Analysis of Current and Potential Limited Irrigation Methods for 

United States Department of Agriculture (USDA) 

Federal Crop Insurance Corporation (FCIC) Program 

Final Research Report 

Solicitation: RFQ1396983 

July 24, 2020 

Prepared For: 

Deputy Administrator for Product Management 

USDA/RMA/Room 403 

6501 Beacon Drive 

Kansas City, MO 64133-4675 

DeputyAdministrator@rma.usda.gov 

ATTENTION: 

shawn.beach@usda.gov 

Person’s Authorized to Sign on Offeror’s Behalf: 

S. Clifton Parks 

President & CEO 

1700 Research Parkway, Suite 290 

College Station, TX 77845 

913-982-2441 (p) 

512-548-7511 (f) 

cparks@agrilogic.com 

TIN # 26-4731702 

DUNS # 830444944 

NAICS Code: 524298 
 

CONTENTS 

OVERVIEW ____________________________________________________________________ 1 

INTRODUCTION ..............................................................................................................................................................1 

BACKGROUND ON GROUNDWATER IN THE GREAT PLAINS.......................................................................................................1 

Kansas ...................................................................................................................................................................3 

Nebraska ...............................................................................................................................................................5 

Colorado................................................................................................................................................................7 

DEVELOPMENT OF THE SHERIDAN 6 LEMA .........................................................................................................................8 

LIMITED IRRIGATION CROP INSURANCE PROGRAM BACKGROUND ______________________________ 11 

EXPECTED YIELD REDUCTION METHODS............................................................................................................................13 

RMA DOCUMENTATION TOOL FOR LIMITED IRRIGATION .....................................................................................................14 

EDUCATION AND OUTREACH EFFORTS ..............................................................................................................................15 

ANALYSIS OF CURRENT PROGRAM ___________________________________________________ 17 

PROGRAM PARTICIPATION .............................................................................................................................................17 

YIELD ANALYSIS............................................................................................................................................................18 

WATER USAGE AND YIELD..............................................................................................................................................21 

PREMIUM COMPARISONS ..............................................................................................................................................25 

CONCLUSION__________________________________________________________________ 27 

ADAPTIVE LOCATION WITH INADEQUATE INCENTIVES ..........................................................................................................27 

INDISTINCTNESS DUE TO WEATHER PATTERNS ...................................................................................................................30 

UNCLEAR STANDARDS ...................................................................................................................................................32 

ADMINISTRATIVE MANAGEMENT.....................................................................................................................................33 

SUMMARY ..................................................................................................................................................................34 

RECOMMENDATIONS ____________________________________________________________ 36 

CONTINUE TO OFFER PROGRAM IN CURRENT LOCATIONS.....................................................................................................36 

ACCOUNTING FOR WEATHER AND IMPROVING YIELD CURVE ESTIMATES .................................................................................37 

ENHANCE LIMITED IRRIGATION PROGRAM PARTICIPATION THROUGH INSURED SPECIFIC ECONOMIC ASSESSMENT ..........................41 

PAPERWORK MANAGEMENT/ADMINISTRATIVE STREAMLINING .............................................................................................42 

LOCAL ADVISORY COMMITTEE EXPERTISE..........................................................................................................................45 

REFERENCES __________________________________________________________________ 47 

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APPENDIX A. LISTENING SESSION REPORT ____________________________________________ 51 

LISTENING SESSION FLYERS.............................................................................................................................................64 

LISTENING SESSION SLIDES .............................................................................................................................................68 

WEBINAR FLYER...........................................................................................................................................................77 

WEBINAR SLIDES..........................................................................................................................................................78 

APPENDIX B. LEMA DATA REVIEW_________________________________________________ 83 

YIELD DISTRIBUTION ANALYSIS ........................................................................................................................................83 

YIELD AND WATER RELATIONSHIP ANALYSIS ......................................................................................................................85 

PREMIUM ESTIMATES....................................................................................................................................................87 

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LIST OF TABLES 

TABLE 1. UNIVERSITY OF NEBRASKA–LINCOLN CORN YIELD REDUCTION TABLE BASED ON WATER USE 

CHANGES ............................................................................................................................................. 13 

TABLE 2. WATER RIGHTS DIVERSIONS ASSOCIATED WITH IRRIGATED CORN POLICIES INSURED IN 

SHERIDAN AND THOMAS COUNTIES, KANSAS, 2006 TO 2017............................................................. 22 

TABLE 3. EXAMPLE COMPARISON OF INSURANCE GUARANTEES AND PREMIUMS .................................... 30 

APPENDIX A TABLE 1. LISTENING SESSION ATTENDEES............................................................................ 52 

APPENDIX A TABLE 2. LIMITED IRRIGATION CONTACTS ........................................................................... 62 

APPENDIX A TABLE 3. LI WEBINAR REGISTRANTS.................................................................................... 63 

APPENDIX B TABLE 1. REGRESSION RESULTS OF YIELD, PRECIPITATION, AND IRRIGATION WATER 

RELATIONSHIPS.................................................................................................................................... 86 

APPENDIX B TABLE 2. INSURANCE COST ESTIMATIONS FOR YIELD PROTECTION FOR CORN IN SHERIDAN 

COUNTY, KANSAS IN 2020................................................................................................................... 87 

LIST OF FIGURES 

FIGURE 1. OGALLALA AQUIFER WATER LEVEL CHANGES, PREDEVELOPMENT TO 2015 ............................ 2 

FIGURE 5. REPUBLICAN RIVER WATER CONSERVATION DISTRICT RETIRED VERSUS ACTIVE WELLS MAP8 

FIGURE 7. NORTHWEST KANSAS GROUNDWATER MANAGEMENT DISTRICT NO. 4 HIGH PRIORITY AREAS 

FIGURE 2. ESTIMATED USABLE LIFETIME FOR THE HIGH PLAINS AQUIFER IN KANSAS .............................. 3 

FIGURE 3. GROUNDWATER MANAGEMENT DISTRICTS IN KANSAS .............................................................. 5 

FIGURE 4. NEBRASKA NATURAL RESOURCE DISTRICTS .............................................................................. 6 

FIGURE 6. ORIGINAL SHERIDAN COUNTY 6 LEMA...................................................................................... 9 

............................................................................................................................................................. 10 

FIGURE 8. EXAMPLE DISPLAY OF THE RMA DOCUMENTATION TOOL....................................................... 15 

FIGURE 9. KANSAS COUNTIES WITH WRITTEN AGREEMENT LIMITED IRRIGATION INSURABLE PRACTICES 

FOR CORN ............................................................................................................................................ 17 

FIGURE 10. KANSAS COUNTIES WITH WRITTEN AGREEMENT LIMITED IRRIGATION INSURABLE PRACTICES 

FOR SOYBEANS .................................................................................................................................... 18 

FIGURE 11. PRIOR FOUR-YEAR AVERAGE YIELDS FOR CORN POLICIES LIKELY INSURED UNDER LIMITED 

IRRIGATION WRITTEN AGREEMENTS, 2013 TO 2019........................................................................... 19 

FIGURE 12. ANNUAL AVERAGE IRRIGATED CORN YIELDS FOR SHERIDAN AND THOMAS COUNTY, KANSAS 

CONTROL AND TARGET AREAS, 2000 TO 2018.................................................................................... 20 

FIGURE 13. ANNUAL AVERAGE IRRIGATED SOYBEANS YIELDS FOR SHERIDAN AND THOMAS COUNTY, 

KANSAS CONTROL AND TARGET AREAS, 2000 TO 2018 ..................................................................... 21 

FIGURE 14. SPRING GROWING SEASON WATER AVAILABILITY FOR IRRIGATED CORN POLICYHOLDERS IN 

SHERIDAN AND THOMAS COUNTIES, KANSAS, 2008 TO 2017............................................................. 24 

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FIGURE 15. PRODUCER PREMIUM FOR 75% COVERAGE BASED ON APPROVED YIELDS FOR IRRIGATED AND 

