported Acres ................................................... 51

Table 18. Acres Insured, Guarantees per Acre, and Premiums for Irrigated and Non-irrigated 

Practices Separately Insurable in a Quarter-Section with Pivot Irrigation System ...... 53

Table 19. Acres Insured, Guarantee per Acre, and Premium for Irrigated Practice 

when Corners of a Center-pivot Irrigation System are Included 

in the Irrigated Practice Acreage .................................................................................. 54

Table 20. Acres Insured, Guarantees per Acre, and Premiums for Irrigated 

and Non-irrigated Practices Separately Insurable in a Quarter-Section 

with Pivot Irrigation System, Irrigated Yield is Reduced by 86.8 Bushels per Acre ... 54

Table 21 Acres Insured, Guarantee per Acre, and Premium for Irrigated Practice 

when Corners of a Center-pivot Irrigation System are Included in the 

Irrigated Practice Acreage and Yield is Reduced by 86.8 Bushels per Acre................. 55

Table 22. Acres Insured, Guarantee per Acre, and Premium for Irrigated Practice 

when Corners of a Center-pivot Irrigation System are Included in the 

Irrigated Practice Acreage and Yield is Reduced Proportionately 

by 68.1 Bushels per Acre.............................................................................................. 55

Table 23. A Comparison of Irrigation in Colorado, Kansas, and Nebraska in 2003 and 2008 .... 66

List of Appendices

Appendix A. Samples of Available Data

Exhibit 1. NASS 2008 Quick Stats 2.0 Data for Corn, by County in Colorado, Kansas, and 

Nebraska

Exhibit 2. Daily Precipitation Data for the Growing Season (April 1through September 30), 

Sheridan County, Kansas, Every Fifth Year 1972 to 2012

Exhibit 3a. Cumulative Precipitation Metadata for Five Study Area Counties, Crop Years 

1951 through 2012

Exhibit 3b. Annual Crop Year Precipitation for Five Study Area Counties, Crop Years 1951 

through 2012

Appendix B. Stakeholder Input

Exhibit 1. Listening Session Agenda

Exhibit 2. Press Release

Exhibit 3. Newspaper Advertisement

Exhibit 4. Stakeholder Comments

Appendix C. Documentation Tool for Written Agreements Regarding Limited Irrigation
Feasibility Report for Insuring Irrigation

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1

SECTION I. EXECUTIVE SUMMARY

This second deliverable under the Indefinite Delivery Indefinite Quantity (IDIQ) Contract 

for Insuring Irrigation has two fundamental purposes: 1) to evaluate the yield adjustment 

tables established by the University of Nebraska – Lincoln (UNL) for corn and soybeans 

in Colorado, Kansas, and Nebraska, and 2) to evaluate whether it is feasible to insure 

acreage to which a reduced amount of water is applied as irrigated practice. The 

Government posed several questions in the Task Order relating to these topics.

For the reasons summarized below, the Contractor believes the UNL tables are not the 

appropriate vehicle for managing the crop insurance offer when the amount of water 

applied to a unit is reduced. However, the Contractor believes feasible approaches are 

possible. More development of alternatives is needed.

The UNL tables fundamentally are based in a plant growth model, models that are 

notorious for ability to predict in-sample (i.e., replicating the results of the data used for 

estimation), but for lack of predictive ability out-of-sample (i.e., when data other than the 

data used for estimation of the model are substituted). As the Government stated in the 

questions it posed, the model is based on experimental plot research results under limited 

regimes of moisture stress. Some of the data are relatively dated and may have resulted 

from hybrids that no longer are in production. Considering the rapid advances in seed 

technology in recent years, the reaction of modern varieties to the same stress may differ 

materially.

Importantly, producers who attended the listening sessions did not agree that the amount 

of reduction indicated by the UNL tables was justified. They believed management of 

other attributes of the production process – tillage, better timed irrigation applications, 

improved varieties, etc. – could (to varying degrees) offset the effects of moderate 

reductions in available irrigation water supplies. In its review, the Contractor agrees that 

the observations used to estimate the model may not replicate actual production 

conditions. The extent to which it overstates the required adjustments is not known.

These limitations of the UNL model raise questions about the advisability of incurring 

the significant time and expense associated with replicating it for all crops and states. 

Required data most likely will not be found in some cases. However, as producers in 

other production areas become aware of changes to the policy regarding irrigated acreage 

that is occurring in Kansas, they too will want assistance for managing crop insurance 

guarantees in the face of reduced water supplies, thereby placing demands on the Risk 

Management Agency (RMA) of the United States Department of Agriculture (USDA) to 

respond.

The Government asked the Contractor to consider the effects of a reduced APH yield due 

to adjustments made to reflect reduced water supplies on premium rate requirements. 

The Contractor considered a number of factors related to the existing premium rating

structure and concluded use of the current irrigated premium rate schedule is appropriate 

for small to moderate reductions in water use. The irrigated premium rate schedule 

already is applied without knowledge of the amount of water actually used to achieve the 
Feasibility Report for Insuring Irrigation

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approved APH yield, which varies significantly within a county. The Contractor 

acknowledges that a lower APH yield can be the result of numerous factors – quality of 

land and management, varieties grown, tillage, others – but water use must be considered 

as one of those factors. A high yielding producer in the county might be using 15 inches 

of water while a lower yielding producer is using 12 inches. Both presently are insured 

with the same rating schedule, with the lower yielding producer paying a higher premium 

rate due to the lower ratio of actual yield to reference yield. Suppose a reduction of three 

inches in water availability to the producer who has historically used approximately 15 

inches of water causes an expected loss in yield to a level consistent with that established 

by the producer who presently uses 12 inches. The Contractor could identify no reason 

why Producer A (historical 15 inches, now 12 inches) should pay a different premium 

rate than Producer B (historical 12 inches, now 12 inches) for the same approved yield.

The Government also asked that the Contractor consider the question as to whether the 

non-irrigated premium rating schedule would be appropriate for rating reduced approved 

yields due to reductions in water supply. The Contractor concluded that the differences 

in the reference yield and the impact of the ratio of the unit yield to the reference yield 

were so great in some cases that the resulting premium rates would be inappropriate. At 

extreme reductions in water availability – where the expected yield approaches the nonirrigated yield – using the lesser of the rate developed for the irrigated or the nonirrigated practice might be appropriate.

The Government also asked whether acceptable records on applied irrigation (such as 

timing, frequency, and location of historical irrigation practices) are available and 

accessible for insurance companies to establish accurate insurance offers and guarantees 

for limited irrigation. The Contractor pursued this question in the listening sessions. 

Based on the feedback obtained in those sessions, it would appear that information on 

total water pumped could be available, perhaps at a well level for the most recent years 

(those within the record retention period specified in the Basic Provisions), but further 

detail most likely is not. In particular, there may be no records of water transfer from a 

well to a different site of use or of water applied to a specific crop insurance unit, 

especially if third-party verification is deemed an essential part of the documentation.

The Government asked that the Contractor provide a list of pros/cons associated with 

using limited irrigation in place of current policy and procedure for the irrigated practice. 

The most important ‘pro’ in response to this issue is the lack of acceptance of the insured 

population with current policy and procedure. There is absolutely no acceptance among 

stakeholders of the idea that any reduction in water availability relative to historical use 

automatically triggers a reduction in insured acres or demotion of the acreage to nonirrigated practice. This was evident from the comments made during the listening 

sessions. Other ‘pros’ are that the Agency will be perceived as responsive to emerging 

trends in the agricultural sector and as providing a needed service to agriculture.

The Contractor identified the proposed approach for irrigation as the major con. 

Producers are not willing to accept the idea that water is the only limiting resource 

affecting yields, which is the current policy. In addition, the level of detailed information 
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required for a written agreement is daunting. Using written agreements to extend 

coverage consumes time and resources and this approach cannot be scaled up in a 

practical framework.

The Government asked the Contractor to “Suggest modifications and improvements to 

the limited irrigation methodology developed by UNL and RMA’s drafted procedures.” 

The Contractor was not able to suggest usable modifications to the methodology used by 

UNL. As noted earlier, it has certain deficiencies that render it less than applicable in 

actual practice. The effects of multiple factors affecting crop production are not 

considered in its estimates. It requires data not routinely available in many areas for 

many crops. With regard to RMA’s drafted procedure, the Contractor suggested changes 

to the language to make the document more specific and internally consistent. But, note 

that these suggestions are premised on the basis that the UNL yield adjustment tables are 

the basis for the 2013 insurance offer.

As requested by the Government, the Contractor proposed various alternatives for 

managing limited irrigation for crop insurance purposes. As requested, these are in the 

nature of “brain-storming” conceptual approaches without any limitations imposed by 

current policy and procedure. There may be argument as to whether some are feasible. 

However, the intent is to stimulate thought about the alternatives in keeping with the 

general rules for brain-storming.

Finally, the Contractor advanced several recommendations to move forward. Some are 

implicit in the previous statements made in this Executive Summary. The Contractor 

concludes that improvements to the treatment of limited irrigation are possible and 

certain actions are proposed. Most importantly, the recommendations call for taking 

steps to assure that the data from the 2013 crop year are available for analysis. Among 

the remaining recommendations are proposals that analysis be undertaken to determine 

the potential approaches that can improve treatment of limited irrigation. In particular, 

attention is given to the imprecise nature of the present policy and procedure that assumes 

any reduction, no matter how small, in water availability will result in impairment of 

production capability to the extent that the acreage must be declared as non-irrigated.
Feasibility Report for Insuring Irrigation

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SECTION II. INTRODUCTION

Solicitation D13PS59998 (Solicitation) identifies the objective of the first task order 

under the IDIQ Contract on Insuring Irrigation as conducting two reviews regarding 

Limited Irrigation. The first review addressed existing RMA documents, policies, and 

procedures for insuring irrigated crops, and the impact of reduced irrigation on those 

policy and procedures. In this second review:

“The contractor ... [evaluates] if limited irrigation would be a feasible 

alternative crop insurance product...” This includes a review and 

evaluation of “all RMA provided documents for limited irrigation 

including the University of Nebraska – Lincoln (UNL) developed 

methodology, yield reduction tables for corn and soybeans in Nebraska, 

Kansas and Colorado, and the RMA drafted limited irrigation 

underwriting procedures.1

The term “irrigated practice” is defined in the Basic Provisions as:

“A method of producing a crop by which water is artificially applied 

during the growing season by appropriate systems and at the proper 

times, with the intention of providing the quantity of water needed to 

produce at least the yield used to establish the irrigated production 

guarantee or amount of insurance on the irrigated acreage planted to the 

insured crop.”2

This is the only term related to irrigation defined in the provisions for crop insurance. 

Details about the irrigated practice as it applies to insurance are incorporated into several 

crop insurance underwriting documents, including the Crop Insurance Handbook (CIH), 

the Loss Adjustment Manual Standards Handbook (LAM) and the Irrigated Practice 

Guidelines. The Irrigated Practice Guidelines are Exhibit 48 of the Document and 

Supplementary Standards Handbook (DSSH).

Section 6B(11) of the CIH directs Approved Insurance Providers (AIPs) to provide a 

copy of the Irrigated Practice Guidelines annually to all insureds to whom the 

information might apply. Section 12A of the CIH contains irrigated practice guidelines

for the insurance provider, a compilation of various provisions in different sections of the 

Basic Provisions affecting irrigated practice. The section of the CIH labeled “IRR 

practice guidelines for planted or perennial crop acreage” (Section 12(A)(1)) and Exhibit 

48 in the DSSH do not contain identical language, but rather incorporate congruent 

guidance aimed at the two audiences, the insurance provider and the insured, 

respectively. What is identical in these two documents is the list of factors an insured 

must be able to document to the AIP’s satisfaction to show that adequate facilities and 

water supply existed at the time insurance attached. This list includes:

 Water source history, trends, and forecasting reliability;

 Water supply availability and usage;

 Pump efficiency and capacity;

 

1 USDA, RMA, 2012, Solicitation, Statement of Work, Section 2.4.2.

2 USDA, RMA, 2010, Common Crop Insurance Policy: Basic Provisions (11-BR), pp. 3-4, with the same language 

appearing in 05-BR for policies on crops harvested before the 2011 crop year.
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 Water requirements (amount and timing) of all crops to be irrigated;

 Water rights (primary, secondary, urban versus agricultural use, etc.);

 Contingency plans to handle shortages;

 Acres to be irrigated;

 Ownership of the water (state or federal versus landowner);

 Meters, measuring devices, and methods used;

 Soil types, soil moisture levels, and pre-plant irrigation needs;

 Water conservation methods, devices used, and plans utilized (if applicable);

 Past crop planting history and tillage methods;

 Quantity and quality of the water supply;

 Supplemental water availability and usage (including return flow);

 Recommendations from local County Extension Service (CES) or National 

Resource Conservation Service (NRCS), and other sources (recognized by CES or 

NRCS to be an expert in this area) regarding irrigation and crop production;

 Factors considered in reporting acreage to be insured under an irrigated practice; 

and

 Information the insured knew (or should have known) and when the insured knew 

(or should have known) such information pertinent to supporting a good irrigation 

practice.

The CIH speaks to the amount of water available for irrigation in Section 9(C)(2), stating:

“For irrigated acreage... there is not a reasonable expectation of having 

adequate water to carry out an irrigated practice.

“If the insured knew or had reason to know on or before the final planting 

date or during the late planting period (for crops with a late planting 

period) that the insured’s water will be reduced, then no reasonable 

expectation of having adequate water to carry out an irrigation practice 

exists. Available water resources will be verified using information from 

State Departments of Water Resources, U.S. Bureau of Reclamation, 

NRCS, or other source whose business includes collection of water data or 

regulation of water resources.” [emphasis added]

RMA has required the Contractor to address in this report specific questions concerning 

the impact of limited irrigation on prevented planting. Section 9C(7)(f) of the CIH 

provides information about the maximum number of eligible acres for prevented planting 

coverage when “irrigation facilities” are added for the current crop year. Section 

9C(10)(k) states that prevented planting coverage is not provided on any acreage based 

on an irrigated practice unless adequate irrigation facilities are in place to carry out an 

irrigated practice on the acreage prior to the insured cause of loss that prevented the 

insured from planting the insured crop. Additional comments concerning language 

addressing irrigation in the CIH and LAM from the first deliverable under this IDIQ are 

incorporated into this report by reference.
Feasibility Report for Insuring Irrigation

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To assure precision in the use of language in the remainder of the report, the Contractor 

provides the following definitions:

Deficit Irrigation – Irrigation using less water than the amount required to 

achieve maximum evapotranspiration.

Irrigation – Artificially applying water to cropland at the proper times by 

appropriate systems.

Limited Irrigation – Applying water to a crop artificially by appropriate 

systems at inappropriate times or applying less water during the appropriate 

times than the quantity of water that was used to establish the irrigated 

production guarantee or amount of insurance on the irrigated acreage planted 

to the insured crop.3

RMA has used the term “Reduced Irrigation” without definition, but meaning 

implicitly: “Irrigation using less water than the quantity of water used to establish 

the approved yield on the irrigated acreage planted to the insured crop.” The 

reader will note the difference between the meaning of reduced irrigation and the 

meaning of limited irrigation; limited irrigation is a subset of reduced irrigation.

A crucial element of the definition of “Irrigated Practice” in the Basic Provisions is that 

the producer is not required to maximize the yield, i.e., achieve maximum 

evapotranspiration. The definition only states that each producer is expected to follow 

practices intended to achieve the approved yield for the unit in any year. The producer is 

free to follow whatever practices make the greatest economic sense in his/her situation. 

The only requirement is that the producer must follow the practice of providing irrigation 

sufficient to result in a yield at least equal to the yield on which the production guarantee 

is based (i.e., the approved yield). This quantity may be greater or lesser in any particular 

year due to the amount and timing of rainfall and soil moisture at the beginning of the 

season.

The water used in irrigation is a production input that like most agricultural inputs 

follows the law of diminishing returns. If all other inputs are held constant, eventually 

lower per-unit increases of output (i.e., yield) are realized with the addition of another 

unit of water. In fact, if carbon dioxide or a mineral becomes limiting, adding more 

water can result in reduced yields as the excess water washes away required mineral 

inputs or increases the spread of disease.

The definition of Irrigated Practice makes it appropriate for a producer to use deficit 

irrigation to optimize his or her economic outcome. Deficit irrigation is also an important 

tool for reducing irrigation water use. However, the language in Section 9(C)(2) of the 

CIH does not speak to the amount of reduction in the supply of irrigation water, only to 

the knowledge that the supply will be reduced.

 

3 The Contractor notes the definition of “Limited Irrigation” in the contract would better be the definition for “Limited 

Irrigation Practice” and has provided a definition of the irrigation process. When the practice is addressed in this 

report, the definition from the Solicitation for Limited irrigation: “A method of producing a crop by which less 

water is artificially applied during the growing season by appropriate systems and at the proper times than the 

quantity of water that was used to establish the irrigated production guarantee or amount of insurance on the irrigated 

acreage planted to the insured crop” will be used.
Feasibility Report for Insuring Irrigation

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Consequently, in the report on the review of existing RMA documents, policies, and 

procedures for insuring irrigated crops, the Contractor concluded that the knowledge of a 

reduced supply of irrigation water prior to planting would require the insured to either 

irrigate fewer acres (so the amount of water per acre on the irrigated acreage was not 

reduced) or report the acreage with reduced irrigation as acreage managed under a nonirrigated practice.

Sources of Irrigation Water

Only relatively fresh water (i.e., with a relatively low concentration of dissolved 

minerals) is useful for irrigation. In the United States, surface and ground water are the 

primary sources of irrigation water.4 Surface water is water from precipitation that has 

collected to form relatively still or moving bodies of water. Lakes and ponds are still 

bodies of water. While lakes are generally bigger than ponds, there is no standard for 

classification. 

By volume, Lake Superior is the largest lake in North America. It contains more than 

10,000 cubic kilometers of fresh water.5 Most lakes contain fresh water. A vast majority 

of lakes and ponds have outlets that flow into streams, rivers, etc. Lakes without outlets 

(i.e., those located in closed basins such as the Great Salt Lake) tend to accumulate 

minerals and often become highly saline. Since lakes are ephemeral (on a geological 

timescale all lakes are drying up), the smallest lakes are disappearing and many of these 

small lakes are becoming too salty for use as irrigation sources. Reservoirs are 

constructed lakes or ponds.

Branches, brooks, creeks, forks, kills, rivers, runs, streams, and washes are moving 

bodies of fresh water. As a rule, rivers are the largest followed by forks and branches, 

which in turn are larger than the rest. However, these terms are used colloquially and 

some larger moving bodies of water may be called creeks, kills, or runs in the local

vernacular. These moving bodies of water may be permanent (i.e., always flowing) or 

ephemeral (i.e., seasonal, sometimes dry). Canals and ditches are constructed rivers and 

streams.

Groundwater is water that resides within the soil and rock beneath the Earth’s surface. A 

unit of contiguous groundwater is called an aquifer. Aquifers can be constrained (trapped 

between two impervious layers) or unconstrained (sitting on top of the highest layer of 

impervious rock). Aquifers supply water to wells. Unconstrained aquifers are generally 

recharged (replenished) by precipitation that percolates through the soil and rock from the 

surface, or are refilled by water flowing from higher elevations through a series of 

underground channels.6

Generally, aquifers are less affected by short droughts than are surface water features. 

However, since constrained aquifers are trapped between two impervious layers of rock, 

 

4

In some countries desalinated sea water is used for irrigation, but this practice is rare in the U.S. agricultural 

economy.

5 Almost 10 billion acre feet of water.

6

In many instances the channels are nothing more than the spaces between the soil, subsoil, or bedrock particles.
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they can be drained of usable water if the water is extracted by human actions (e.g., from 

wells). Unconstrained aquifers are more subject to the effects of natural conditions, 

while both constrained and unconstrained aquifers can be significantly affected by use as 

an irrigation source.

The Ogallala Aquifer is an aquifer underlying much of the Great Plains. The northern 

parts are unconstrained, while the southern parts are largely constrained. The Ogallala 

Aquifer contains about one third as much water as Lake Superior. Between about 1930 

and 2005, 253 million acre feet (312 km3or about 9 percent of the total) were withdrawn 

from the aquifer. 7The Ogallala Aquifer is recharged very slowly. The largest recharge 

rates are in the northern High Plains (2.76–4.37 in./yr.) where the aquifer is largely 

unconstrained, followed by the central High Plains (0.20–2.13 in./yr.) and then the 

southern High Plains (0.008–1.26 in./yr.).8 In 1966, the United States Geological Survey 

(USGS) estimated the aquifer is recharged over its entire area at an average rate of less 

than an inch per year, but the area-weighted average extraction rate for the Ogallala 

aquifer water in 2005 was almost 55 inches per year.

9

Irrigation Facilities

Irrigation has been used to improve agricultural production for more than 8,000 years.10 

Initially, surface water and shallow wells were used to supply water for manual irrigation 

using buckets. Manual irrigation is not appropriate for commercial production in the 

United States, but is used for small holdings in developing countries. The economic costs 

of manual irrigation are very low.

Surface or Gravity Irrigation Systems

Water is introduced and distributed by gravity using the soil as the medium in surface 

irrigation systems.11 The simplest surface irrigation system is flood irrigation. In flood 

irrigation, a level field surrounded by dikes is flooded. This works well for fields that are 

level; for fields that are not level, water supplied at the higher side will flow down the 

gravitational gradient. The flow can be better controlled if the field is furrowed 

perpendicular to the gravitational gradient.12 Surface irrigation systems tend to be less 

costly to develop and maintain than most other types of irrigation systems. Surface 

irrigation systems tend to be less affected by climatic and water quality issues, are more 

suited for use when water supplies are available less frequently, and when the supply is 

more variable in rate and duration. However, it is more difficult to quantify the 

availability of water to the crops irrigated by gravitational flows on the soil surface. 

 

7 McGuire, V.L., 2007, Changes in Water Levels and Storage in the High Plains Aquifer, Predevelopment to 2005,

U.S. Geological Survey Fact Sheet 2007-3029, http://pubs.usgs.gov/fs/2007/3029/, accessed April, 2013.

8 Gurdak, J.J. and C. D. Roe, USGS, 2009, Recharge Rates and Chemistry Beneath Playas of the High Plains 

Aquifer—A Literature Review and Synthesis, http://pubs.usgs.gov/circ/1333/pdf/C1333.pdf, accessed April, 2013.

9 McGuire, V.L., 2007, op cit.

10 Ashkenazi, E., 2012, Ancient Well Reveals Secrets of First Jazreel Valley Farmers, Haaretz, November 9, 2012, 

http://www.haaretz.com/news/national/ancient-well-reveals-secrets-of-first-jezreel-valley-farmers-1.476288, 

accessed April, 2013.

11 Drought Advisory, Surface Irrigation Systems, Cooperative Extension, Washington State University, EM4828, 

March 2003.

12 UN, FAO, 1989, FAO Irrigation and Drainage Papers: Surface Irrigation Systems, 

http://www.fao.org/docrep/T0231E/ t0231e04.htm, accessed March, 2013.
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Surface irrigation systems tend to be less efficient at supporting evapotranspiration. 

Within a field irrigated by a surface system, some areas are over-watered and others are 

under-watered. 13

Sprinkler Irrigation

Sprinkler irrigation is a commonly used type of irrigation in the United States and is 

suitable for most row, field, and tree crops. In sprinkler or overhead irrigation, water is 

piped, usually by pumping, to one or more locations within the field and distributed by an 

overhead system of sprinklers or high-pressure guns. Sprinkler irrigation is a method of 

applying irrigation water that is more similar to natural rainfall than a surface irrigation 

system. The water is sprayed into the air so it breaks up into small water drops which fall 

onto the crop and the ground. The pump supply system, sprinklers, and operating 

conditions must be designed to provide a uniform application of water over the irrigated 

acreage.

14

 Sprinkler irrigation can be used on most soil types and farmable slopes. 

Sprinkler irrigation systems can be designed to water from above or into the canopy of 

the crop being watered, and allow the producer to change the irrigation intensity (amount 

of water being applied to the land). Fertilizer and pesticides can also be distributed 

through sprinkler irrigation systems. If there is an adequate supply of water at the 

appropriate times and it is economically feasible, soil moisture can be maintained at 

levels that optimize the transpiration element of evapotranspiration.

15

 However, as noted 

earlier, deficit irrigation is often practiced to optimize economic outcomes, while 

optimizing transpiration would be used to maximize the yield. There is strong correlation 

between yield and evapotranspiration, which has been the subject of academic research 

for more than 50 years.16

The initial cost of a sprinkler irrigation system is relatively high. These systems require 

relatively high energy inputs, and adverse weather conditions (e.g., high winds and 

temperatures) tend to diminish the efficacy of the system. Depending on the spray 

pattern, water losses to evaporation can be quite large. Furthermore, untimely above 

canopy sprinkling can wash pesticides from the plants.

Subsurface Irrigation/Drainage (Sub-irrigation)

If the soil water balance is poor (i.e. saturated, overly dry, etc.) crop productivity is 

reduced. Initially, large portions of Arkansas, Illinois, Indiana, Iowa, Louisiana, 

Minnesota, Mississippi, Missouri, Ohio, and Texas were unsuited to cultivation because 

the soils frequently were too wet. Pipe or tile drainage systems reduced the soil 

saturation to a point where a balance was achieved. Most of the drainage of these fields 

occurred in the early 1900s in response to improvements in drainage technology and 

government support for development of drainage districts. Despite the Depression, the 

 

13 UN, FAO, 1989, FAO Irrigation and Drainage Papers: The Practice of Irrigation,

http://www.fao.org/docrep/T0231E/ t0231e03.htm, accessed March, 2013.

14 Brouwer, C., K. Prins, M. Kay, and M. Heibloem, UN, FAO, 1989, Training Manual 5, Irrigation Water 

Management: Irrigation Methods:: Sprinkler Irrigation, http://www.fao.org/docrep/S8684E/s8684e06.htm, accessed 

March, 2013.

15 Ibid

16 Allison, F.E., E.M. Roller and W.A. Raney, 1958, Relationship Between Evapotranspiration and Yields of Crops 

Grown in Lysimeters Receiving Natural Rainfall, Agronomy Journal, 50:506-511.
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10

federal government provided financial assistance in the 1920s and 1930s to maintain and 

expand drainage systems. Drainage of irrigated lands in the west expanded at the same

time. By the late 1970s, the federal government began discouraging wetland drainage.17 

By integrating a water source (i.e., an irrigation reservoir) in the upland portion of the 

subsurface drainage system, a producer can create a subsurface irrigation system. The 

system can capture excess water from precipitation leaching into the drainage system in a 

run-off reservoir. This excess precipitation is pumped into the irrigation reservoir for use 

when needed. During irrigation, water from the irrigation reservoir flows through the 

drains and into the soil beneath the roots of the crop (usually 4 to 5 feet below the 

surface). Capillary rise, water moving vertically upward through tiny spaces between the 

soil particles, brings the water from the deeper soil to the crop root zone. A subsurface 

irrigation/drainage system has very high initial installation costs; however tiling is 

gaining popularity in many regions in the United States because of its efficiency of water 

usage.

Localized Irrigation

Localized irrigation is the distribution of water under low pressure through a piped 

network adjacent to plants (also known as drip irrigation). A localized irrigation system 

can be very effective for areas where a water source is limited and individual plants can 

be watered. Localized irrigation provides a means to deliver light and frequent watering. 

This keeps salt concentration in the soil water to a minimum.18 Localized irrigation 

provides many advantages over traditional surface or sprinkler irrigation, especially when 

water resources are scarce and/or costly. Drip irrigation can cover a much larger, highlytargeted zone with the available water. Since the irrigated area is shaded by the plants 

being watered, evaporation is minimized and the amount of water required to maintain 

appropriate soil moisture levels in the root zone is reduced. Fertilizer usage can also be 

minimized by using the same drip system to target the application area rather than 

spreading the fertilizer over the entire field. By keeping the foliage dry, the risk of 

disease is reduced. The soil remains properly aerated. Furthermore, the output of each 

nozzle can be controlled, allowing different levels of water application according to the 

needs of the individual plant, without additional labor once the system has been set up. 

However, because the nozzles need to be cleaned periodically, maintenance costs in areas 

with high mineral content in the irrigation water can be high. Providing localized 

irrigation to row or field crops is difficult, but the system works well for tree, perennial, 

and some fruit and vegetable crops. The initial capitalization needed to design, purchase 

and install a localized irrigation system is very high.

Irrigation Regulations

The next section addresses laws and regulations governing the irrigation water by state 

for Colorado, Kansas, and Nebraska. These three states utilize a version of a system 

known as the prior appropriation doctrine that is common in the western United States. 

 

17 NRCS East National Technology Support Center, 2011, Drainage: the Invisible Infrastructure of the Midwest, 

http://soilquality.org/history/history_drainage_midwest.html, accessed March, 2013; Ahmet, K, 2011, Subirrigation 

in Field Crops and Usage in Greenhouses, http://www.agricultureguide.org/subirrigation-in-field-crops-and-usagein-greenhouses/, accessed March, 2013.

18 Savva, A.P., and K. Frenken, UN, FAO, 2002, Irrigation Manual, ftp://ftp.fao.org/agl/aglw/docs/irrigman9.pdf, 

accessed March, 2013.
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11

In the eastern United States, the riparian doctrine is most common. Under the riparian 

doctrine, the owner of land adjacent to a water source has first rights to the water; under 

the prior appropriation doctrine, the first user of the water generally has superior rights.

Colorado

Water in Colorado is owned and managed by the state of Colorado through its Division 

of Water Resources (DWR). Colorado, like Nebraska and Kansas, follows the First in 

Time, First in Right doctrine for water accessibility. Colorado is unique in that it is the 

first state to implement management of the distribution of water by public officials.19 

There are seven division offices of the DWR throughout the state:

 Division 1 Greeley Office – South Platte River Basin,

 Division 2 Pueblo Office – Arkansas River Basin,

 Division 3 Alamosa Office – Rio Grande Basin,

 Division 4 Montrose Office – Gunnison River Basin,

 Division 5 Glenwood Springs Office – Colorado River Basin,

 Division 6 Steamboat Springs Office – Yampa/White River Basin, and

 Division 7 Durango Office – San Juan/Delores River Basin.

Each of these divisions is further broken into a total of 78 water districts. In addition, 

there are advisory committees and rulemaking groups. Advisory committees are 

permanent groups which recommend policies for better irrigation water management. 

Rulemaking groups are temporary committees that hold hearings and provide input to the

State Engineer Office (SEO) concerning water policy administration.20

Surface Water

The Colorado Constitution appropriated all surface water as property of the public. 

Furthermore, the Constitution states, “The right to divert the unappropriated waters of 

any natural stream to beneficial uses shall never be denied.” It prioritizes the diversion of 

water during times when water availability cannot meet demand to domestic uses 

followed by agriculture and then manufacturing uses.21 A unique feature of the Colorado 

surface water governance is that precipitation is considered property of the state. 

Consequently, it is illegal in Colorado to capture precipitation without a permit from the 

DWR. Colorado has the most extensive surface water monitoring system in the lower 48 

states. The system provides near real-time monitoring of the level of surface water 

features. For more than 25 years, surface water in Colorado has been monitored using 

over 500 gauges on surface water features throughout the state.22 The state manages day 

to day use of surface water for irrigation using these data.

 

19 Colorado Division of Water Resources, no date specified, History of Water Rights,

http://water.state.co.us/SurfaceWater/ SWRights/Pages/WRHistory.aspx, accessed March, 2013.

20 Colorado Division of Water Resources, no date specified, Rulemaking Groups and Advisory Committees,

http://water.state.co.us/SurfaceWater/RulemakingAndAdvising/Pages/default.aspx, accessed March 2013.

21 Colorado Division of Water Resources, Joseph Grantham, Revised Edition, 2011, Synopsis of Colorado Water Law.

22 Thomas W. Ley, Ph.D., PE; Phil L. DeArcos; Russell V. Stroud; David G. Hutchens; 2010;The Colorado SatelliteLinked Water Resources Monitoring System: 25 Years Later; 

http://water.state.co.us/DWRIPub/DWR%20General%20Documents/USCIDColoradoSMSpaper_Ley.pdf, accessed 

March, 2013
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12

Ground Water

Colorado monitors groundwater levels by measuring water levels in more than 1,500 

wells. In addition to monitoring these wells, DWR works with the Colorado Ground 

Water Commission (CGWC) to regulate the use of ground water in the state. Permits are 

required to use groundwater. The permits are considered property rights, and can be sold 

independently of the land where the well is located. The CGWC has designated eight 

ground water basins in eastern Colorado with 13 Ground Water Management Districts 

(GWMDs) within these basins. The GWMDs have additional administrative authority 

within their boundaries. The GWMDs are authorized to adopt rules and regulations to 

help administer ground water use within a district. However, only the CGWC can issue 

or change permits.23 Since 1967, permits for large-capacity wells24 have not been issued 

for any proposed well in the same aquifer closer than a half mile from an existing largecapacity well. Since 1990, permits are not issued for a new well if that well will deplete 

the groundwater in a three-mile radius by 40 percent within 100 years. Obtaining permits 

or increasing the draw on an existing well is difficult because of these two standards.

In general, irrigation water for corn and soybeans is primarily used in the eastern plains 

of Colorado. Surface irrigation is a commonly used irrigation practice. However, as 

access to water statewide is controlled, monitored, and managed by the DWR offices, not 

only do producers face the risk of too little precipitation during the growing season, they 

also face the risk of available water being withheld by the state during “appropriate 

times” for crop production.

Kansas

The state of Kansas owns the water in the state and dedicates it for “the use of the people 

of the state, subject to the control and regulation of the state...”25 The Department of 

Agriculture regulates water resources through the Division of Water Resources (DWR). 

Water rights permits for both surface water diversion and wells are issued by the DWR. 

The DWR also monitors water usage. Unless the water is used for domestic purposes, it 

is illegal to use water in Kansas without a water right from the DWR.26 Water rights 

holders provide yearly reports on use. There are five field offices of the DWR in Kansas 

which each employ a water commissioner and staff familiar with local water issues. 

These field offices administer available water supplies, determine water right compliance, 

conduct data collection, respond to public inquiries, process certain water right changes, 

conduct field inspections and investigations, and provide access to water right records. 

Nearly 85 percent of water used in Kansas is used for irrigation.27 Some of the field 

offices assess “safe yield” while others assess “allowable depletion.” Safe yield requires

 

23 Colorado Division of Water Resources, no date specified, Ground Water Administration and Well Permitting, 

http://water.state.co.us/GROUNDWATER/Pages/default.aspx, accessed March 2013.

24 Wells whose capacity exceeds 50 gallons per minute.

25 KANSAS WATER APPROPRIATION ACT, K.S.A. 82a-701 through 82a-737 and 82a-740 through 82a-742 and 

K.S.A. 42-303 and 42-313, Revised December, 2012.

26 Kansas defines Domestic use as: “the use of water by any family unit for household purposes, watering farm and 

domestic animals, and watering lawns, orchards or gardens not exceeding 2 acres in size.”

http://www.gmd4.org/LawSum/lawsum.htm

27 Kansas Water Resources, 2009, Kansas Department of Agriculture, 

http://www.ksda.gov/includes/document_center/dwr/ Publications/KansasWaterResources.pdf, accessed March, 

2013.
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13

that total water use in a district must be an allowable percentage of the aquifer recharge in 

the area. Allowable depletion focuses on depletion of the supply by a specific amount in 

a specified time.

Surface Water

Only about one quarter of the 5 to 6 million acre-feet (6.2 to 7.4 km3) of water used 

annually in Kansas is diverted from surface water, mainly rivers. In the western areas of 

Kansas, surface water is very limited; groundwater rights permits are far more prevalent 

in this area. In the eastern areas of Kansas, surface water is relatively abundant. The 

DWR has been actively involved in providing for future access to water supplies in 

eastern Kansas by building, expanding and maintaining reservoirs to store water for 

periods of shortage.

Groundwater

In Kansas, anyone with a well who has been pumping water from a well since June 28, 

1945 has a vested right and can use groundwater for nondomestic purposes as long as the 

use is for “beneficial purposes.” These wells are essentially exempt from regulation 

within limits based on historical use. Otherwise, groundwater is managed under the 

authority of local groundwater management districts (GMD), including:

 Western Kansas Groundwater Management District No. 1;

 Equus Beds Groundwater Management District No. 2;

 Southwest Kansas Groundwater Management District No. 3;

 Northwest Kansas Groundwater Management District No. 4; and

 Big Bend Groundwater Management District No. 5.

These districts provide guidance for and regulation of “future water use development...”

and “plan for future water needs.”28 GMDs are governed by a locally-elected Board of 

Directors. GMDs create policy and regulations concerning the use of groundwater in the 

respective districts. The policy and regulation are subject to approval by the DWR.

In addition to GMDs, the DWR chief engineer has had the authority since 1978 to 

designate areas as Intensive Groundwater Use Control Areas (IGUCAs). In IGUCAs, 

extensive public input is sought for flexible solutions to complex water access issues 

rather than simply relying on the First-in-Time, First-in-Right doctrine. To further 

enhance local input regarding water usage, Local Enhanced Management Areas 

(LEMAs) were authorized by the Kansas Legislature in 2012. LEMAs provide GMDs a 

regulated process to address groundwater declines and other conditions of concern 

through locally-generated management plans that include specific goals and corrective 

control provisions. LEMAs are different from IGUCAs in that enforcement of the 

management process remains under local authority rather under the DWR.29 To date, the 

 

28 Western Kansas Groundwater Management District No.1, no date Specified, News and Information, 

http://www.gmd1.org/index-1.html, accessed March, 2013.

29 Kansas DWR Chief Engineer Order of Decision obtained from 

http://www.ksda.gov/water_management_services/?cid=2021.
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14

one LEMA accepted by the DWR affects portions of Thomas and Sheridan Counties 

(“Sheridan 6 LEMA”).30

Nebraska

Water in Nebraska is “held by the state for the benefit of its citizens.”31 Water rights are 

issued and managed by the Nebraska Department of Natural Resources (NDNR) and the 

rights are “legally attached to a parcel of land or a position in the state and is transferred 

with the land to subsequent owners.”32 Surface and ground water are governed by 

different laws, with different regulatory bodies managing these resources. Surface waters 

are regulated by five field offices for the NDNR, which provide local contacts with 

NDNR personnel. Groundwater usage is regulated by Natural Resource Districts (NRD). 

Each NRD has an elected Board which works cooperatively with the NDNR. Currently, 

there are 23 NRDs in Nebraska. Where there is no NRD, residents follow the correlative 

rights doctrine that residents must share when groundwater supplies are limited.

Surface Water

Access to and use of surface waters in Nebraska are governed by the state constitution 

and subsequent legislation. The primary rule governing use of surface water in Nebraska 

is the Appropriative First-in-Time, First-in-Right Rule.33 This rule, in essence, provides 

for the “diversion of water from the surface waters of the state based on the date the 

water right was obtained” and entitles “land owners or organizations to remove a set 

amount of water from a specific location.”34 When situations arise in which surface 

waters are insufficient to meet the demands of all users this rule protects those who were 

first to obtain the water rights. However, there is a hierarchy of users defined in the 

legislative rules governing water rights with domestic use having a higher ranking than 

agricultural uses which in turn ranks higher than manufacturing.35

Groundwater

Groundwater access and usage is governed under the Correlative Rights Rules in 

Nebraska. These rights allow land owners to extract groundwater from an underlying 

aquifer for “beneficial purposes.” The determination of what constitutes “beneficial 

purposes” is made by the NRD’s Board of Directors. Once a water well permit has been 

issued by the local NRD, the land owner is allowed to develop the well and use as much 

groundwater as needed until it is determined that the use of the water is no longer 

beneficial. All water wells in Nebraska must be registered with the NDNR which keeps a 

statewide database. NRDs are required to maintain a groundwater management plan for 

both water quality and quantity.

 

30 Kansas DWR, 2013, Order of Designation Approving the Sheridan 6 Local Enhanced Management Area within 

Groundwater management District 4, 

http://dwr.kda.ks.gov/LEMAs/SD6/LEMA.SD6.OrderOfDesignation.20130417.pdf, accessed April, 2013.

31 Nebraska Department of Natural resources, 2007 Groundwater Management and protection, 

http://www.dnr.state.ne.us/ Publications/GWMgmt_ProtectionActStatutes_0807.pdf, accessed March, 2013.

32 UNL Water, Agricultural irrigation Team, 2012, Regulations & Policies: Surface Water, Groundwater, Chemigation, 

and Natural Resources Districts, http://water.unl.edu/web/cropswater/regulations, accessed March, 2013.

33 Nebraska Legislature, 1920, Nebraska State Constitution Article XV-6, http://nebraskalegislature.gov/laws/

articles.php?article=XV-6, accessed March, 2013.

34 UNL Water, Agricultural irrigation Team, 2012, op cit.

35 Nebraska Legislature, 1920, op cit.
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15

Since 1996 Nebraska has passed additional regulations and created boards to study, 

review, and recommend changes to the state’s water legislation, all in an effort to try to 

maintain enough water to meet the needs of its citizens. The state recognized links 

between surface and ground water and began exploring ways to assess impacts of water 

usage to the overall water availability for the state’s citizens. To that end, the state 

created a Water Policy Task Force36 which was tasked to:

1) Review existing laws related to the integrated management of hydrologic surface 

water and groundwater and determine if any changes are needed to adequately 

address Nebraska’s conjunctive use and integrated management of these 

resources; 

2) Evaluate the utility of allowing permanent and temporary transfers and leasing of 

water rights and creating a water banking system; and 

3) Determine what issues related to inequities between surface water and 

groundwater users need to be addressed and what actions need to be taken.

Following the creation of this task force, Nebraska enacted a law addressing both ground 

and surface waters, which identified criteria to classify watersheds as being under, fully, 

or over-appropriated. Nearly half the state has since been classified as being fully or 

over-appropriated. In 2009, the legislature passed a law limiting new development of 

irrigated acres within areas surrounding surface water resources in areas that were 

classified as fully appropriated by NDNR. However, the development limitations have

subsequently been reversed.37 Recent limitations on irrigation water use have been 

temporary rather than permanent.

Limited Irrigation

As noted earlier, crop insurance policy and procedures presently mandate that a producer 

who knows or who has reason to know that water availability will be restricted for a crop 

year must reduce the number of acres to which water is applied so the historical amount 

of water can be applied to the reduced acreage. If this is not done (i.e., the producer 

maintains the same acreage but applies a lesser amount of water per acre), the entire unit 

is to be reported as a practice other than irrigated if such practice is offered. Otherwise, 

the acreage is uninsurable.

RMA’s criteria for feasibility identify the requirements to establish an appropriate 

feasibility recommendation for a crop insurance product in the broadest terms.

The proposed insurance coverage must conform to RMA’s enabling legislation, 

regulations, and procedures that cannot be changed. The enabling legislation is Title 

7, Chapter 36, Subchapter I of the U.S. Code, as amended.38 Amendment of this code 

requires an act of Congress. The Regulations and Procedures implementing this Act are 

the responsibility of the FCIC Board of Directors and USDA RMA. This criterion 

provides no absolute barrier to the insurance of crops under limited irrigation.

 

36 Initially made up of 49 members.

37 http://water.unl.edu/web/cropswater/regulations

38 See for example http://www.law.cornell.edu/uscode/text/7/chapter-36/subchapter-I.
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16

Producers or their agents must be willing to pay the appropriate price for the 

insurance. The willingness of producers or their agents to pay will be influenced by the 

coverage available and the costs associated with the insurance offer. Producers in 

Colorado, Kansas, and Nebraska generally participate in crop insurance programs, and 

unless the costs or procedures for insuring crops under limited irrigation are particularly 

onerous, the Contractor would expect producers to be willing to pay the appropriate price 

for the insurance.

The insurance product must be effective, meaningful and reflect the actual risks of 

the producers. Corn and soybeans are already insured in Colorado, Kansas, and 

Nebraska. The actual insurable risks the producer faces appear to be addressed by the 

existing insurance. However, the insureds’ perceptions of the utility of the insurance and 

of the ability of the insurance to protect the insured from financial failure affect the 

meaningfulness of the product. Consequently, the approach used to address limited 

irrigation scenarios may impact whether the insurance is considered meaningful.

The perils affecting production must be identified and categorized as insurable and 

non-insurable. Since insurance for corn and soybeans already exists, the only barrier 

under this criterion is whether there is an antagonistic effect of limited irrigation on losses 

due to other causes.

The insurance product must be ratable and operable in an actuarially sound 

manner. It must be possible for an actuarially-sound premium rate to be determined. 

This is fundamentally a question of data availability in terms of quantity of statistically 

valid observations or of the quality of non-quantifiable (judgmental) observations. This 

is a fundamental question addressed in this report.

The insurance product must contain underwriting, rating, pricing, loss 

measurement, and insurance contract terms and conditions. Appropriate 

management practices have been defined and required of stakeholders under the existing 

insurance. Again, the only barrier under this criterion is whether there is an antagonistic 

effect of limited irrigation on losses due to other causes.

There must be an appropriate geographic distribution of production to ensure a 

sound financial insurance program. An appropriate geographic distribution of 

insurance risk is required to address the need for insurance that is responsible to the 

taxpayer, since stakeholders operating in a limited geographic area could face collective 

catastrophic loss not protected by the insurance pool funds. The Contractor understands 

this requirement to apply to the entire FCIC portfolio in the aggregate, which is 

distributed throughout the United States. This criterion is therefore not a barrier to the 

insurance of crops under limited irrigation.

There must be enough interest for the risk to be spread over an acceptable pool of 

insureds. An appropriate pool size is also required to address the need for insurance that 

is responsible to the taxpayer, since a limited pool could face collective catastrophic loss 

not protected by the insurance pool funds. A sufficient number of stakeholders, who are 
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17

not identically affected by perils, must be willing to buy the insurance as part of an 

overall farm risk management strategy. Without an appropriate pool of insured 

enterprises, the insurer faces the risk of catastrophic losses. Indemnities in excess of the 

realized premiums may occur, increasing the subsidy costs to the taxpayer. The 

Contractor understands this requirement also applies to the entire FCIC portfolio in the 

aggregate, which involved more than 1.1 million policies and almost $110 billion of 

insured liability in 2012. This criterion is therefore not a barrier to the insurance of crops 

under limited irrigation.

Customers must not be able to select insurance only when conditions are adverse. 

At the time of enrollment the purchaser must be unable to predict the outcome. If the 

purchaser can predict the outcome at the time of enrollment, not only will adverse 

selection occur, but unscrupulous purchasers could “farm” the insurance to maximize 

profits. Only unpredictable outcomes fall into the category of appropriately insurable 

risks. Predictable outcomes do not include risks, but are characterized by certainty. 

However, because the insured with limited irrigation water supply can choose where to 

apply that water, this criterion is an issue that is addressed in the report.

Moral hazards must be avoidable or controllable. There must be a clearly defined 

outcome or phenomenon to be insured and the outcome must be subject to random 

variation; the variation in outcome must be separable into that part which can or might be 

manipulated, and that part which cannot be controlled. Again, because the insured with 

limited irrigation water supply can choose where to apply that water, this criterion is an 

issue that is addressed in the report.

There can be no chance of beneficial gain. If an insured individual benefits unduly 

from participation in the program, that gain introduces the possibility that the insurance 

would change the status of the insured within the pool of stakeholders. Insurance should 

be only a vehicle to manage risk; there should be no possibility that indemnity payments 

will become a fundamental element of the typical income stream. As long as the rating 

and underwriting are appropriate, this criterion is not a barrier to the insurance of crops 

under limited irrigation.

There must be no unacceptable change in market behavior or unacceptable market 

distortions in terms of either a change in quantity supplied or shift in the supply 

curve. Although the production of corn and soybeans in Colorado, Kansas, and 

Nebraska is substantial, the global nature of these crops as commodities makes the issues 

of market behavior and distortion moot.

Consequently, the remainder of this report addresses the feasibility of introducing limited 

irrigation as an alternative crop insurance product and incorporates the Contractor’s 

assessments of eleven specific concerns, including:

 The basis for establishing the yield reduction estimates;

 The focus of the proposed adjustment technique on yield rather than yield 

variability;

 The availability of acceptable records for implementation of the approach;
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 Effects on prevented planting claims and rate;

 Long-term data maintenance;

 The applicability of the current continuous rating function for estimating risk;

 The effects of substitution of the non-irrigated practice for limited irrigation;

 Whether separate limited irrigated rates are required;

 Irrigation underwriting requirements for each APH database;

 Potential impacts of implementing a limited irrigation product on RMA; and

 Potential impacts of implementing a limited irrigation product on AIP systems, 

forms, and processing.
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SECTION III. DATA AVAILABILITY AND APPLICABILITY

By contract, this report focuses on corn and soybeans in Colorado, Kansas, and Nebraska. 

However, inherent in the question of the feasibility of insuring limited irrigation is the 

need to avoid market distortion. Consequently, consideration of other crops and states 

other than the study crops and states is important.

There are many data available for corn and soybean production including annual, 

aggregate estimates of acreage planted, acreage harvested, yields, and value by state and 

county maintained by the USDA National Agricultural Statistics Service (NASS). The 

information for NASS statistics is gathered in many ways, including: “...surveys, 

telephone interviews, face-to-face interviews, and field observations.”

39

 Based on the 

responses to data collection, NASS publishes estimates for acreage, production, yield by 

practice and county, by practice and agricultural district, and by practice and state.

The Census of Agriculture

Once every five years, the National Agricultural Statistics Service (NASS) conducts a 

nationwide survey, the Census of Agriculture (Census). For selected crops, including the 

major field and row crops, the Census reports data on farm numbers, acreage planted, 

acreage harvested, production, value, and data on irrigated and non-irrigated acreage. 

These data are available at the national (Table 1), state, and county levels. The Census 

also reports voluminous demographic data on the characteristics of farms and producers.

 

39 USDA, NASS, 2009, NASS Surveys: The Foundation of Estimates, http://www.nass.usda.gov/Education_and_ 

Outreach/Understanding_Statistics/Foundation_of_Estimates/index.asp, accessed may, 2013.
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20

Table 1. United States Specified Field and Row Crops by Extent of Irrigation on 

Individual Farms,12007

Crop Attribute Extent of Irrigation

Entire Crop Part of the Crop None of the Crop

Corn for Grain

Farms 17,927 20,984 308,849

Acreage Irrigated 6,103,769 7,053,000

Dryland Acreage 6,435,486 66,656,287

Average Yield 180.0 150.0 144.3

Corn for Silage

Farms 8,173 1,491

Acreage Irrigated 1,369,278 128,010

Dryland Acreage 164,203 74,653

Average Yield 24.8 17.0 15.1

Soybean

Farms 7,007 13,326 258,777

Acreage Irrigated 2,175,069 3,062,006

Dryland Acreage 3,396,716 55,282,030

Average Yield 45.3 40.8 40.2

Wheat (All)

Farms 7,695 7,518 145,597

Acreage Irrigated 1,806,902 1,557,177

Dryland Acreage 3,703,599 43,865,291

Average Yield 80.3 42.7 37.0

Grain Sorghum

Farms 2,092 2,391 21,759

Acreage Irrigated 443,599 401,615

Dryland Acreage 670,030 5,254,590

Average Yield 86.9 74.7 69.2

1 Yields are in bushels except for corn silage for which yield is reported in tons. 

Source: The Contractor’s Research Department after data from the 2007 Census of Agriculture Table 32. Specified Crops 

Harvested - Yield per Acre Irrigated and Non-irrigated: 2007, published in 2009.

The Farm and Ranch Irrigation Survey (Irrigation Survey) is a supplement to the Census 

and is the only single source of national and state-level information on irrigation and 

agricultural water use for which the data are collected by a uniform, published 

methodology. The information collected includes application methods, equipment, 

facilities and expenditures, irrigated crop acreage, and irrigated yields. NASS last

conducted this survey for the 2008 crop year as a follow-up to the 2007 Census. 

According to the 2008 Irrigation Survey supplementing the 2007 Census, 54,929,915 

acres were irrigated in 2008 on 89,646 farms.40 In the 3 study states, just over 14 million 

acres (Table 2) were irrigated in 2008 on 41,143 farms (Table 3), representing 25.5 

percent of the irrigated acreage in the United States and 45.9 percent of farms with 

irrigation. However, it is important to note the estimates reported in the Irrigation Survey 

are constrained by the level of response from the subjects of the survey. The Census data 

provide a one in five years snapshot of the nation’s agricultural economy. Though useful 

for establishing the potential impact of changes in crop insurance programs, the 

applicability of these data to insurance development efforts is quite limited.

 

40 USDA, NASS, 2010, 2007 Census of Agriculture: Farm and Ranch Irrigation Survey (2008).
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Table 2. Total Irrigated Acreage in the Three Study States by Irrigation Type, 2008

State

Acreage by Irrigation Type

Gravity Sprinkler Drip Sub-irrigation

Colorado 1,547,072 1,402,688 23,061 2,495

Kansas 184,624 2,435,812 9,268 -

Nebraska 1,669,351 6,724,262 4,189 -

Source: The Contractor’s Research Department after data from the 2007 Census of Agriculture: Farm and 

Ranch Irrigation Survey (2008), published in 2010.

Table 3. Total Number of Irrigated Farms in the Three Study States by Irrigation 

Type, 2008

State

Farms

Gravity Sprinkler Drip Sub-irrigation

Colorado 10,252 4,337 524 13

Kansas 1,475 3,811 153 -

Nebraska 6,506 14,018 54 -

Source: The Contractor’s Research Department after data from the 2007 Census of Agriculture: Farm and 

Ranch Irrigation Survey (2008), published in 2010

The Irrigation Survey also includes state-level data on major crops. In the study states, 

more corn is grown than soybeans on both an acreage and production basis. In each 

study state, more of each of these crops is grown with irrigation than without. Under 

irrigation, the yields for corn for grain differs from state to state while the yields for 

soybeans and corn for silage are very similar across the three state study region (Table 4).
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Table 4. Irrigated and Non-Irrigated Production of Corn and Soybeans in the Study States, 2008

Crop Attribute Colorado Kansas Nebraska

Irrigated Non-irrigated Irrigated Non-irrigated Irrigated Non-irrigated

Corn for Grain

Farms 2,337 257 2,896 1,454 12,530 8,525

Acreage Harvested 796,040 87,610 1,368,126 475,908 5,058,195 1,230,756

Yield 177 48 185 71 184 129

Corn for Silage

Farms 848 20 394 230 1,115 524

Acreage Harvested 92,563 1,720 75,978 19,111 89,346 20,430

Yield 23 8 22 18 22 17

Soybean

Farms 30 - 2,148 1,079 10,541 7,560

Acreage Harvested 4,832 - 396,613 281,995 2,272,944 957,491

Yield 57 - 53 36 57 43

Source: The Contractor’s Research Department after data from the 2007 Census of Agriculture: Farm and Ranch Irrigation Survey (2008), published in 2010.
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The Census provides useful information on the role of crops in the agricultural economy as well 

as useful demographic information about farm structure at the national, state, and county levels. 

The Irrigation Survey provides an overview of the role irrigation plays in the production of major 

crops at the national and state levels. It also provides useful information concerning the 

complexity of developing insurance that takes into account the crop irrigated and the state where 

the production occurs. However, both the Census and the Irrigation Survey are conducted only 

once every five years. Neither provides farm-level data on the effects of irrigation or the risks 

inherent in changing the amount of irrigation water applied. Nor do these surveys provide 

information about precipitation or soil moisture.

NASS Quick Stats

The largest single NASS data collection each year is the June Agricultural Survey. Producers are 

sampled by both geographic location and operational characteristics. For the area sampling, 

approximately 10,000 locations within the total U.S. land mass are studied through interviews 

with approximately 50,000 producers or producer representatives (sampling about 2.25 percent 

of total U.S. farms and ranches). Large farms are sampled at high rates, while small farms (e.g., 

less than 50 acres of cropland) are randomly selected at very low rates. The December survey is 

supplemented with a mailing to a county sample of about 300,000 farm operators (about 15 

percent of U.S. farms) to collect information to support the County Data program. The responses 

from this supplemental sample are combined with those from the December survey and 

aggregated to a county summary.

NASS publishes annual agricultural U.S., state, and county-level data for many commodities 

based on surveys of representative samples of producers. The Quick Stats online application 

allows the NASS databases to be queried by commodity, state, and year. County-level data for 

each state are prepared and published by individual NASS State Statistical Service Offices. The 

NASS state offices aggregate data totals for Agricultural Statistics Districts (multi-county 

groupings) and for each state. County data are “assembled” starting from state estimates and 

working back to the county level. Since NASS uses sample surveys, it is not possible to publish 

information for all counties (Table 5). This is due to low response rates; non-disclosure rules;

and other technical and policy considerations.

Table 5. Counties Reporting Corn Production to NASS, by Study State, 200841

State Counties

NASS County Numbers

Practice Not 

Specified Irrigated Non-irrigated

Colorado 63 20 7 7

Kansas 105 49 13 13

Nebraska 93 18 75 75

Source: The Contractor’s Research Department after data from USDA, NASS, Quick Stats, accessed

May, 2013.

There are 63, 105, and 93 counties in Colorado, Kansas and Nebraska, respectively. NASS 

maintains cooperative agreements with state Departments of Agriculture and/or land grant 

 

41 The Contractor reports the 2008 data to provide an easy comparison between the Irrigation Survey data and the other data 

reported herein.
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24

universities to assist with data collection. Funding limits the information availability for crops,

data elements, and years. Since for so many counties the corn yields have data without 

information about the irrigation used, the Quick Stats data have limited potential to reflect the 

impact of irrigation on yields in many counties. Yet, there is useful information about the impact 

of irrigation of yields for some counties (Table 6 and Appendix A, Exhibit 1), including 

information about the county-level variability of those yields from year to year.

Table 6. Metadata on County-level Corn Yields (bushels/acre) in the Study States, 2008

State

Practice Not Specified Irrigated Non-irrigated

Low High

Acreweighted 

Mean

Low High

Acreweighted 

Mean

Low High

Acreweighted 

Mean

Colorado 39 214 139 153 192 177 39 76 48

Kansas 72 183 133 150 193 185 30 125 71

Nebraska 114 190 162 136 204 184 42 159 129

Source: The Contractor’s Research Department after data from USDA, NASS, Quick Stats, accessed May, 2013

However, since the NASS annual county data focus on the major grains, oilseeds, cotton, dry 

edible beans, sugar and tobacco,

42 there are many irrigated crops whose annual irrigated and nonirrigated yields cannot be inferred from these data. Furthermore, the Quick Stats data are not 

structured to reflect the RMA definition of irrigated practice and cannot reflect the risks inherent 

in changing the amount of irrigation water applied. Nor do these NASS data provide information 

about precipitation or soil moisture. Consequently, while these data have some applicability to 

crop insurance development, the applicability to development of insurance for limited irrigation 

is constrained.

National Oceanographic and Atmospheric Administration: National Climate Data Center

The National Oceanographic and Atmospheric Administration (NOAA) is an agency of the U.S. 

Department of Commerce. NOAA is responsible for maintaining current and historical weather 

data. NOAA’s National Climatic Data Center (NCDC) maintains the world’s largest climate 

data archive. Records in the archive include paleoclimatic data, hand written journals, and recent 

and current digital weather data. NCDC has developed numerous U.S. datasets which can be 

used to understand the risks caused by weather and, to some extent, by climate variability.

The NCDC Cooperative Summary of the Day (DSI-3200)43 and the Quality Controlled Local 

Climate Dataset (QCLCD) provide raw data for risk assessment related to amounts of 

precipitation (and consequently, in aggregate, of soil moisture content). The DSI-3200 includes

data from 1850. The data were collected at almost 30,000 stations. Some stations have been in 

operation since 1850; some reported data for a single year. The DSI-3200 data are originally 

reported as DSI-3201 and DSI-3202. These preliminary series contains daily data for 

cooperative stations throughout the United States, but have not been reviewed or have received 

only limited review.

 

42 Reflecting the use of these data in national crop programs.

43 Preliminary Cooperative Summary of the Day (DSI-3202/3201) datasets are published with a shorter lag time, but with limited 

quality control.
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The cooperative station network is comprised primarily of stations operated by universities, state 

services, and the National Weather Service (NWS). The vast majority of the NWS observers are 

volunteers (non-paid, private individuals). However, the network also includes the NWS 

principal climatological stations operated by highly trained observers. The network also includes 

stations supported by other federal agencies (e.g., the Department of Interior and Department of 

Transportation). Commonly the observers at these stations are employees of the Federal 

Aviation Administration, National Park Service, Bureau of Land Management, U.S. Forest 

Service, U.S. Geological Survey, and Tennessee Valley Authority. A few stations in the network 

are stations of the U.S. Department of Defense, primarily at military bases.

The observing equipment used at all DSI-32NN stations, whether at volunteer sites or federal 

installations, is calibrated and maintained by NWS field representatives. There is also Federal 

supervision of the initial data reporting quality control processes. When data entry is not 

automated, the preliminary data are manually edited prior to manual entry. They are then double 

entered, with discrepancies between the two files corrected. Finally, the dataset is run through a 

program to validate aspects of the minimum and maximum temperatures recorded for the day. 

However, these processes leave gaps in the data when a measurement was not recorded or was 

deleted because of the Quality Control (QC) process. Furthermore, data from one set of 

instruments can be reported in the NCDC datasets as coming from more than one location, while 

historical data from different stations at the same location are not linked.

Data from the QCLCD consist of hourly, daily, and monthly summaries for approximately 1,600 

U.S. locations. Most of the stations reporting to QCLCS are included in the DSI-3200 dataset. 

QCLCD data have undergone more thorough QC than DSI-3200, but gaps in the data are not 

filled. QCLCD values for precipitation are available beginning with 2005 and continue through 

current readings (with a 48 hour lag for the QC process). Due to gaps in the data, issues with 

values from a single set of instruments being reported more than once, and changes in the 

instrumentation, the raw NCDC data cannot be used for insurance development without 

substantial data management.

The Contractor in a private development effort has examined the active DSI-32NN stations. 

There are almost 7,000 stations that have consistently reported both precipitation and 

temperature. The Contractor cleaned data from these stations (to remove aberrant values), filled 

gaps in the data (to provide appropriate values for the station’s history), and back-cast the station 

dataset (to provide a uniform long-term data history for each currently active station). The 

Contractor then made scaling adjustments to both historical and filled values to assure the data 

variability associated with risk are captured in the dataset, while variations resulting from 

instrumentation changes are eliminated. The result of this effort is a proprietary weather dataset 

based on the NCDC raw data but structured appropriately for risk assessment.

The Contractor can extract data from the proprietary weather dataset to reflect the precipitation 

available for crop production (Appendix A, Exhibit 2 displays growing season (April 1 through 

September 30) daily precipitation for a single location for every fifth year beginning in 1972 and 

ending in 2012; complete daily precipitation for this location for all years October 1, 1971 to 

September 30, 2012 are available upon request). For the few counties where a weather station is 

not available, the data from stations in adjacent counties can be aggregated using either a simple 
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average or a distance weighted average. The cumulative precipitation by crop year in Sheridan 

County, Kansas, illustrates the nature of such an extraction and aggregation (Table 7). On the 

advice of the local extension agent, the Contractor aggregated precipitation data for the study of 

soil moisture available to a corn crop beginning the day after the end of the harvest season of the 

prior crop year (October 1) through the end of the harvest for the crop year (September 30 the 

following year). The mean annual crop year precipitation was 21.2 inches with a standard 

deviation of 5.2 inches. 

Table 7. Aggregate Annual Crop Year Precipitation1(Inches) in Sheridan County, 

1972 through 20122

Year Precipitation Year Precipitation Year Precipitation

1972 23.3 1986 17.7 2000 13.6

1973 26.5 1987 20.5 2001 25.8

1974 16.0 1988 15.2 2002 8.9

1975 26.2 1989 15.4 2003 16.0

1976 20.1 1990 22.3 2004 19.2

1977 23.1 1991 20.3 2005 25.0

1978 15.3 1992 30.3 2006 18.8

1979 21.0 1993 37.7 2007 23.2

1980 21.3 1994 17.7 2008 18.8

1981 21.5 1995 27.6 2009 26.7

1982 21.0 1996 26.1 2010 14.8

1983 18.5 1997 18.0 2011 22.8

1984 23.9 1998 20.8 2012 22.6

1985 23.8 1999 25.9

Source: The Contractor’s Research Department after data from NOAA, NCDC, cleaned, filled, backcast, and scaled to reflect variability.

1 The precipitation for the crop year was aggregated from October 1 (the day after the end of the harvest 

season of the previous crop year) through September 30 (the end of harvest for the crop year).

2 The period was chosen to coincide with the availability of yield data from NASS’s Quick Stats 2.0.

From 1972 through 2012, there were only 2 years when the natural precipitation in Sheridan 

County was 30 inches or more,44 1992 and 1993. In those 2 years the non-irrigated corn yields 

for Sheridan County reported in the NASS Quick Stats 2.0 dataset were 86.4 and 74.1 bushels 

per acre, respectively. However, even during these wet years, the non-irrigated yields in 

Sheridan County were just 58 and 55 percent of the irrigated yields (148.3 and 135.3 bushels per 

acre).45 Crop year 1993 was exceptionally cold, so yields were likely limited by the available 

growing degree days.

 

44 This precipitation value was chosen as the amount to support full evapotranspiration for short season corn as documented in 

Howell, T.A., J.A.Tolk, A.D.Schneider, and S.R. Evett, 1998, Evapotranspiration, Yield, and Water Use Efficiency of Corn 

Hybrids Differing in Maturity, Agronomy Journal, 90: 3–9. The UNL model is also based on a maximum application of 30 

inches of irrigation water.

45 Some of the yield reduction in 1993 could also be accounted for by the excessively wet year, which restricts respiration in the 

plant root system, disrupts pollination, and increases losses to disease. The disparity between irrigated and non-irrigated yields 

could result from numerous factors including, but not limited to, planting densities, amounts of mineral nutrients applied, and 

varietal selections.
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While the extension agent recommendation concerning the effect of precipitation on soil 

moisture available for corn production initially seemed imprudent, there was a stronger 

correlation between non-irrigated yields of corn in Sheridan County and the entire year’s 

aggregate precipitation (un-weighted) than between those yields and other periods of 

precipitation, whether the precipitation was weighted by the time the precipitation occurred or 

un-weighted (Table 8).

Table 8. Correlations between Precipitation (inches) in Sheridan County and Crop Yields 

(Bu/Acre) by Irrigation Approach, 1972 through 2010

April to

September

January to

September

January to

September

October to

September

October to

September

October to

September

October to

September

Precipitation

Weighting

None None Simple None Simple Three

Periods

Monthly

Irrigated 0.01 -0.02 -0.05 0.08 0.05 0.02 -0.01

Non-irrigated 0.43 0.42 0.39 0.49 0.47 0.45 0.43

Source: The Contractor’s Research Department after data from NOAA: NCDC, cleaned, filled, back-cast, and scaled to reflect variability and 

from NASS.

1 The simple weighting valued precipitation before April 1 at half the actual value. The three period weighting valued precipitation from October 

1 through December 31 at one quarter the actual value and precipitation from January 1through March 31 at half the actual value. The monthly 

weighting increased the relative fractional value of precipitation from October through March, by month.

The unexpected impact of the full annual precipitation in Sheridan County on non-irrigated corn 

yields raises an import point in the consideration of the insurance of irrigated corn crops grown 

under reduced or limited irrigation. The soil water capacity and the loss of soil water to 

evaporation can both have important impacts on the “quantity of water needed to produce at least 

the yield used to establish the irrigated production guarantee or amount of insurance on the 

irrigated acreage planted to the insured crop.” While in one area October precipitation may 

make an important contribution to a crop’s water balance, in another the precipitation in 

February will hardly affect the moisture available to a crop.

Insurance Data

RMA, the AIPs, and insurance agents keep voluminous data on the crop insurance they 

underwrite and sell. There are more data for corn than for any other crop, followed closely by 

the data for soybeans. In terms of quantity, wheat data are a distant third, with about half the 

amount of data available for soybeans. This distribution reflects the total acreage of the crops. 

With well over 100 crops insured under the different plans RMA manages, the depth and breadth 

of data by crop vary widely.

Data Available from RMA

 Acreage Insured under the Irrigated Practice – by plan, by crop, by unit, policy, 

county, and state, by year.