NON-IRRIGATED CORN IN SHERIDAN COUNTY, KANSAS IN 2020....................................................... 26 

FIGURE 16. SILT SOIL CONTENT MAP......................................................................................................... 29 

FIGURE 17. TOTAL ANNUAL PRECIPITATION SHERIDAN AND THOMAS COUNTY, 2005 TO 2018............... 31 

FIGURE 18. ANNUAL WATER USE VERSUS RADER PRECIPITATION ........................................................... 32 

FIGURE 19. CROP WATER ALLOCATOR SCREENSHOT ................................................................................ 40 

APPENDIX A FIGURE 1. LISTENING SESSION LOCATIONS........................................................................... 51 

APPENDIX B FIGURE 1. ESTIMATED PROBABILITY DENSITY FUNCTIONS FOR IRRIGATED & NON-IRRIGATED 

CORN IN SHERIDAN AND THOMAS COUNTIES, KANSAS BASED ON YIELDS FROM 1988 TO 2018 ....... 84 

APPENDIX B FIGURE 2. ESTIMATED PROBABILITY DENSITY FUNCTIONS FOR IRRIGATED & NON-IRRIGATED 

CORN IN SHERIDAN AND THOMAS COUNTIES, KANSAS BASED ON YIELDS FROM 1988 TO 2012 AND 

2013 TO 2018 ....................................................................................................................................... 85 

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OVERVIEW 

INTRODUCTION 

AgriLogic Consulting, LLC (hereafter referred to as AgriLogic) has developed this report to address 

the objectives detailed in the United States Department of Agriculture (USDA) Risk Management 

Agency (RMA) Solicitation RFQ 1396983 - Research of Current and Potential Limited and 

Subsurface Irrigation Methods for USDA Crop Insurance Program. Per the requirement of the 

Food, Conservation, and Energy Act of 2018 (2018 Farm Bill): 

The contractor shall obtain program performance analysis and industry 

perceptions of the existing limited irrigation program and provide 

recommendations for improving participation. 

AgriLogic has worked with industry experts, producers, and state officials over the course of 

seven months to develop a comprehensive recommendation regarding the current and potential 

demand for the program as well as the perceived need. Notwithstanding its final 

recommendation, AgriLogic also provides strategies for RMA to consider regarding 

improvements for the program given the election of program continuance. The scope of the 

research was limited to irrigated practices related to corn and soybeans production in Kansas, 

Nebraska, and Colorado. 

This report is divided into five major sections. The first includes a background and overview on 

the landscape of water use and availability issues. It then goes into detail on specific 

circumstances in Kansas, Nebraska, and Colorado and examines the impacts of regulations. The 

second section includes a background review of the Limited Irrigation Crop Insurance Program 

followed by an analysis of the current program in the fourth section. The fifth section includes 

conclusions on the effectiveness of the current program based on four formative factors. The 

final section includes recommendations from AgriLogic regarding proposed modifications for the 

continuation of the Limited Irrigation Crop Insurance Program. 

BACKGROUND ON GROUNDWATER IN THE GREAT PLAINS 

A large portion of the Great Plains of the United States rests over one of the largest freshwater 

aquifers in the world. The Ogallala Aquifer has been a groundwater source which agricultural 

producers have relied upon for decades to ensure quality crops and good yields even in drought 

conditions. Water utilization and recharge vary tremendously in different parts of the plains. The 

aquifer covers parts of eight states and the groundwater depths, capacities, and recharge rates 

differ depending on the specific location. In general, the aquifer is thicker toward the northern 

locations, with better recharge rates that may be more easily sustained with careful management 

as demonstrated in Figure 1. 

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Continued availability of an adequate supply of irrigation water is critical to agricultural 

production in many regions dependent on the Ogallala. It is estimated that by 2050, 35% of the 

Southern High Plains region will decline to the point that irrigation will not be economically 

feasible (KGS, 2015). Some areas, particularly parts of Texas, Kansas and Colorado, already 

appear to be in that situation. An overview of the water situation and water laws in each state 

provide a framework for the subsequent research, analyses, and recommendations contained 

herein. 

Figure 1. Ogallala Aquifer Water Level Changes, Predevelopment to 2015 

Source: United States Geological Survey, 2020 

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Kansas 

It was thought for many years that the water supply from the Ogallala would continue for 

generations, possibly indefinitely. High volumes of extractions for irrigation, however, have 

caused a rapid depletion of the Ogallala water supply, and it has become apparent to many 

agricultural producers that they will not be able to rely on this water source for irrigation as they 

have in past years. While many areas are facing this issue, Western Kansas has seen some of the 

most substantial losses in water availability, with many areas decreasing in saturated thickness 

more than 60 feet. In these critical areas, researchers project a lifespan of less than 25 years. 

Note that the High Plains Aquifer, which is depicted in Figure 2, includes the Ogallala as well as 

several smaller Pleistocene and alluvial aquifers. 

Figure 2. Estimated Usable Lifetime for the High Plains Aquifer in Kansas 

Source: Kansas Geological Survey, 2015 

Most of the Kansas water rights are based on the concept of prior appropriation established by 

state legislation in 1945 (CWI, 2017). Prior to 1945, irrigators were granted vested water rights 

that are senior to any appropriation rights. Several laws have passed since 1945 that have granted 

authority to local water districts to manage the water within their boundaries. One of these laws 

authorized the formation of Locally Enhanced Management Areas (LEMAs), including Sheridan 6, 

where the pilot Limited Irrigation Crop Insurance Program was initiated. 

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Five Groundwater Management Districts (GMDs) work together along with state and federal 

agencies to locally manage their water usage and ultimately regulate the water tables in the 

aquifer. The GMDs closely monitor the current and historical fluctuations in the aquifer and how 

it responds to implemented regulations. The districts have five purposes (GMD4, 2016): 

1) Oversee conservation practices to ensure preservation of the aquifer on a local level; 

2) Act as a resource to producers in the district to better manage their water use; 

3) Contribute to the research and education effort of aquifer conservation; 

4) Work as a median between producers and government officials to adhere to the 

Groundwater Management District Act; and 

5) Manage resources in an efficient and economically beneficial approach. 

The GMDs all served as a crucial resource during the research and listening session phases of this 

review of the Limited Irrigation Crop Insurance Program. John Hildebrand, conservation specialist 

for Big Bend GMD5, was an initial subject matter expert contacted in Kansas. Based on 

recommendations made by Mr. Hildebrand, AgriLogic scheduled listening sessions in St. John 

(GMD5), Garden City (GMD3), and Colby (GMD4), Kansas. A map of the five GMD locations is 

found in Figure 3. 

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Figure 3. Groundwater Management Districts in Kansas 

Source: Kansas Department of Agriculture, 2020 

Nebraska 

Nebraska has generally had a more abundant supply of groundwater that is also aided by a faster 

recharge rate compared to Kansas and Colorado, and most counties are expected to have more 

than 200 years until depletion (Ogallala Water, 2018). Until recently, Nebraska had the most 

irrigated acres of any state in the U.S., but an irrigation survey in 2018 shows California has 

surpassed Nebraska with 8.4 million acres while Nebraska has 7.7 million irrigated acres (NASS, 

2019). Nebraska is not without its water challenges; however, the water shortage issues are 

mostly related to surface water. The worst drought in a quarter of a century was experienced in 

2012, resulting in the Nebraska Department of Natural Resources ordering 1,100 farmers to halt 

irrigation from surface water sources as the rivers from which they drew from had dropped 

significantly. This did not dramatically affect the state’s overall yields as the order did not pertain 

to well irrigation. Of the irrigated acreage in Nebraska, 90 percent pull water from wells rather 

than relying on surface water sources (Reuters, 2012). The NRD’s also play a role in Nebraska’s 

compliance with the Republican River settlement agreement between Kansas, Nebraska and 

Colorado. Nebraska’s enforcement of the interstate compact directly involves the flow of surface 

water and in other cases the indirect impact of groundwater withdrawals on stream flows 

(Republican River, 2019). 