 Acreage Insured under a Non-irrigated Practice46– by plan, by crop, by unit, policy, 

county, and state, by year.

 Approved Yield – by policy, practice, and unit, by year.

 Insurance Experience – by plan, by crop, by county and state, by practice, by year.

 

46 Including continuous cropping, summer fallow, not following another crop and the non-irrigated practice codes.
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 Limited Irrigation Yield Adjustment – University of Nebraska tables.

 Number of Producers47 Insuring Both Irrigated and Non-irrigated Practices for a 

Crop during the Same Year – can be derived by crop, by county and state, by year.

 Number of Producers Insuring Only in the Irrigated Practice for a Crop – can be 

derived by crop, by county and state, by year.

 Number of Producers Insuring Only in the Non-irrigated Practice for a Crop – can 

be derived by crop, by county and state, by year.

 RMA Rainfall “Index” Value – by grid, by year for 64 years (not available for western 

Colorado and many other parts of the United States).

 Yield under the Irrigated Practice – by crop, by county and state, by year, and by unit 

and policy, by year for the approved yield database history.

 Yield under the Non-irrigated Practice – by crop, by county and state, by year, and by

unit and policy, by year for the approved yield database history.

Data Theoretically Available from AIPs or Producers

 Irrigation Source – by policy and unit.

 Irrigation Supply – percent of normal by policy and unit.

 Irrigation Well Flow – gallons per minute.

 Expected Curtailments of Supply – by producer or water district.

Data Whose Availability is Questionable

 Total Acre Inches of Water Applied to a Unit – by crop, by year.

 RMA Rainfall “Index” Rainfall – The index is a derived number and reflects relative 

rather than absolute rainfall. The underlying data should be available from the contractor 

who derives the index values for RMA, but the cost of such data is likely to be 

substantial.

For the most part, the question is not “Are data available,” but rather “Were the data collected in 

a manner that makes them applicable to the analysis of risk required for development of an 

actuarially-sound insurance product for limited irrigation?” This is complicated by few types of 

data whose availability is truly limited, including data on:

 Soil moisture at planting and during the growing season,

 The timing of application of irrigation water (e.g., Colorado tells producers when they 

can draw river water and that period can vary from year to year),

 The varieties planted, and

 The growing season length.

Nonetheless, the wealth of data available in the RMA datasets provides a basis for evaluation of 

numerous elements of any limited irrigation approach as illustrated by the analysis in this report.

 

47 The term “producer” reflects an insured person. A producer may be more than one person (sole proprietorship, partnership, 

etc.).
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SECTION IV. ANALYSIS OF THE UNL MODEL

The UNL partnership model48 is discussed in detail in this section of the report. In addition to a 

general review of the model, the Contractor specifically addresses the following comments and 

questions from the Solicitation.

“The [model] methodology appears to be based on yield trial data from relatively 

limited areas, additional research is needed to determine if the model results are 

applicable to other areas and especially other soil types. This is critical because 

an inappropriate yield adjustment could dramatically over or underinsure 

producers.”

“The methodology was focused on the effect of irrigation on yield levels, but has 

not addressed the effect on yield variability. This is needed because the 

variability of yields is what determines losses and premium rates. Without a 

sufficient understanding of how much yield risk increases as irrigation decreases, 

RMA does not have a basis to establish actuarially sound premium rates.”

“Are acceptable records available and accessible on applied irrigation (such as 

timing, frequency, and location of historical irrigation practices) for insurance 

companies to establish accurate insurance offers and guarantees for limited 

irrigation?”

“Are the data supporting limited irrigation models sustainable and maintainable 

in the future so appropriate coverage and premium rates can be properly 

updated?”

In addition to these matters, the Contractor addresses two fundamental questions regarding the 

model: “Is it feasible to use the model function to offer insurance for limited irrigation for corn 

and soybean in Sheridan and Thomas Counties, Kansas, for the short term?” and “Is it feasible to 

use the model yield adjustment approach to offer insurance for limited irrigation for any insured 

irrigated crop for the long term?”

The UNL partnership team used a crop production function approach to represent the impact of 

water stress on crop yield, building on the procedure of Stewart and Hagan49 and that of Martin, 

Watts, and Gilley.

50

 As RMA has noted, the first of these studies focuses on limited field trials 

grown under three levels of water stress, while the second is a generalized simulation based on 

the available literature at the time. Based primarily on these studies, the UNL partnership team 

extrapolates from a linear relationship of crop yield to seasonal evapotranspiration (ET):

Y = Yn + b (ET - ETn)

 

48 The document “Procedures for Adjusting APH when Implementing a Deficit Irrigation Insurance Practice,” provided to the 

Contractor by RMA, is incorporated into this report in its entirety by reference. The authors of that document used the term

“deficit irrigation” without definition, but in the same sense implicitly as the Contractor uses the term “reduced irrigation.” 

Specific elements of the UNL procedures document will be cited as elements of the analysis of the UNL model.

49 Stewart, J.I., and R.M. Hagan, 1973, Functions to Predict Effects of Crop Water Deficits. Journal of Irrigation and Drainage

Engineering, 99: 421-439. 

50 Martin, D.L., D.G. Watts and J.R. Gilley, 1984, Model and production function for irrigation management. Journal of 

Irrigation and Drainage Engineering, 110: 149-164.
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where Y is the yield at harvest, Yn is the yield at harvest without irrigation, b is the slope of the 

yield-ET relationship, ET is the crop evapotranspiration at a specified irrigation level and ETn is 

the evapotranspiration for the non-irrigated crop. While the UNL partnership team correctly 

states numerous researchers have shown, under experimental conditions, this linear relationship 

exists for many irrigated crops grown in the Great Plains. But the UNL team does not emphasize 

the experimental nature of these studies, which include among other characteristics:

 Limited periods of water stress;

 Consistent planting densities;

 Changes in water losses to evaporation with differing planting densities;

 Consistent planting approaches (i.e., tillage, etc.);

 Careful timing of the stress to address plant growth stages; and

 A single variety within a trial.

These experimental conditions do not reflect the management approaches that have been used by 

each producer to develop an APH for establishing an approved yield, since over the years water 

is applied either when such application is allowed or when it is most likely to be efficacious; 

planting densities have changed to reflect the variety chosen and seed company 

recommendations; applications of nutrients have changed to reflect soil tests and planting 

densities; and tillage practices may have been modified to conserve water. Thus, though the 

models provide information about the relative effects of different amounts of irrigation, they do 

not reflect time series production patterns as does an APH.

The partnership model does address Stewart and Hagan’s conclusion that “the Y versus [added 

irrigation water] function is convex, reflecting decreasing irrigation efficiency [percentage of 

irrigated water utilized for evapotranspiration] as actual crop ET approaches fulfillment of 

maximum requirements.” They expand on Martin et al.’s production functions for the linear 

yield-ET relationship based on five constants:

 Yn,

 ETn,

 The yield when the crop is fully irrigated,

 The ET when the crop is fully irrigated, and

 The amount of gross irrigation required to produce the full yield (Df).

However, in the analysis, they assume (based on the 1973 and 1984 studies) that the slope of the 

yield-ET relationship should equal the slope of the yield-ET relationship when the production 

function is evaluated at zero irrigation. That is the element of the relationship with the highest 

efficiency. Evidence that this slope is appropriate under actual field conditions (as opposed to 

experimental conditions) is limited. Its use is based on a simplifying assumption that 

consequently maximizes the apparent effects of reducing irrigation.

Nonetheless, the UNL partnership team has developed an elegant model for adjusting approved 

yields for corn and soybean in selected production regions. The data required by RMA to 

maintain the approved yield procedure are the Df (which changes as new varieties and practices 

are introduced), yield per inch of ET (which is a function of the variety grown), and water use 

efficiency at full irrigation (values defined by the partnership team, by crop and irrigation system 

type for each location).
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The challenge in this analysis is to integrate the knowledge and information available concerning 

limiting factors on crop growth/development: weather data and historic weather patterns in the 

areas affected by limited irrigation; water availability, and soil moisture at planting. To test the 

success of the model in capturing these attributes, the Contractor selected five counties (one in 

eastern Colorado and one each in eastern and western Kansas and Nebraska). The weather data 

for these counties was extracted and two measures of precipitation were calculated: total annual 

crop year precipitation (October through September of the following year) and growing season 

precipitation (April through September). These values were then compared with the amount of 

water required to achieve full irrigation and the yield boost resulting from full irrigation (Tables 

9 and 10).

Table 9. Relationship between Total Annual Crop Year Precipitation and Yield Boost from 

Full Irrigation

County

Total 

Cumulative 

Precipitation 

(inches) 

Irrigation to 

produce Full 

ET (inches)

Total 

Annual 

Water from 

Precipitation 

and 

Irrigation

Yield boost 

from Full 

irrigation 

(bushels per 

acre)

Kit Carson County, Colorado 15.90 20 36 152.4

Perkins County, Nebraska 20.75 18 39 143.3

Sheridan County, Kansas 21.07 17 38 146.1

Butler County, Nebraska 29.02 12 41 90.1

Washington County, Kansas 31.74 13 45 85.3

Source: The Contractor’s Research Department after data from NOAA: NCDC, cleaned, filled, back-cast, and scaled to reflect variability and 

from The UNL Partnership tool.

Table 10. Relationship between Total Growing Season Precipitation and Yield Boost from 

Full Irrigation

County

Cumulative 

Precipitation 

(inches) during 

the Growing 

Season

Irrigation to 

produce Full 

ET (inches)

Total Growing 

Season Water 

from 

Precipitation 

and Irrigation

Yield boost 

from Full 

irrigation 

(bushels per 

acre)

Butler County, Nebraska 10.58 12 23 90.1

Kit Carson County, Colorado 12.53 20 33 152.4

Sheridan County, Kansas 15.88 17 33 146.1

Perkins County, Nebraska 16.11 18 34 143.3

Washington County, Kansas 23.33 13 36 85.3

Source: The Contractor’s Research Department after data from NOAA: NCDC, cleaned, filled, back-cast, and scaled to reflect variability and 

from The UNL Partnership tool.

The two counties with the greatest amount of annual crop year precipitation (Washington 

County, Kansas, and Butler County, Nebraska) require the least amount of irrigation to produce 

full evapotranspiration. Full irrigation in these counties provides the smallest yield boost. These 

results are as expected. However, the growing season precipitation has a much weaker 
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relationship with the amount of water required for full irrigation (r = - 0.21) than does the annual 

precipitation (r = - 0.96).

In its report to RMA, the partnership team suggests the approved yields for crop insurance for 

both reduced and limited irrigation practices require reductions to reflect decreases in the 

available irrigation water supply. This is based on the assumption that a producer’s approved 

yield overstates yield expectations when known irrigation water supplies for a year are less than 

historical amounts. Challenges to this inference include changes in the water requirements for 

seeds for commercial production in areas where irrigation is a common practice; changes in the 

management practices that affect evapotranspiration; and limiting factors other than 

evapotranspiration on crop growth/development. It would also be useful if the model could 

include analysis of historic weather trends in the areas affected by limited irrigation as the 

Contractor has seen both positive and negative trends depending on the region of the country 

being studied. Once these are considered, the effects of water availability can be more clearly 

assessed.

Seed

Most seed companies provide “drought tolerance” ratings for the hybrids they market for both 

irrigated and non-irrigated production. These ratings provide producers an effective tool for seed 

selection under limited irrigation conditions. New hybrids from DuPont, Pioneer, and Syngenta 

were commercially available for the 2012 crop year, while Monsanto introduced several new 

hybrids for the 2013 crop year. The companies emphasize that the enhanced drought tolerance 

associated with these hybrids is not associated with “yield drag.” The hybrids are bred for use in 

areas where corn growers are looking for ways to reduce irrigation and conserve water supplied 

by aquifers. The performance of these hybrids during the 2012 drought suggests a yield 

improvement of 5 to 10 bushels per acre under drought (or limited irrigation) conditions have 

been achieved and further progress is anticipated.51

Management Practices that Affect Evapotranspiration

Evapotranspiration incorporates two components: evaporation of water from the soil and 

transpiration of water from the plant tissues. Soil structure introduces yet another element into 

the water balance as any runoff of precipitation and irrigation water from the soil decreases water 

use efficiency. Tillage more than any other management practice affects evaporation of soil 

moisture. The more the soil is worked, the greater the amount of evaporation. Concurrently, 

tillage increases oxidative degradation of soil organic molecules, reducing infiltration of the soil 

by water and in the worst cases leading to runoff. Finally, passages over the field by heavy 

equipment lead to compaction, which also increases runoff.52

 

51 Thomison, P. A. Lindsey, A. Geyer, R. Minyo, , 2013, Drought tolerant corn hybrids, http://www.agprofessional.com/resourcecenters/corn/seeds/seed-news/Drought-tolerant-corn-hybrids-202130431.html?view=all, accessed May, 2013.

52 Peiretti, R.A., 2004, No Till Improves Soil Functioning and Water Economy, World Soybean Congress, 

http://www.fao.org/fileadmin/templates/agphome/images/iclsd/documents/wk1_c2_Peiretti.pdf, Accessed may, 2013; van 

Donk, S.J. and N.L. Klocke, 2012, Tillage and Crop Residue Removal Effects on Evaporation, Irrigation Requirements, and 

Yield, http://www.ksre.ksu.edu/irrigate/OOW/P12/vanDonk12.pdf, accessed May, 2013.
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Both academic researchers and producers have long understood the effects of planting densities 

on evapotranspiration.53 Since each plant acts as a wick to carry soil moisture into the 

atmosphere, the greater the planting density, the greater the potential for transpiration. Corn is 

particularly sensitive to these density effects. The C4 photosynthetic pathway used by corn

maintains open stomata even under mild water stress. In contrast, the stomata of soybean plants 

closes relatively early in stressful situations, limiting loss of both water and yields.

Limiting Factors Other than Evapotranspiration

Since early in the 20th century, biologists have studied the conditions that limit plant growth. 

The result of this research, generally known as the principle of limiting factors, states the 

maximum possible rate of plant growth at any moment in time is limited by the single basic 

resource in least supply. These potentially limiting resources include light, water, carbon 

dioxide, major minerals, (the nitrogen, potassium, phosphorus of commercial fertilizers) and a 

variety of micronutrients including boron, calcium, magnesium, iron, sulfur manganese, and 

zinc. The condition of the soil can also limit growth. Compacted soils can limit the access of 

roots to oxygen for respiration and porous, loose soils can limit the availability of water to the 

plant and physically constrain the growth of roots. Each crop plant (species and variety) has a 

specific range of tolerance for particular environmental conditions, and each condition has a 

different effect. In general, in agricultural scenarios, climate factors are the most important 

constituents limiting plant growth and development. The three most important climatic factors 

are sunlight, temperature, and precipitation.

The collective knowledge concerning plant growth limiting factors has affected agricultural 

management practices. Soil analyses allow application of appropriate fertilizers and 

micronutrients. Pesticides can control the limitations imposed by disease, insects, and 

competition from weeds. The spacing of the planted seed optimizes the availability of light for 

photosynthesis. Producers schedule planting and harvest to optimize yields (or revenue) and 

minimize risks associated by inclimate and/or inclement temperatures. Soil texture is managed 

by introducing amendments and by tillage practices. Outside of very costly semi-permanent 

tiling and soil drainage systems, there are few tools to address excessive moisture (which can 

also starve a plant root system for oxygen, inhibit root development, and encourage growth of 

potentially harmful fungi). The producer’s principal tool to address insufficient moisture is 

irrigation.

Solicitation Questions

With regard to the specific question in the Solicitation concerning the approved yield adjustment 

model, the Contractor has the following responses:

The [approved yield reduction] methodology appears to be based on yield trial 

data from relatively limited areas, additional research is needed to determine if 

the model results are applicable to other areas and especially other soil types. 

This is critical because an inappropriate yield adjustment could dramatically over 

or underinsure producers.

 

53 Kirby, E.J.M., 1970, Evapotranspiration from barley grown at different plant densities, The Journal of Agricultural Science 75:

445-450.
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The Contractor agrees the approved yield adjustment model methodology is based primarily on 

yield trial data from relatively limited areas. The model uses an engineering approach to 

quantify changes in plant production resulting from changes in available water. Plant growth 

models are notorious for their success at capturing the growth when tested in-sample (i.e., with 

elements of the data used to create the model) and for their failure to predict production of outof-sample populations.54

 The yield adjustment model uses an approach which is likely more 

complex than it needs to be to achieve an estimate of reduction that is likely expressed with more 

precision than appropriate considering the limitations on the sample data available. Furthermore, 

the partnership team uses NASS data to establish yield under maximum irrigation; the Contractor 

believes RMA data would be more reflective of the production of the insured population.

The methodology was focused on the effect of irrigation on yield levels, but has 

not addressed the effect on yield variability. This is needed because the 

variability of yields is what determines losses and premium rates. Without a 

sufficient understanding of how much yield risk increases as irrigation decreases, 

RMA does not have a basis to establish actuarially sound premium rates.

This topic is discussed in detail in the section on rating approaches. The RMA continuous rating 

function already captures yield-related differences in yield variability. The yield ratio curve 

provides higher premium rates as the approved yield decreases relative to the reference yield. 

Due to the uncertainties regarding the practices that were used in establishing an approved yield

in the RMA database and conditions that existed when those crops were grown, the Contractor 

believes it would most likely be appropriate to use the rating for irrigation based on the vast and 

enormously varied experience represented in the RMA insurance experience rather than trying to 

develop a theoretical construct for limited irrigation yield variability whose statistical basis 

would at best be static and in the worst cases would not exist.

Are acceptable records available and accessible on applied irrigation (such as 

timing, frequency, and location of historical irrigation practices) for insurance 

companies to establish accurate insurance offers and guarantees for limited 

irrigation?

There is no evidence these records are generally available. While the insurance policy requires 

the producer be able to produce such records, the nature of the irrigation documentation actually 

available is constantly changing. Producers most likely would be challenged by an AIP to 

produce such records only in the event of a claim for indemnity that was based in water 

availability; in the event of a loss due to hail or a similar situation, such records most likely 

would not be requested. It is reasonable to expect the most detailed records available are the 

newest records. Testimony from producers and agents suggests the records available from third 

parties vary considerably depending on location and local water administration policies. Some 

 

54 See for example Körner, C., 1991, Some often overlooked plant characteristics as determinants of plant growth – a 

reconsideration. Functional Ecology 5: 162-173; Heuvelink E. 1999. Evaluation of a dynamic simulation model for tomato

crop growth and development. Annals of Botany 83: 413–422.; Hu, B.G. and M. Jaeger, 2003, Plant growth modeling and 

applications, Proceedings 2003 International symposium on plant growth modeling, simulation, visualization and their 

applications, Beijing: Tsinghua University Press/Springer.
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digital records will be available from some producers, but many of those will not include third 

party verification.

Are the data supporting limited irrigation models sustainable and maintainable in 

the future so appropriate coverage and premium rates can be properly updated?

Inasmuch as the model is a theoretical construct, the model itself can be updated using the 

partnership methodology. However, the Contractor does not believe development of separate 

rates for the limited irrigation practice is practical or appropriate. Please see the section on rating 

approaches.

Regarding the additional question posed by the Contractor: “Is it feasible to use the partnership

model to adjust approved yields in offering insurance for limited irrigation for corn and soybean 

in Sheridan and Thomas Counties, Kansas, for the short term?” The Contractor believes the 

partnership model provides an appropriate estimate of the reduction in yield that will occur under 

limited irrigation if the producer makes no changes to his or her management practices other than 

decreasing the amount of irrigation water applied. For the short term, this is an expeditious 

approach to providing insurance for limited irrigation and a much better alternative than the 

policy alternatives of requiring a reduction in irrigated acres or requiring the crop to be insured 

with a non-irrigated practice. 

Regarding the additional question posed by the Contractor: “Is it feasible to use the partnership

model to adjust approved yields in offering insurance for limited irrigation for any insured 

irrigated crop for the long term?” The data do not exist to replicate the partnership approach 

everywhere that corn and soybean are grown with irrigation. Nor do all the requisite data exist to 

replicate the partnership approach for other irrigated crops. Consequently, the Contractor 

believes it would be in the best interests of the Agency to use the partnership project as a means 

to test alternative, simpler models for offering insurance with a reduced approved yield for crops 

grown under limited irrigation.
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SECTION V. ANALYSIS OF THE RMA UNDERWRITING DRAFT

The RMA Underwriting Guidelines for limited irrigation are contained in a six-page 

“Informational Memorandum Draft Procedures” (IMDP) provided to the Contractor for this 

review. The draft procedures are limited to “selected counties in Colorado, Kansas, and 

Nebraska” where availability of limited irrigation coverage is provided through Special 

Provisions statements. The Contractor was able to identify only two counties – Sheridan and 

Thomas Counties, Kansas – where the Special Provisions statements were incorporated for 2013. 

Concurrently, the state of Kansas implemented a Local Enhanced Management Area (LEMA) in 

designated sections of these two counties. The LEMA limits total water use to 55 acre-inches 

during 5 years beginning 2013 in the designated sections.

The draft guidelines incorporate the UNL reduction tables as the mechanism by which limited 

irrigation is to be implemented. Limited irrigation is not implemented as a separate practice but 

is considered to be the irrigated practice since the adjusted APH yield is regarded as the “yield 

upon which the insurance guarantee is based, meeting the definition of irrigated practice.” But, 

to differentiate crop insurance experience accrued under the adjusted yields (Section 5 of the 

Guidelines):

For the 2012 and subsequent crop years, the limited irrigation corn or soybeans 

must be recorded on the insured’s acreage report. A separate line entry is 

required on the acreage report when full irrigation and limited irrigation are 

carried out on the same unit. In addition, the limited irrigation acreage must be 

identified and reported to RMA through the Policy Acceptance and Storage 

System (PASS) on the applicable Type 11 Acreage Record. The PASS limited 

irrigation code is xxxxx.

The APH database is not to be modified (Section 2 of the Guidelines). An adjusted APH 

yield is to be designated on the Type 15 record by a yet to be specified “yield limitation 

flag.” The term presumably means the “yield limitation code” (field 31 of the Type 15 

record). This is a two-byte field and there are ample available numerical designators to 

include this information. This situation also requires a modification of the rules for field 

45 (approved yield) of the Type 11 record. The rule “Approved Yield must equal

reduced Approved Yield when Yield Limitation Code equal Approved Yield Reduced 

Inconsistent Approved Yields, “10” or Approved Yield Reduced Different Production 

Methods, “11” in the Type 11 record would need modification to incorporate the situation 

when the approved yield has been reduced for limited irrigation.

The Contractor notes that the proposed treatment of limited irrigation allows the producer 

to use previously certified APH data as a basis for determining the approved yield and the 

guarantee for the current crop year. This avoids the need to start anew with transitional 

yields (or modified transitional yields), a situation that frequently becomes an issue when 

a new practice/type are included on the actuarial documents.

The statement “The PASS limited irrigation code is xxxxx” is unclear. The indicated 

length is five bytes. The Type 11 record contains the following five byte fields: insured 

share percent, experience factor, yield conversion factor, warehouse code, guarantee 
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adjustment factor, and residual factor. It is not intuitively clear where the information is 

to be entered.

These technical matters presumably would be rectified if and when the Guidelines are 

issued for implementation. Meanwhile, for crop year 2013, RMA did not provide the 

Contractor with any instructions that had been issued to the AIPs regarding the manner 

for processing any requests for limited irrigation that may be filed by producers in the 

designated sections of Sheridan and Thomas Counties, Kansas. It appears the draft 

Guidelines have not been issued to the AIPs. Further, the statements in the Special 

Provisions do not provide guidance.

The draft expands the amount of information required of the insured. In addition to the 

normal requirements for certifying production and acreage for prior crop years, the 

insured also is required to provide “historical water use records for at least the most 

recent 4 years of APH yields” (section 8) to qualify for the limited irrigation treatment of 

planted acreage. The records must be “third party verified.” Elsewhere in this report, the 

Contractor has noted potential difficulties with obtaining historical water use data 

specific to a unit level, but also noted more recent data should be more readily available. 

This particular provision does alleviate to a degree any concerns about lack of availability 

of records in general but does not necessarily address the issue of unit level information. 

However, if the most recent four years of APH yields extend more than four years into 

the past, the issue about availability of records may still be of concern.

The Contractor raises a question about the applicability of the Paperwork Reduction Act 

to the additional information requirements. The Contractor does not have knowledge of 

the respondent burden hours allotted for completion of acreage reports, but in the 

proposed rule published July 14, 2006 FCIC estimated the respondent burden to be 0.4 

hours per response, with an average of 3.6 responses per respondent. 55 The statement 

notes “Producers are required to report specific data when they apply for crop insurance 

and report acreage, yields, and notices of loss.” The additional information required to 

obtain irrigated coverage on acreage subject to limited irrigation might affect this 

estimate.

The requirement that the water records be “third party verified” may not present an issue 

at the producer level but may be an issue at a unit level. Further, while not an issue at the 

producer level in states with strongly regulated use of surface and ground waters, this 

requirement could become an issue in an area where water allocations are less stringently 

monitored.

Section 6 of the draft does require entry of a unique yield descriptor code to identify 

actual annual yields reported under a regime of limited irrigation. This provides an 

opportunity to perform analyses of the reliability of the yield reduction scheme that is 

adopted (UNL tables or alternative) by comparing those yields to yields in the database 

that were certified when the water restrictions were not known to be effective.

 

55 Federal Register, Vol. 71, No. 135, page 40195.
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Section 1 of the draft Guidelines advises AIPs that they may “develop their own election 

document or use an example document found on the Topeka Regional Office web page: 

http://www.rma.usda.gov/aboutrma/fields/ks_rso/.” The example document duplicates 

most of the information already contained on a valid APH database (see Crop Insurance 

Handbook, pages 620 ff). It also indicates need to enter water use in both acre-feet and 

acre-inches. It seems the primary purpose of the form should be to: 1) tie water use to a 

specific unit already designated on a Production Report, and 2) document that water use. 

Copying information from one form to another seems superfluous. In addition, entry of 

both acre-feet and acre-inches seems excessive and prone to error. For example, suppose 

the usage was 0.9 acre-feet. This corresponds to 10.8 acre-inches. Does the user enter 

0.9 acre-feet and 10.8 acre-inches? The UNL tables use whole inches as the unit of 

measure, and the draft Guidelines do not indicate any need to interpolate. In fact, all 

instructions describe usage of the UNL tables as being in gross inches. Thus, entry of 11 

acre-inches would seem to be a sufficient documentation.

Section 4 provides guidance on how to use the UNL tables. The last step directs the user 

to “Enter the resulting yield in the approved APH yield block” (block 25 on the sample 

form). However, the “Examples of Completed APH Databases” (CIH, pages 620 ff) also 

require entry of the approved APH yield.

The Contractor believes if this form is to be used, it should be simplified to require 

documentation only of the gross acre-inches of water applied (rounded to the nearest 

whole inch, as in the examples of how to apply the UNL tables). Once this information is 

documented, the user should be instructed to enter the approved yield in the appropriate 

field of the APH database form for the affected unit with an entry in the field “Other” to 

note the APH yield has been adjusted to reflect intended reduction of x inches of 

irrigation water for the current crop year.

Section 7 constitutes most of the draft Guidelines. This section depicts a 10 year 

progression of the change in the approved yield when historical water use is reduced from 

12 to 9 acre-inches. The illustrations show a reduction of 27 bushels per acre in the first 

2 years, 19 bushels in the next 4 years, 10 bushels in the next 3 years, and 0 thereafter. 

However, the UNL tables in Section 3 of the draft procedures contains a reduction of 

25.8 bushels (rounds to 26 bushels applicable to a reduction from 12 to 9 inches), a 

reduction of 17.8 bushels (rounds to 18 bushels) for a reduction from 11 to 9 inches, and 

a reduction of 9.2 bushels (rounds to 9 bushels) for a reduction from 10 to 9 inches. The 

indicated adjustments in Section 7 most likely are appropriate for some county but do not 

conform to the illustrated county. There should be consistency in the examples relative 

to the illustration of the UNL tables.

The IMDP use the UNL yield reduction tables as the mechanism by which limited irrigation 

insurance is to be implemented. Limited irrigation is treated as the irrigated practice with an 

adjusted APH yield as the “yield upon which the insurance guarantee is based.” With 

appropriate adjustments, as suggested by the Contractor, the IMDP could provide appropriate 

guidance for implementation of the proposed limited irrigation insurance approach.
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SECTION VI. RATING APPROACHES

This section of the report focuses on rating insurance for corn and soybeans in the relevant 

production areas. In particular, the Contractor addresses the utility of the premium rate 

generated under the irrigated practice continuous rating function for limited irrigation yields; 

consideration of insuring limited irrigation using the non-irrigated rate function versus the 

irrigated rate function; consideration of a separate limited irrigated practice with applicable rates; 

quantification of the effect of limited irrigation on yield variability; and additional research 

needed to determine if the model results are applicable to other areas and especially soil types.

FCIC base premium rates fundamentally are an average of loss cost ratios over a defined 

experience period. The loss cost ratio is the result of dividing the indemnity amount by the 

liability amount. Since crop insurance offers a variety of coverage levels, RMA adjusts the 

historical data to a common coverage level (65 percent). Actual losses at the various coverage 

levels are recalculated and liabilities are adjusted to amounts that would have been observed at 

that common coverage level. The resultant ratios of adjusted indemnity to adjusted liability form 

the loss cost ratios used for the rate adequacy analysis. The Contractor notes that certain 

adjustments are made to actual indemnities before these calculations are made. These include 

such policy provisions as prevented planting, high risk land, replanting payments, adjusting 

revenue coverage plans to a yield basis, etc. The goal is to achieve an estimate of the indemnity 

that would have been observed at the base coverage level under a pure loss of yield insurance 

plan for the majority of producers in the county.56

Obviously, there are no empirical observations of loss experience under a limited irrigation 

regime, or at least there are no identifiable observations. Hence, the fundamental approach for 

ratemaking utilized by RMA cannot be applied to provide guidance regarding questions about 

the appropriate premium rate for a limited irrigation practice. The Contractor instead must rely 

on logical constructs from statistics and from the structure of the University of Nebraska Lincoln 

(UNL) adjustment tables.

It is a fundamental axiom of statistics that:

Variance (y) = Variance (y – c)

where y is a random variable and c is a constant. In this case, y represents the dataset of all 

irrigated approved yields in a county and c represents an amount to be deducted from each of 

those approved yields to establish the basis of a limited irrigation guarantee.57 Since the variance 

of the dataset of transformed yields is identical to the variance of the dataset of the original 

approved yields, the coefficient of variation (c.v.) is greater. The c.v. is a measure formed as the 

ratio of the standard deviation of a dataset to its mean, and is a measure of relative risk. To 

illustrate this relationship, the Contractor compared two counties: Sherman County, Kansas, and 

Perkins County, Nebraska. These two counties have similar yield profiles but significant 

differences in premium rates. Data for these counties for the 2011 crop year for corn are 

 

56 This paragraph is a summary of pages 15-26 of “A Comprehensive Review of the RMA APH and COMBO Rating 

Methodology” located at http://www.rma.usda.gov/pubs/2009/comprehensivereview.pdf, accessed May 2, 2013. 

57 It makes no difference if the dataset is all yields in the county or is a subset of all yields in the county that are subject to 

reduction due to reduced water availability.
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included in Tables 11 and 12. Both counties have significant acreage of both irrigated and nonirrigated practice corn. Approved yields in both counties vary over a wide range, and should 

provide a reasonable foundation for examining rating issues. It should be noted the APH data 

do not incorporate specific knowledge of the amount of water applied (artificial + natural) 

to achieve the approved yield. It is possible the range of APH approved yields reflects 

different total amounts of water for the different insured units. The existing APH premium rates 

are likely already applied to different levels of total water available for evapotranspiration, as the 

chance that all units are receiving the same precipitation and all insureds are applying the same 

per acre quantities of water approaches zero. In addition, the approved yield for a unit may 

include non-irrigated acreage in the corners of a center pivot irrigation system, depending on the 

planting and harvest practices used by the insured. To the extent this occurs, the approved yield 

for irrigated acreage will be biased downward relative to units that reported the irrigated circles 

and the non-irrigated corners separately.

Table 11. Yields and Actuarial Data for Corn for the 2011 Crop Year, Sherman County, 

KS and Perkins County, NE

Practice

Average 

Approved 

Yield

Standard 

Deviation

Coefficient of 

Variation

Base 

Premium 

Rate*

Reference Yield

Sherman County, KS

Non-irrigated (003) 58.4 15.5 26.5% 29.8% 40

Irrigated (002) 185.1 22.1 11.9% 8.7% 156

Perkins County, NE

Non-irrigated (003) 66.8 10.6 15.9% 14.1% 53

Irrigated (002) 182.1 16.5 9.0% 5.1% 168

* Base premium rate is the sum of the base rate and the fixed load.

Source: The Contractor’s Rating Department after RMA data.
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Table 12. Reported Acres, Premium, Indemnity, and Liability for Ranges of Approved 

Yields, Sherman County, KS and Perkins County, NE for 2011 Crop Year

Sherman County Irrigated Practice Sherman County Non-irrigated Practice

Approved 

Yield 

Range

Reported 

Acres

Premium 

($1,000)

Indemnity 

($1,000)

Liability 

($1,000)

Approved 

Yield 

Range

Reported 

Acres

Premium 

($1,000)

Indemnity 

($1,000)

Liability 

($1,000)

130-140 2,313 204 0 1,032 20-30 714 28 0 47

140-150 3,506 230 43 1,489 30-40 15,085 542 66 1,187

150-160 5,641 208 39 1,517 40-50 23,484 1,054 145 2,731

160-170 15,930 910 208 7,016 50-60 25,010 891 156 3,505

170-180 17,371 1,003 357 7,957 60-70 30,405 1,280 414 5,784

180-190 32,429 1,614 159 13,952 70-80 13,825 429 34 2,116

190-200 27,771 1,365 135 12,700 80-90 1,509 88 34 445

200-210 17,893 958 54 8,933 90-100 1,061 56 16 276

210-220 15,249 718 97 8,635 110-120 320 9 0 51

220-230 3,200 152 1 1,595 Total 111,413 4,378 865 16,142

230-240 718 40 0 365

Total 142,022 7,402 1,092 65,192

Perkins County Irrigated Practice Perkins County Non-irrigated Practice

120-130 123 6 0 61 30-40 242 3 0 9

140-150 1,656 87 54 675 40-50 5,280 244 3 717

150-160 4,114 247 165 2,109 50-60 30,099 939 79 4,404

160-170 13,673 728 222 7,545 60-70 73,864 2,383 380 13,710

170-180 35,929 1,793 873 18,833 70-80 44,549 1,611 569 11,045

180-190 40,596 1,791 1,448 20,957 80-90 11,228 443 95 3,158

190-200 29,309 1,347 2,007 15,804 90-100 439 13 0 97

200-210 11,972 645 1,470 7,327 100-110 6 0 0 1

210-220 6,696 369 67 4,311 Total 165,706 5,635 1,126 33,142

220-230 260 15 0 223

Total 144,327 7,028 6,305 77,845

Source: The Contractor’s Rating Department after RMA data.