Several legislative and governing measures were put in place in Nebraska to monitor 

groundwater use. Both the Reasonable Use Doctrine and the Correlative Rights Doctrine were 

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Colorado 

The Ogallala Aquifer underlies nearly 14 percent of Colorado in the eastern portion of the state 

(Ogallala Water, 2018). Colorado has been highly proactive in attempting to conserve 

groundwater, resulting in a state loss of an estimated 600,000 acres of irrigated farmland 

between 1996 and 2016. The state water plan estimates that Colorado could lose another 

600,000 acres of irrigated land by 2050 if the status quo of “buying and drying” irrigated land 

continues, resulting from rapidly growing urban areas buying up irrigation water. Colorado’s 

cities are paying large sums of money for irrigation water rights and leaving the previously 

irrigated land limited to dryland farming (The Fence Post, 2017). 

There are multiple groundwater laws in Colorado, with The Colorado Ground Water 

Management Act of 1965 being the most impactful. The act was critical in water regulation as it 

formed management districts that would later lead to preservation of water levels in the ground 

water basins (CDNR, 2020). Additional groundwater management has come from the Republican 

River Compact in 1942 and the Water Division Districts. 

Surface water law in Colorado falls under the Prior Appropriation Doctrine. In the early 

development of water resource for mining, Colorado needed a different system than the riparian 

system which was the most common legal principle for regulating use of water from streams. 

This approach was not effective for many situations in Colorado where the mining operations 

were not close to a stream. As a result, the Prior Appropriation Doctrine was adopted. 

The Republican River Water Conservation District (RRWCD) was created in 2004 as a result of the 

Republican River Contract. The District’s primary function is to promote conservation of 

groundwater resources by using federal programs to voluntarily retire water rights. The District 

currently has two programs in effect to assist with these efforts. The Conservation Reserve 

Enhancement Program (CREP) was established to permanently retire a well, create a grassland 

habitat, and in turn reward the producer or well-owner with an annual payment under a 15-year 

contract. The Environmental Quality Incentives Program (EQIP) works slightly differently as large 

capacity water rights used for irrigation are voluntarily retired in return for compensation 

determined by the Natural Resources Conservation Service (NRCS) and RRWCD. Figure 5 shows 

the currently active wells in blue compared to EQIP retired wells in red and CREP retired wells in 

yellow. 

Conversations with the Republican River WCD led the AgriLogic team to set up the initial listening 

session in Wray, Colorado. Due to the management structure of water use in Colorado, the team 

did not work directly with districts to host listening sessions. Instead, after speaking to water 

experts in the area, the team chose to host sessions at common producer meeting spots along 

the Kansas border where water rights have presented irrigation issues. Holyoke and Burlington, 

Colorado were the other two locations included in the listening session tour. 

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Figure 5. Republican River Water Conservation District Retired versus Active Wells Map 

Source: Republican River Water Conservation District, 2020 

DEVELOPMENT OF THE SHERIDAN 6 LEMA 

With concerns of the lifespan of the aquifer and what that could mean for future generations, 

Kansas producers came together and enacted a plan to conserve the aquifer. The Sheridan 

County 6 High Priority Area, as shown in Figure 6, is an area of 99 square miles with 28,000 acres 

of irrigated land in Sheridan and Thomas Counties where producers proposed a reduction in 

irrigation water use over a period of time. In this area, there are 110 landowners who have 

historically pumped an average of 31,000 acre-feet per year. The plan was launched in 2013 with 

an allocation of 55 inches per acre over five years (an average of 11 inches per year compared to 

being allowed to use up to 14 inches prior to LEMA). Producers were given the choice of using all 

the water allocation the first year or to spread the use out over five years. The hard number in 

the order by the Kansas Water Office was that no more than 114,000 acre-feet of water could be 

used by the entire Sheridan 6 LEMA area for the period of 2013-2017 (Barfield, 2013). This 

amount included not only water for irrigation but for other purposes as well. Across the Sheridan 

6 area, the restriction on producers was a limit of 55 inches over five years which on average 

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would be a reduction of 20 percent. From 2013 to 2017, groundwater use was actually reduced 

by 25.7 percent exceeding the initial goal of 20 percent. It is also worth noting that some 

producers had already adjusted their water use to this lower amount prior to the launch of the 

program. 

Figure 6. Original Sheridan County 6 LEMA 

Source: Kansas Department of Agriculture, 2019 

Sheridan 6 has been extended for another five years from 2018 through 2022. GMD4 has 

submitted a plan that the Chief Engineer has accepted, extending the LEMA to all parts of the 

district making it the first district-wide LEMA in Kansas. The district includes all or parts of 10 

counties and covers over 3 million acres in northwest Kansas. A goal in this formation (DWR, 

2017) was for the district: 

[t]o promote improved management of water used district-wide with a goal not to exceed 

1.7 million acre-feet (AF) for irrigation over five years within the townships displaying an 

annual decline rate for the period 2004 to 2015 of 0.5% or greater annual decline and 

promote more efficient use by non-irrigation uses. 

Different townships will have different water restrictions based on the extent of their water 

decline. The renewal of the original Sheridan 6 and its extension as a district-wide LEMA for 

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GMD4 are a testament to the strong support for water conservation in this area as well as 

validation of the LEMA concept. 

Figure 7. Northwest Kansas Groundwater Management District No. 4 High Priority Areas 

Source: USDA RMA, 2019 

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LIMITED IRRIGATION CROP INSURANCE PROGRAM 

BACKGROUND 

This section provides an overview of the Limited Irrigation Crop Insurance Program underscored 

by the previous discussion on water use and availability. The Sheridan 6 LEMA discussed above 

is one area covered by the current Limited Irrigation Crop Insurance Program. A brief discussion 

of the pilot program is provided along with current tools utilized in implementing the adjustment 

procedures. 

The inevitable outcome of the various means employed to conserve water use in aquifer 

interaction areas is that agricultural producers must limit their individual water use, either 

voluntarily or by enforced prescription. Setting aside the discussion on property rights related to 

this issue, we are left to consider the implications specific to production practices and insurance. 

Without adequate water, producers are left with two primary options to continue production of 

a given higher-water-use crop without the limited irrigation program. The first alternative is plant 

fewer irrigated acres and report remaining acreage either as prevented planting, if eligible, or 

insure it under a non-irrigated production practice. The second alternative is to plant all acres 

with limited water and insure under a non-irrigated practice. Due to the rapidly declining water 

levels and increasing water restrictions, producers impacted by actual or potential restrictions 

were concerned that they would not be able to continue eligibility for fully irrigated insurance 

coverage, and that these restrictions would negatively impact their irrigated yields. These 

producers also realized the downfalls of insuring their acreage under a non-irrigated practice— 

with lower production guarantees and higher premium rates—if the water allocation and use 

was only reduced by a fraction. As a solution, producers sought an appropriate reduction to their 

yields which recognized the water restriction limitation but allowed them to continue to insure 

such acreage as irrigated. 

Leaders in this area requested RMA to develop a new crop insurance alternative to support this 

new approach to water conservation that would provide a yield guarantee appropriate for the 

producers’ reduced level of irrigation. In the development of the pilot program, the University of 

Nebraska–Lincoln (UNL), under a cooperative agreement with RMA, modeled the potential 

reduction in yield corresponding to a given reduction in water use to help producers in Kansas, 

Colorado, and Nebraska better understand the potential trade-off between various levels of 

water allocation and usage. This model would provide estimates of potential yields to assist these 

producers in making the best crop management decisions for their farms. The model developed 

by the UNL under cooperative agreement with RMA, including its features and appropriateness, 

is reviewed and discussed in a later section of this report. 

Limited irrigation, as defined by RMA, is: 

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“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.” 

This practice was created to assist producers in complying with many of the new regulations that 

have coincided with decreasing water levels of the Ogallala Aquifer. As producers use less water, 

it was assumed that yields would drop, resulting in a lower fully irrigated Actual Production 

Histories (APHs or approved yields). The limited irrigation practice was designed to track a 

producer’s APH separately while allowing them to preserve their historical APH from their fully 

irrigated practice. By creating a limited irrigation practice, producers were allowed the flexibility 

of growing their irrigated crops within the guidelines of water usage in their area without penalty, 

outside of paying a slightly higher crop insurance premium rate associated with the lower 

approved yield. 

Beginning with the 2013 crop year, RMA issued Special Provision statements authorizing limited 

irrigation written agreements for corn and soybeans in Sheridan 6. By offering coverage through 

written agreement for these acres, RMA was able to respond to a local conservation effort in a 

proactive manner and test the limited irrigation model and actuarial appropriateness of the 

adjusted irrigated premium rate associated with the limited irrigation practice in a small sample 

area. This area was the first LEMA plan approved by the Kansas Division of Water Resources 

representing approximately 100 irrigated producers. 

RMA lists seven steps required of the producer in order to obtain limited irrigation coverage by 

written agreement if the producer has met the requirements to apply for the program. To be 

eligible, the producer must have an order to apply less irrigation water than previously used to 

sustain their APH, provide historical water use records and intended maximum level irrigation in 

gross inches on one of three types of irrigation systems (Center Pivot, Improved Gravity, or 

Gravity), and be willing to provide other pertinent information to the program. If the producer 

meets these requirements, the following steps are required to request coverage: 

1) Contact a crop insurance agent to assist with completing and submitting the application; 

2) Compile necessary documentation including but not limited to historical APH records, 

verification of previous water use, and an Actuarial Change form; 

3) Review of information by the Approved Insurance Provider (AIP); 

4) Submission of request from the AIP to the Topeka RO; 

5) Topeka RO specialists verify information and a yield and separate database are approved; 

6) The offer is sent back to the AIP for review; 

7) An offer is sent to the producer to either accept or reject (USDA, 2018). 

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RMA DOCUMENTATION TOOL FOR LIMITED IRRIGATION 

In 2016 the RMA Documentation Tool for the Limited Irrigation Crop Insurance Program was 

developed by the Kansas Geological Survey (KGS) under a sub-contract through the Kansas Water 

Office. The tool was designed to allow producers the ability to look up historical water use 

information online—free and publicly available—and calculate estimated yields based on the 

RMA yield tables developed by the UNL model. Users can access data using a water rights number 

that queries the Water Information Management and Analysis System (WIMAS) to show past 

water usage in reference to the crops planted for each year1. 

An example of the structure of the documentation tool is provided in Figure 8. Once a water 

rights number is provided, the user can view the potential types of use, producer information, 

insured crop, and system type in addition to 10 years of historical water usage collected from the 

WIMAS database which is updated daily (Wilson, 2017). In the yellow columns, producers can 

change their historical data manually if the WIMAS data does not accurately reflect one or more 

pieces of information. Column 20 is left blank and producers can then enter their historical yields 

in bushels per acre for each year. Calculated fields shown in blue are generated output. Yields 

that are entered and the resulting projections are not saved to maintain producer confidentiality. 

A producer can explore customized yield projections based on proposed water applied and 

irrigated acres. Once these are entered in Columns 22-23, the outputs of proposed water use, 

percent reduction in average water use, and expected reductions in yields are provided in 

Columns 24-28. These outputs are based on the averages of Columns 18-21 and are calculated 

using the RMA yield tables for limited irrigation applications. Once calculated, the producer can 

then enter the values into the RMA Cost Estimator to obtain a premium quote associated with 

their limited irrigation yields for specified units. This website serves as a planning tool for the 

user and provides easy access to documentation of water use for the purpose of obtaining a 

limited irrigation written agreement. 

This information can be accessed by inputting a specific water rights number at the following link: 

http://hercules kgs.ku.edu/geohydro/rma/wr lookup.cfm. 

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about the Limited Irrigation Crop Insurance Program and its goals. One of these trainings was 

held on February 14, 2017 in Garden City, Kansas covering topics that included the availability of 

the Limited Irrigation Crop Insurance Program , an economic study on impacts of conservation, 

irrigation and water technology farm updates, and regional groundwater levels (KWO, 2017). 

Despite, the readily available training documents, the impressive turnout at the 2017 listening 

sessions, and the significant amount of time at the Kansas sessions spent reviewing tool features, 

there were several agents who were unaware of the RMA Documentation Tool. These agents 

stated that had they known this tool was available they would have been more likely to 

recommend the program to their producers. It is possible that these particular agents may not 

have attended the 2017 training sessions or began selling crop insurance after these training 

sessions occurred. Regardless, it is the viewpoint of AgriLogic that a lack of education and 

outreach is not a major barrier or justification for low participation in the Limited Irrigation Crop 

Insurance Program. 

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ANALYSIS OF CURRENT PROGRAM 

PROGRAM PARTICIPATION 

Obtaining from RMA program data for the existing limited irrigation program in 

Kansas. The contractor shall analyze this data and provide the results that 

demonstrate the insurance experience and level of participation. 

Despite the offering of limited irrigation written agreements in conjunction with outreach and 

education, there has been minimal participation by producers. From 2013 through 2016, there 

were only two limited irrigation written agreements for corn each year and none for soybeans. 

Beginning with the 2017 crop year, RMA expanded the pilot program in Kansas, offering limited 

irrigation written agreements to approximately 44 counties for corn and 30 counties for soybeans 

as depicted in Figure 9 and Figure 10. These locations were selected due to perceived constituent 

interest and availability of adequate water records. Despite the expanded offerings, for 2017 and 

2018, RMA Topeka Regional Office, which governs the pilot area, received only five limited 

irrigation written agreement requests for corn each year and none for soybeans. 

Figure 9. Kansas Counties with Written Agreement Limited Irrigation Insurable Practices for Corn 

Source: USDA RMA Topeka Regional Office, 2017 

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Figure 10. Kansas Counties with Written Agreement Limited Irrigation Insurable Practices for 

Soybeans 

Source: USDA RMA Topeka Regional Office, 2017 

AgriLogic requested policy level information, including those with written agreements for limited 

irrigation, for corn in the 44 counties and soybeans in the 30 counties offering the Limited 

Irrigation Crop Insurance Program to provide an analysis as to why participation may be low. In 

an email dated November 21, 2019 from Shawn Beach, a mathematical statistician for the USDA 

RMA who spearheaded the limited irrigation project, AgriLogic was informed that RMA would 

not be able to provide information identifying which of the policies were participating in the 

limited irrigation written agreements. This was also confirmed during a monthly update call on 

April 13th, 2020. Instead, RMA provided a report of all grain policies sold in Sheridan and Thomas 

Counties from 1981-2018. These data were categorized as either “target” areas—those within 

the LEMA—or “control” areas—polices within three miles of the outer LEMA boundaries and 

within Sheridan and Thomas Counties. These did not specifically identify which had limited 

irrigation written agreements. 

YIELD ANALYSIS 

AgriLogic identified seven policies which were likely those insured under limited irrigation written 

agreements. These included six irrigated corn policies in Sheridan County and one in Thomas 

County which were insured between 2009 and 2019. These ranged from 95 to 480 acres in 

individual insured acres and totaled 1,653.5 insured acres in the 2019 commodity year. The 

associated approved yields ranged from 149 to 238 bushels per acre totaling 324,232 bushels in 

expected production for 2019. All but one policy exhibited increases in their approved yields 

from 2018 to 2019. The acre-weighted mean approved yield across all policies was 233 bushels 

per acre for 2019. The rate yield, or average yield, over the 2009 to 2018 period for almost all 

the policies was approximately equal to the approved yield. One policy, identified as Sheridan C, 

did have a rate yield that was only 54% of the approved yield. 