As shown in Table 11, higher base premium rates are associated with higher c.v. values. Note 

also, although the reference yields and the average approved yields58 for the irrigated practice are 

similar for the two counties, the base premium rate in Sherman County is much higher, as is the 

c.v. for that county. However, the difference in base premium rates for the irrigated practice are 

not nearly as pronounced as the difference in the base premium rates for the non-irrigated 

practice, reflecting the differences in the c.v. values. These empirical results are consistent with 

the theoretical argument that premium rates are related to the c.v. of the yield data.

The UNL adjustment tables compare a current reduction (in inches) of available water to the 

amount of irrigation water applied historically. For each inch of current reduction relative to a 

specific historical amount, the tables specify an amount by which the yield is expected to 

decrease on average. Alternatively, the tables also can be interpreted to indicate the increase in 

 

58 The data are simple averages. However, an acreage weighted average yield is within two bushels of the values shown.
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yield (again, on average) expected by application of additional water. For example, Table 13 

contains the adjustment table for Sherman County, Kansas.
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Table 13. UNL Yield Adjustment Table for Limited Irrigation, Sherman County, KS

1) Select State

Kansas

2) Select County

Sherman

3) Select Irrigation System

Pivot System (AE = 0.85)

4) Select Crop

CORN

Historical Water 

Use, Inches

Reduction in Historical Water Supply, Inches of Gross Irrigation

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

Reduction in Bushels per Acre

1 -12.2 na na na na na na na na na na na na na na

2 -12.0 -24.2 na na na na na na na na na na na na na

3 -11.8 -23.8 -36.0 na na na na na na na na na na na na

4 -11.5 -23.3 -35.3 -47.5 na na na na na na na na na na na

5 -11.3 -22.8 -34.6 -46.5 -58.8 na na na na na na na na na na

6 -11.0 -22.3 -33.8 -45.5 -57.5 -69.8 na na na na na na na na na

7 -10.7 -21.7 -33.0 -44.5 -56.2 -68.2 -80.5 na na na na na na na na

8 -10.4 -21.1 -32.1 -43.4 -54.9 -66.6 -78.6 -90.9 na na na na na na na

9 -10.1 -20.5 -31.2 -42.2 -53.4 -64.9 -76.7 -88.7 -100.9 na na na na na na

10 -9.7 -19.8 -30.2 -40.9 -51.9 -63.1 -74.7 -86.4 -98.4 -110.6 na na na na na

11 -9.3 -19.0 -29.1 -39.5 -50.2 -61.2 -72.5 -84.0 -95.7 -107.7 -120.0 na na na na

12 -8.9 -18.2 -27.9 -38.0 -48.4 -59.1 -70.1 -81.3 -92.9 -104.6 -116.6 -128.8 na na na

13 -8.4 -17.3 -26.6 -36.3 -46.4 -56.8 -67.5 -78.5 -89.7 -101.2 -113.0 -125.0 -137.2 na na

14 -7.8 -16.2 -25.1 -34.4 -44.1 -54.2 -64.6 -75.3 -86.3 -97.5 -109.1 -120.8 -132.8 -145.0 na

15 -7.1 -14.9 -23.3 -32.2 -41.5 -51.2 -61.3 -71.7 -82.4 -93.4 -104.7 -116.2 -127.9 -139.9 -152.2

Source: The UNL Partnership Team, 2013 Deficit Irrigation Insurance Template.
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The UNL tables are constructed such that adjustments are made up to a specified maximum of 15 

inches of reduction in historical water use.59 The table may be interpreted as follows. Assume a 

producer has historically added one inch of irrigation water to the acreage. If this one inch is no 

longer applied, the table indicates the yield will decline by 12.2 bushels per acre, i.e., it will be 

reduced to a non-irrigated yield. Stated another way, the addition of the one inch of water is 

expected to increase the yield by 12.2 bushels per acre relative to the non-irrigated yield. If two 

inches of irrigation water historically have been applied, the expected increase in yield is 24.2 

bushels relative to the non-irrigated yield (12.0 bushels compared to the first inch of irrigation 

water). Similarly, as additional amounts of irrigation water are added, the expected yield 

increases but the rate of increase decreases until a maximum is achieved at 15 inches of irrigation 

water, which results in an increase in yield of 152.2 bushels per acre relative to the non-irrigated 

yield for Sherman County. The adjustment table for Perkins County is similar, and maximizes 

the increase in yield at 143.3 bushels per acre with 15 inches of irrigation water.

60

The amount of adjustment in an approved yield is indicated by the row in which the historical 

amount of irrigation water occurs. For example, if 15 inches historically have been applied, a 

reduction of one inch in availability reduces the expected yield by 7.1 bushels. Reducing water 

availability by two inches reduces the expected yield by 14.9 bushels, with additional reductions 

in expected yield until the entire 15 inches are reduced, at which point the reduction in yield is 

the same as the increase that was expected at that level.61 Note that each inch of reduction in 

water use results in a yield change that is substantially the same as the increase associated with 

use of additional water. For example, the 7.1 bushel reduction amount cited above compares to 

the increase in yield between use of 14 and 15 inches of water (e.g., 154.4 – 145.0 = 7.2). The 

differences are rounding.

It is evident from Table 13 that each incremental inch of reduction in irrigation water results in a 

larger adjustment to the expected irrigated yield, i.e., the value of c in the expression above 

becomes larger. As the constant c increases, both the expected yield and the c.v. approach the 

values for the non-irrigated yields.62 The theoretical construct indicates the base premium rate 

must be increased if approved yields are reduced to accommodate a limited irrigation practice. 

Unfortunately, this requires a different amount of adjustment in the base premium rate for every 

inch of decrease in available water since the value of c is based on the amount (in inches) that 

water is reduced, a factor that would expand the actuarial documents significantly.

 

59 The term “gross inches” in the table refers to the total amount of irrigation water applied. Since water distribution systems are 

not 100 percent efficient, not all the water that is applied can be utilized by the crop.

60 The data are for a center pivot system that is considered to have 85 percent efficiency in use of gross inches of applied water. 

The yield “boost” would be lower for other irrigation systems. For example, a gravity system has an efficiency of only 60 

percent and the yield “boost” at 15 inches of gross water application is only 127 bushels per acre.

61 Note that, in contrast to the reduced marginal response to additional applications of water when applications are increasing,

there is an increased marginal response to reductions.

62 The Contractor notes that very low irrigated approved yields will be limited (cupped) at the non-irrigated reference yield (or 

the producer’s proven non-irrigated approved yield) if available water is reduced by a very large amount. In this case, the c.v. 

will be smaller than the original amount due to the number of fixed yields in the dataset. The Contractor did subtract the 

maximum 152.2 bushels from the irrigated approved yields for Sherman County. This corresponds to a combination of 15 

inches of historical use and a reduction of 15 inches. Since more than half the adjusted approved yields were cupped at the 

non-irrigated reference yield, the resulting average adjusted approved yield is 45.6 bushels and the c.v. is 21.6.
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The Contractor used the information of Table 13 to construct a set of average yields relative to 

the non-irrigated reference yield for the two counties. For example, if one inch of water is 

historically applied, the UNL tables for Sherman County indicate the estimated yield is 40.0 + 

12.2 bushels, or 52.2 bushels if the non-irrigated reference yield for the county is accepted as the 

base. The maximum implied irrigated yield, assuming the non-irrigated reference yield as the 

base, occurs with supplemental water equal to 15 inches (40 bushels + 152.2 bushels). The 

yields at all other levels of water application reflect the adjustment factor appropriate for that 

level of water application. For example, the entry of 150.6 bushels for historical water use of 10 

inches represents the 40.0 bushel non-irrigated reference yield + 110.6 bushels from irrigation 

(from Table 13). The results of analysis using this approach are contained in Table 14.
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Table 14. Estimated Yield Levels, Premium Rates (65% Coverage Level), and Premiums 

per Acre for Corn, Sherman County, KS and Perkins County, NE with UNL Adjustment 

Factors Incorporated Using Non-irrigated Reference Yield as the Base (2011 Crop Year 

Parameters)

Sherman County, KS

Historical Water Use Implied 

Yield

Irrigated 

Premium 

Rate

Total 

Premium 

in 

Bushels

Nonirrigated 

Premium 

Rate

Total 

Premium 

in 

Bushels

15 192.2 6.0% 7.56 14.7% 18.37

14 185.0 6.3% 7.57 14.7% 17.68

13 177.2 6.6% 7.61 14.7% 16.94

12 168.8 7.0% 7.67 14.7% 16.13

11 160.0 7.5% 7.76 14.7% 15.29

10 150.6 8.1% 7.89 14.7% 14.39

9 140.9 8.8% 8.07 14.7% 13.47

8 130.9 9.8% 8.33 14.7% 12.51

7 120.5 11.1% 8.67 14.7% 11.52

6 109.8 12.8% 9.15 14.7% 10.49

5 98.8 15.3% 9.81 14.7% 9.44

4 87.5 18.9% 10.73 14.7% 8.36

3 76.0 23.2% 11.48 14.7% 7.26

2 64.2 23.2% 9.70 14.7% 6.14

1 52.2 23.2% 7.89 18.0% 6.10

0 40.0 23.2% 6.04 27.3% 7.10

Base Rate 4.6% 23.4%

Fixed Load 3.1% 3.9%

Reference Yield 156 40

Exponent -2.131 -1.906

Perkins County, NE

15 196.3 4.3% 5.47 7.6% 9.74

14 190.1 4.4% 5.48 7.6% 9.44

13 183.1 4.6% 5.50 7.6% 9.09

12 175.5 4.8% 5.53 7.6% 8.71

11 167.4 5.1% 5.57 7.6% 8.31

10 158.6 5.5% 5.64 7.6% 7.87

9 149.5 5.9% 5.73 7.6% 7.42

8 140.0 6.4% 5.86 7.6% 6.95

7 130.2 7.1% 6.03 7.6% 6.46

6 120.0 8.0% 6.27 7.6% 5.96

5 109.5 9.2% 6.58 7.6% 5.44

4 98.7 10.9% 7.00 7.6% 4.90

3 87.7 13.3% 7.58 7.6% 4.35

2 76.4 14.3% 7.11 8.1% 4.01

1 64.8 14.3% 6.03 10.3% 4.33

0 53.0 14.3% 4.94 14.1% 4.86

Base Rate 3.0% 11.9%

Fixed Load 2.1% 2.2%

Reference Yield 168 53

Exponent -2.027 -1.932

Source: The Contractor’s Rating Department after RMA data.

The premium rates at each yield level in Table 14 are calculated from the rating parameters 

shown below the data for each county. Rates are cupped or capped as appropriate when the ratio 
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of the implied yield to the reference yield is less than 0.50 or greater than 1.50, consistent with 

RMA procedure. Premium amounts per acre are in bushels per acre and are based on a 65 

percent coverage level guarantee.

Application of the non-irrigated rates to these irrigated yields results in a flat-rated schedule with 

premium amounts that are more than double the premium calculated using the irrigated premium 

rating parameters for the highest yield ratios, because of the large differences in the reference 

yields and the base premium rates between the two practices. For low yield ratios, the irrigated 

premium rate schedule produces higher premium rates and costs than does the non-irrigated 

premium rate schedule.

One might ask about the impact of relaxing the constraints that the yield ratio cannot be less than 

0.50 or greater than 1.50. Removing the 1.50 yield ratio constraint from the non-irrigated rate 

values results in a premium rate of 5.1 percent and reduces the total premium by 1.23 bushels per 

acre (16.1 percent) for the 192.2 bushel yield in Sherman County. Considering the large amount 

of data that have been incorporated into the irrigated practice rates, it clearly would be 

inappropriate to charge a smaller total premium for production under limited irrigation than that 

generated by the continuous rating function irrigated premium rate parameters for an approved 

yield of 192.2 bushels per acre. At the other extreme, the indicated premium rate if the 0.50 

constraint is relaxed results in a premium rate of 310 percent for a yield of 40 bushels under 

irrigated practice in Sherman County. This also clearly is inappropriate.

The Government posed the following question in the Task Order:

“If the lower limited irrigated yield seeks the appropriate rate level (a higher 

rate) on the irrigated practice rate table, why wouldn’t the limited irrigated yield 

seek the appropriate rate (since the higher limited irrigated yield relative to the 

reference yield would generate a lower rate) on the non-irrigated practice rate 

table?” 

The foregoing discussion illustrates the large differences in base premium rates and reference 

yields between the two practices result in inappropriate premium rates for the irrigated practice 

yields if the non-irrigated premium rate schedule is used to develop the premium rates for limited 

irrigation acreage. Furthermore, since it is unlikely producers are claiming an irrigated practice 

if they have irrigated with just one, two, or three inches of water rather than eight, nine, ten or 

more inches, building down from the irrigated parameters rather than up from the non-irrigated 

parameters seems more logical. The Contractor recommends the alternative of using the nonirrigated practice rate table not be considered.

The Contractor constructed a set of adjusted yields based on the UNL yield adjustments if the 

available water supplies are reduced by one to 15 inches and the producer had historically used 

15 inches of water (an amount nearer to the “typical” irrigation application). Those results are 

included in Table 15.
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Table 15. Indicated Yields, Premium Rates, and Total Premiums Associated with Water 

Reductions Assuming Historical Use of 15 Inches of Water, Sherman County, KS and 

Perkins County, NE

Sherman County, KS Perkins County, NE

Reduction 

in Use

Adjusted 

Yield

Irrigated 

Premium 

Rate

Total 

Premium 

in 

Bushels 

Reduction 

in Use

Adjusted 

Yield

Irrigated 

Premium 

Rate

Total 

Premium 

in 

Bushels 

1 185.1 6.3% 7.56 1 190.1 4.4% 5.48

2 177.3 6.6% 7.57 2 183.1 4.6% 5.50

3 168.9 7.0% 7.61 3 175.5 4.8% 5.53

4 160.0 7.5% 7.67 4 167.3 5.1% 5.57

5 150.7 8.1% 7.76 5 158.6 5.5% 5.64

6 141.0 8.8% 7.89 6 149.5 5.9% 5.73

7 130.9 9.8% 8.07 7 140.0 6.4% 5.86

8 120.5 11.1% 8.33 8 130.2 7.1% 6.03

9 109.8 12.8% 8.67 9 120.0 8.0% 6.27

10 98.8 15.3% 9.15 10 109.5 9.2% 6.58

11 87.5 18.9% 9.81 11 98.7 10.9% 7.00

12 76.0 23.2% 10.73 12 87.7 13.3% 7.59

13 64.3 23.2% 11.48 13 76.4 14.3% 7.11

14 52.3 23.2% 9.70 14 64.8 14.3% 6.03

15 40.0 23.2% 7.89 15 53.0 14.3% 4.94

Source: The Contractor’s Rating Department after RMA data.

Table 15 demonstrates that the effect of the adjustments is to move the implied yield and 

premium rate downward by one inch of water. For example, the yield and premium rate that 

occur for a reduction of 1 inch of water relative to historical use of 15 inches as shown in Table 

15 are the same as the information shown in Table 14 for historical application of 14 inches of 

water. If the historical use had been 14 inches, the adjusted yield and premium for a 1 inch 

reduction would be the same as the yield and premium that would have existed for historical use 

of 13 inches of water. If historical use had been 13 inches, the effect of a 1 inch reduction is the 

same as historical use of 12 inches, and so forth.

In both counties, the high fixed load relative to the magnitude of the base rate creates an increase 

in premium cost per acre as the yield declines. Hence, reducing the approved yield on which the 

guarantee is based for limited irrigation increases premiums per acre for that practice slightly 

relative to the premium for full irrigation, but under the limited irrigation practice there is a 

lower guarantee. Since the fixed rate loads apply over wide areas and irrigated premium rates 

tend to be low, this characteristic exists for many more counties that the two sample counties.

In the Task Order, the Government posed the question:

“The methodology [of the UNL adjustments] was focused on the effect of 

irrigation on yield levels, but has not addressed the effect on yield variability. 

This is needed because the variability of yields is what determines losses and 
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premium rates. Without a sufficient understanding of how much yield risk 

increases as irrigation decreases, RMA does not have a basis to establish 

actuarially sound premium rates.”

As the Contractor noted earlier, the set of approved yields that currently exists has no 

information attached to it regarding the quantities of water used to produce those yields. In 

addition, the impact of the corners of center pivot irrigation systems may have resulted in smaller 

irrigated approved yields on a unit basis than was actually achieved on the acres that were 

actually irrigated.63 Under the current insurance, producers already most likely are insuring 

approved yields produced with a variety of amounts of applied water.

The Contractor considered the contribution of irrigation to increasing a producer’s approved 

yield by examining the difference between the non-irrigated approved yield and the irrigated 

approved yield for those policy numbers for which both practices were reported for crop year 

2011. The goal is to examine the range of approved yields already insured with irrigated practice 

premium rates. The data are presented in Table 16.

Table 16. Policy Number Counts, Ranges of Approved Yields, and Increases in Approved 

Yields for Irrigated Practice for Policy Numbers with Both Irrigated and Non-irrigated 

Practice, Sherman County, KS and Perkins County, NE, 2011 Crop Year

Sherman 

County, 

KS

Perkins 

County, 

NE

Total Number of Policy Numbers 559 599

Policy Numbers with Both Practices 206 250

Minimum Irrigated Yield for Policy Numbers with Only Irrigated 

Practice 135.0 127.0

Minimum Irrigated Yield for Policy Numbers with Both Practices 133.6 140.0

Maximum Irrigated Yield for Policy Numbers with Only Irrigated 

Practice 226.9 210.0

Maximum Irrigated Yield for Policy Numbers with Both Practices 238.0 220.0

Minimum Difference in Approved Yields for Policy Numbers with Both 

Practices 71.1 74.0

Maximum Difference in Approved Yields for Policy Numbers with 

Both Practices 177.0 160.0

Source: The Contractor’s Rating Department after RMA data.

Both counties have a significant number of policies that reported corn for insurance in the 2011 

crop year, with about 40 percent reporting acreage of both irrigated and of non-irrigated practice. 

The results are not based on a small number of policies. The minimum irrigated yield and the 

maximum irrigated yield are comparable for each group of policies within a county regardless of 

whether the producer specialized in irrigated practice or reported both practices. The minimum 

difference in approved yields for policies that reported both practices is very similar in both 

counties while there is about a ten percent difference in the maximum differences.

 

63 A discussion of the impact of this factor is found later in this section.
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The last two rows of the table provide interesting data that sheds light on the question posed by 

the Government. The row that reports the minimum differences is the most difficult to interpret 

because it could represent situations in which the producers reported irrigated units with included 

non-irrigated corners as well as pure irrigated units that happened to have low yields due to 

relatively small use of irrigation water. Or, it could represent situations in which the producer 

had an irrigated unit on which the water availability had been restricted and the producer only 

was able to pump a limited amount of water. The data included in the FCIC database do not 

permit any firm assessments of the reasons for the difference in yields.

The maximum differences provide a more meaningful basis for comparisons. Consider, for 

example, the indicated increase in yield associated with application of 15 gross inches of water 

of 152.2 bushels in Sherman County, Kansas and 143.3 bushels in Perkins County, Nebraska. 

The maximum difference in both counties is within 10 to 15 percent of the maximum increase 

included in the UNL tables. The UNL data represent an expected or mean outcome; there can be 

situations where the actual amount of difference is higher or lower depending on management 

ability, soil characteristics, variety planted, and other variables not recognized by the UNL 

tables. Hence, the similarity of the data supports the idea that the UNL tables are representative 

of outcomes under production conditions.

The Contractor also examined the difference of the irrigated and non-irrigated yield on policies 

that reported both practices as reported in Table 17. For example, the yield range 70 to 80 in 

Sherman County, Kansas is the result of subtracting the average approved yield for non-irrigated 

practice acreage from the average approved yield for irrigated practice acreage on policies that 

reported both practices. The average yield is the mean of the difference for the acreage included 

in the range. The column labeled total acres represents the number of acres (both irrigated 

practice and non-irrigated practice) included in the range. Reasons for the wide range of yield 

“boost” (between 70 and 180 bushels per acre) can include soil types, irrigation systems and 

efficiency, typical date of planting, variety planted, amount of fertilizer applied, and amount of 

water applied, among other factors. The point is that the acreage insured under irrigated practice 

under the present crop insurance offer already includes a very wide range of yield “boost” 

relative to yields for non-irrigated practice. Recall the statistical law presented at the beginning 

of this section. This law is based on the premise that the random variable y is generated by a 

statistical distribution that has specific and consistent properties. That condition may not hold 

with regard to the distribution of approved yields for irrigated practice acreage. Hence, the 

variability cited in the issue posed by the Government may already be accommodated under the 

present rating structure for the irrigated practice.
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Table 17. Average Difference of Irrigated Yield Relative to Non-irrigated Yield on Policies 

with Both Practices and Reported Acres

Sherman County, KS Perkins County, NE

Yield 

Range

Average 

Yield

Total 

Acres

Percent 

of Acres

Yield 

Range

Average 

Yield

Total 

Acres

Percent 

of Acres

70-80 73 2,565 1% 70-80 74 262 0%

80-90 85 1,537 1% 80-90 86 1,466 1%

90-100 95 6,981 4% 90-100 95 14,832 7%

100-110 104 6,274 4% 100-110 106 56,115 25%

110-120 115 24,823 14% 110-120 115 58,785 26%

120-130 125 37,099 21% 120-130 125 62,617 28%

130-140 135 34,105 19% 130-140 133 25,844 12%

140-150 146 41,826 23% 140-150 145 4,211 2%

150-160 154 15,888 9% 150-160 160 212 0%

160-170 162 5,819 3%

170-180 176 1,982 1%

Total 178,899 Total 224,344

Source: The Contractor’s Rating Department after RMA data.

In the Task Order, the Government posed the following questions: “Is the premium rate 

generated under continuous rating for the lower limited irrigated yield using the irrigated practice 

rate table a reasonable estimate of the risk?” “Should there be a separate limited irrigated 

practice with applicable rates?”

The Contractor believes it is useful to discuss these questions jointly since the two are related.

The report “A Comprehensive Review of the RMA APH and COMBO Rating Methodology” 

cited earlier contains the following statements regarding the yield ratio (page 37):

“The yield ratio curve, based on the negative exponent in equation 4.2, is part of a 

mechanism to individualize the county-level unloaded rate to reflect differences in 

expected loss costs for insured units depending on the relationship between the 

individual rate yield and the reference yield. As discussed above, this approach 

essentially implies that premium rates should be inversely related to individual 

average (rate) yields. That is, farmers with higher yields relative to the county 

have lower rates and those with yields lower than the county have higher rates.

As Milliman and Robertson (2000, p. 33) point out, the rationale for using this 

approach stems from RMA research that demonstrated that “on average, the 

probability of a loss is greater for producers with a yield lower than the average 

for an area and vice versa [for producers with yields higher than the area 

average].” This finding indicates that as an individual’s mean yield increases 

relative to the county average; their proportional yield variability decreases such 

that it lowers the likelihood of an indemnified loss. Hence, premium rates are 

structured to decline with increases in individual rate yields.”
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It is important to note the distinction between premium rates and premiums per acre. As the 

cited material states, the yield ratio curve does result in lower premium rates as the approved 

yield increases relative to the reference yield. However, it is possible for total premium per acre 

to remain relatively flat over a range of yield ratios or it may increase because the percentage 

increase in yield (guarantee) is greater than the percentage decrease in the premium rate. This 

outcome results from the treatment of the two components of the premium rate: the base rate, 

which is subject to the yield ratio adjustment, and the fixed load which is not. The fixed load 

becomes a larger percentage of the total rate as the base rate decreases. For the two counties 

included as examples, the premium per acre does decrease as the yield increases. Conversely, 

the total premium per acre increases as the approved yield is decreased to reflect the lower 

expected yields under limited irrigation.

Due to the uncertainties regarding the actual interpretation of the approved yields in the RMA 

database, and due to the small differences in total premium in the range in which most approved 

yields fall, the Contractor believes it would be difficult to justify a separate rating schedule that 

generated two different premium rates for the same yield. That is, if the approved yield is 185 

bushels under standard APH procedures and the adjusted yield is 185 bushels, how does one 

explain a rationale to charge a higher premium rate in the second case? In spite of any 

hypothetical differences in yield variability under the irrigated and limited irrigation practices, 

the imperfections of the data make it difficult to develop a convincing argument. FCIC was 

perfectly willing to accept a premium rate of x percent for a yield of 185 bushels that may have 

been the result of applying 14 inches of irrigation water historically. An adjusted yield based on 

applying 14 inches of water should be conceptually identical.

The Contractor notes that premium rates and premium amounts do differ, sometimes materially, 

when the irrigated yield is low, especially if that adjusted yield is less than 50 percent of the 

reference yield. The Contractor believes this situation can be managed by inserting a rule that 

the premium rate be the lesser of the amount determined with the irrigated or the non-irrigated 

rating schedule.

In the Task Order, the Government posed the following question: “Are the data supporting 

limited irrigation models sustainable and maintainable in the future so appropriate coverage and 

premium rates can be properly updated?”

The UNL model is discussed in detail in Section IV of this Deliverable. Specific considerations 

affecting its ability to be extended and updated are contained in that section. In the present 

section, the Contractor notes that maintenance on a continuing basis will depend on the ability of 

RMA to identify the specific data points generated by units on which the limited irrigation 

practice is followed. With this ability, loss cost ratios for those units could be compared to units 

on which the irrigated and non-irrigated practices are followed. These loss cost ratios would 

allow updating in accordance with the normal RMA procedure, defined in “A Comprehensive 

Review of the RMA APH and COMBO Rating Methodology” (page 38) as follows:

“The current RMA rating procedure for type/practice is described in an internal 

document titled “RMA Type/Practice Rating Methodology Interim Underwriting 

Guidelines”. In the current system, crop type/practice is accounted for by 
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53

multiplying the variable rate component of the county target rate by a 

type/practice factor (TpFactor) for each type/practice combination. In 

constructing these type/practice factors the RMA uses experience at a multicounty level, at the state level, or at a multi-state level. Deciding on the proper 

level of aggregation for any crop and region is a matter of balancing two primary 

considerations: homogeneity of risks and volume of data. The risks associated 

with each crop type/practice are more homogeneous at a disaggregate level; 

however, aggregation provides a greater volume of data. The approach taken to 

address this problem varies by region. For example, in deriving the Tp Factors 

for irrigated and non-irrigated practices in the Western States, grouping a 

smaller number of geographically clustered counties within the state is more 

typical since the average rainfall (and the importance of irrigation) changes 

significantly over shorter distances.”

The Contractor earlier had raised a topic regarding the inclusion of the production and acreage of 

the non-irrigated corners of a center pivot irrigation system in an irrigated practice under some 

conditions. The average yield included in the irrigated practice APH database includes the 

production from both the irrigated and non-irrigated portions of the unit divided by the total unit 

acres. This raises the question: “Does forcing inclusion of the non-irrigated acres and 

production in the irrigated unit have any bearing on the UNL tables for limited irrigation?”

Assume the producer is using a center pivot system without the corner extension units on a 160 

acre quarter section. The area of the inscribed circle constitutes 78.5 percent of the area of a 

square of this size. The entire quarter section is planted to corn.

Further assume the acreage is located in Perkins County, Nebraska. The average yield for the 

irrigated portion of the acreage is 168 bushels per acre and the average yield for the non-irrigated 

portion is 53 bushels per acre.64 First consider the case that the practices are separately 

reportable, are reported separately, and ignoring the loss of acreage that would occur to create a 

divider between the two practices. Guarantees and premiums are shown in Table 18.

Table 18. Acres Insured, Guarantees per Acre, and Premiums for Irrigated and Nonirrigated Practices Separately Insurable in a Quarter-Section with Pivot Irrigation System

Irrigated Nonirrigated Total

Acres insured 125.7 34.3 160.0

Approved Yield 168 53

Guarantee/acre (65%) 109 34

Total guarantee (bu.) 13,701 1,166 14,868

Premium rate 0.051 0.141

Total premium (bu.) 699 164 863

Source: The Contractor’s Rating Department after RMA data.

 

64 The Contractor acknowledges that these data are not separately maintained in the APH databases. These are the reference 

yields for the county and in this example are used as the basis for establishing the approved yield.
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Now assume the acreage does not meet the conditions for establishing separate irrigated and nonirrigated units. The guarantee and premium for this situation are shown in Table 19.

Table 19. Acres Insured, Guarantee per Acre, and Premium for Irrigated Practice when 

Corners of a Center-pivot Irrigation System are Included in the Irrigated Practice Acreage

Irrigated

Acres insured 160

Approved Yield 143

Guarantee/acre (65%) 93

Total guarantee (bu.) 14,880

Premium rate 0.063

Total premium (bu.) 937

Source: The Contractor’s Rating Department 

after RMA data.

Now suppose this producer had been using 15 inches of irrigation water but is required to reduce 

usage by five inches. According to the UNL adjustment tables for Perkins County, the expected 

irrigated practice yield decreases by 86.8 bushels. The adjusted data for separately reportable 

practices are shown in Table 20.

Table 20. Acres Insured, Guarantees per Acre, and Premiums for Irrigated and Nonirrigated Practices Separately Insurable in a Quarter-Section with Pivot Irrigation System,

Irrigated Yield is Reduced by 86.8 Bushels per Acre

Irrigated Nonirrigated Total

Acres insured 125.7 34.3 160.0

Adjusted Yield 81 53

Guarantee/acre (65%) 53 34

Total guarantee (bu.) 6,662 1,166 7,828

Premium rate 0.143 0.141

Total premium (bu.) 953 164 1,117

Source: The Contractor’s Rating Department after RMA data.

Table 21 contains the data that would apply if the entire unit was reported as irrigated practice.
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Table 21 Acres Insured, Guarantee per Acre, and Premium for Irrigated Practice when 

Corners of a Center-pivot Irrigation System are Included in the Irrigated Practice Acreage 

and Yield is Reduced by 86.8 Bushels per Acre

Irrigated

Acres insured 160

Adjusted Yield 56

Guarantee/acre (65%) 36.4

Total guarantee (bu.) 5,824

Premium rate 0.143

Total premium (bu.) 833

Source: The Contractor’s Rating Department 

after RMA data.

Applying the adjustment amount to the adjusted yield sharply reduces the total guarantee when 

the total acreage in the area with a center pivot system is planted to the same crop and the 

practices do not qualify to be reported separately. However, this situation can be rectified by 

adjusting the amount in the UNL tables to reflect the proportion of the acreage that is affected by 

the center pivot system. As noted earlier, the area of the inscribed circle composes 78.5 percent 

of the area of the square. Thus, rather than reducing the adjusted yield by 86.8 bushels, it should 

be reduced by 68.1 bushels. The results of this adjustment are shown in Table 22.

Table 22. Acres Insured, Guarantee per Acre, and Premium for Irrigated Practice when 

Corners of a Center-pivot Irrigation System are Included in the Irrigated Practice Acreage 

and Yield is Reduced Proportionately by 68.1 Bushels per Acre

Irrigated

Acres insured 160

Adjusted Yield 75

Guarantee/acre (65%) 48.75

Total guarantee (bu.) 7,800

Premium rate 0.143

Total premium (bu.) 1115

Source: The Contractor’s Rating Department after 

RMA data.

These results are substantially the same as those contained in Table 20 where the practices are 

separately reportable.

In the Task Order, the Government posed the following question:

“Allowing limited irrigation acreage to be reported as an irrigated practice 

would seem to inflate future eligibility for irrigated prevented planting payments 

since a producer would not have to reduce the number of planted irrigated acres 

under limited irrigation. What potential premium rate increase would this 

present?”

Whether or not allowing limited irrigation acreage to be reported as an irrigated practice would 

inflate future eligibility for irrigated prevented planting payments depends on the manner the 
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limited irrigation is introduced. If it is introduced as a separately identified practice (i.e., distinct 

from practice 002), the effect will be to reduce prevented planting payments for practice 002 and 

introduce prevented planting payments for practice nnn. This situation is identical to that 

described in the Prevented Planting Loss Adjustment Standards Handbook ((FCIC-25370-3) at 

section E(5)(a) (page 77): “There is a total of 100 acres of wheat in unit 0001-001OU. The 

insured claims all 100 acres as summerfallow, but only has a history of 50 acres summerfallow 

and 50 acres of continuous cropping on the unit. The insured cannot be paid PP on 100 acres of 

summerfallow unless all 100 acres claimed as PP qualify for a summerfallow practice.”

However, if limited irrigation was introduced under practice code 002 then the prevented 

planting payments also would be made under practice code 002. Or, if limited irrigation is not 

allowed and acreage upon which reduced irrigation is applied must be reported as a non-irrigated 

practice, the prevented planting payments would accrue under that non-irrigated practice.

The Contractor notes that the eligibility for prevented planting payments is established as the 

maximum number of acres of the crop/practice/type in any one of the four most recent crop 

years. This could delay the impact of reduced irrigation for some years into the future since the 

database would include practice 002 acreage and the producer could assert intent to apply water 

consistent with practice 002.

The prevented planting payment amount per eligible acre equals the prevented planting payment 

factor (default value or the value chosen by the insured for an additional premium amount) 

multiplied by the approved yield, the coverage level percentage, and the projected price. The 

total prevented planting payment equals the payment amount per acre multiplied by the number 

of prevented planting acres and by share.

Under the current Basic Provisions, an irrigated prevented planting insurance guarantee will be 

established only if there are adequate water and irrigation facilities. If limited irrigation was 

introduced as an insured practice, the approved yield would be reduced to reflect the expected 

yield with lesser water applied during the growing season. This reduces the payment amount per 

acre.