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Based on a comparison of the average of the yields for the prior four years beginning in 2013 and 

going through 2020, almost all policies are exhibiting constant to increasing mean yields over the 

period. As shown in Figure 11, the prior four-year mean for each policy appears to be generally 

increasing for most years except for the latter two years of Thomas A. Since 2013 marked the 

period in which irrigation water usage was to be curtailed for these policies, it might have been 

expected that yields would have trended downward to some degree, but this does not appear to 

be the case. For whatever reason or reasons, be it adjusted management practices, a change in 

planted corn varieties, a generally favorable year-to-year weather pattern, etc., it does not 

appear that irrigation limits negatively impacted actual yields over this period. 

Figure 11. Prior Four-Year Average Yields for Corn Policies Likely Insured under Limited Irrigation 

Written Agreements, 2013 to 2019 

Source: USDA RMA, 2020 

The contrast in yields between the control and target areas for corn is demonstrated in Figure 

12. Control and target yields are shown for irrigated corn in both counties. Of the yield series, 

all but the control area in Thomas County seem to vary together for the most part. Trend lines 

for the three series that tend to covary exhibit very similar year to year changes and expected 

yields. The target area in Thomas County does exhibit both a higher relative yield in 2017 and a 

lower yield in 2018. This is also the area in which yields dropped notably from 2012 to 2013 when 

the LEMA regulations were put in place. Yields in the control area in Thomas County are 

consistently higher than those for the other counties in all years but 2017. The results of 

additional analyses of insured corn production in Sheridan and Thomas Counties can be found in 

Appendix B. 

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Figure 12. Annual Average Irrigated Corn Yields for Sheridan and Thomas County, Kansas Control 

and Target Areas, 2000 to 2018 

Source: USDA RMA Insurance Experience, 2019 

As demonstrated in Figure 13, production of soybeans reached a record high for Sheridan County 

in 2018, both inside the LEMA and in the control areas. This can likely be attributed to favorable 

weather patterns discussed later in this section. No production of soybeans has been reported 

within the LEMA target area in Thomas County since 2000. When comparing target and control 

areas in Sheridan County, the linear trend lines indicate higher relative expected yields for the 

control area since the implementation of the LEMA regulations. The expected differential in 

yields between the two areas is less than 5 bushels per acre in 2018. 

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Figure 13. Annual Average Irrigated Soybeans Yields for Sheridan and Thomas County, Kansas 

Control and Target Areas, 2000 to 2018 

Source: USDA RMA Insurance Experience, 2019 

WATER USAGE AND YIELD 

RMA provided water rights information associated with specific policies in the insurance 

experience data for irrigated production in Sheridan and Thomas Counties. For certain policies, 

the policyholders or landowners’ water rights identification numbers were provided that were 

linked to the RMA Documentation Tool database. The cross references between the policy 

numbers and the water rights numbers are linked to assist in evaluating water use. The reported 

acres provided in the tool represent the water right holder’s annual acreage by crop for each 

unit. Given certain factors such as share percentage and actual final planted acres, these may 

not be equal to the acres reported in the insurance filings. It is also unclear whether producers 

consistently entered information on a single crop basis, and, if crops were aggregated, what the 

acreage breakout by crop was for each year. Regardless, the resulting database provides insight 

into the change in water diverted for irrigation over the period in which the LEMA regulations 

were enacted. 

If the policyholder data and associated water rights information are both correct and 

representative of the Sheridan area LEMA, then water used for irrigation has generally been 

declining over the last several years. The total reported water diverted that can be associated 

with crop insurance policy data is shown in Table 2. From 2006 to 2017, the total water diverted 

has exhibited a downward trend in use even though the total acres associated with the water 

rights diversions has been relatively constant. Assuming both the reported water and reported 

acres are reasonable gauges of actual water applied and actual acreage planted, then both the 

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To estimate the irrigation water applied for a given acre within the Sheridan LEMA, the RMA 

policy data was used in conjunction with RMA Documentation Tool to evaluate individual 

operation water diversion as allocated across the corresponding acres represented. Based on 

the net insured acre-weighted average of inches of irrigation water applied, it was estimated that 

mean irrigation water ranged from 3.8 inches in 2015 to 9.1 inches in 2012. These averages 

appear to be lower than those represented in other data sources in the area, but since these are 

based on the producer-entered values associated with each policy, there is no adequate stance 

on which to test questions of validity. It could be that water was not allocated across all the 

reported acres listed and/or the grower just accepted the acreage amounts that were populated 

by the documentation tool. Reporting issues notwithstanding, the average irrigation usage 

shown by these data was 7.1 inches before 2013 and 5.1 inches for 2013 to 2017. As Figure 14 

illustrates, the average total water available for 2013 to 2017 was just over 4 inches lower than 

that of the prior years due to the reduction of average precipitation and average irrigation water 

use. Irrigation water as a percent of total water available spiked in 2012 at over 46% with a low 

of 16% in 2008. Given that irrigation water applications compliment seasonal precipitation, it is 

difficult to disentangle restricted water use from the intervals of necessary irrigation 

supplementation. That stated, even with lower average precipitation, average irrigation water 

as a percent of total growing season available water did drop from 28% to 23% between the two 

periods. 

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Figure 14. Spring Growing Season Water Availability for Irrigated Corn Policyholders in Sheridan and 

Thomas Counties, Kansas, 2008 to 2017 

Source: USDA RMA, 2020; NOAA CPC, 2020 

A final analysis in the water usage and yield discussion includes the relationship between total 

seasonal available water and the net yields in each year. Despite the availability and timing of 

water, there are several factors that can influence yields on a given farm. Some have been 

mentioned in this report and can include production perils, crop varieties, growing degree days, 

management of chemical applications, etc. Regardless, it is instructive to evaluate the empirical 

relationship between estimated available water during a growing season and the resulting yields 

even if these additional factors cannot be held constant. 

In conclusion, using a combination of the RMA policy data, the RMA Documentation Tool, and 

the NOAA precipitation information, yield and precipitation data were extracted from the various 

sources and aligned. Of the available information, 354 policy-years of yield, precipitation, and 

irrigation observations were examined spanning from 2006 to 2017. A regression analysis was 

conducted on the yield observations to examine the impact of variations in precipitation and 

irrigation before and after the 2013 LEMA regulation implementation. A summary of the 

regression and brief explanation are provided in Appendix B. As expected, the most significant 

factor was annual precipitation. Even so, the pre/post 2013 comparisons yielded ambiguity when 

considering changes in average precipitation and irrigation over the two periods. Evaluating only 

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the mean yields over the respective periods, the yields for the latter period are 4.7% higher than 

the pre-2013 period. When evaluated at the average annual values for each factor, the 

precipitation, irrigation, and pre/post 2013 factors only impacted departures from the overall 

mean yield between -12 and 12%. As with other aspects of these comparisons, the conclusion is 

that the net impact of limited irrigation was difficult to separate from other yield influences. 

PREMIUM COMPARISONS 

A comparison of premium rates was conducted for insuring corn in Sheridan County, Kansas. 

Liability, total premium, and producer premium were calculated for 75% Yield Protection (YP) 

coverage on 100-acre optional unit policies of corn grown for grain. Additional premium 

calculation data are provided in Appendix B Table 2. The producer premium in dollars per acre 

as well as dollars per $100 of liability are shown in Figure 15 for a range of approved yields under 

both irrigated and non-irrigated practices. The producer premium per acre—shown by the solid 

lines—is both significantly higher and steeper moving from lower to higher approved yields for 

non-irrigated practices. The reference yield for non-irrigated production is 75 bushels, so the 

expected range of production for most non-irrigated operations is from about 37 to 111 bushels. 

The reference yield for irrigated practices is 191 bushels, and the associated expected range of 

production is from 96 to 287 bushels. The producer premium per acre for both practices is 

between $20 and 25 at the respective reference yields. 

Premiums associated with non-irrigated practices rise sharply once approved yields begin 

exceeding 100 bushels. This is partly due to the increasing value per acre associated with higher 

yields, but it is also due to the fact that the floor of the non-irrigated producer premium rate is 

around 7.2%. The maximum non-irrigated rate is about 12.7%. By way of comparison, the 

producer premium rates for irrigated practices ranges from 2.5 to 3.8%. The producer premium 

amount in dollars per $100 of liability—shown by the dashed lines in Figure 15–reflects the fact 

that there is a much wider range of possible outlays associated with non-irrigated practices 

relative to those of irrigated practices. This is due to the exponential adjustments made on the 

relative yield for each practice based on insurance experience. This non-fixed portion of the 

premium rates reflects much higher relative variability in risk associated with non-irrigated 

practices. Even across a wide range of approved yields, the change in producer premium per 

$100 of liability is less than $2. 

Without any rating adjustments or considerations of premium subsidies specifically attributable 

to potential limited irrigation practice designations, the actuarial rates associated with those 

practices would naturally fall between the irrigated and non-irrigated practice rate curves. Based 

on the Sheridan County example, it is unclear what degree of the attributes of the two respective 

curves the limited irrigation practice curve would reflect. As some of the other analyses in this 

report suggests, perhaps the rates would be very similar to those of the irrigated practices, and 

they would ultimately just be slightly higher than but parallel to the irrigated practice curve. If, 

as one might expect, the limited irrigation practice reflects a higher relative risk across the range 

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of approved yields, then the rate curve would be higher and steeper than that of the irrigation 

practice curve. 

Two of the primary insurance criteria are potentially impacted by a producer switching from a 

full irrigation to a limited irrigation practice: absolute yield and relative yield variability. Although 

not fully evidenced by some of the analyses in this report associated with comparative yields 

under reduced water usage due to several potential confounding factors, it is expected that yields 

will decline as less irrigation water is utilized. Additionally, it is expected that yields will vary 

more for limited irrigation relative to full irrigation. If a producer under a limited irrigation 

production regime has the opportunity to insure under an irrigated practice, or a potential new 

category of limited irrigation, a cost-minimizing approach would incentivize that producer to 

prefer to remain categorized as irrigated. If the approved yield would remain the same under 

either scenario but perhaps decline to some degree over the years, the rates associated with the 

limited irrigation practice would at some point increase above that of the irrigated practice. 

Considering less water use leading to lower average yields over time, a cost-minimizing producer 

would seek to keep insurance costs lower under the irrigated practice for the same value 

associated with the guarantee. 

Figure 15. Producer Premium for 75% Coverage based on Approved Yields for Irrigated and NonIrrigated Corn in Sheridan County, Kansas in 2020 

Source: USDA RMA Actuarial Information Browser, 2020 

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CONCLUSION 

Although in the context of innovative water conservation efforts, the Sheridan 6 LEMA has 

proven to be one of the most successful programs anywhere in the U.S., there is widespread 

agreement that the Limited Irrigation Crop Insurance Program offered in this area did not have 

the desired outcome in terms of producer participation and impact. Sheridan 6 was successful in 

large part because of the leadership by local producers in the innovative development of the 

LEMA framework and the strong partnership between the producers, Northwest Kansas 

Groundwater Management District 4 (GMD4), and the state of Kansas. Considering the 

cooperation that existed at the local, area, and state level, there were initially high expectations 

for the Limited Irrigation Crop Insurance Program, but in hindsight this program has not induced 

substantial producer involvement as evidenced by the lack of participation. 

AgriLogic has identified four primary factors that we believe have contributed to continued low 

participation in the Limited Irrigation Crop Insurance Program based on research, analyses, and 

discussions with industry experts. These include: 

1) Adaptive location with inadequate incentives; 

2) Indistinctness due to weather patterns; 

3) Unclear standards; and 

4) Administrative management. 

These will be discussed in detail in the subsequent sections. 

ADAPTIVE LOCATION WITH INADEQUATE INCENTIVES 

The role that producers played in developing the irrigation restrictions for Sheridan 6 led many 

of them to believe from the beginning that they could adjust to utilizing less water without 

drastically impacting their farm level economic circumstances. Dr. Bill Golden, an agricultural 

economist with Kansas State University, has been a long-time partner of the GMD4 in evaluating 

the economics of water conservation for the district. Dr. Golden predicted, that, before the 

Sheridan 6 restrictions were implemented, producers could still be successful with the new 

restrictions by adopting new technologies and changing their field-management practices 

(Walton, 2013). Dr. Golden developed a research approach to account for many of the factors at 

play for a given year by comparing planting decisions made by the Sheridan 6 producers to those 

of their neighbors over a five-year period from 2013 to 2017. His findings related to the Sheridan 

6 production area were: 

• Reduction in irrigated corn acreage by 22.9%; 

• Increase in irrigated grain sorghum acreage by 400.8%; 

• Increase in irrigated wheat acreage by 87.2%; 

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• Producer reported data for the 2013 through 2016 crop years indicate irrigated corn 

producers within the LEMA boundary (both those with and without the limited irrigation 

written agreements) used 23.1% less groundwater, while only yielding 1.2% less corn as 

compared to irrigated corn producers outside the LEMA boundary; 

• Somewhat surprisingly, irrigated corn producers within the LEMA boundary reported 

4.3% more cash flow than their higher yielding counterparts outside the LEMA; and 

• Producers that grew irrigated grain sorghum inside the LEMA boundary applied an 

average of 4.1 inches per acre, 60.5% less groundwater, yielded 13.8% less grain, but 

generated 59.9% more cash flow than their counterparts outside the LEMA (Golden, 

2018). 

An econometric estimate concluded that most of the budgetary savings were achieved through 

a reduction in the level of water use given the same cropping patterns. The study also noted 

there was a small but significant reduction in water use due to changes in cropping patterns 

(Drysdale, 2018). Mitchell Baalman, a producer in Sheridan 6, also noted the importance of notill methods and efficient use of fertilizer and seeds stating that these practices have led to LEMA 

producers being better managers and that the uncertainty of weather has caused them to 

oversee their water use differently (Water + Energy Progress, 2013). The 20% reduction in water 

available to producers, while significantly less than before the regulations were adopted, did not 

have a negative impact on yields or profits. Producers in Sheridan 6 are to be commended for 

their proactive change in farming and irrigation practices to reduce their water use and remain 

profitable compared to their neighbors who did not have the same restrictions. However, based 

on research and comments from producers, Sheridan 6 is a unique production area of Western 

Kansas due to having better soil, more ideal weather conditions, and producers who have elected 

to be proactive in their management strategies as compared with other areas of Western Kansas. 

The differences between soil profiles along with weather patterns, which will be discussed later 

in the report, are two factors that can lend to relatively stable producer yields in the LEMA. 

Different soil types have been credited with varying yields and water use efficiency based on each 

soil’s water and nutrient holding capacities. In general, non-sandy soils can vary from medium to 

fine texture and allow for greater water holding capacities, allowing plant roots to pull water for 

a longer period. In comparison, sandy soils lose much of their water to gravitational pull resulting 

in a lower field capacity. In the map overlay shown in Figure 16, yellow areas mark greater than 

60% silt content areas while dark blue areas exhibit high sand content areas. Sheridan and 

Thomas Counties have a relatively high silt and clay content, while Finney and Kearny Counties 

have the highest concentration of sandy soils in Western Kansas. These latter two counties 

exhibit some of the lowest water holding capacities in the state. 

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Figure 18. Annual Water Use Versus Rader Precipitation 

Source: Kansas Geological Survey, 2018 

UNCLEAR STANDARDS 

Extensive rules and regulations for the limited irrigation practice were developed by RMA. There 

has, however, been some difficulty in the interpretation and implementation of these procedures 

for every situation. Irrigation guidelines are recorded in the Document and Supplemental 

Standards Handbook (FCIC, 2020) that states: 

It is important that these guidelines be utilized to document whether, at the time insurances 

attaches, there is a reasonable expectation of receiving adequate water to carry out a good 

irrigation practice for acreage reported under the irrigated practice. 