Allowing limited irrigation acreage to be reported as an irrigated practice may have no effect on 

the acreage eligible for a prevented planting insurance guarantee for a crop, or the effect may be 

delayed for several years. The outcome depends on the number of crop years of data included in 

the APH database for the crop and the producer’s adjustments in cropping patterns that would 

occur in the absence of allowing a limited irrigation practice. The prevented planting payment 

amount per acre most likely would be reduced if limited irrigation acreage can be reported as an 

irrigated practice but separate from practice 002.

With regard to the impact on premium rate loads if limited irrigation acreage is allowed to be 

reported as an irrigated practice, the following considerations apply. A premium rate represents 

two factors: the frequency that an insurable event results in an indemnity and the severity 

(percent of loss) on insured acreage when the event occurs. Severity is known with certainty for 

prevented planting: it is, for example, 60 percent of the guarantee per acre for a timely planted 

crop for most crops. This means the frequency that prevented planting occurs is the only factor 
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influencing the appropriate premium rate load. Since frequency is a result of natural causes 

beyond the control of the producer, there is no reason to expect a change in frequency with 

introduction of limited irrigation. Introduction of limited irrigation practice would have be no 

impact on the premium rate load for prevented planting.

The argument also can be framed as follows. Suppose a producer has planted 160 acres of corn 

for each of the previous 4 most recent crop years and has reported those acres as irrigated 

practice (as defined in the Basic Provisions). An insurable cause of loss prevents planting of 100 

acres in the current crop year. This is less than the least amount of acreage reported in any 1 of 

the 4 most recent crop years; therefore, the producer is eligible for a prevented planting 

guarantee on the 100 acres. Suppose the approved yield is 200 bushels per acre and the coverage 

level is 65 percent. The guarantee is 130 bushels per acre and the prevented planting payment is 

78 bushels per acre. The loss cost ratio is 60 percent.

Now suppose instead the producer has planted 160 acres of corn for each of the previous 4 most 

recent crop years and has reported those acres with a limited irrigation practice. All other factors 

are as stated in the previous paragraph. Suppose the yield for limited irrigation practice has been 

reduced by 10 percent, to 180 bushels per acre. The guarantee is 117 bushels per acre and the 

preventing planting guarantee is 70.2 bushels per acre. The loss cost ratio is 60 percent.

Within limits, appropriate adjustments to the approved yield for acreage grown under limited 

irrigation result in appropriate rates for the insurance of that acreage. The limits include the 

amount of reduction in irrigation water, the proportion of irrigation water to natural precipitation, 

and limited changes to other management practices (amount of fertilizer, planting practices, 

variety chosen, etc.). The effects of these limitations on the Contractor’s recommendations are 

incorporated into the Contractor’s feasibility recommendations.
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SECTION VII. STAKEHOLDER INPUT

The Contractor gathered stakeholder input during discussions with producers, insurance industry 

representatives, educators, and government personnel in two listening sessions and in one-on-one 

conversations. The listening sessions were broadly advertised. A press release (Appendix B, 

Exhibit 1) was prepared with RMA’s cooperation. On the advice of agricultural educators in the 

region, the Contractor provided the press release to newspapers serving the western half of 

Kansas, radio stations with an agricultural focus in Nebraska, and “The Progressive Farmer” (an 

agricultural magazine with a significant online presence). The press release was also sent to 

water regulatory offices in Colorado, Kansas, and Nebraska; agricultural educators; and the 

RMA Topeka Regional Office (RO). RMA distributed the release to AIPs to recruit insurance 

industry stakeholders. Insurance agencies were encouraged to extend invitations to key 

producers. An advertisement (Appendix B, Exhibit 2) for the meetings was placed in the 

regional Colby newspaper (with a subscription base of about 1,000) and the local free advertising 

weekly distributed to about 1,000 rural customers who do not subscribe to the newspaper.

The listening sessions conducted in Colby, Kansas, on March 13, 2013, and in Kearney, 

Nebraska, on March 14, 2013, were well attended. All totaled, 125 individuals attended the 2

sessions (not counting the Contractor’s representatives and counting RMA personnel who 

attended both sessions only once). Attendees included 53 insurance industry representatives, 7 

state government officials all representing offices with authority over irrigation water extraction, 

5 growers association representatives, 4 educators/researchers, a representative from each of the 

Kansas U.S. Senator’s offices, an irrigation engineer, and representatives of the USDA Farm 

Services Agency (FSA) and Natural Resources Conservation Service (NRCS). RMA personnel 

at both meetings included two professionals from Kansas City and one from the Topeka RO. 

Additional conversations outside the listening session venues were held with RMA personnel in 

Kansas and the Topeka RO, including individuals who did not attend the listening sessions. 

Only four attendees specifically identified themselves as producers on the sign-in sheets. The 14 

attendees who provided only their name and address during sign-in and the 28 attendees who did 

not sign in are most likely producers. In the Contractors experience, representatives of producer 

organizations and some of the insurance agents are most likely producers as well. Consequently, 

the Contractor believes at least 45 producers attended the listening session and the number may 

have been as high as 70. The producers indicated they grow corn, soybeans, wheat, and 

sorghum. It is likely some also grow other crops, particularly sunflowers and feed crops such as 

hay, milo, and oats.

Input was obtained from stakeholders from 5 states: Colorado (at least 8 stakeholders), Iowa (1

stakeholder); Kansas (at least 42 stakeholders), Nebraska (at least 35 stakeholders), and Texas (1

stakeholder).

Information was gleaned from stakeholder comments in compliance with the contract 

requirements regarding the Paperwork Reduction Act. The flow of the meeting was controlled 

by an agenda (Appendix B, Exhibit 3). The Contractor refrained from asking questions in any 

way that might be construed as a survey of the group; however individuals were queried to seek 

clarification of comments they made. Information obtained in this manner is qualitative and 

cannot be construed to represent a statistically valid sample. Nevertheless, the information 

gleaned from the voluntary comments of stakeholders provides substantial value concerning
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agricultural management processes; risks, acceptance of the existing risk management products,

and reaction to possible new risk management approaches like the RMA-proposed Limited 

Irrigation construct. Although the Contractor provided an email address for comments, no input 

was received through this channel.

Summary of Stakeholder Input

To preserve the anonymity of individual stakeholders, comments gathered at the two listening 

sessions are summarized collectively. Individual comments and anonymous characterization of 

their sources are documented in Appendix B, Exhibit 4.

At each session, as much as half the input from stakeholders was in the form of questions about 

the existing insurance for corn, soybeans, and other crops and the impact of reduced irrigation on 

that insurance. After providing summary information reflecting the first deliverable under this 

contract, the Contractor referred stakeholders to RMA policy and underwriting documents for 

answers to their specific questions. RMA personnel, primarily from the Topeka RO, responded 

to some of the follow-on questions. From these questions it was clear producers and insurance 

industry stakeholders were concerned by the constraints current policy language places on their 

options if the supply of irrigation water is reduced. There was special concern about the 

insurance options if knowledge of the reduction in irrigation water supply precedes the acreage 

reporting date.

Producers indicated that from year to year, soil moisture at planting and precipitation will affect 

how much irrigation water is required to grow a crop. Furthermore, different crops require 

different amounts of irrigation water. From region to region, soil quality, slope, and the aspect of 

the slope (the direction the slope faces) also impact how much water is needed to have a good 

economic outcome.

Virtually all stakeholders in every category recognize the importance of irrigation to agricultural

production and the changes in production under the irrigated practice that are likely to occur as 

irrigation water becomes more limited. Stakeholders from Colorado, Kansas, and Nebraska all 

indicated that reductions in water allocations are occurring or are expected to occur in the near 

future. Different producers have responded or are likely to respond to respond to changes in 

supply of irrigation water differently. Some will water fewer acres. Others will provide less 

water per acre to their irrigated land, still others will change the crops they grow or change the 

way they treat their corners on land irrigated using center pivot irrigation systems (e.g., planting 

crops requiring less water in the corners). One of the things producers have seen is yields from 

crops irrigated with 80 percent of the water used historically can be as high as the historical 

yields achieved with application of 100 percent of the historical amount of water.

Producers, producer associations, and insurance industry personnel believe crop insurance is a 

vital risk management tool for producers. Maximizing yield on fewer acres is not viewed as the 

best way to optimize economic outcome. However, crop insurance is viewed as an essential tool 

for developing appropriate strategies to optimize economic outcomes. Being required to report 

crops grown with reduced irrigation as non-irrigated (if allowed) or uninsurable is viewed as 

unfair. An insurance program for limited irrigation for corn is considered essential. No similar 

observation about soybeans was made. Concern was expressed about how reduced irrigation
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affects the preventive planting program. The impact of the timing of application of water was 

raised. In some western Kansas counties, the soil moisture for the new crop accumulates from 

the dry down of the previous years’ crop. In other areas, irrigation water is applied shortly 

before planting, but rarely during the growing season itself. Producers from Colorado were 

concerned because the government regulation of the access to water includes designation of 

specific days they have access to water. While this has always been the case, the insurance 

requirements that irrigation water be applied at the appropriate time and changes in the timing 

water is available to the producer can create loss adjustment issues with human actions outside 

the producer’s control.

Insurance industry personnel expressed concern about how these various management strategies 

could be addressed with either the existing insurance or with the existing insurance and a limited 

irrigation product. In some irrigated areas, the applied irrigation water is not metered. Insurance 

records indicate that the amount of irrigation water applied is inversely related to soil moisture 

and precipitation. However, the Contractor is not confident that the timing and amount of water 

applied historically will be as well documented as would be required for implementation of the 

Limited Irrigation product. Concern was also expressed about the impact of having non-irrigated 

crops being watered. Since the underwriting for the non-irrigated crops does not as clearly 

address changes in the amount of water applied, this could introduce gaming of the insurance.

The Sheridan 6 LEMA was supported as a logical approach to changes in the available water 

supply. However, the uncertainty associated with decisions about water supply made 

independently by regulatory authorities is a particular concern of producers. Producers said they

would like to conserve the water in their wells rather than focus on short-term returns. It was 

considered appropriate that the public policy provide appropriate incentive for good water 

management.

The National Sorghum Producers representative indicated his association was concerned that the 

proposed Limited Irrigation product for corn and soybeans would distort the markets for crops in 

the region and lead fewer producers to grow crops with limited water requirements. He indicated 

that the T-yields for irrigated sorghum and corn are already creating disincentives for switching 

from corn to soybeans, and adding limited irrigation insurance for corn would only exacerbate 

that situation.

As noted earlier, the most noteworthy inputs were:

 Limited availability of irrigation water is a fact of life and will continue to be an issue for 

agricultural producers for the foreseeable future;

 Changes in management strategies have allowed the producers to achieve better yields 

with less water;

 Conserving water for all purposes is an appropriate public policy, even for agricultural 

production; and

 Having a Limited Irrigation product for only a few crops will exacerbate what some 

perceive as an already distorted market.
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SECTION VIII. IMPACT OF IMPLEMENTATION

Introducing a mechanism to insure limited irrigation will impact the insured, the insurance agent, 

the AIP, and RMA. Not doing so will primarily impact the insured. This impact on the insured 

if a mechanism to insure limited irrigation is not developed was addressed in the first deliverable 

under this Task Order:

[Regarding] the situation wherein a producer either voluntarily reduces water 

usage or is required to reduce usage and has established an APH yield which is 

based totally or in part on a regime of greater water availability/usage. If the 

anticipated yield under the reduced irrigation is less than “the yield used to 

establish the irrigated production guarantee or amount of insurance on the 

irrigated acreage planted to the insured crop,” crop insurance policy and 

procedures presently mandate that a producer reduce the number of acres to 

which water is applied so the historical amount of water can be applied to the 

reduced acreage. If this is not done (i.e., the producer maintains the same 

acreage but applies a lesser amount of water per acre with an anticipated lower 

yield than that used to establish the guarantee), the entire unit is to be reported as 

a practice other than Irrigated.65

It was clear from the stakeholder input during listening sessions that producers and insurance 

industry stakeholders were concerned about the constraints current policy language places on the 

insurance alternatives if the supply of irrigation water is reduced (as it already has been in some 

cases). There was special concern about the insurance options if knowledge of the reduction in 

irrigation water supply precedes the acreage reporting date. Not providing options for an insured 

who is dealing with a reduction in irrigation supply imposes a burden on the insured that is 

deemed by stakeholders to be unacceptable. The remainder of this section addresses the impact 

of the limited irrigation insurance approach proposed for Sheridan and Thomas Counties in 

Kansas and the impact if that approach is expanded to corn and soybeans grown under irrigation 

in all of Colorado, Kansas, and Nebraska.

The proposed limited irrigation insurance approach is documented in a Special Provisions 

statement for Sheridan and Thomas Counties, which reads:

“If you intend to apply less irrigation water than was used to establish your 

irrigated approved APH yield and you are in a Local Enhanced Management 

Area (LEMA), you may qualify for a written agreement to establish coverage for a 

limited irrigation practice. In addition to providing the minimum supporting 

documentation for a type/practice written agreement, you must also provide:

1. Your LEMA order from the Chief Engineer or delegate to apply less 

irrigation water within a five year period than historically used to support 

your irrigation practice;

2. Your historical water use for each unit or APH data base for which a 

limited irrigation practice yield is requested. Water use records must be 

provided for at least the most recent 4 years of APH yields to be 

considered. Acceptable water use records include your annual water use 

 

65 The Contractor, 2013, Indefinite Quantity Indefinite Delivery Contract for Insuring Irrigation: Task Order 1: Limited Irrigation 

Analysis & Evaluation: Deliverable 1: Review of RMA’s Current Policies and Procedures, page 5.
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reports, as recorded on the State’s Water Right Information System 

(WRIS) or the water right file in the Division of Water Resource’s 

Stockton office and must be expressed in gross acre inches;

3. Your intended maximum level of irrigation for the current year, in gross 

acre-inches;

4. Your type of irrigation system (Center Pivot, Improved Gravity, or 

Gravity); and

5. Any other pertinent information to establish the distribution of irrigation 

water from a point of diversion to multiple fields, if applicable.

The request for written agreement and all supporting documentation must be 

submitted to the Regional Office through your crop insurance agent on or before 

the acreage reporting date. The following site provides additional information 

that may be useful in making the request to the Regional Office: 

http://www.rma.usda.gov/aboutrma/fields/ks_rso/

To assist insureds and agents in organizing the data necessary to support a written agreement, 

RMA provides a documentation tool at http://www.rma.usda.gov/fields/ 

ks_rso/2012/template.pdf (Appendix C). The data required to document historical production, 

assess approved yields, and provide sufficient protections to avoid adverse selection and moral 

hazard likely impose significant new data collection requirements on the insured and the insurer.

Section 6B(11) of the CIH directs the AIP to annually provide a copy of the Irrigated Practice 

Guidelines to all insureds to whom the information might apply. The guidelines are contained in 

the Document and Supplementary Standards Handbook (FCIC-24040-01 (06-2012), page 146ff). 

Subsection 48(2)(A) of the Document and Supplementary Standards Handbook states:

Insured must be able to demonstrate, to the approved insurance provider’s 

satisfaction, that adequate facilities and water existed, at the time insurance 

attached, to carry out a good irrigation practice for the insured crop. Some 

factors that the insured should be able to document and/or demonstrate would 

include, but are not limited to the following;

a. Water source history, trends, and forecasting reliability;

b. Supplemental water supply availability and usage (including return flow);

c. Pumping plant efficiency and capacity;

d. Water distribution uniformity and flexibility of the system or district;

e. Water requirements (amount and timing) of all crops to be IRR;

f. Water rights (primary, secondary, urban versus agricultural use, etc.);

g. Contingency plans available to handle water shortages;

h. Acres to be IRR, amount of water to be applied, and expected yield;

i. Ownership of water (state or federal versus landowner);

j. Use of meters and other measuring devices or methods;

k. Soil types, soil moisture levels, and pre-plant irrigation needs;

l. Water conserving methods, devices, and plans utilized;

m. Past crop planting history, trends, and recommended local practices;

n. Prudent activities and practices utilized by non-insured insureds;

o. Irrigation water supply (both quantity and quality) and facilities;
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p. Recommendations from local CES or NRCS, and other sources recognized 

by CES or NRCS to be an expert in this area regarding irrigation and crop 

production; and

q. Information the insured knew (or should have known), and when the 

insured knew (or should have known) such information.

66

The operative language in these statements is: “Insured must be able to demonstrate, to the 

approved insurance provider’s satisfaction, that adequate facilities and water existed, at the 

time insurance attached, to carry out a good irrigation practice for the insured crop.” (emphasis 

added) If the AIP required all the records implicit in the Subsection 48(2)(A) statement, then the 

producer has maintained all the records required to implement the proposed Limited Irrigation 

approach. However, if the AIP was satisfied with lesser documentation in the past, it is 

reasonable an insured would have assumed maintenance of these more limited records was 

appropriate. The provision only requires the insured demonstrate that adequate facilities and 

water existed at the time insurance attached to the AIP’s satisfaction. Creating that state of 

satisfaction might be as simple as an interview between the agent and the insured:

“Did you believe you would have adequate water to carry out the irrigated 

production practice this year?”

“Yes. I did not receive any notification from the [ditch company or other appropriate 

authority] that water would be restricted.”

Which might or might not lead to a follow-up with the authority:

“Did you advise producers that water might be restricted?”

“No.”

Consequently, there may be no record accessible 10 or even 4 years later of the quantity of water 

applied to any particular acreage. Furthermore, the requirements for recordkeeping to satisfy the 

AIP, though implicit in the Irrigated Practice Guidelines, is not specified as an obligation of the 

insurance under the irrigated practice.

One issue is when the insured must be able to demonstrate that adequate irrigation water was 

available. The Basic Provisions state:

“If insurance is provided for an irrigated practice, you must report as irrigated 

only that acreage for which you have adequate facilities and adequate water, or 

the reasonable expectation of receiving adequate water at the time coverage 

begins, to carry out a good irrigation practice. If you knew or had reason to 

know that your water may be reduced before coverage begins, no reasonable 

expectation exists.”67

The proposed procedures to insure limited irrigation as the irrigated practice require an insured to

agree to a reduction of the approved APH yield in accordance with published Yield Reduction 

 

66 USDA, RMA, 2013, Document and Supplementary Standards Handbook (FCIC-24040-02), 147.

67 USDA, RMA, 2010, Common Crop Insurance policy (11-BR), 17.
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Tables. The reduced approved APH yield becomes the yield upon which the insurance guarantee 

is based, thereby meeting the definition of irrigated practice in the policy.

There is potential for disagreement between the insured and the insurer over the phrase “the 

expectation of applying less irrigation water than what is required to produce the yield upon 

which their guarantee is based.” Over the period during which the APH was established, water 

was applied either when such application was allowed (by a regulatory body) or when it is most 

likely to be efficacious (based on the producer’s judgment). Planting densities in a unit may 

have changed to reflect the variety chosen and seed company recommendations. Applications of 

nutrients may have changed to reflect soil tests and planting densities, with a resulting change in 

the amount of irrigation water required. Furthermore, tillage practices may have been modified 

to conserve water. Thus, though the published Yield Reduction Tables provide a basis for 

adjusting the APH, they do not necessarily reflect time series production patterns the APH does. 

Nonetheless, for the purpose of this analysis, assume agreement is reached between the insured

and the AIP on the amount of irrigation water required to produce the yield upon which the 

guarantee is based. Then the calculations for the APH are those that are used for all crops and 

the adjustment to the APH is a relatively mechanical process imposing a limited burden on the 

AIP and their agent.

The insured is required to report the limited irrigation acreage on his or her acreage report. 

Separate line entries are required on the acreage report when full irrigation and limited irrigation 

are carried out on the same unit. In addition, the limited irrigation acreage must be identified and 

reported to RMA by the AIP through the Policy Acceptance and Storage System (PASS) on the 

applicable Type 11 Acreage Record. Following production under a Limited Irrigation practice, 

the actual yield must be recorded into the insured’s Irrigated Practice APH database. These 

actual yields from limited irrigation must be identified with the appropriate limited irrigation 

yield descriptor. These procedures impose relatively minor burdens on the AIP, the AIP’s agent 

and RMA, hardly different from existing requirements.

It is important to note the proposed approach for insuring limited irrigation does not require a 

separate APH database be established. The AIPs and RMA instead use a “yield limitation flag”

to identify an approved APH yield that has been reduced according to the Yield Reduction 

Tables for limited irrigation. Yet, since yield reductions to the approved APH yield continue to 

be made until the approved APH yield is representative of the yield upon which the guarantee is 

based (given the expected irrigation water application), the AIP is maintaining an irrigation 

database. If additional reductions in irrigation water supply are made, additional appropriate 

adjustments to the APH need to be made until the APH history reflected this new level of 

available water. It is conceivable that changes in water supply could be made often enough in 

some regions so the approved APH yield in the RMA database is never representative of the 

available water supply.

The data required to document historical production, determine approved yields, and to avoid 

adverse selection and moral hazard does not technically impose substantial new data collection 

requirements on the insured and the insurer. It is, however, possible that many (or even most) 

insureds will be hard pressed to provide appropriate documentation of historical water 
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application, especially at the smallest unit level. This issue may be much more difficult for crop 

years for which the record retention period has expired.

Providing insurance for limited irrigation through Written Agreements will impose an 

unacceptable burden regarding review and approval of those agreements by the Government. 

Finally, if the proposed approach is expanded to other areas and/or other crops, RMA will be 

required to generate additional Yield Reduction Tables for publication. Due to data limitations, 

that task will be much more difficult for corn and soybeans in states other than Colorado, Kansas 

and Nebraska and for any other crops.
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SECTION IX. RESEARCH FINDINGS

In the 2008 Irrigation Survey, NASS reported 54,929,915 acres in the United States on 206,834

farms, irrigated with 91,235,036 acre feet of water.68 In 2003, the NASS estimates were 

52,492,687 acres on 210,106 farms,

69 irrigated with 86,757,665 acre feet of water.70

 

Consequently, there was a 0.49 percent increase in the average amount of irrigation water 

applied per irrigated acre in the United States between the two surveys. In Colorado, the average 

amount of irrigation water applied per irrigated acre between the two surveys increased by 1.9

percent, while in Kansas and Nebraska, that amount decreased by 1.0 and almost 29 percent, 

respectively (Table 23). Furthermore, anecdotal testimony indicates that since the 2008 survey 

the amount of irrigation water applied per acre on some operations has decreased, in some cases 

significantly.

Table 23. A Comparison of Irrigation in Colorado, Kansas, and Nebraska in 2003 and 2008

Colorado Kansas Nebraska

2003 2008 2003 2008 2003 2008

Farms with Irrigation 11,567 12,778 4,878 4,508 16,278 14,812

Irrigated Acres 2,562,329 2,865,840 2,543,950 2,570,003 7,516,171 8,365,545

Irrigation Water Applied (Acre-feet) 3,984,941 4,541,276 3,145,502 3,146,607 8,450,468 6,699,545

Acre-feet Irrigation Water Applied per 

Acre 1.56 1.58 1.24 1.22 1.12 0.80

Percent Change from 2003 1.9 -1.0 -28.8

Source: The Contractor’s Research Department after data from Table 12 in the 2007 Census of Agriculture: Farm and Ranch Irrigation Survey 

(2008), published in 2010 and Table 12 in the 2002 Census of Agriculture: Farm and Ranch Irrigation Survey (2003), published in 

2004.

Not introducing a mechanism to insure limited irrigation will impact the insured, and may lead to 

problems with underwriting and loss adjustment. The impact on the insured was addressed in the 

first deliverable under this Task Order:

[Regarding] the situation wherein a producer either voluntarily reduces water 

usage or is required to reduce usage and has established an APH yield which is 

based totally or in part on a regime of greater water availability/usage. If the 

anticipated yield under the reduced irrigation is less than “the yield used to 

establish the irrigated production guarantee or amount of insurance on the 

irrigated acreage planted to the insured crop,” crop insurance policy and 

procedures presently mandate that a producer reduce the number of acres to 

which water is applied so the historical amount of water can be applied to the 

reduced acreage. If this is not done (i.e., the producer maintains the same 

acreage but applies a lesser amount of water per acre with an anticipated lower 

yield than that used to establish the guarantee), the entire unit is to be reported as 

a practice other than Irrigated.71 

 

68 The 2013 survey has yet to be distributed to respondents.

69 USDA, NASS, 2010, 2007 Census of Agriculture: Farm and Ranch Irrigation Survey (2008), Table 1.

70 USDA, NASS, 2010, 2007 Census of Agriculture: Farm and Ranch Irrigation Survey (2008), Table 12, page29.

71 The Contractor, 2013, Indefinite Quantity Indefinite Delivery Contract for Insuring Irrigation: Task Order 1: Limited Irrigation 

Analysis & Evaluation: Deliverable 1: Review of RMA’s Current Policies and Procedures, page 5.
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It was clear from input during the listening sessions that producers and insurance industry 

stakeholders were concerned about the constraints current policy language places on the 

insurance alternatives when the supply of irrigation water is reduced. There was special concern 

about the insurance options if knowledge of the reduction in irrigation water supply occurs 

before the insurance attaches (or if the reason for the reduction is “man-made,” i.e., a regulatory 

action). Not providing options for an insured who is dealing with a reduction in irrigation supply 

imposes a burden on the insured that is deemed by stakeholders to be unacceptable.

The remainder of this section addresses the impact of the limited irrigation insurance approach

proposed for Sheridan and Thomas Counties in Kansas and the impact if that approach is 

expanded to corn and soybeans grown under irrigation in all of Colorado, Kansas, and Nebraska.

On Wednesday, April 17, 2013, the Chief Engineer of the Kansas Department of Agriculture 

Division of Water Resources issued his Order of Designation setting forth the complete terms for 

the Sheridan 6 LEMA.

72

 The LEMA limits total water use per acre to 55 acre-inches during the 

5 years beginning with 2013 in the “designated sections” of Sheridan and Thomas Counties. 

Consideration of the changes in irrigation the LEMA might require, the effects of similar 

regulatory actions in other areas, and voluntary reductions in the amount of irrigation water 

applied to acres insured under the irrigated practice led RMA to develop preliminary procedures 

for addressing limited irrigation. A partnership project with the UNL addressed theoretical 

reductions in yields for corn and soybeans in selected counties in Colorado, Kansas, and 

Nebraska.

The objective of this task under the task order was to determine if the proposed limited irrigation 

approach would be a feasible alternative crop insurance product. RMA’s criteria for feasibility 

identify the requirements to establish an appropriate feasibility recommendation for a crop 

insurance product in the broadest terms. An initial review of RMA’s 12 criteria for feasibility of 

an insurance product indicated that 7 required additional evaluation. These included:

 The perils affecting production must be identified and categorized as insurable and noninsurable;

 The insurance product must be ratable and operable in an actuarially sound manner;

 The insurance product must contain underwriting, rating, pricing, loss measurement, and 

insurance contract terms and conditions;

 Customers must not be able to select insurance only when conditions are adverse;

 Moral hazards must be avoidable or controllable;

 The insurance product must be effective, meaningful and reflect the actual risks of the 

producers; and

 Producers or their agents must be willing to pay the appropriate price for the insurance.

RMA crop insurance for corn and soybeans already exists. The perils affecting corn and soybean 

production have already been identified and categorized as insurable and non-insurable as 

elements of this existing insurance. The barrier under this criterion is whether there is a

 

72 Barfield, D.W., 2013, Order of Designation Approving the Sheridan 6 Local Enhanced Management Area within Groundwater 

Management District No. 4, http://dwr.kda.ks.gov/LEMAs/SD6/LEMA.SD6.OrderOfDesignation.20130417.pdf, Accessed 

May, 2013.
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significant antagonistic effect of limited irrigation on losses due to other causes sufficient to 

require a separate identification and categorization of these corollary effects.

There are limited data on such antagonistic effects. Though there are references to greater 

susceptibility of stressed plants to disease, there do not appear to be substantial data to quantify 

that increased susceptibility for most crops in most regions. However, RMA loss data, and the 

accompanying information about causes of loss, suggest the primary effects of weather on 

productivity are much greater than any corollary effect of susceptibility to disease due to water

stress. Both primary and corollary effects of weather on productivity have been, and will 

continue to be, captured in the actual yields of producers and incorporated into the insurance

rates. Therefore, the existing identification and categorization is sufficient for the purposes of a 

limited irrigation insurance construct. Consequently, identification and categorization of 

corollary damage due to water stress is not a barrier to any form of limited irrigation insurance.

The Contractor has addressed the rating of limited irrigation insurance in detail earlier in this 

report, noting that within limits, appropriate adjustments to the approved yield for acreage grown 

under limited irrigation result in appropriate rates for the insurance of the acreage grown under 

limited irrigation. The limits include the amount of reduction in irrigation water, the proportion 

of irrigation water to natural precipitation, and limited changes to other management practices 

(amount of fertilizer, planting practices, variety chosen, etc.). Since these latter factors have 

affected the yield from irrigated acreage over time, an amount of reduction in irrigation supply 

over time that would affect an approved yield by less than one [two] standard deviation[s] of the 

actual yields used to calculate the approved yield might not appropriately be considered less than 

the amount required “to establish the irrigated production guarantee or amount of insurance on 

the irrigated acreage planted to the insured crop.” Conversely, if reduction of the amount of 

irrigation water is so great as to result in an expected yield near that of a non-irrigated crop (e.g., 

within one [two] standard deviation[s] of the actual yields resulting in the producers approved 

yield for the crop when it is not irrigated or the county yield for the non-irrigated crop), then the 

crop might not appropriately be considered irrigated.

As noted in the section on rating, the outcome regarding prevented planting of allowing limited 

irrigation acreage to be reported as an irrigated practice will depend on the number of crop years 

of data included in the APH database for the irrigated crop and any reduction of irrigated acreage 

that would have occurred in the absence of allowing insurance for limited irrigation. Any 

adjustments to rates will need to consider the approved approach to insure limited irrigation. 

Consequently, the Contractor believes rating is not a barrier to insuring limited irrigation and the 

existing continuous rating function should be used, with appropriate adjustments to the premium 

for prevented planting once the insurance approach is finalized.

Appropriate management practices for insured crops have been defined and required of 

stakeholders under the existing insurance. The Contractor has provided suggestions regarding 

changes to the policies and procedural documents required for the insurance of limited irrigation. 

The potential impact of the antagonistic effect of limited irrigation on losses due to other causes

was addressed as related to the identification and categorization of perils. No additional 

underwriting should be required for these corollary effects. The primary barrier related to the

underwriting is the requirement for documentation of water applied to a unit. This barrier is 
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especially challenging if written, third-party documentation applicable to an insured unit is 

required. Most likely some compromises will be necessary to provide a mechanism for 

certification of the amounts of water applied to a unit and for mechanisms to verify compliance 

with the requirements for application of irrigation water. Since the insured with limited 

irrigation water supply can choose where to apply that water, this underwriting is a potential 

barrier to feasibility. In addressing this barrier, there should be consideration of the extent to 

which irrigation documentation has heretofore been required. It seems likely that procedures 

comparing losses between insureds in a county may be sufficient to provide the tools for 

compliance with RMA procedures.

Corn and soybeans are already insured in Colorado, Kansas, and Nebraska. Most producers 

participate in the insurance program. The actual insurable risks the producer faces appear to be 

addressed by the existing insurance. However, the insureds’ perceptions of the utility of the 

insurance and of the ability of the insurance to protect the insured from financial failure affect 

the meaningfulness of the product. Consequently, the approach used to address limited irrigation 

scenarios might impact whether the insurance is considered meaningful by a producer. While no 

insured indicated a willingness to forego insurance so he or she could reduce the irrigation water 

applied to acreage currently insured under the irrigated practice, none indicated that a reduction 

of his or her approved yield was an attractive alternative.

Most irrigation in the affected area is by pivot circles, and often a circle will have its own water 

supply. Consequently, the choices a producer has regarding how much acreage to irrigate and 

how much water to apply to a circle are likely more limited than the many alternative reduced 

irrigation scenarios that can be conceive when these constraints need not be considered.

Ultimately, the willingness of producers to pay will be influenced by the coverage available and 

the costs associated with the insurance offer. Unless the costs or procedures for insuring crops 

under limited irrigation are particularly onerous, the Contractor would expect producers to be 

willing to pay the appropriate price for the insurance.

Although the limited irrigation insurance as proposed would be cumbersome (e.g., it is built on 

written agreements and requires the insured to provide data that may be hard to obtain) and 

challenging to maintain (e.g., it requires careful monitoring of the effects on rates and 

development of Yield Reduction Tables for other states and other crops), the approach is feasible

but expensive.

The Yield Reduction Tables provided to the Contractor are logical, but may be over-engineered, 

with a precision that ignores the disparity between the data used to create the tables and the data 

used to develop APHs. For the level of precision provided in the output, the tables should 

incorporate the length of the growing season for the variety planted, since that has an important 

effect on the total evapotranspiration. The yield reductions should also be truncated at low initial 

levels of historic irrigation water applied. That is to say, if a producer is adding just two inches, 

he or she is not really irrigating but rather adding supplemental water to a non-irrigated crop 

(most likely just prior to planting). Even if that were the basis of developing the irrigated 

database, the impact of eliminating half the irrigation water on yield variability would argue for 

calling the new practice non-irrigated rather than adjusting the old irrigated yield. Research is 
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required to determine what would be considered a reasonable range for added irrigation water in 

a county to determine where such truncation would be made.

Finally, if Colorado, Kansas, and Nebraska insureds get limited irrigation insurance for corn and 

soybeans, every insured producer who adds water to their corn and soybean crop will want 

limited irrigation insurance if they are required to or choose to reduce the amount of irrigation 

water they apply to their crops. Likewise, if all corn and soybeans get limited irrigation 

insurance, anyone who irrigates any crops will want the option.

Alternatives for Addressing Limited Irrigation

The Government requested the Contractor supply brief summaries of alternative approaches for 

addressing insurance of crops grown under reduced/limited irrigation. The purpose of this 

request was not to determine if an alternative is better, nor to evaluate the applicability of 

alternatives to other crops or regions, nor to develop the concept. Instead, this activity was 

undertaken to stimulate thinking and consideration of courses the Government might take. By 

presenting a wide variety of alternative approaches, the Contractor hopes to stimulate thoughts 

about changes, whether subtle or major, that might make the final insurance product for crops 

grown under reduced/limited irrigation better. Consequently, even outrageous ideas were 

included in the following list, which presents only the basis of the concept, the most obvious 

issues with the approach, and the general data requirement. If the only outcome of a reader 

reviewing this list is the reader saying: “But what about ...,” then this activity has served its 

purpose.