Selected definitions include: 

• Good Irrigation Practice: “The application of adequate water in an acceptable manner, at 

proper times, to allow production of a normal crop which is often identified as the 

approved APH yield for crops.” 

• Reasonable Expectation of Adequate Water: “The insured had no reason to know at the 

time coverage began the amount of irrigation may be limited or reduced. No reasonable 

expectation exists if the insured knew, or had reason to know, the amount of irrigation 

water may be reduced before coverage begins.” 

• Determination of Reasonable Expectation of Adequate Water: “Factors to be considered 

(applicable to both the AIP and the insured) when determining and documenting whether 

a reasonable expectation of adequate water existed include, but are not limited to the 

following: Most recent 10-year historical average of available water and any applicable 

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forecasting data from a credible authority responsible for monitoring and forecasting 

such conditions such as Irrigation Districts...” 

• Failure to Qualify or Carry Out a Good Irrigation Practice: “If the acreage fails to qualify 

for insurance under the irrigated practice, it will result in such acreage being insured 

under a practice other than irrigated. If no other practice is available for the acreage, 

insurance will not be considered to have attached on the acreage.” 

Similarly, for limited irrigation, RMA documentation implies that in order to meet limited 

irrigation practice guidelines, “a producer has to have enough water to deliver the right amount 

of water at the right time to produce the yields on which the agreement is written” (RMA, 2018). 

However, this does not specify what qualifier must be met for the producer to meet limited 

irrigation requirements in the first year in which he/she is moving from a fully irrigated practice 

to the limited irrigation practice. It only specifies how to maintain the threshold once the limited 

irrigation practice is being participated in. 

Since the pilot program did not include a specific threshold or criteria when a producer would be 

ineligible to receive coverage as fully irrigated, it is possible that some producers in Sheridan 6 

may have continued with a fully irrigated policy when they should have seriously considered the 

option of a limited irrigation practice. As a result, their irrigated practice yields for the specific 

insurance units are already reflective of the limited water availability to a significant degree since 

the decline has been gradual over an extended period. Current irrigation guidelines place a strong 

emphasis on past irrigation history and consider forecasts of water conditions by credible 

authorities, but the application of interpretations of this can vary (even between an insured’s 

wells providing water to an insured unit). The concern is that current guidelines may allow 

producers with a more rapidly declining APH yield (because of reduced water) to continue with 

a fully irrigated practice when that may not be appropriate depending on the water situation. A 

more definitive procedure in implementing the limited irrigation practice requirements would be 

of value in making it more transparent to insureds as to when they should convert from a fully to 

a limited irrigation practice. However, the ultimate driver we believe should be on the economics 

of optimizing the long-term financial stability of their operation. 

ADMINISTRATIVE MANAGEMENT 

According to comments made at listening sessions, paperwork and bookkeeping, specifically the 

written agreement process, while not the only culprit, may have been another factor contributing 

to fewer producers and their agents taking advantage of the Limited Irrigation Crop Insurance 

Program. Written agreements require additional steps and paperwork, hence additional 

administrative burden, for both the producer and the agent. In conclusion, while the written 

agreement process in and of itself is not likely a major hindrance to program participation, 

AgriLogic would surmise that when considered in addition to the other grounds listed above, it 

does seem to be a contributing factor to the overall lack of participation. Several strategies for 

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RMA to consider, which could result in potential increased efficiency and minimized 

administrative tasks in this area, are provided in the Recommendation section of this report. 

SUMMARY 

Although the program offering has not had the desired outcome does not mean it is impossible 

to design a program that will be effective for producers. Crop insurance is not normally thought 

of as a tool for water conservation, but crop insurance policies do impact producers’ decisions 

about water management. The biggest overall issues with crop insurance as it relates to irrigation 

is the lack of a policy that meets the needs of producers who do not have the capacity to meet 

the requirements of a fully irrigated policy but are in a position to apply some level of irrigation 

water. Although producers’ water resources may be limited, they are likely in a far better 

situation in terms of potential yields and production risks than non-irrigated producers. This 

situation is the reason that the Limited Irrigation Crop Insurance Program was developed initially 

and continues to be a valid need especially in areas where water is becoming more limited. 

To survive and be competitive in today’s agricultural environment, producers are required to use 

a higher level of management and conservation of all resources than ever before including water 

resources. State and federal government entities are placing an ever-increasing emphasis on 

developing programs and policies that support and incentivize water conservation. Crop 

insurance greatly impacts producer behavior in terms of the conservation and management of 

water resources. The issues around irrigation and crop insurance are only going to grow in 

importance and it is increasingly important that RMA continue to develop an irrigation policy for 

the new realities of agriculture including being an integral part of developing tools that meet the 

new and emerging challenges in water resource management. 

The objective and strategy behind the Limited Irrigation Crop Insurance Program were obviously 

a great step forward in recognizing the need to contribute to the sustained water levels of the 

Ogallala Aquifer and the success of farmers as they transition into a reduced water supply and 

greater restrictions on water use, both now and in the future. However, more than minor changes 

are needed in order to have a viable option for producers who find themselves in a mandatory 

or voluntary reduced water situation. Important lessons can be learned from the existing 

program and will contribute to the design of the recommended program modifications provided. 

Among the provisions that should be considered and continued are: 

1) Limited irrigation should be established and maintained as a separate practice. 

Requirements should consider the different water requirements applicable for different 

crops as previously noted as well as the yield model discussed in the Recommendations 

section of the report. Producers would be required to keep a separate APH data base for 

their limited irrigation practice. Also, several years of insurance experience would be 

valuable in determining what modifications may be needed in the program. Improving 

the program over time will require monitoring of the program and input from the advisory 

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committee of producers and others. In addition to the APH for limited irrigation practice 

a producer may also have some acreage insured as fully irrigated. As an example, a 

producer may plant fewer acres at a specific location, permitting insurance as a fully 

irrigated practice. In cases such as this, the producer would need to maintain separate 

APH databases for each practice. 

2) Written Agreements have received considerable push back, but this process also has 

important advantages, primarily potential flexibility in providing an insurance offering 

tailored to the needs of an individual producer. For instance, some producers may be able 

to demonstrate their ability to exceed the standard output from the model and perhaps 

that could be considered. Factors that influence a producer’s ability to utilize water are 

unique for each farm and also vary from year to year. These variables include the soil 

characteristics (water holding capacity), variety differences (response to water or lack of), 

tillage practices (cover crops and reduced tillage), irrigation system (pivot or subsurface 

drip) and producers’ expertise with technology for water management including tools for 

monitoring plant stress, soil moisture, remote control of irrigation, and irrigation 

scheduling tools. Until such time as there is enough experience and participation in a 

program, it would be difficult to publish limited irrigation as a standard practice, although 

this would be the ultimate goal. In the meantime, written agreements should be utilized 

to allow flexibility in the program. 

The following are specific examples why it is advisable for RMA to continue offering an effective 

program for scenarios in which producers have limited irrigation. 

1) Producer Interest - Producers and insurance agents at the listening sessions suggested 

that some type of Limited Irrigation Crop Insurance Program should be available because 

the water supply issues, particularly for the Ogallala Aquifer are only going to become 

more severe in the future. 

2) Need - In addition to the Kansas Water Office and the Kansas Department of Agriculture, 

several water districts have indicated a need for this type of program. As an example, the 

Southwest Kansas Groundwater Management District 3 (GMD3) stated in the latest draft 

of their groundwater management program: “Risk management is a key influence of the 

farm bill on the district groundwater program activities. Input and potential partnerships 

with RMA and others will be encouraged to further develop useful risk management 

products for limited irrigation and supported to limit unnecessary irrigation in declining 

groundwater areas.” (Revised Groundwater Management Program, Southwest Kansas 

GMD No. 3, draft on February 2020) 

3) Flexible Insurance Offering - Current insurance programs only offer actuarial options for 

irrigated and non-irrigated policies. There is a definite need for an in-between policy 

option for areas facing a declining and limited water supply for irrigation. 