Option 1: Maintain Existing Policy Language and Procedures with Very Limited Changes.

Approach: Two practices, Irrigated (IRR) and Non-irrigated (NI). Irrigated practice 

definition continues to focuses on achieving the approved yield.

Problems: 

Adjustments to management practices to increase yield have not been treated as new 

practices under the existing insurance.

Clearer guidelines are required to determine when reduced water application changes an 

irrigated practice to some form of non-irrigated production.

Surface water shortfalls may be indemnified as failure of irrigation supply, but ground 

water restrictions are not.

Many insureds will consider the requirements of the existing policy language and 

procedures unfair when regulators require them to reduce water.

Many insureds will consider the requirements of the existing policy language and 

procedures unfair when land receiving reduced irrigation has to be treated as some 

form of not irrigated production.

Producers believe they can achieve their approved yield by adjusting planting practices, 

irrigation timing and equipment, and varieties.

Data requirements: No new data are required.

Option 2: Add a Limited Irrigation Practice with Its Own Practice Code.

Approach: Add a limited irrigation (LI) practice in counties where the Irrigated Practice 

already exists. The irrigated practice definition continues to focuses on achieving the 

approved yield. Limited irrigation results in a decrease in the approved yield.
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Problems:

A new database will need to be created and maintained.

Clear guidelines are required to determine when reduced irrigation changes an irrigated 

practice to limited irrigation production.

Some insureds will consider this approach unfair since under existing rules transitional 

yields must be used when there are fewer than four actual yields representing the 

practice.

Producers believe they can achieve their approved yield by adjusting planting practices, 

irrigation timing and equipment, and varieties.

Data requirements: Tables like the UNL Yield Reduction Tables will be required for any 

crop in any area where regulations or availability require reducing irrigation.

Option 3a: Maintain Existing Irrigation Policy and Procedures but Change the Definition for 

Irrigated Practice.

Approach: Two practices, Irrigated (IRR) and Non-irrigated (NI). Irrigated practice 

definition focuses on all practices collectively that are required to obtain the approved 

yield. 

Problems:

Substantial underwriting changes will need to address the new approach.

Most likely the developer will need to integrate yield trend and irrigation amounts.

Data requirements: Data about multiple management approaches, including comprehensive 

data on irrigation amounts to assess how “all practices collectively” affect yield.

Option 3b: Maintain Existing Irrigation Policy and Procedures but Change the Definition for 

Irrigated Practice.

Approach: Two practices, Irrigated (IRR) and Non-irrigated (NI). Irrigated practice 

definition focuses on all practices collectively that are required to obtain the guaranteed 

yield.

Problems:

Effectively eliminates the deductible.

Rating would need to address this structure and a change in the Act would likely be 

required.

Substantial underwriting changes will need to address the new approach.

Data requirements: No new data required.

Option 4: Maintain Existing Irrigation Practices and Insurance Procedures but Allow a Database 

Restart using T-yields under Reduced/Limited Irrigation.

Approach: Two practices, Irrigated (IRR) and Non-irrigated (NI). Irrigated practice 

definition continues to focuses on achieving the approved yield.

Problems:

IRR T-yield would need to be revisited.

NI corners may or may not be included in IRR approved yield, that difference could 

either reward or short-change the producer during a restart.

All producers who elect new T-yields are not equally affected by reducing the irrigation 

(as demonstrated by the UNL Yield Reduction Tables)

Some good producers would be penalized by low T-yields.
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Data requirements: Yield estimates of a crop grown under a regime with less water are 

needed to establish T-yields for the “restart.”

Option 5: Maintain Existing Irrigation Practices and Insurance Procedures but Allow a Database 

Restart using Personal T-Yield under Reduced/Limited Irrigation.

Approach: Two practices, Irrigated (IRR) and Non-irrigated (NI). Irrigated practice 

definition continues to focuses on achieving the approved yield.

Problems:

An adjustment factor for a producer’s relative yield experience in county would need to 

be developed.

Adjustments to management practices to increase yield have not been treated as new 

practices under the existing insurance. This could distort any personal T-yields 

generated.

Underwriting would need to be revisited to assure the approach does not result in 

beneficial gain.

Data requirements: No new data required.

Option 6: Add a Third Practice Called Supplemental Irrigation.

Approach: Three practices, Irrigated (IRR), Non-irrigated (NI), and Supplemental irrigation 

(SI). Irrigated practice definition continues to focuses on achieving the approved yield. 

Supplemental irrigation builds on new T-yields that build up from non-irrigated rather 

than down from irrigated. Non-irrigated is more discrete than irrigated because irrigated 

sometimes includes non-irrigated land but the reverse seems to be less often true.

Problems:

A new database will need to be created and maintained.

Clear guidelines are required to determine when reduced irrigation causes a change to 

supplemental irrigation production.

The production from IRR and NI practices may have been comingled.

Some insureds will consider this approach unfair since under existing rules transitional 

yields must be used when there are fewer than four actual yields representing the 

practice.

Data requirements: For corn and soybeans in the study states, no new data required if the 

UNL data are accepted for drawing the lines between the three practices. Tables like the 

UNL Yield Reduction Tables will be required for any crop in any area where regulations 

or supply require reducing irrigation.

Option 7: Use the Suggested Limited Irrigation Insurance approach, but Replace the Yield 

Reduction Tables with a Formula Based on Average Annual Rainfall for the County 

and the Insured’s Historic and Expected Irrigation Amounts.

Approach: Two practices, Irrigated (IRR) and Non-irrigated (NI). Irrigated practice 

definition continues to focuses on achieving the approved yield. Insureds with limited 

irrigation adjust their approved yield by a factor that is (annual county rainfall + expected 

irrigation)/ (annual county rainfall + historic irrigation), a major simplification of the 

yield function underlying the Yield Reduction Tables.

Problems:

Might oversimplify the yield reduction function.
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Requires appropriate underwriting so the acreage under irrigation is not manipulated for 

beneficial gain.

Data requirements: Annual County Average Rainfall, Insured’s Historic water application.
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SECTION X. RECOMMENDATIONS

This section of the report contains the recommendations of the Contractor for consideration by 

RMA. In accordance with the Task Order, these recommendations focus on a continuation of 

information development oriented toward ultimately designing a workable solution for the issue 

of limited irrigation.

Limited irrigation is a complex issue; one that cannot be easily and readily addressed. The 

subject of irrigation has been one of significant discussion within RMA, with the AIPs, and with 

insured persons and their representatives. The present rules and procedures regarding irrigation 

were developed over many years. A major impetus driving the issue has been surface water 

availability. Increased population and concurrent demand for water for household use have 

placed increasing stress on available water, especially when coupled with below normal 

snowpack in many years. Recently, concerns about withdrawal rates from the Ogallala aquifer in 

parts of Kansas have resulted in restrictions on water use by agricultural producers in those areas.

The Contractor believes that more restrictions on availability of water for agricultural use are 

likely in the coming years. This will place increasing pressure on RMA to adapt its policy on 

insuring irrigated acreage. The Contractor believes it will be increasingly difficult to continue 

the position that acreage with impaired water availability relative to historical availability must 

either be reduced for insurance purposes or be reported as a non-irrigated practice. But, since 

actuarially responsible answers are difficult to determine, a focused effort will be needed to be 

responsive to the issue.

Recommendation 1: Fully implement the Special Provisions statements for Sheridan and 

Thomas Counties, Kansas for the 2013 crop year.

The Contractor is not aware that guidance has been given to the AIPs with regard to 

implementing the limited irrigation alternative for these two counties. At the very least, the 

Contractor has not found a Product Management bulletin on this subject. The Topeka RO 

website has only the Documentation Tool and a completed example of it under the Limited 

Irrigation link. It is important that the 2013 data be identifiable and subject to analysis so that 

the impacts of reduced water use can be better understood.

Recommendation 2: Use the available weather data, RMA historical yield data, and 

Irrigation Survey data to explore, to the extent possible, the mitigation of effects of deficit 

irrigation in Nebraska (between 2003 and 2008) by other management practices.

There was nearly a 29 percent reduction in water applied to each irrigated acre in Nebraska 

between 2003 and 2008. According to NASS data, the irrigated corn yields in the state those two 

years were almost identical. NASS, RMA, and proprietary weather data can be mined to 

understand better the changes in irrigated yields between those two years. This can provide 

useful information about the extent to which the yield under reduced irrigation is affected by 

management strategies other than irrigation. RMA data provides a mechanism to mine farm 

level data by county to appreciate the degree to which the mitigation is a general phenomenon.

Recommendation 3: Use available weather data, UNL Yield Reduction tables, RMA 

historical yield data, and RMA summary of business data to model, to the extent possible, 

the maximum effects on indemnities of allowing limited irrigation to be insured as an 
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irrigated practice without a yield adjustment. Determine the extent to which modeled 

increases in indemnities, if any, would result in beneficial gain.

The limited data available for Nebraska suggest that producer management decisions might 

offset some, or even all, of the effects of reduced irrigation, at least in the short run. If yield 

trend increases offset limited irrigation yield reductions, RMA could establish a set of 

underwriting rules allowing a producer to maintain some, or all, of the APH database already 

established for his or her irrigated crops. The rules would require the producer to address the 

change in available irrigation water by strategies acceptable to the insurer. However, this 

approach is only feasible if beneficial gains can be avoided. Data are available that could be 

used to model outcomes under this approach to determine whether an actuarially sound construct

might exist. If that is the case, draft underwriting rules would be developed.

Recommendation 4: Analyze as soon as possible the acceptance of the Limited Irrigation 

offer extended via the Special Provisions for Sheridan and Thomas Counties, Kansas for 

the 2013 crop year.

The Special Provisions offer was limited to those parts of Sheridan and Thomas Counties where 

a LEMA was effective for the 2013 crop year. This encompasses land in 101 sections, or a total 

of 64,640 acres. Testimony during the review process that established the LEMA focused on the 

flexibility of the five-year allocation and the ability to move water rights among different points 

of diversion, a factor that producers who testified during the hearings stated would enable them 

to farm acreage profitably during the proposed LEMA period of five years. The response of 

producers in these 101 sections will be illustrative. Will these producers accept the reduction in 

the APH yield? Or will they reduce irrigated acreage but apply the historical amount water to 

the reduced acreage? Or will they move water among units, allowing those with lower 

performing wells to become non-irrigated practice and moving the water to another unit that will 

be irrigated at higher amounts of water?

Some answers perhaps will be found by examining the requests for and acceptance of Written 

Agreements to become eligible for reduced irrigated guarantees. This information would be 

available from the Topeka RO. But existence of a Written Agreement does not mean the 

producer reported acreage under its terms. Hence, it would be interesting to find: 1) how many 

producers filed a request, 2) how many were approved by the RO and accepted by the insured, 3) 

the historical amount of water applied and the average approved yield, 4) the amounts of 

reduction in water use that were anticipated, and 5) the number of approved requests that resulted 

in an adjusted yield as reported on an acreage report. Since the area is limited, the rate of 

acceptance of the UNL tables should be identifiable before the insurance experience is available.

Recommendation 5: Analyze the performance of the reduced yields for limited irrigation 

for the 2013 crop year.

This recommendation cannot be completed in the near term. In contrast to Recommendations 2, 

3, and 4, the analysis for this recommendation cannot be undertaken until the yields for 2013 are 

reported. This could be as late as the Production Reporting Date (approximately May 1, 2014). 

However, it is essential that comparisons of yields on units with limited irrigation adjustment and 

units without adjustment begin as soon as possible to improve knowledge of: 1) the validity of 

the UNL tables, and 2) quantification of the “yield drag” associated with reduced water 

application. Even so, since information about differences in tillage practices, varieties planted, 
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76

fertilizer use, and a host of other variables that affect yield will not be known, these results will 

not be complete.

Recommendation 6: Do not rely upon the UNL yield adjustment table approach as the 

appropriate means to respond to the limited irrigation issue on a long-term basis in the 

three-state study area and do not expand it to include other states and crops.

The Contractor acknowledges that the approach utilized by the UNL study team does utilize 

information available at the time the study was done. But, as RMA correctly noted in the 

questions included in the Task Order, it is based on the results of small plot research under 

experimental conditions. More particularly, several of the observations are dated and might be 

representative of hybrid varieties no longer in production. Seed technology has moved with 

seemingly lightning speed in recent years. Round-up Ready corn seed makes management of 

weeds that compete for moisture more effective. Varieties that control corn rootworm make the 

plant more efficient in using available water. Other genetic improvements have made the plant 

more efficient in using available water, sunlight, and other inputs affecting growth. The 

expanding acreage of corn and soybeans in the Northern Plains, an area where the crops 

traditionally never were grown, is evidence of significant genetic improvement in the seeds.

Attempting to replicate the UNL model in other states and for other crops likely will prove timeconsuming and costly. The basic information needed to construct the estimates may not exist in 

many cases, thereby rendering appropriate estimates impossible. The Contractor believes 

resources will be better utilized by considering alternative approaches that are simpler and less 

burdensome on producers, AIPs, and RMA.

The Contractor acknowledges that the state of Kansas has put urgency into the need to take 

short-term measures in that state. Since there is no other alternative at this time, the UNL yield 

adjustment tables should be used where a LEMA has been established in that state. Based on the 

listening sessions, the Contractor believes producer satisfaction with the amounts of reduction in 

yield will be low, thus giving urgency to seeking alternatives. While developing an alternative to 

the UNL model may not be possible for the 2014 crop year, emphasis should be given in the near 

term to refining the estimated yield drag to determine if the adjustments can be made more 

palatable to producers.

Recommendation 7: Investigate the potential for developing better targeted measures of 

the effect of reduced water usage.

Presently, the Basic Provisions and associated Handbooks all take the position that any reduction 

in available water is de facto proof that a unit will be unable to produce the yield upon which the 

guarantee is based. Stakeholders do not accept this position, believing that other inputs or 

alternate management approaches can be substituted effectively and economically to replace this 

reduced input.

The UNL yield reduction procedures essentially are a continuation of the premise that any 

reduction in available water will be unable to produce the yield on which the guarantee is based. 

The procedures assume a fine granularity of data and a long history of uniform practices. Any 

fix needs to address other levels of granularity and history lengths that better represent the yield 

potential under reduced application of water. Producers believe they need some flexibility in 

managing their irrigation. Tillage, seed, and other production inputs and practices used currently 
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77

are not the same as those used historically. The challenge is to find a solution that does not 

create procedures that burden the insured, the AIP, and the Government unduly.

One approach might be to consider the effect of trend adjustments to the approved yield and how 

these might be modified to acknowledge reduced application of irrigation water.

Recommendation 8: Evaluate several alternative conceptual approaches to management of 

insurance for irrigated acreage chosen from among those advanced by the Contractor, by 

RMA, or by any other source.

Based on the results of this feasibility study, the Contractor believes additional investigations 

into the potential yield drag, if any, associated with reduced application of irrigation water under 

field conditions are needed. These investigations must be targeted to be achievable under the 

constraints of the crop insurance system.
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Appendix A

Samples of Available Data

Exhibit 1. NASS 2008 Quick Stats 2.0 Data for Corn, by County in Colorado, 

Kansas, and Nebraska

Exhibit 2. Daily Precipitation Data for the Growing Season (April 1through 

September 30), Sheridan County, Kansas, Every Fifth Year 1972 to 2012
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Exhibit 1. NASS 2008 Quick Stats 2.0 Data for Corn, by 

County
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Colorado

CountyAcres PlantedGrain - Acres HarvestedGrain - Production buGrain - Yield bu/acreIrrigated Acres PlantedGrain - Irrigated Acres HarvestedGrain - Irrigated ProductionGrain - Irrigated YieldNon-irrigated Acres PlantedGrain - Non-irrigated Acres HarvestedGrain - Non-irrigated Production buGrain - Non-irrigated Yield bu/acreSilage - Acres HarvestedSilage, Irrigated - Acres HarvestedSilage, Non-Irrigated - Acres Harvested

Adams 14,600 10,100 946,000 94

Baca 102,000 48,600 5,231,000 108 3,600 1,300 2,300

Bent 12 143 1,762,000 149 1,100

Boulder 1,000

Cheyenne 39,500 31,400 2,879,000 92 1,700

Delta 4,800 2,500 500,000 200

Elbert 8,200 7,700 338,000 44

El Paso 800 800 122,000 153

Kiowa 15,900 12,400 750,000 60

Kit Carson 191,000 168,000 16,765,000 100 98,000 89,100 13,650,000 153 93,000 78,900 3,115,000 39 8,100 5,200 2,900

Larimer 13,500 4,800 590,000 123

Lincoln 33,500 28,000 1,080,000 39

Logan 74,000 70,400 9,688,000 138 55,000 52,700 8,538,000 162 19,000 17,700 1,150,000 65 2,900

Mesa 2,900 1,600 205,000 128

Montrose 11,000 7,800 1,396,000 179

Morgan 62,800 39,000 6,413,000 164

Otero 16,700 14,400 2,680,000 186

Phillips 107,500 105,800 16,110,000 152 72,000 71,500 13,500,000 189 35,500 34,300 2,610,000 76

Prowers 33,100 26,500 3,480,000 131

Pueblo 7,500 5,800 1,240,000 214

Washington 66,800 52,400 4,070,000 78

Weld 123,800 73,400 12,357,000 168

Yuma 240,200 224,200 40,685,000 181 220,000 206,500 39,570,000 192 20,200 17,700 1,115,000 63

Others (4 counties) 65,000 61,800 8,943,000 145 271,500 187,400 32,052,000 171 154,800 125,600 5,240,000 42 0 21,900 7,600

Totals 1,118,500 938,700 130,291,000 139 716,500 607,200 107,310,000 177 322,500 274,200 13,230,000 48 12,700 27,100 10,500
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Kansas

CountyAcres PlantedGrain - Acres HarvestedGrain - Production buGrain - Yield bu/acreIrrigated Acres PlantedGrain - Irrigated Acres HarvestedGrain - Irrigated ProductionGrain - Irrigated YieldNon-irrigated Acres PlantedGrain - Non-irrigated Acres HarvestedGrain - Non-irrigated Production buGrain - Non-irrigated Yield bu/acreSilage - Acres Harvested

Atchison 57,500 56,000 7,440,000 133

Barton 25,500 23,200 3,783,000 163

Bourbon 7,600 7,300 650,000 89

Brown 104,500 103,600 14,460,000 140

Butler 55,400 52,600 6,139,000 117

Cherokee 49,100 47,700 3,807,000 80

Clay 18,700 17,900 2,822,000 158 11,000 10,900 1,950,000 179 7,700 7,000 872,000 125

Comanche 1,500 1,300 176,000 135

Cowley 12,500 11,300 981,000 87

Doniphan 81,300 80,000 14,635,000 183

Douglas 25,600 24,900 2,872,000 115

Edwards 66,700 64,300 10,220,000 159

Ellis 4,500 4,000 358,000 90

Finney 97,100 92,400 15,180,000 164 4,500

Geary 6,700 6,300 879,000 140

Gove 62,100 57,600 5,010,000 87

Gray 5,200

Harper 3,500 2,800 202,000 72

Harvey 40,000 38,300 5,290,000 138

Hodgeman 16,800 12,800 2,100,000 164

Jefferson 37,000 35,900 5,070,000 141

Kearny 50,000 47,800 8,615,000 180 2,000

Kingman 9,600 9,200 1,387,000 151

Labette 33,200 31,600 2,664,000 84

Lincoln 1,900 1,600 160,000 100

Lyon 24,800 22,000 2,677,000 122

McPherson 25,300 23,700 3,845,000 162

Marion 26,100 22,700 2,055,000 91 900 800 120,000 150 25,200 21,900 1,935,000 88

Marshall 73,800 71,200 9,792,000 138

Miami 15,600 14,800 1,541,000 104

Mitchell 9,200 8,400 1,090,000 130 3,000 2,900 500,000 172 6,200 5,500 590,000 107

Morton 21,500 20,000 3,335,000 167

Nehama 82,800 78,800 9,787,000 124

Ness 7,400 6,900 540,000 78

Osage 29,500 29,000 3,010,000 104

Osborne 9,100 8,600 1,072,000 125

Ottawa 2,600 2,000 293,000 147 1,100 1,100 184,000 167 1,500 900 109,000 121

Pawnee 41,200 39,500 6,590,000 167

Pottawatomie 32,800 30,500 4,655,000 153
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Grain - Acres HarvestedGrain - Production buGrain - Yield bu/acreIrrigated Acres PlantedGrain - Irrigated Acres HarvestedGrain - Irrigated ProductionGrain - Irrigated YieldNon-irrigated Acres PlantedGrain - Non-irrigated Acres HarvestedGrain - Non-irrigated Production buGrain - Non-irrigated Yield bu/acreSilage - Acres Harvested

Pratt 65,800 64,700 9,370,000 145

Republic 60,100 58,900 9,650,000 164

Rice 31,600 30,800 4,145,000 135

Rooks 7,700 6,800 700,000 103 500 400 70,000 175 7,200 6,400 630,000 98

Saline 2,900 2,400 300,000 125 800 700 120,000 171 2,100 1,700 180,000 106

Sedgwick 36,800 35,100 4,590,000 131

Sheridan 126,000 123,300 15,571,000 126

Sherman 115,500 108,900 14,125,000 130

Stafford 71,600 69,100 9,320,000 135

Sumner 21,500 20,000 1,720,000 86

Thomas 152,500 148,700 16,708,000 112

Washington 40,900 37,200 4,527,000 122 6,200 6,100 1,045,000 171 34,700 31,100 3,482,000 112

Wichita 47,400 35,500 5,085,000 143

Woodson 11,600 11,600 1,382,000 119

Others (9 counties) 1,788,100 1,668,500 224,045,000 134 1,503,500 1,458,100 269,621,000 185 1,065,400 945,500 65,222,000 69 33,300

Totals 3,173,700 2,979,600 397,008,000 133 1,516,000 1,470,100 271,660,000 185 1,142,300 1,013,000 72,148,000 71 35,300
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Nebraska

CountyAcres PlantedGrain - Acres HarvestedGrain - Production buGrain - Yield bu/acreIrrigated Acres PlantedGrain - Irrigated Acres HarvestedGrain - Irrigated ProductionGrain - Irrigated YieldGrain - Non-irrigated Acres PlantedGrain - Non-irrigated Acres HarvestedGrain - Non-irrigated Production buGrain - Non-irrigated Yield bu/acreSilage - Acres HarvestedSilage, Irrigated - Acres HarvestedSilage, Non-Irrigated -Acres Harvested

Adams 174,000 172,300 31,229,000 181 150,000 149,100 28,329,000 190 24,000 23,200 2,900,000 125

Antelope 185,000 180,000 31,630,400 176 150,000 146,200 28,216,600 193 35,000 33,800 3,413,800 101

Banner 10,700 9,900 1,030,500 104 6,300 6,000 816,000 136 4,400 3,900 214,500 55

Boone 163,000 155,000 26,385,400 170 114,000 107,300 19,850,500 185 49,000 47,700 6,534,900 137

BoxButte 51,400 47,600 6,671,700 140 48,000 44,500 6,541,500 147 3,400 3,100 130,200 42

Boyd 26,500 23,700 2,884,300 122 3,500 3,500 682,500 195 23,000 20,200 2,201,800 109

Brown 40,000 37,300 6,961,500 187 111

Buffalo 202,000 197,200 34,101,200 173 176,000 172,000 31,304,000 182 26,000 25,200 2,797,200

Burt 123,000 121,700 19,377,700 159 35,000 34,600 6,574,000 190 88,000 87,100 12,803,700 147

Butler 138,000 136,300 21,839,500 160 70,000 68,900 12,470,900 181 68,000 67,400 9,368,600 139

Cass 113,000 112,000 16,089,800 144

Cedar 170,000 162,000 25,752,000 159 66,000 64,700 12,616,500 195 104,000 97,300 13,135,500 135

Chase 166,000 163,000 28,628,500 176 139,000 137,500 26,537,500 193 27,000 25,500 2,091,000 82

Cherry 20,500 17,700 3,356,100 190

Cheyenne 31,600 28,700 4,011,500 140 26,300 23,900 3,752,300 157 5,300 4,800 259,200 54

Clay 164,000 160,100 30,473,900 190 133,000 129,300 25,730,700 199 31,000 30,800 4,743,200 154

Colfax 102,000 97,900 15,354,800 157 42,000 40,100 7,378,400 184 60,000 57,800 7,976,400 138

Cuming 156,000 150,000 24,061,900 160 34,000 32,300 6,524,600 202 122,000 117,700 17,537,300 149

Custer 247,000 236,600 38,662,000 163 188,000 180,200 32,796,400 182 59,000 56,400 5,865,600 104

Dakota 58,000 57,400 9,856,700 172

Dawson 205,000 200,100 35,367,000 177 194,000 189,600 34,128,000 180 11,000 10,500 1,239,000 118

Deuel 18,200 17,400 2,463,600 142

Dixon 103,000 101,200 16,397,500 162

Dodge 135,000 131,800 20,536,500 156 61,000 59,900 10,542,400 176 74,000 71,900 9,994,100 139

Douglas 25,000 19,700 2,612,700 133

Dundy 98,000 94,000 14,340,000 153 68,000 66,500 12,635,000 190 30,000 27,500 1,705,000 62

Fillmore 183,000 181,700 32,786,500 180 141,000 140,000 26,740,000 191 42,000 41,700 6,046,500 145

Franklin 78,000 77,200 13,349,600 173 55,000 54,600 10,592,400 194 23,000 22,600 2,757,200 122

Frontier 88,000 86,100 11,722,000 136 42,000 40,700 7,000,400 172 46,000 45,400 4,721,600 104

Furnas 100,000 98,700 12,971,100 131 31,800 32,000 5,946,600 187 68,000 66,900 7,024,500 105

Gage 140,000 138,000 19,414,600 141 33,000 32,600 5,607,200 172 107,000 105,400 13,807,400 131

Garden 25,000 24,500 3,785,700 155

Garfield 11,500 9,600 1,640,000 171 10,300 8,600 1,548,000 180 1,200 1,000 92,000 92

Gosper 84,000 82,800 13,283,300 160 56,000 55,300 10,285,800 186 28,000 27,500 2,997,500 109

Greeley 70,000 68,400 11,742,400 172 57,000 56,000 10,304,000 184 13,000 12,400 1,438,400 116

Hall 191,000 186,500 31,911,800 171 178,000 174,200 30,485,000 175 13,000 12,300 1,426,800 116

Hamilton 200,000 198,700 38,116,200 192 184,000 183,000 35,839,700 196 16,000 15,700 2,276,500 145

Harlan 91,000 89,400 14,291,100 160 49,000 48,700 9,447,800 194 42,000 40,700 4,843,300 119

Hayes 70,000 68,300 10,784,500 158 45,000 44,100 8,775,900 199 25,000 24,200 2,008,600 83
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restrictions on the title page of this report. County Acres Planted Grain - Acres Harvested

Grain - Production buGrain - Yield bu/acreIrrigated Acres PlantedGrain - Irrigated Acres HarvestedGrain - Irrigated ProductionGrain - Irrigated YieldGrain - Non-irrigated Acres PlantedGrain - Non-irrigated Acres HarvestedGrain - Non-irrigated Production buGrain - Non-irrigated Yield bu/acreSilage - Acres HarvestedSilage, Irrigated - Acres HarvestedSilage, Non-Irrigated -Acres Harvested

Hitchcock 56,000 54,600 5,602,800 103 17,000 16,800 3,108,000 185 39,000 37,800 2,494,800 66

Holt 173,500 166,600 30,595,600 184 164,000 159,200 29,929,600 188 9,500 7,400 666,000 90

Howard 101,000 99,400 16,282,800 164 84,000 82,800 14,490,000 175 17,000 16,600 1,792,800 108

Jefferson 89,000 87,300 14,096,600 161 43,000 42,500 7,735,000 182 46,000 44,800 6,361,600 142

Johnson 40,000 39,600 5,137,200 130 8,000 8,000 1,440,000 180 32,000 31,600 3,697,200 117

Kearney 162,000 157,200 28,607,600 182 142,000 137,500 25,987,500 189 20,000 19,700 2,620,100 133

Keith 98,000 96,900 15,291,600 158 70,000 69,300 13,028,400 188 28,000 27,600 2,263,200 82

Keya Paya 12,500 10,500 1,591,200 152 9,500 8,600 1,462,000 170 3,000 1,900 129,200 68

Knox 128,000 122,100 16,502,400 135 38,000 37,200 6,993,600 188 90,000 84,900 9,508,800 112

Lancaster 119,000 117600 16,460,800 140 9,000 8,500 1,445,000 170 110,000 108,800 15,015,800 138

Lincoln 206,000 197,800 32,885,800 166 172,000 165,400 29,937,400 181 34,000 32,400 2,948,400 91

Logan 24,000 23,600 3,674,700 156 16,600 16,300 2,966,600 182 7,400 7,300 708,100 97

Loup 8,500 7,500 1,274,300 170

Madison 128,000 122,700 18,402,900 150 63,000 61,300 10,482,300 171 65,000 61,400 7,920,600 129

Merrick 134,000 131,800 20,244,600 154 126,000 124,800 19,593,600 157 8,000 7,000 651,000 93

Morrill 65,000 61,500 9,764,800 159

Nance 80,000 78,200 12,940,600 165 47,000 46,400 8,584,000 185 33,000 31,800 4,356,600 137

Nehama 74,000 67,300 9,579,000 142 6,000 5,400 1,036,800 192 68,000 61,900 8,542,200 138

Nuckolls 89,000 88,200 14,494,200 164 35,000 34,800 6,751,200 194 54,000 53,400 7,743,000 145

Otoe 114,000 113,000 14,818,700 131 4,000 3,900 635,700 163 110,000 109,100 14,183,000 130

Pawnee 39,000 38,400 5,058,600 132 3,000 3,000 492,000 164 36,000 35,400 4,566,600 129

Perkins 188,000 186,700 27,548,000 148 108,000 107,400 20,728,200 193 80,000 79,300 6,819,800 86

Phelps 174,000 169,600 33,721,000 199 163,000 158,900 32,415,600 204 11,000 10,700 1,305,400 122

Pierce 130,000 126,500 21,690,300 171 76,000 74,400 14,656,800 197 54,000 52,100 7,033,500 135

Platte 192,000 186,800 32,901,000 176 126,000 122,200 23,340,200 191 66,000 64,600 9,560,800 148

Polk 130,000 125,900 20,042,800 159 104,000 100,700 16,514,800 164 26,000 25,200 3,528,000 140

Red Willow 80,000 78,100 10,841,500 139 34,000 33,300 6,227,100 187 46,000 44,800 4,614,400 103

Richardson 93,000 91,600 12,870,400 141 3,000 2,900 452,400 156 90,000 88,700 12,418,000 140

Rock 26,000 25,000 4,745,400 190

Saline 121,000 120,600 19,397,200 161 58,000 57,800 10,982,000 190 63,000 62,800 8,415,200 134

Sarpy 32,000 31,300 4,715,700 151 4,000 4,000 648,000 162 28,000 27,300 4,067,700 149

Saunders 162,000 148,700 22,141,000 149 52,000 44,600 7,983,400 179 110,000 104,100 14,157,600 136

Scotts Bluff 88,000 84,800 12,710,100 150

Seward 137,000 135,600 21,968,100 162 79,000 78,100 13,745,600 176 58,000 57,500 8,222,500 143

Sheridan 34,400 30,300 4,670,200 154

Sherman 77,000 75,400 12,796,300 170 60,000 58,900 11,014,300 187 17,000 16,500 1,782,000 108

Sioux 15,200 12,000 1,812,000 151

Stanton 85,000 82,600 11,786,600 143 21,000 20,200 3,737,000 185 64,000 62,400 8,049,600 129

Thayer 129,000 128,200 22,945,600 179 88,000 87,800 17,208,800 196 41,000 40,400 5,736,800 142

Thurston 89,000 87,600 14,239,900 163
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contained on this sheet is subject to the Order Number: D13PD00306

restrictions on the title page of this report. County Acres Planted Grain - Acres Harvested

Grain - Production buGrain - Yield bu/acreIrrigated Acres PlantedGrain - Irrigated Acres HarvestedGrain - Irrigated ProductionGrain - Irrigated YieldGrain - Non-irrigated Acres PlantedGrain - Non-irrigated Acres HarvestedGrain - Non-irrigated Production buGrain - Non-irrigated Yield bu/acreSilage - Acres HarvestedSilage, Irrigated - Acres HarvestedSilage, Non-Irrigated -Acres Harvested

Valley 72,000 69,500 11,882,900 171 63,000 61,300 10,972,700 179 9,000 8,200 910,200 111

Washington 82,000 80,600 12,403,100 154 10,000 9,300 1,636,800 176 72,000 71,300 10,766,300 151

Wayne 122,000 117,200 19,613,800 167 27,000 26,100 5,220,000 200 95,000 91,100 14,393,800 158

Webster 72,000 70,300 11,153,600 159 33,000 32,100 6,034,800 188 39,000 38,200 5,118,800 134

Wheeler 34,000 31,500 4,764,000 151 31,000 29,000 4,524,000 156 3,000 2,500 240,000 96

Other (8 Counties) 33,500 29,200 3,937,600 135 411,000 372,100 62,777,200 169 363,800 363,000 51,900,700 143 160,000 24,000 13,500

Totals 8,596,000 8,347,900 1,356,479,400 162 5,194,300 5,038,700 926,918,000 184 3,414,000 3,319,100 429,561,400 129 160,000 24,000 13,500
Feasibility Report for Insuring Irrigation

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Exhibit 2. Daily Precipitation Data for the Growing Season 

(April 1through September 30), Sheridan County, Kansas, 

Every Fifth Year 1972 to 2012

Data are available for all days October 1, 1971 through September 30, 2012 upon request.
Feasibility Report for Insuring Irrigation

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Date Precipitation

4/1/1972 0.00

4/2/1972 0.00

4/3/1972 0.00

4/4/1972 0.00

4/5/1972 0.00

4/6/1972 0.00

4/7/1972 0.00

4/8/1972 0.00

4/9/1972 0.00

4/10/1972 0.00

4/11/1972 0.01

4/12/1972 0.00

4/13/1972 0.00

4/14/1972 0.00

4/15/1972 0.00

4/16/1972 0.47

4/17/1972 0.00

4/18/1972 0.00

4/19/1972 0.00

4/20/1972 0.01

4/21/1972 0.02

4/22/1972 0.00

4/23/1972 0.00

4/24/1972 0.00

4/25/1972 0.00

4/26/1972 1.28

4/27/1972 0.13

4/28/1972 0.00

4/29/1972 0.01

4/30/1972 0.00

5/1/1972 0.32

5/2/1972 0.00

5/3/1972 0.00

5/4/1972 0.00

5/5/1972 0.00

5/6/1972 0.67

5/7/1972 0.01

5/8/1972 0.00

5/9/1972 0.00

5/10/1972 0.29

5/11/1972 0.36

Date Precipitation

5/12/1972 0.46

5/13/1972 0.13

5/14/1972 0.00

5/15/1972 0.00

5/16/1972 0.00

5/17/1972 0.00

5/18/1972 0.00

5/19/1972 0.00

5/20/1972 0.00

5/21/1972 0.00

5/22/1972 0.00

5/23/1972 0.16

5/24/1972 0.00

5/25/1972 0.60

5/26/1972 0.00

5/27/1972 0.58

5/28/1972 0.39

5/29/1972 0.02

5/30/1972 0.00

5/31/1972 0.00

6/1/1972 0.00

6/2/1972 0.00

6/3/1972 0.00

6/4/1972 0.00

6/5/1972 0.00

6/6/1972 0.00

6/7/1972 0.00

6/8/1972 0.00

6/9/1972 0.00

6/10/1972 0.00

6/11/1972 1.15

6/12/1972 0.00

6/13/1972 0.00

6/14/1972 0.05

6/15/1972 0.00

6/16/1972 0.00

6/17/1972 0.00

6/18/1972 0.38

6/19/1972 0.00

6/20/1972 0.00

6/21/1972 0.15

Date Precipitation

6/22/1972 0.03

6/23/1972 0.00

6/24/1972 0.00

6/25/1972 0.00

6/26/1972 0.83

6/27/1972 0.13

6/28/1972 0.26

6/29/1972 0.00

6/30/1972 0.00

7/1/1972 0.00

7/2/1972 0.00

7/3/1972 0.12

7/4/1972 0.18

7/5/1972 0.00

7/6/1972 0.00

7/7/1972 0.57

7/8/1972 0.00

7/9/1972 0.00

7/10/1972 0.00

7/11/1972 0.01

7/12/1972 0.00

7/13/1972 0.00

7/14/1972 0.00

7/15/1972 0.33

7/16/1972 0.03

7/17/1972 0.00

7/18/1972 0.00

7/19/1972 0.00

7/20/1972 0.00

7/21/1972 0.15

7/22/1972 0.00

7/23/1972 0.00

7/24/1972 0.00

7/25/1972 0.55

7/26/1972 0.25

7/27/1972 2.32

7/28/1972 0.46

7/29/1972 0.00

7/30/1972 0.00

7/31/1972 0.00

8/1/1972 0.80

Date Precipitation

8/2/1972 0.00

8/3/1972 1.38

8/4/1972 0.04

8/5/1972 0.00

8/6/1972 0.00

8/7/1972 0.00

8/8/1972 0.00

8/9/1972 0.00

8/10/1972 0.00

8/11/1972 0.00

8/12/1972 0.00

8/13/1972 0.00

8/14/1972 0.00

8/15/1972 0.00

8/16/1972 0.00

8/17/1972 0.00

8/18/1972 0.00

8/19/1972 0.00

8/20/1972 0.00

8/21/1972 0.00

8/22/1972 0.12

8/23/1972 0.00

8/24/1972 0.00

8/25/1972 0.91

8/26/1972 0.00

8/27/1972 0.00

8/28/1972 0.00

8/29/1972 0.00

8/30/1972 0.11

8/31/1972 0.00

9/1/1972 0.09

9/2/1972 0.64

9/3/1972 0.00

9/4/1972 0.02

9/5/1972 0.00

9/6/1972 0.00

9/7/1972 0.00

9/8/1972 0.00

9/9/1972 0.00

9/10/1972 0.00

9/11/1972 0.00

Date Precipitation

9/12/1972 0.00

9/13/1972 0.00

9/14/1972 0.00

9/15/1972 0.00

9/16/1972 0.00

9/17/1972 0.00

9/18/1972 0.00

9/19/1972 0.00

9/20/1972 0.95

9/21/1972 0.15

9/22/1972 0.00

9/23/1972 0.00

9/24/1972 0.00

9/25/1972 0.00

9/26/1972 0.00

9/27/1972 0.00

9/28/1972 0.00

9/29/1972 0.00

9/30/1972 0.00

4/1/1977 0.00

4/2/1977 0.12

4/3/1977 0.00

4/4/1977 0.38

4/5/1977 0.00

4/6/1977 0.00

4/7/1977 0.00

4/8/1977 0.00

4/9/1977 0.00

4/10/1977 0.00

4/11/1977 0.00

4/12/1977 0.07

4/13/1977 0.36

4/14/1977 0.00

4/15/1977 0.09

4/16/1977 0.28

4/17/1977 0.00

4/18/1977 0.29

4/19/1977 0.00

4/20/1977 0.86

4/21/1977 0.12

4/22/1977 0.00
Feasibility Report for Insuring Irrigation

Use or disclosure of information or data A8 Risk Management Agency

contained on this sheet is subject to the Order Number: D13PD00306

restrictions on the title page of this report.

Date Precipitation

4/23/1977 0.00

4/24/1977 0.00

4/25/1977 0.00

4/26/1977 0.00

4/27/1977 0.00

4/28/1977 0.01

4/29/1977 0.00

4/30/1977 0.31

5/1/1977 0.00

5/2/1977 0.01

5/3/1977 0.00

5/4/1977 0.00

5/5/1977 0.00

5/6/1977 0.00

5/7/1977 0.00

5/8/1977 0.00

5/9/1977 0.00

5/10/1977 0.01

5/11/1977 0.00

5/12/1977 0.00

5/13/1977 0.00

5/14/1977 0.00

5/15/1977 1.96

5/16/1977 0.00

5/17/1977 0.06

5/18/1977 0.00

5/19/1977 0.81

5/20/1977 0.00

5/21/1977 0.58

5/22/1977 0.76

5/23/1977 0.00

5/24/1977 0.00

5/25/1977 1.20

5/26/1977 0.65

5/27/1977 0.22

5/28/1977 0.00

5/29/1977 0.45

5/30/1977 0.00

5/31/1977 0.02

6/1/1977 0.00

6/2/1977 0.00

Date Precipitation

6/3/1977 0.62

6/4/1977 0.00

6/5/1977 0.00

6/6/1977 0.01

6/7/1977 0.00

6/8/1977 0.00

6/9/1977 0.00

6/10/1977 0.00

6/11/1977 0.00

6/12/1977 0.64

6/13/1977 0.73

6/14/1977 0.42

6/15/1977 0.00

6/16/1977 0.00

6/17/1977 0.00

6/18/1977 0.00

6/19/1977 0.01

6/20/1977 0.59

6/21/1977 0.12

6/22/1977 0.40

6/23/1977 0.00

6/24/1977 0.00

6/25/1977 0.28

6/26/1977 0.00

6/27/1977 0.00

6/28/1977 0.00

6/29/1977 0.00

6/30/1977 0.00

7/1/1977 0.00

7/2/1977 0.00

7/3/1977 0.00

7/4/1977 0.00

7/5/1977 0.00

7/6/1977 0.00

7/7/1977 0.00

7/8/1977 0.00

7/9/1977 0.00

7/10/1977 0.41

7/11/1977 0.00

7/12/1977 0.00

7/13/1977 0.00

Date Precipitation

7/14/1977 0.00

7/15/1977 0.46

7/16/1977 0.00

7/17/1977 0.00

7/18/1977 0.00

7/19/1977 0.00

7/20/1977 0.00

7/21/1977 0.25

7/22/1977 0.19

7/23/1977 0.00

7/24/1977 0.00

7/25/1977 0.50

7/26/1977 0.91

7/27/1977 0.14

7/28/1977 0.00

7/29/1977 0.00

7/30/1977 0.00

7/31/1977 0.00

8/1/1977 0.00

8/2/1977 0.27

8/3/1977 0.00

8/4/1977 0.08

8/5/1977 0.09

8/6/1977 0.03

8/7/1977 0.01

8/8/1977 0.00

8/9/1977 0.00

8/10/1977 0.00

8/11/1977 0.58

8/12/1977 0.00

8/13/1977 0.00

8/14/1977 0.39

8/15/1977 0.03

8/16/1977 0.11

8/17/1977 0.15

8/18/1977 0.00

8/19/1977 0.00

8/20/1977 0.00

8/21/1977 0.03

8/22/1977 0.00

8/23/1977 0.31

Date Precipitation

8/24/1977 0.01

8/25/1977 0.24

8/26/1977 0.00

8/27/1977 0.00

8/28/1977 0.00

8/29/1977 0.00

8/30/1977 0.00

8/31/1977 0.01

9/1/1977 0.00

9/2/1977 0.04

9/3/1977 0.00

9/4/1977 0.00

9/5/1977 0.00

9/6/1977 0.00

9/7/1977 0.00

9/8/1977 0.00

9/9/1977 0.00

9/10/1977 0.00

9/11/1977 0.00

9/12/1977 0.04

9/13/1977 0.00

9/14/1977 0.00

9/15/1977 0.00

9/16/1977 0.00

9/17/1977 0.00

9/18/1977 0.00

9/19/1977 0.00

9/20/1977 0.00

9/21/1977 0.00

9/22/1977 0.00

9/23/1977 0.00

9/24/1977 0.00

9/25/1977 0.00

9/26/1977 0.00

9/27/1977 0.00

9/28/1977 0.00

9/29/1977 0.39

9/30/1977 0.00

4/1/1982 0.00

4/2/1982 0.00

4/3/1982 0.04

Date Precipitation

4/4/1982 0.00

4/5/1982 0.00

4/6/1982 0.00

4/7/1982 0.01

4/8/1982 0.00

4/9/1982 0.00

4/10/1982 0.00

4/11/1982 0.00

4/12/1982 0.00

4/13/1982 0.00

4/14/1982 0.00

4/15/1982 0.00

4/16/1982 0.00

4/17/1982 0.23

4/18/1982 0.00

4/19/1982 0.00

4/20/1982 0.00

4/21/1982 0.00

4/22/1982 0.00

4/23/1982 0.00

4/24/1982 0.00

4/25/1982 0.00

4/26/1982 0.00

4/27/1982 0.14

4/28/1982 1.46

4/29/1982 0.00

4/30/1982 0.00

5/1/1982 0.00

5/2/1982 0.00

5/3/1982 0.00

5/4/1982 0.00

5/5/1982 0.14

5/6/1982 0.29

5/7/1982 0.00

5/8/1982 0.00

5/9/1982 0.00

5/10/1982 0.01

5/11/1982 0.00

5/12/1982 0.01

5/13/1982 0.25

5/14/1982 1.00
Feasibility Report for Insuring Irrigation

Use or disclosure of information or data A9 Risk Management Agency

contained on this sheet is subject to the Order Number: D13PD00306

restrictions on the title page of this report.

Date Precipitation

5/15/1982 0.00

5/16/1982 0.00

5/17/1982 0.00

5/18/1982 0.00

5/19/1982 0.00

5/20/1982 0.00

5/21/1982 0.18

5/22/1982 0.00

5/23/1982 0.00

5/24/1982 0.02

5/25/1982 0.77

5/26/1982 0.25

5/27/1982 0.18

5/28/1982 0.17

5/29/1982 0.96

5/30/1982 0.50

5/31/1982 0.19

6/1/1982 0.00

6/2/1982 0.47

6/3/1982 0.07

6/4/1982 0.17

6/5/1982 0.00

6/6/1982 0.00

6/7/1982 0.01

6/8/1982 0.00

6/9/1982 0.05

6/10/1982 0.00

6/11/1982 0.08

6/12/1982 0.09

6/13/1982 0.49

6/14/1982 0.00

6/15/1982 0.18

6/16/1982 0.05

6/17/1982 0.00

6/18/1982 0.23

6/19/1982 0.02

6/20/1982 0.00

6/21/1982 0.00

6/22/1982 0.16

6/23/1982 0.00

6/24/1982 0.00

Date Precipitation

6/25/1982 0.05

6/26/1982 0.50

6/27/1982 0.44

6/28/1982 0.00

6/29/1982 0.00

6/30/1982 0.12

7/1/1982 0.60

7/2/1982 0.00

7/3/1982 0.00

7/4/1982 0.00

7/5/1982 0.00

7/6/1982 0.00

7/7/1982 0.00

7/8/1982 0.00

7/9/1982 0.12

7/10/1982 0.52

7/11/1982 0.00

7/12/1982 0.01

7/13/1982 0.00

7/14/1982 0.00

7/15/1982 0.40

7/16/1982 0.00

7/17/1982 0.00

7/18/1982 0.00

7/19/1982 0.00

7/20/1982 0.00

7/21/1982 0.00

7/22/1982 0.00

7/23/1982 0.00

7/24/1982 0.00

7/25/1982 0.00

7/26/1982 0.00

7/27/1982 0.69

7/28/1982 0.00

7/29/1982 0.00

7/30/1982 0.24

7/31/1982 0.00

8/1/1982 0.00

8/2/1982 0.00

8/3/1982 0.00

8/4/1982 0.42

Date Precipitation

8/5/1982 0.00

8/6/1982 0.00

8/7/1982 0.00

8/8/1982 0.00

8/9/1982 0.00

8/10/1982 0.33

8/11/1982 0.01

8/12/1982 0.00

8/13/1982 0.00

8/14/1982 0.00

8/15/1982 0.00

8/16/1982 0.00

8/17/1982 0.00

8/18/1982 0.00

8/19/1982 0.00

8/20/1982 0.00

8/21/1982 0.08

8/22/1982 0.00

8/23/1982 0.07

8/24/1982 0.00

8/25/1982 0.00

8/26/1982 0.00

8/27/1982 0.00

8/28/1982 0.00

8/29/1982 0.00

8/30/1982 0.00

8/31/1982 2.07

9/1/1982 0.15

9/2/1982 0.00

9/3/1982 0.00

9/4/1982 0.00

9/5/1982 0.00

9/6/1982 0.00

9/7/1982 0.00

9/8/1982 0.00

9/9/1982 0.15

9/10/1982 0.00

9/11/1982 0.00

9/12/1982 0.33

9/13/1982 0.20

9/14/1982 0.20

Date Precipitation

9/15/1982 0.00

9/16/1982 0.00

9/17/1982 0.00

9/18/1982 0.00

9/19/1982 0.00

9/20/1982 0.00

9/21/1982 0.00

9/22/1982 0.00

9/23/1982 0.00

9/24/1982 0.00

9/25/1982 0.00

9/26/1982 0.00

9/27/1982 0.00

9/28/1982 0.00

9/29/1982 0.00

9/30/1982 0.00

4/1/1987 0.00

4/2/1987 0.00

4/3/1987 0.00

4/4/1987 0.00

4/5/1987 0.00

4/6/1987 0.00

4/7/1987 0.00

4/8/1987 0.00

4/9/1987 0.00

4/10/1987 0.00

4/11/1987 0.00

4/12/1987 0.00

4/13/1987 0.58

4/14/1987 0.86

4/15/1987 0.00

4/16/1987 0.00

4/17/1987 0.00

4/18/1987 0.00

4/19/1987 0.00

4/20/1987 0.00

4/21/1987 0.00

4/22/1987 0.00

4/23/1987 0.00

4/24/1987 0.00

4/25/1987 0.00

Date Precipitation

4/26/1987 0.00

4/27/1987 0.00

4/28/1987 0.00

4/29/1987 0.00

4/30/1987 0.00

5/1/1987 0.00

5/2/1987 0.00

5/3/1987 0.11

5/4/1987 0.27

5/5/1987 0.30

5/6/1987 0.09

5/7/1987 0.00

5/8/1987 0.00

5/9/1987 0.00

5/10/1987 0.00

5/11/1987 0.00

5/12/1987 0.00

5/13/1987 0.05

5/14/1987 0.00

5/15/1987 0.00

5/16/1987 0.00

5/17/1987 0.00

5/18/1987 0.05

5/19/1987 0.28

5/20/1987 0.01

5/21/1987 0.81

5/22/1987 0.00

5/23/1987 0.00

5/24/1987 0.12

5/25/1987 0.02

5/26/1987 0.03

5/27/1987 0.00

5/28/1987 0.00

5/29/1987 0.00

5/30/1987 0.00

5/31/1987 0.00

6/1/1987 0.00

6/2/1987 0.00

6/3/1987 0.00

6/4/1987 0.00

6/5/1987 0.00
Feasibility Report for Insuring Irrigation

Use or disclosure of information or data A10 Risk Management Agency

contained on this sheet is subject to the Order Number: D13PD00306

restrictions on the title page of this report.

Date Precipitation

6/6/1987 0.00

6/7/1987 0.00

6/8/1987 0.00

6/9/1987 0.00

6/10/1987 0.18

6/11/1987 0.55

6/12/1987 0.00

6/13/1987 0.00

6/14/1987 0.00

6/15/1987 0.00

6/16/1987 0.01

6/17/1987 0.10

6/18/1987 0.00

6/19/1987 0.00

6/20/1987 0.00

6/21/1987 0.21

6/22/1987 0.00

6/23/1987 0.00

6/24/1987 0.54

6/25/1987 0.07

6/26/1987 0.00

6/27/1987 0.12

6/28/1987 0.00

6/29/1987 0.53

6/30/1987 0.01

7/1/1987 0.00

7/2/1987 0.60

7/3/1987 0.10

7/4/1987 1.13

7/5/1987 0.00

7/6/1987 0.00

7/7/1987 0.00

7/8/1987 0.76

7/9/1987 0.16

7/10/1987 0.00

7/11/1987 0.00

7/12/1987 1.54

7/13/1987 0.00

7/14/1987 0.00

7/15/1987 0.05

7/16/1987 0.00

Date Precipitation

7/17/1987 0.00

7/18/1987 0.12

7/19/1987 0.00

7/20/1987 0.00

7/21/1987 0.00

7/22/1987 0.00

7/23/1987 0.00

7/24/1987 0.00

7/25/1987 0.00

7/26/1987 0.00

7/27/1987 0.00

7/28/1987 0.00

7/29/1987 0.00

7/30/1987 0.00

7/31/1987 0.00

8/1/1987 0.00

8/2/1987 0.01

8/3/1987 0.00

8/4/1987 0.00

8/5/1987 0.00

8/6/1987 0.00

8/7/1987 0.25

8/8/1987 0.16

8/9/1987 0.00

8/10/1987 0.00

8/11/1987 0.00

8/12/1987 0.00

8/13/1987 0.76

8/14/1987 0.00

8/15/1987 0.00

8/16/1987 0.00

8/17/1987 0.00

8/18/1987 0.00

8/19/1987 0.00

8/20/1987 0.00

8/21/1987 0.00

8/22/1987 0.00

8/23/1987 0.18

8/24/1987 0.08

8/25/1987 0.07

8/26/1987 0.00

Date Precipitation

8/27/1987 0.00

8/28/1987 0.00

8/29/1987 0.00

8/30/1987 0.00

8/31/1987 0.00

9/1/1987 0.00

9/2/1987 0.00

9/3/1987 0.00

9/4/1987 0.00

9/5/1987 0.01

9/6/1987 0.00

9/7/1987 0.04

9/8/1987 0.00

9/9/1987 0.00

9/10/1987 0.00

9/11/1987 0.10

9/12/1987 0.00

9/13/1987 0.00

9/14/1987 0.00

9/15/1987 0.00

9/16/1987 0.30

9/17/1987 0.00

9/18/1987 0.11

9/19/1987 0.00

9/20/1987 0.00

9/21/1987 0.00

9/22/1987 0.00

9/23/1987 0.00

9/24/1987 0.00

9/25/1987 0.00

9/26/1987 0.00

9/27/1987 0.00

9/28/1987 0.00

9/29/1987 0.00

9/30/1987 0.00

4/1/1992 0.00

4/2/1992 0.00

4/3/1992 0.00

4/4/1992 0.00

4/5/1992 0.00

4/6/1992 0.00

Date Precipitation

4/7/1992 0.05

4/8/1992 0.00

4/9/1992 0.00

4/10/1992 0.00

4/11/1992 0.00

4/12/1992 0.00

4/13/1992 0.00

4/14/1992 0.00

4/15/1992 0.38

4/16/1992 0.01

4/17/1992 0.00

4/18/1992 0.00

4/19/1992 0.01

4/20/1992 0.00

4/21/1992 0.00

4/22/1992 0.00

4/23/1992 0.01

4/24/1992 0.00

4/25/1992 0.00

4/26/1992 0.00

4/27/1992 0.00

4/28/1992 0.00

4/29/1992 0.03

4/30/1992 0.00

5/1/1992 0.00

5/2/1992 0.00

5/3/1992 0.00

5/4/1992 0.00

5/5/1992 0.00

5/6/1992 0.00

5/7/1992 0.00

5/8/1992 0.00

5/9/1992 0.00

5/10/1992 0.00

5/11/1992 0.00

5/12/1992 0.00

5/13/1992 0.00

5/14/1992 0.16

5/15/1992 0.00

5/16/1992 0.00

5/17/1992 0.18

Date Precipitation

5/18/1992 0.00

5/19/1992 0.00

5/20/1992 0.00

5/21/1992 0.00

5/22/1992 0.00

5/23/1992 0.00

5/24/1992 0.00

5/25/1992 0.13

5/26/1992 0.03

5/27/1992 0.25

5/28/1992 0.22

5/29/1992 0.00

5/30/1992 0.00

5/31/1992 0.02

6/1/1992 0.24

6/2/1992 0.12

6/3/1992 0.07

6/4/1992 0.34

6/5/1992 0.65

6/6/1992 0.75

6/7/1992 0.00

6/8/1992 0.15

6/9/1992 0.00

6/10/1992 0.68

6/11/1992 1.02

6/12/1992 0.00

6/13/1992 0.00

6/14/1992 0.00

6/15/1992 0.05

6/16/1992 0.00

6/17/1992 0.00

6/18/1992 0.00

6/19/1992 0.00

6/20/1992 0.00

6/21/1992 0.02

6/22/1992 0.01

6/23/1992 0.00

6/24/1992 0.00

6/25/1992 0.00

6/26/1992 0.14

6/27/1992 0.24
Feasibility Report for Insuring Irrigation

Use or disclosure of information or data A11 Risk Management Agency

contained on this sheet is subject to the Order Number: D13PD00306

restrictions on the title page of this report.

Date Precipitation

6/28/1992 0.12

6/29/1992 0.00

6/30/1992 0.00

7/1/1992 0.00

7/2/1992 0.00

7/3/1992 0.00

7/4/1992 0.00

7/5/1992 0.00

7/6/1992 0.00

7/7/1992 0.00

7/8/1992 0.98

7/9/1992 1.22

7/10/1992 0.00

7/11/1992 0.00

7/12/1992 1.46

7/13/1992 0.67

7/14/1992 0.00

7/15/1992 0.00

7/16/1992 0.41

7/17/1992 0.00

7/18/1992 0.00

7/19/1992 0.00

7/20/1992 0.12

7/21/1992 0.00

7/22/1992 0.03

7/23/1992 0.00

7/24/1992 0.00

7/25/1992 0.09

7/26/1992 0.23

7/27/1992 0.00

7/28/1992 0.00

7/29/1992 0.30

7/30/1992 0.07

7/31/1992 0.00

8/1/1992 0.69

8/2/1992 0.00

8/3/1992 0.92

8/4/1992 0.35

8/5/1992 2.70

8/6/1992 0.00

8/7/1992 0.04

Date Precipitation

8/8/1992 0.00

8/9/1992 0.00

8/10/1992 0.00

8/11/1992 0.17

8/12/1992 0.82

8/13/1992 0.00

8/14/1992 0.00

8/15/1992 0.00

8/16/1992 0.00

8/17/1992 0.00

8/18/1992 1.90

8/19/1992 0.00

8/20/1992 0.00

8/21/1992 0.00

8/22/1992 0.00

8/23/1992 0.00

8/24/1992 0.00

8/25/1992 0.40

8/26/1992 0.03

8/27/1992 0.00

8/28/1992 0.00

8/29/1992 0.00

8/30/1992 0.00

8/31/1992 0.00

9/1/1992 1.21

9/2/1992 0.00

9/3/1992 0.00

9/4/1992 0.09

9/5/1992 0.00

9/6/1992 0.00

9/7/1992 0.06

9/8/1992 0.03

9/9/1992 0.00

9/10/1992 0.00

9/11/1992 0.00

9/12/1992 0.00

9/13/1992 0.00

9/14/1992 0.00

9/15/1992 0.00

9/16/1992 0.00

9/17/1992 0.00

Date Precipitation

9/18/1992 0.02

9/19/1992 0.00

9/20/1992 0.15

9/21/1992 0.00

9/22/1992 0.00

9/23/1992 0.00

9/24/1992 0.00

9/25/1992 0.00

9/26/1992 0.05

9/27/1992 0.00

9/28/1992 0.00

9/29/1992 0.00

9/30/1992 0.00

4/1/1997 0.00

4/2/1997 0.01

4/3/1997 0.01

4/4/1997 0.03

4/5/1997 0.01

4/6/1997 0.01

4/7/1997 0.00

4/8/1997 0.00

4/9/1997 0.00

4/10/1997 0.10

4/11/1997 0.22

4/12/1997 0.06

4/13/1997 0.00

4/14/1997 0.00

4/15/1997 0.00

4/16/1997 0.00

4/17/1997 0.00

4/18/1997 0.00

4/19/1997 0.00

4/20/1997 0.00

4/21/1997 0.00

4/22/1997 0.01

4/23/1997 0.00

4/24/1997 0.00

4/25/1997 0.10

4/26/1997 0.09

4/27/1997 0.04

4/28/1997 0.00

Date Precipitation

4/29/1997 0.00

4/30/1997 0.23

5/1/1997 0.00

5/2/1997 0.20

5/3/1997 0.04

5/4/1997 0.00

5/5/1997 0.00

5/6/1997 0.01

5/7/1997 0.00

5/8/1997 0.00

5/9/1997 0.01

5/10/1997 0.00

5/11/1997 0.00

5/12/1997 0.00

5/13/1997 0.00

5/14/1997 0.00

5/15/1997 0.01

5/16/1997 0.00

5/17/1997 0.00

5/18/1997 0.01

5/19/1997 0.25

5/20/1997 0.01

5/21/1997 0.00

5/22/1997 0.00

5/23/1997 1.27

5/24/1997 0.01

5/25/1997 0.05

5/26/1997 0.08

5/27/1997 0.05

5/28/1997 0.00

5/29/1997 0.00

5/30/1997 0.19

5/31/1997 0.01

6/1/1997 0.00

6/2/1997 1.06

6/3/1997 0.50

6/4/1997 0.04

6/5/1997 0.00

6/6/1997 0.00

6/7/1997 0.00

6/8/1997 0.00

Date Precipitation

6/9/1997 0.01

6/10/1997 0.00

6/11/1997 0.00

6/12/1997 0.01

6/13/1997 0.01

6/14/1997 0.00

6/15/1997 0.00

6/16/1997 0.00

6/17/1997 0.00

6/18/1997 0.00

6/19/1997 0.05

6/20/1997 0.00

6/21/1997 0.00

6/22/1997 0.01

6/23/1997 0.00

6/24/1997 0.01

6/25/1997 0.67

6/26/1997 0.48

6/27/1997 0.00

6/28/1997 0.00

6/29/1997 0.76

6/30/1997 0.01

7/1/1997 0.00

7/2/1997 0.00

7/3/1997 0.00

7/4/1997 0.00

7/5/1997 0.00

7/6/1997 0.41

7/7/1997 0.22

7/8/1997 0.00

7/9/1997 0.14

7/10/1997 0.01

7/11/1997 0.00

7/12/1997 0.01

7/13/1997 0.00

7/14/1997 0.00

7/15/1997 0.10

7/16/1997 0.00

7/17/1997 0.00

7/18/1997 0.00

7/19/1997 0.00
Feasibility Report for Insuring Irrigation

Use or disclosure of information or data A12 Risk Management Agency

contained on this sheet is subject to the Order Number: D13PD00306

restrictions on the title page of this report.

Date Precipitation

7/20/1997 0.00

7/21/1997 0.00

7/22/1997 0.00

7/23/1997 0.00

7/24/1997 0.00

7/25/1997 0.00

7/26/1997 0.00

7/27/1997 0.00

7/28/1997 1.35

7/29/1997 0.01

7/30/1997 0.68

7/31/1997 0.01

8/1/1997 0.00

8/2/1997 0.00

8/3/1997 0.00

8/4/1997 0.00

8/5/1997 0.01

8/6/1997 0.88

8/7/1997 0.40

8/8/1997 0.00

8/9/1997 0.00

8/10/1997 0.02

8/11/1997 0.57

8/12/1997 0.00

8/13/1997 0.00

8/14/1997 0.01

8/15/1997 0.00

8/16/1997 0.00

8/17/1997 0.96

8/18/1997 0.00

8/19/1997 0.62

8/20/1997 0.00

8/21/1997 0.24

8/22/1997 0.46

8/23/1997 0.00

8/24/1997 0.00

8/25/1997 0.00

8/26/1997 0.00

8/27/1997 0.00

8/28/1997 0.00

8/29/1997 0.07

Date Precipitation

8/30/1997 0.15

8/31/1997 0.01

9/1/1997 0.01

9/2/1997 0.00

9/3/1997 0.01

9/4/1997 0.01

9/5/1997 0.01

9/6/1997 0.00

9/7/1997 0.01

9/8/1997 0.00

9/9/1997 0.01

9/10/1997 0.01

9/11/1997 0.00

9/12/1997 0.00

9/13/1997 0.00

9/14/1997 0.01

9/15/1997 0.08

9/16/1997 0.00

9/17/1997 0.01

9/18/1997 0.00

9/19/1997 0.00

9/20/1997 0.01

9/21/1997 0.08

9/22/1997 0.19

9/23/1997 0.10

9/24/1997 0.01

9/25/1997 0.01

9/26/1997 0.00

9/27/1997 0.00

9/28/1997 0.00

9/29/1997 0.00

9/30/1997 0.00

4/1/2002 0.00

4/2/2002 0.00

4/3/2002 0.00

4/4/2002 0.00

4/5/2002 0.00

4/6/2002 0.00

4/7/2002 0.00

4/8/2002 0.04

4/9/2002 0.01

Date Precipitation

4/10/2002 0.00

4/11/2002 0.01

4/12/2002 0.00

4/13/2002 0.00

4/14/2002 0.03

4/15/2002 0.00

4/16/2002 0.00

4/17/2002 0.01

4/18/2002 0.00

4/19/2002 0.00

4/20/2002 0.00

4/21/2002 0.05

4/22/2002 0.01

4/23/2002 0.00

4/24/2002 0.00

4/25/2002 0.00

4/26/2002 0.00

4/27/2002 0.04

4/28/2002 0.03

4/29/2002 0.00

4/30/2002 0.00

5/1/2002 0.00

5/2/2002 0.01

5/3/2002 0.00

5/4/2002 0.00

5/5/2002 0.00

5/6/2002 0.00

5/7/2002 0.01

5/8/2002 0.02

5/9/2002 0.00

5/10/2002 0.00

5/11/2002 0.06

5/12/2002 0.01

5/13/2002 0.01

5/14/2002 0.00

5/15/2002 0.00

5/16/2002 0.32

5/17/2002 0.28

5/18/2002 0.00

5/19/2002 0.00

5/20/2002 0.00

Date Precipitation

5/21/2002 0.00

5/22/2002 0.00

5/23/2002 0.00

5/24/2002 0.12

5/25/2002 0.64

5/26/2002 0.00

5/27/2002 0.00

5/28/2002 0.00

5/29/2002 0.00

5/30/2002 0.00

5/31/2002 0.00

6/1/2002 0.00

6/2/2002 0.00

6/3/2002 0.00

6/4/2002 0.18

6/5/2002 0.07

6/6/2002 0.01

6/7/2002 0.00

6/8/2002 0.00

6/9/2002 0.00

6/10/2002 0.00

6/11/2002 0.00

6/12/2002 0.00

6/13/2002 0.19

6/14/2002 0.07

6/15/2002 0.00

6/16/2002 0.00

6/17/2002 0.00

6/18/2002 0.00

6/19/2002 0.00

6/20/2002 0.05

6/21/2002 0.00

6/22/2002 0.00

6/23/2002 0.00

6/24/2002 0.00

6/25/2002 0.00

6/26/2002 0.27

6/27/2002 0.01

6/28/2002 0.00

6/29/2002 0.00

6/30/2002 0.00

Date Precipitation

7/1/2002 0.00

7/2/2002 0.00

7/3/2002 0.00

7/4/2002 0.00

7/5/2002 0.00

7/6/2002 0.11

7/7/2002 0.00

7/8/2002 0.00

7/9/2002 0.00

7/10/2002 0.00

7/11/2002 0.00

7/12/2002 0.00

7/13/2002 0.00

7/14/2002 0.00

7/15/2002 0.00

7/16/2002 0.00

7/17/2002 0.00

7/18/2002 0.00

7/19/2002 0.00

7/20/2002 0.00

7/21/2002 0.00

7/22/2002 0.34

7/23/2002 0.00

7/24/2002 0.00

7/25/2002 0.00

7/26/2002 0.00

7/27/2002 0.00

7/28/2002 0.00

7/29/2002 0.01

7/30/2002 0.00

7/31/2002 0.00

8/1/2002 0.00

8/2/2002 0.00

8/3/2002 0.00

8/4/2002 0.00

8/5/2002 0.08

8/6/2002 0.00

8/7/2002 0.00

8/8/2002 0.00

8/9/2002 0.98

8/10/2002 0.03
Feasibility Report for Insuring Irrigation

Use or disclosure of information or data A13 Risk Management Agency

contained on this sheet is subject to the Order Number: D13PD00306

restrictions on the title page of this report.

Date Precipitation

8/11/2002 0.00

8/12/2002 0.01

8/13/2002 0.62

8/14/2002 0.00

8/15/2002 0.00

8/16/2002 0.00

8/17/2002 0.00

8/18/2002 0.00

8/19/2002 0.00

8/20/2002 0.00

8/21/2002 0.00

8/22/2002 0.01

8/23/2002 0.18

8/24/2002 0.28

8/25/2002 0.00

8/26/2002 0.00

8/27/2002 0.14

8/28/2002 0.04

8/29/2002 0.00

8/30/2002 0.00

8/31/2002 0.00

9/1/2002 0.00

9/2/2002 0.00

9/3/2002 0.00

9/4/2002 0.00

9/5/2002 0.00

9/6/2002 0.00

9/7/2002 0.00

9/8/2002 0.00

9/9/2002 0.00

9/10/2002 0.42

9/11/2002 0.01

9/12/2002 0.00

9/13/2002 0.15

9/14/2002 0.10

9/15/2002 0.00

9/16/2002 0.00

9/17/2002 0.00

9/18/2002 0.00

9/19/2002 0.10

9/20/2002 0.01

Date Precipitation

9/21/2002 0.00

9/22/2002 0.00

9/23/2002 0.00

9/24/2002 0.00

9/25/2002 0.00

9/26/2002 0.00

9/27/2002 0.00

9/28/2002 0.00

9/29/2002 0.03

9/30/2002 0.00

4/1/2007 0.00

4/2/2007 0.00

4/3/2007 0.00

4/4/2007 0.00

4/5/2007 0.00

4/6/2007 0.03

4/7/2007 0.01

4/8/2007 0.00

4/9/2007 0.01

4/10/2007 0.17

4/11/2007 0.01

4/12/2007 0.01

4/13/2007 0.15

4/14/2007 0.41

4/15/2007 0.01

4/16/2007 0.00

4/17/2007 0.00

4/18/2007 0.00

4/19/2007 0.00

4/20/2007 0.00

4/21/2007 0.01

4/22/2007 1.31

4/23/2007 0.01

4/24/2007 0.10

4/25/2007 0.18

4/26/2007 0.10

4/27/2007 0.14

4/28/2007 0.00

4/29/2007 0.00

4/30/2007 0.00

5/1/2007 0.00

Date Precipitation

5/2/2007 0.00

5/3/2007 0.00

5/4/2007 0.00

5/5/2007 0.01

5/6/2007 0.01

5/7/2007 0.00

5/8/2007 0.00

5/9/2007 0.00

5/10/2007 0.00

5/11/2007 0.00

5/12/2007 0.00

5/13/2007 0.00

5/14/2007 0.00

5/15/2007 1.06

5/16/2007 0.00

5/17/2007 0.00

5/18/2007 0.00

5/19/2007 0.00

5/20/2007 0.00

5/21/2007 0.00

5/22/2007 0.01

5/23/2007 0.10

5/24/2007 0.05

5/25/2007 0.00

5/26/2007 0.05

5/27/2007 0.00

5/28/2007 0.00

5/29/2007 0.00

5/30/2007 0.84

5/31/2007 0.00

6/1/2007 0.01

6/2/2007 0.01

6/3/2007 0.00

6/4/2007 0.00

6/5/2007 0.00

6/6/2007 0.00

6/7/2007 0.00

6/8/2007 0.00

6/9/2007 0.00

6/10/2007 0.00

6/11/2007 0.00

Date Precipitation

6/12/2007 0.00

6/13/2007 0.43

6/14/2007 1.15

6/15/2007 0.01

6/16/2007 0.00

6/17/2007 0.00

6/18/2007 0.00

6/19/2007 0.00

6/20/2007 0.17

6/21/2007 0.01

6/22/2007 0.00

6/23/2007 0.00

6/24/2007 0.00

6/25/2007 0.00

6/26/2007 0.00

6/27/2007 0.01

6/28/2007 0.01

6/29/2007 0.00

6/30/2007 0.00

7/1/2007 0.00

7/2/2007 0.00

7/3/2007 0.00

7/4/2007 0.00

7/5/2007 0.00

7/6/2007 0.00

7/7/2007 0.00

7/8/2007 0.00

7/9/2007 0.19

7/10/2007 0.00

7/11/2007 0.18

7/12/2007 0.22

7/13/2007 0.16

7/14/2007 0.02

7/15/2007 0.00

7/16/2007 0.00

7/17/2007 0.00

7/18/2007 0.00

7/19/2007 0.01

7/20/2007 0.00

7/21/2007 0.00

7/22/2007 0.00

Date Precipitation

7/23/2007 0.00

7/24/2007 0.01

7/25/2007 0.00

7/26/2007 0.00

7/27/2007 0.00

7/28/2007 0.00

7/29/2007 0.41

7/30/2007 0.01

7/31/2007 0.01

8/1/2007 1.04

8/2/2007 0.01

8/3/2007 0.05

8/4/2007 0.00

8/5/2007 0.00

8/6/2007 0.50

8/7/2007 0.02

8/8/2007 0.04

8/9/2007 0.00

8/10/2007 0.00

8/11/2007 0.00

8/12/2007 0.00

8/13/2007 0.00

8/14/2007 0.00

8/15/2007 0.00

8/16/2007 0.00

8/17/2007 0.01

8/18/2007 0.00

8/19/2007 0.00

8/20/2007 0.00

8/21/2007 0.00

8/22/2007 0.04

8/23/2007 1.46

8/24/2007 0.20

8/25/2007 0.42

8/26/2007 0.00

8/27/2007 0.01

8/28/2007 0.00

8/29/2007 0.00

8/30/2007 0.00

8/31/2007 0.00

9/1/2007 0.00
Feasibility Report for Insuring Irrigation

Use or disclosure of information or data A14 Risk Management Agency

contained on this sheet is subject to the Order Number: D13PD00306

restrictions on the title page of this report.

Date Precipitation

9/2/2007 0.00

9/3/2007 0.00

9/4/2007 0.00

9/5/2007 0.00

9/6/2007 0.00

9/7/2007 0.00

9/8/2007 0.01

9/9/2007 0.00

9/10/2007 0.06

9/11/2007 0.29

9/12/2007 0.00

9/13/2007 0.00

9/14/2007 0.00

9/15/2007 0.18

9/16/2007 0.00

9/17/2007 0.00

9/18/2007 0.28

9/19/2007 0.00

9/20/2007 0.01

9/21/2007 0.00

9/22/2007 0.00

9/23/2007 0.00

9/24/2007 0.00

9/25/2007 0.01

9/26/2007 0.00

9/27/2007 0.00

9/28/2007 0.00

9/29/2007 0.11

9/30/2007 0.01

4/1/2012 0.00

4/2/2012 0.57

4/3/2012 1.57

4/4/2012 0.49

4/5/2012 0.03

4/6/2012 0.00

4/7/2012 0.00

4/8/2012 0.00

4/9/2012 0.00

4/10/2012 0.00

4/11/2012 0.00

4/12/2012 0.06

Date Precipitation

4/13/2012 0.00

4/14/2012 0.00

4/15/2012 0.04

4/16/2012 0.11

4/17/2012 0.00

4/18/2012 0.00

4/19/2012 0.00

4/20/2012 0.05

4/21/2012 0.00

4/22/2012 0.00

4/23/2012 0.00

4/24/2012 0.00

4/25/2012 0.00

4/26/2012 0.02

4/27/2012 0.74

4/28/2012 0.03

4/29/2012 0.00

4/30/2012 0.00

5/1/2012 0.00

5/2/2012 0.00

5/3/2012 0.00

5/4/2012 0.00

5/5/2012 0.00

5/6/2012 0.00

5/7/2012 0.13

5/8/2012 0.13

5/9/2012 0.00

5/10/2012 0.00

5/11/2012 0.00

5/12/2012 0.00

5/13/2012 0.00

5/14/2012 0.00

5/15/2012 0.00

5/16/2012 0.00

5/17/2012 0.00

5/18/2012 0.00

5/19/2012 0.06

5/20/2012 0.00

5/21/2012 0.00

5/22/2012 0.00

5/23/2012 0.00

Date Precipitation

5/24/2012 0.10

5/25/2012 0.00

5/26/2012 0.00

5/27/2012 0.00

5/28/2012 0.00

5/29/2012 0.00

5/30/2012 0.18

5/31/2012 0.07

6/1/2012 0.00

6/2/2012 0.00

6/3/2012 0.00

6/4/2012 0.00

6/5/2012 0.00

6/6/2012 0.00

6/7/2012 0.00

6/8/2012 0.00

6/9/2012 0.00

6/10/2012 0.00

6/11/2012 0.00

6/12/2012 0.00

6/13/2012 0.00

6/14/2012 0.48

6/15/2012 0.00

6/16/2012 0.30

6/17/2012 0.00

6/18/2012 0.00

6/19/2012 0.00

6/20/2012 0.00

6/21/2012 0.00

6/22/2012 0.00

6/23/2012 0.00

6/24/2012 0.00

6/25/2012 0.00

6/26/2012 0.00

6/27/2012 0.00

6/28/2012 0.17

6/29/2012 0.00

6/30/2012 0.24

7/1/2012 0.00

7/2/2012 0.00

7/3/2012 0.00

Date Precipitation

7/4/2012 0.00

7/5/2012 0.00

7/6/2012 0.00

7/7/2012 2.80

7/8/2012 0.15

7/9/2012 0.00

7/10/2012 0.00

7/11/2012 0.00

7/12/2012 0.00

7/13/2012 0.00

7/14/2012 0.00

7/15/2012 0.00

7/16/2012 0.00

7/17/2012 0.00

7/18/2012 0.00

7/19/2012 0.00

7/20/2012 0.00

7/21/2012 0.00

7/22/2012 0.00

7/23/2012 0.00

7/24/2012 0.00

7/25/2012 0.00

7/26/2012 0.00

7/27/2012 0.00

7/28/2012 0.00

7/29/2012 0.00

7/30/2012 0.14

7/31/2012 0.00

8/1/2012 0.15

8/2/2012 0.00

8/3/2012 0.00

8/4/2012 0.00

8/5/2012 0.00

8/6/2012 0.00

8/7/2012 0.00

8/8/2012 0.00

8/9/2012 0.00

8/10/2012 0.00

8/11/2012 0.00

8/12/2012 0.00

8/13/2012 0.00

Date Precipitation

8/14/2012 0.12

8/15/2012 0.00

8/16/2012 0.00

8/17/2012 0.00

8/18/2012 0.00

8/19/2012 0.00

8/20/2012 0.00

8/21/2012 0.00

8/22/2012 0.00

8/23/2012 0.40

8/24/2012 1.80

8/25/2012 0.00

8/26/2012 0.00

8/27/2012 0.00

8/28/2012 0.00

8/29/2012 0.00

8/30/2012 0.00

8/31/2012 0.00

9/1/2012 0.00

9/2/2012 0.00

9/3/2012 0.00

9/4/2012 0.35

9/5/2012 0.00

9/6/2012 0.00

9/7/2012 0.10

9/8/2012 0.00

9/9/2012 0.00

9/10/2012 0.00

9/11/2012 0.00

9/12/2012 0.49

9/13/2012 0.00

9/14/2012 0.00

9/15/2012 0.00

9/16/2012 0.00

9/17/2012 0.00

9/18/2012 0.00

9/19/2012 0.00

9/20/2012 0.00

9/21/2012 0.00

9/22/2012 0.00

9/23/2012 0.00
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Date Precipitation

9/24/2012 0.00

9/25/2012 0.00

9/26/2012 0.00

9/27/2012 0.00

9/28/2012 0.00

9/29/2012 0.00

9/30/2012 0.00
Feasibility Report for Insuring Irrigation

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Exhibit 3a. Cumulative Precipitation Metadata for Five 

Study Area Counties, Crop Years 1951 through 2012
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County

Cumulative Precipitation (inches)

Growing 

Season

Prior to 

Growing 

Season

Total 

Precipitation

Kit Carson 

County, 

Colorado

Average 12.53 3.37 15.90

Standard Deviation 3.04 1.41 3.48

Low 6.28 1.03 8.95

High 20.16 6.78 24.35

Sheridan 

County, 

Kansas

Average 15.88 5.19 21.07

Standard Deviation 4.71 2.33 5.17

Low 5.92 1.37 8.16

High 28.77 10.57 37.67

Washington 

County, 

Kansas

Average 23.33 8.42 31.74

Standard Deviation 6.53 3.37 8.37

Low 10.81 2.84 15.10

High 43.20 19.45 57.62

Butler 

County, 

Nebraska

Average 10.58 18.44 29.02

Standard Deviation 5.53 6.04 6.31

Low 3.75 4.50 16.27

High 26.26 32.00 44.70

Perkins 

County, 

Nebraska

Average 16.11 4.64 20.75

Standard Deviation 4.96 1.65 5.38

Low 8.09 1.78 11.32

High 32.27 9.19 35.29
Feasibility Report for Insuring Irrigation

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Exhibit 3b. Annual Crop Year Precipitation for Five Study 

Area Counties, Crop Years 1951 through 2012
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Year

Kit Carson County, Colorado Sheridan County, Kansas Washington County, Kansas Perkins County, Nebraska Butler County, Nebraska

Apr. 1 

to Sept.

30

Oct. 1 to 

Sept. 30

Oct. 1 to 

Mar. 31

Apr. 1 to 

Sept. 30

Oct. 1 to 

Sept. 30

Oct. 1 to 

Mar. 31

Apr. 1 to 

Sept. 30

Oct. 1 to 

Sept. 30

Oct. 1 to 

Mar. 31

Apr. 1 to 

Sept. 30

Oct. 1 to 

Sept. 30

Oct. 1 to 

Mar. 31

Apr. 1 to 

Sept. 30

Oct. 1 to 

Sept. 30

Oct. 1 to 

Mar. 31

1951 15.15 16.44 1.28 26.60 29.25 2.65 43.20 53.19 9.99 26.94 29.19 2.25 24.37 33.31 8.94

1952 8.41 12.16 3.76 11.25 14.31 3.06 16.99 25.97 8.98 11.95 17.36 5.41 9.42 21.87 12.45

1953 9.13 11.09 1.96 17.50 20.66 3.16 20.12 26.55 6.43 11.36 14.96 3.60 4.34 26.17 21.83

1954 6.28 10.06 3.78 12.08 17.71 5.63 28.62 35.74 7.12 9.74 15.27 5.53 3.76 16.27 12.51

1955 8.01 10.72 2.71 14.99 18.71 3.72 14.97 19.77 4.80 12.70 16.18 3.48 8.39 19.05 10.67

1956 6.88 9.30 2.42 5.92 8.16 2.24 13.03 15.87 2.84 10.52 12.86 2.34 11.86 38.91 27.06

1957 18.41 22.08 3.67 25.08 29.80 4.72 23.16 28.94 5.78 18.62 24.24 5.62 10.62 27.59 16.98

1958 15.25 18.43 3.18 16.53 23.85 7.32 30.17 37.30 7.13 21.15 27.62 6.47 10.23 35.43 25.21

1959 10.06 12.87 2.81 16.60 21.64 5.04 27.57 31.99 4.42 14.43 19.38 4.95 5.75 27.10 21.35

1960 9.62 14.36 4.74 13.98 22.03 8.05 25.38 36.60 11.22 9.51 16.69 7.18 8.17 25.02 16.85

1961 13.14 18.19 5.05 23.49 28.45 4.96 26.67 32.65 5.98 15.45 19.23 3.78 7.02 29.30 22.28

1962 12.69 15.35 2.66 22.91 29.03 6.12 24.01 34.94 10.93 24.17 27.22 3.05 8.03 28.69 20.66

1963 12.60 15.55 2.95 15.10 20.54 5.44 22.34 30.31 7.97 19.11 22.65 3.54 10.27 28.88 18.61

1964 6.79 8.95 2.16 13.23 15.82 2.59 19.60 24.13 4.53 10.71 14.35 3.64 5.88 37.16 31.28

1965 18.33 20.09 1.76 19.86 23.30 3.44 25.80 33.35 7.55 21.61 23.84 2.23 3.75 19.80 16.05

1966 11.65 13.99 2.34 11.86 18.14 6.28 15.53 18.59 3.06 13.32 18.38 5.06 6.64 34.53 27.90

1967 13.76 14.79 1.03 13.36 15.82 2.46 26.88 30.77 3.89 13.80 15.58 1.78 9.91 33.56 23.65

1968 11.23 13.02 1.79 16.73 18.10 1.37 21.52 25.28 3.76 13.18 15.37 2.19 5.74 23.76 18.03

1969 13.78 15.47 1.69 11.98 16.94 4.96 21.41 33.33 11.92 14.30 17.95 3.65 7.04 24.92 17.88

1970 9.90 14.87 4.97 13.64 20.52 6.88 19.06 24.83 5.77 9.73 14.45 4.72 8.20 27.22 19.02

1971 11.21 14.77 3.55 17.43 20.50 3.07 18.14 25.59 7.45 20.33 25.72 5.39 16.78 40.27 23.49

1972 14.41 16.67 2.26 19.08 23.28 4.20 24.52 33.22 8.70 15.20 18.26 3.06 9.16 37.14 27.98

1973 11.61 18.39 6.78 17.71 26.45 8.74 31.62 51.07 19.45 18.09 22.88 4.79 10.42 23.68 13.26

1974 8.48 12.37 3.88 11.40 16.00 4.60 15.36 25.96 10.60 10.86 15.33 4.47 10.90 24.90 14.01

1975 10.18 12.31 2.13 22.54 26.20 3.66 20.89 28.48 7.59 14.14 17.33 3.19 7.77 18.50 10.73

1976 8.98 11.40 2.42 16.36 20.12 3.76 21.46 30.61 9.15 12.23 15.52 3.29 12.69 40.46 27.77

1977 11.45 14.12 2.68 19.37 23.06 3.69 31.11 36.58 5.47 15.03 21.72 6.69 13.82 33.11 19.29

1978 10.11 11.62 1.51 12.33 15.31 2.98 27.10 34.37 7.27 10.00 12.97 2.97 12.60 24.41 11.81

1979 15.61 19.50 3.89 13.55 20.95 7.40 19.54 31.35 11.81 15.14 20.20 5.06 4.14 18.39 14.26

1980 12.15 17.70 5.55 11.19 21.34 10.15 12.94 25.82 12.88 12.70 18.84 6.14 11.25 31.27 20.03

1981 11.48 15.65 4.17 16.95 21.51 4.56 26.28 33.88 7.60 15.09 19.82 4.73 12.70 44.70 32.00

1982 14.39 16.29 1.90 17.15 21.04 3.89 27.02 36.64 9.62 21.11 25.46 4.35 16.61 37.10 20.49
Feasibility Report for Insuring Irrigation

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Year

Kit Carson County, Colorado Sheridan County, Kansas Washington County, Kansas Perkins County, Nebraska Butler County, Nebraska

Apr. 1 

to Sept.

30

Oct. 1 to 

Sept. 30

Oct. 1 to 

Mar. 31

Apr. 1 to 

Sept. 30

Oct. 1 to 

Sept. 30

Oct. 1 to 

Mar. 31

Apr. 1 to 

Sept. 30

Oct. 1 to 

Sept. 30

Oct. 1 to 

Mar. 31

Apr. 1 to 

Sept. 30

Oct. 1 to 

Sept. 30

Oct. 1 to 

Mar. 31

Apr. 1 to 

Sept. 30

Oct. 1 to 

Sept. 30

Oct. 1 to 

Mar. 31

1983 11.06 16.00 4.94 9.85 18.46 8.61 18.97 28.48 9.51 10.89 17.02 6.13 10.04 31.80 21.77

1984 9.75 14.72 4.97 15.89 23.87 7.98 25.96 37.57 11.61 14.54 19.19 4.65 9.79 33.77 23.98

1985 11.55 15.24 3.69 16.43 23.76 7.33 32.47 44.04 11.57 12.61 16.22 3.61 10.93 39.52 28.60

1986 11.02 13.48 2.46 13.98 17.65 3.67 32.61 42.56 9.95 14.48 18.91 4.43 4.78 23.53 18.76

1987 13.90 18.68 4.78 12.43 20.47 8.04 23.94 39.11 15.17 16.73 22.76 6.03 4.30 22.25 17.95

1988 12.11 14.72 2.61 11.73 15.34 3.61 15.15 21.17 6.02 16.36 21.43 5.07 4.61 21.70 17.10

1989 12.59 14.02 1.43 12.45 15.44 2.99 27.53 31.72 4.19 15.15 17.95 2.80 9.01 27.84 18.83

1990 11.94 14.76 2.82 18.18 22.32 4.14 26.25 33.71 7.46 14.40 17.81 3.41 11.32 28.81 17.49

1991 14.84 18.36 3.53 17.21 20.28 3.07 17.24 23.32 6.08 16.33 22.02 5.69 10.42 34.84 24.42

1992 13.29 19.30 6.02 21.29 30.26 8.97 25.18 35.90 10.72 14.03 21.64 7.61 5.27 32.86 27.60

1993 12.40 15.54 3.15 28.77 37.67 8.90 42.50 57.62 15.12 18.97 24.52 5.55 10.49 30.39 19.91

1994 12.14 15.66 3.52 14.31 17.74 3.43 18.99 24.53 5.54 15.39 20.78 5.39 6.26 23.64 17.38

1995 18.45 24.35 5.90 20.74 27.63 6.89 27.72 36.32 8.60 20.85 29.08 8.23 7.45 30.39 22.93

1996 15.71 17.77 2.05 24.06 26.12 2.06 24.87 28.22 3.35 21.87 26.23 4.36 11.11 29.41 18.30

1997 15.79 17.38 1.59 14.65 17.95 3.30 16.49 23.32 6.83 32.27 35.29 3.02 9.66 27.63 17.97

1998 15.53 21.64 6.10 13.66 20.81 7.15 28.02 40.91 12.89 17.42 23.94 6.52 5.70 26.00 20.31

1999 20.16 23.05 2.88 18.88 25.91 7.03 23.94 34.48 10.54 23.85 28.70 4.85 9.57 25.52 15.95

2000 12.92 16.94 4.01 8.48 13.57 5.09 14.53 20.09 5.56 8.98 13.19 4.21 7.52 22.70 15.18

2001 13.43 17.93 4.50 18.93 25.84 6.91 32.25 44.71 12.46 20.70 26.94 6.24 6.14 23.36 17.22

2002 9.08 11.46 2.38 6.21 8.87 2.66 10.81 15.10 4.29 8.09 11.32 3.23 10.01 27.56 17.55

2003 12.97 16.81 3.84 10.58 16.03 5.45 15.98 22.76 6.78 14.19 18.14 3.95 11.96 25.96 14.00

2004 12.50 14.07 1.57 16.75 19.20 2.45 19.73 31.23 11.50 17.09 19.73 2.64 9.15 24.46 15.31

2005 11.53 14.46 2.93 19.17 25.02 5.85 29.16 35.70 6.54 14.91 19.76 4.85 10.90 30.36 19.46

2006 10.56 15.77 5.20 13.25 18.82 5.57 25.21 32.26 7.05 14.32 18.24 3.92 14.63 36.54 21.91

2007 14.04 19.25 5.22 12.58 23.15 10.57 23.31 34.95 11.64 20.50 27.80 7.30 25.59 34.13 8.54

2008 17.50 20.83 3.33 16.20 18.78 2.58 21.70 34.25 12.55 21.82 25.05 3.23 26.03 34.61 8.58

2009 18.26 23.47 5.21 19.62 26.65 7.03 19.27 25.48 6.21 24.07 33.09 9.02 20.91 32.19 11.28

2010 16.27 22.13 5.87 7.64 14.79 7.15 31.08 44.17 13.09 20.75 29.94 9.19 25.48 35.95 10.47

2011 14.76 17.06 2.30 20.58 22.81 2.23 19.40 26.54 7.14 25.80 29.36 3.56 26.26 30.76 4.50

2012 9.63 12.53 2.89 12.07 22.56 10.49 14.04 24.21 10.17 9.37 13.86 4.49 12.71 18.41 5.70
Feasibility Report for Insuring Irrigation

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Appendix B

Stakeholder Input

Exhibit 1. Press Release

Exhibit 2. Newspaper Advertisement

Exhibit 3. Listening Session Agenda

Exhibit 4. Stakeholder Comments
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Exhibit 1. Press Release
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PRESS RELEASE:

Growers and Other Stakeholders Invited to Listening Session on

Federal Insurance for Crops Produced with Reduced Irrigation.

Farmers know better than most people that fresh water is a precious commodity. In some 

areas, major crops are generally irrigated, while in other areas irrigation is used primarily to 

supplement natural rainfall. Each state has unique systems for determining who gets water and 

how much they get. Throughout the United States there are areas where the amount of irrigation 

water available to producers can vary from year to year, and can be significantly impacted by 

drought. In some areas, this means less water is available for agricultural use, particularly in 

recent years.

Because some farmers are being required to use less water while others are being offered 

alternative approaches to their water allocations, production of irrigated crops is changing. 

Many producers already face reductions from their historical water use; others will in the future. 

These reductions come from a variety of reasons including reduced well capacity, compliance 

with interstate river compacts, Intensive Groundwater Use Control Areas (IGUCAs), and water 

right administration policies. The reduction in the supply of irrigation water creates challenges 

for the farmers who use the water, the organizations that manage water use, and the 

public/private sector programs that insure farmers’ yields or revenues.

As a result, the United States Department of Agriculture (USDA), Risk Management 

Agency (RMA) is evaluating how Federal Crop Insurance currently addresses producers 

intending to apply reduced irrigation. Furthermore, RMA is evaluating the feasibility of 

establishing a limited irrigation guarantee for producers who apply less water than they may have 

historically applied to their irrigated acreage. This USDA initiative has led RMA to issue a

contract to study initially the impacts of “limited irrigation” on crop insurance offers for corn and 

soybeans in select counties in Colorado, Kansas, and Nebraska. For the study, “limited 

irrigation” is defined by RMA as “a method of producing a crop by which less water is 

artificially applied during the growing season by appropriate systems and at the proper times 

than the quantity of water that was used to establish the irrigated production guarantee or amount 

of insurance on the irrigated acreage planted to the insured crop.” 

As part of the contract study, two listening sessions are being held to gather input from 

interested stakeholders. One will be in Colby, Kansas, Community Building (285 E. 5th 

Avenue) on March 13, 2013 at 9:00 AM. The second will be in Kearney, Nebraska, at the 

Buffalo County Extension Building at the Fairgrounds (1400 E. 34 Street) on March 14, 2013 at 

10:00 A.M. Grower, insurance industry, and other interested stakeholders are encouraged to 

attend and share their concerns and feedback about limited irrigation and ideas to address the 

crop insurance consequences of the changing irrigation water situation in future years.

For more information contact:

Randy Landgren

Project Manager

Watts and Associates, Inc. under contract to USDA RMA

rlandgren@wattsandassociates.com

406-252-7776
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Exhibit 2. Newspaper Advertisement

Colby Free Press 

and

The Country Advocate
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B2

ATTENTION PRODUCERS

You’re Invited 

to discuss a United States Department of Agriculture (USDA), Risk Management 

Agency (RMA) evaluation of Federal Crop Insurance for irrigated crops. RMA is 

evaluating the feasibility of establishing a limited irrigation guarantee for 

producers who apply less water than they may have historically applied to their 

irrigated acreage for corn and soybeans in select counties in Colorado, Kansas, 

and Nebraska. For the study, “limited irrigation” is defined by RMA as “a method 

of producing a crop by which less water is artificially applied during the growing 

season by appropriate systems and at the proper times than the quantity of water 

that was used to establish the irrigated production guarantee or amount of 

insurance on the irrigated acreage planted to the insured crop.” 

As part of the contract study, two listening sessions are being held

Colby, Kansas 

Community Building 

285 E. 5th Avenue 

March 13, 2013 

9:00 a.m. 

Kearney, Nebraska 

Buffalo County 

Extension Building 

1400 E. 34 Street 

March 14, 2013 

10:00 a.m.

Grower, insurance industry, and other interested stakeholders are encouraged to 

attend and share their concerns and feedback about limited irrigation and ideas 

to address the crop insurance consequences of the changing irrigation water 

situation in future years. 

For more information contact: 

Randy Landgren • Project Manager 

Watts and Associates, Inc. under contract to USDA RMA 

rlandgren@wattsandassociates.com 

406-252-7776
Feasibility Report for Insuring Irrigation

Use or disclosure of information or data Risk Management Agency

contained on this sheet is subject to the Order Number: D13PD00306

restrictions on the title page of this report.

Exhibit 3. Listening Session Agenda
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B3

Insuring Irrigation

Feasibility Study for Limited Irrigation

Listening Session Agenda

 Introductions

 Watts and Associates, Inc.

 Attendees

 Purpose

 Share Background Information 

 FCIC Insurance Feasibility Contracts

 Identify Insurance Issues Involving Managing Risk

 Gather Interest in the Concept

 W&A to make assessment of feasibility under the Act

 Feedback

 Interest

 Production Activities

 Risks/Perils

 Available Data

 Alternative Approaches

 Questions
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Exhibit 4. Stakeholder Comments (sorted by theme1)

 

1

 Comments were made by producers unless marked with an (a) to identify a comment made by a producer association 

representative, an (i) to identify a comment made by an insurance industry stakeholder. The Contractor believes many 

insurance industry representatives who made comments are also producers.
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B4

Comments addressing whether producers have knowledge of the existing crop insurance 

program:

Crop insurance is recognized as a vital tool, not [just a] valuable [tool], a vital tool for 

producers. (i)

As part of a circle you cut back on your acres and you planted that as dryland but then to 

incorporate chemicals you water that part once or twice you are going to get slapped down to 

dryland yield.

As many farmers there are in here I guarantee you that there are that many different ways to 

deal with this.

We support LEMA.

Comments addressing risk management needs:

The same situation you are dealing with [in Kansas] is what we are dealing with across the 

state line [in Colorado] and we support this type of program.

How does this reduced water affect the preventive planting program? (i)

To encourage producers to reduce irrigated acres, in order to have a full yield on a small 

subset of acres is a long ways away from the optimal most of the time. It is important to the 

grower to have a way to move away from maximize yields on less acres.

Producers have a great concern in our area because we count on surface water, we count on 

ground water, and we count on natural water and part of the biggest issue is that maybe not 

knowing what the restrictions are going to be. (i)

Cities are going to have to come into line as well as industries [regarding water conservation]. 

To make a decision on seed population and to have a successful program, at least three things 

you have to predict, to make that decision on your seed. One is the amount of water you have 

in the soil today, second thing you don’t know what the precipitation, and the third thing is 

that we don’t know how much water we are going to be able to pump because the aquifer is 

declining.

Right now we have new farmers that might have a well on the land that they just bought and 

they chose not to irrigate because they don’t quite have enough to make the county yield. So 

you aren’t even giving them a chance to do a better practice. If you are going to do a limited 

you have to do it both ways (referring to the definition of limited irrigation tied to irrigated 

only) (i)

Comments addressing willingness to participate in a crop insurance program

In corn we definitely need a limited water practice.

Insurance needs to protect that limited irrigation (i)
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B5

Producers say they would like to conserve water in their wells (i)

Comments addressing management:

One of the things we’ve seen in our practices is just because water use is reduced 20%, what 

we finding is that our yields can be just as high with 80% water.

Comments addressing potential underwriting requirements:

I got a farmer that does this; he puts two inches of water on his wheat every fall. He 

immediately takes his sprinklers and puts it on his corn the rest of the year. Is that [wheat]

irrigated or dryland? It is limited irrigation is what it is. (i)

What if 2 or 3 years down the road you built your APH up [applying water to a non-irrigated 

practice] and then you decided to not apply that limited water [to the non-irrigated crop]? (i)

Is there a number of inches of rain that need to be considered to produce an irrigated crop?

What is reasonable expectation?

Is scheduling of when regulated water [can be applied] factored in? (i)

[You] have to examine what irrigation system was used.

Depleted soil moisture is an issue to consider and how it relates to watering after harvest [to 

raise the soil moisture for the next year].

In the state of Oklahoma we don’t have meters, are you going to require them to meter their 

sprinklers? (i)

Our records and our data show that the producer’s water application is directly 

proportionate to rainfall. (i)

Comments addressing what type of risk management insurance would be appropriate for 

limited irrigation:

[The insurance should] show support for our limited irrigation [LEMA] program.

Create a monetary incentive to use less water

Who needs to have to reset [of their approved yield] when [producers] actually have better 

yields. If you are going to [adjust approved yields] you have to look at skip-row cotton and 

adjust things back. (i)

[Yield] is based on what [crop a producer] irrigates, not based on natural precipitation. That 

difference needs to be taken into consideration. (i)

Comments addressing market distortion

As an organization we are opposed to this. One, it is too complicated and it is also excluding 

sorghum. (National Sorghum Producers)
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B6

There is a big discrepancy between the t-yields for irrigated sorghum and irrigated corn it 

pushes guys to stay corn even though the water keeps dropping. (National Sorghum 

Producers)

There are sunflowers grown and milo, too.

[Limited Irrigation] still doesn’t address issues of raising corn fully irrigated for years and 

then a change in practice in this year or the next five years with this LEMA, you want to go to 

pre-watered milo, which you may have done.
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Appendix C

Documentation Tool for Written Agreements Regarding 

Limited Irrigation
Feasibility Report for Insuring Irrigation

Use or disclosure of information or data C1 Risk Management Agency

contained on this sheet is subject to the Order Number: D13PD00306

restrictions on the title page of this report.

Documentation Tool for Limited Irrigation

1. Crop Year: 10. Crop:

2. State: 11. Type:

3. County 12. Practice:

4. Producer Name: 13. FSA FN:

5. Address: 14. Tract:

6. City, ST, Zip: 15. Field:

7. Phone: 16. Unit Number:

8. SSN/EIN: 17. Legal Description:

9. Policy Number: 18. KS Well ID:

19. Year 20. Acres 21. Yield 22.

1Water

(Acre-Feet)

23. Water

(Acre-Inch)

Average

24. Rate Yield: 26. Max Intended Irrigation Current Year:

25. Approved APH Yield: 27. Irrigation System Type:

Notes:

*Please note if a well is providing water to more than one section

1

Include all available years-Please attach all hard record documentation of water use.