4) Collaborative Support - The state water plan for Kansas has as one of its statewide action 

items to address crop insurance policies, such as limited irrigation, that support water 

conservation goals. 

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RECOMMENDATIONS 

Based on the findings of this study, it is AgriLogic’s recommendation that RMA continue its 

Limited Irrigation Crop Insurance Program with the following redesign to better suit producers in 

western Kansas on a pilot basis. For the purposes of this report the “refined pilot program” refers 

to the recommended changes that would be implemented to increase participation in these 

areas. It should be mentioned that these recommendations are made with a proactive stance as 

you will not likely see a broader adoption until more severe regulatory restrictions or 

environmental conditions are observed in the future. The redesigned program, at least for the 

near term, should continue to focus on groundwater and include these components: 

1) Continue to offer program in current locations; 

2) Accounting for weather and improving yield curve estimates; 

3) Enhance participation through insured specific economic assessments; 

4) Improved administrative management; and 

5) Formation of local advisory committees for industry expertise. 

CONTINUE TO OFFER PROGRAM IN CURRENT LOCATIONS 

We recommend the pilot program continue to be offered in the existing locations, but with the 

refined methodology discussed in this report. Due to the significant value that the concept has 

for specific circumstances along with the extensive overall investment already made in 

implementing it, we believe it can be a useful tool for the future if the suggested enhancements 

are adopted. An expansion beyond Western Kansas is not recommended at this time until 

modifications are implemented that lead to a broader adoption in the area(s) for which it is best 

suited. In other words, location choice is the most critical aspect to review before considering 

expansion of the concept. 

The current pilot program encompasses the area with the most extensive database of historical 

water use on the insurable unit level of any state in the region, with an emphasis on ground water 

as the primary irrigation water source. However, the Sheridan 6 area may not have been the most 

indicative of the true value of the program due to the soils in that area that exhibit a stronger 

water holding capacity than many other areas in the pilot. Favorable weather patterns in recent 

years for the area, coupled with many insureds in the broader crop insurance program taking a 

more proactive approach in advanced irrigation management techniques, have led to more water 

efficient operations. Due to the insureds being more water efficient, they have still been able to 

achieve yields comparable to their irrigated production practice history since the program was 

introduced. Hence, the Limited Irrigation Program has not been as broadly adopted as 

anticipated when it was developed. This does not indicate that there will not be a future need 

for the program in this area or that it has not been benefited participants in its current form. 

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Not all producers are interested in a Limited Irrigation Crop Insurance Program, but promoting 

refinements to it, if adopted by USDA, can result a very valuable tool to insureds in areas where 

it is feasible to effectively operate. Producers who serve as board members of water conservation 

districts need to be involved in the implementation process, because producer interest and 

support for the concept will be essential in moving forward with any program modifications. 

Support and interest by irrigation districts should be considered in implementation as well. GMD4 

remains involved in assisting with the program and GMD3 has expressed interest in helping test 

such recommendations as well. 

In addition to potential interest, there are several conditions related to the water supply situation 

that would be important to consider for implementing changes. Areas that are experiencing a 

significant decline of the water table with irrigation districts considering restrictions on water use 

are more likely to have stronger participation in the program with the recommended changes. 

Many producers are aware they are on a path to eventual dryland production unless usage is 

based on available water supplies, alternative crops, and more intensive crop production on 

fewer acres and monitored irrigation practices. Areas that already have local water restrictions 

in place are not necessarily essential to program success but may be considered the most 

opportunistic as the program is being refined and tested. 

In the future, if a refined program is significantly adopted by insureds and it performs well from 

an actuarial perspective, it could be considered for expansion into other areas of Kansas and 

other states. Nebraska and Colorado, for example, as compared to Kansas, generally rely more 

on surface water as a source for irrigation. Surface water has some special challenges from a crop 

insurance standpoint. This is primarily due to the greater degree of uncertainty from one year to 

the next compared to groundwater. River flows and timing are less predictable than ground 

water resources. 

ACCOUNTING FOR WEATHER AND IMPROVING YIELD CURVE ESTIMATES 

There are serious questions about the premise of using any model to make a final determination 

about crop insurance coverage for a producer. Models are projections based on the data supplied 

to the model. The UNL Yield Adjustment Table raises concerns as to its appropriateness for 

several reasons. To accurately reflect current local conditions, water yield models need to 

consider a larger number of variables that are at best challenging to model. According to a review, 

drastic variances occurred in the Garden City, Kansas area due to seasonal changes, changes in 

evaporative demand, and cultural practices (Rudnick et al., 2017). 

In 2013 RMA contracted with Watts and Associates to conduct a Limited Irrigation Feasibility 

Study. This study focused on several issues with the UNL model and the crop production functions 

were discussed. Below are the major issues that were identified in the report: 

• Data for limited irrigation was not abundant at the time and relied mostly on trial plots 

that do not reflect the current situation; 

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• Management practices and precision agriculture strategies were not considered; and 

• Producers did not agree with the model (Watts, 2013). 

In addition to this study, Jonathan Aguilar, a Kansas State University engineer at Garden City, also 

noted that the UNL model does not consider differences in soil type or seasonal moisture and 

the production curve can vary greatly for a dry versus wet year. The UNL model only accounts for 

three irrigation methods and as water availability continues to decline new methods should be 

taken into consideration. 

Finally, RMA’s attempts to work with the model development team to reconcile these issues have 

not been successful and the model continues to function as originally designed without updates 

or improvements that are likely needed to ensure credibility and maximum benefit. It is 

AgriLogic’s understanding that the model is no longer being updated and that the creators may 

no longer be functioning in the same career capacity as when it was developed. Summarily, the 

UNL model was a good first step as a tool for a Limited Irrigation Crop Insurance Program ; 

however, for it to be truly reflective of the situation in Kansas and for producers to trust the 

model, it must account for these additional factors that contribute to yield curve formulation. 

Several models like the UNL model attempt to develop production functions for a large area, but 

the actual production functions can vary drastically within a small area. Factors impacting the 

production function include soil characteristics, use of cover crops and other farming practices, 

as well as the response of different varieties to water. While it is not easy to develop an accurate 

production function, they have the potential to be more accurate if developed for a specific area. 

The Crop Water Allocator (CWA) model developed by Jonathan Aguilar uses the Kansas Water 

Budget (KSWB) and considers additional crops common in western Kansas, crop rotations, soil 

water availability, and irrigation efficiencies. The use of the KSWB is highly regarded by experts 

as it uses average daily values from 30 years of in-depth weather data that tracks changes in 

climate, including maximum and minimum air temperature, solar radiation, and precipitation 

(Drysdale, 2020). Conversations with the Kansas Water Office and Kansas State University 

personnel indicated that multiple datasets were used to create a 30-year baseline that the KSWB 

was created from. This baseline is also used as a comparison when evaluating climate data. The 

model not only includes the water production function, but it also covers more crops than the 

UNL model and accounts for variations in soil type where the UNL model does not. Using land 

split and water allocation to each crop, the CWA can calculate the net economic return, helping 

producers make the best decisions for crop management. The tool uses data field location, 

irrigation, crop information, price per unit and yield per acre to calculate outputs as seen in Figure 

19. 

The Irrigation Application Efficiency allows the user to determine the actual water amount being 

distributed into the soil, rather than just the amount pumped. While efficiencies vary, this 

variable accounts for an infinite number of irrigation methods and can easily be updated as new 

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and more efficient methods become available. The CWA also accounts for maximum yield 

adjustments using the following equation: 

Yiu = Yic (Ymu)/(Ymc) 

where 

Yiu = incremental adjusted yield for user yield-irrigation relationship; 

Yic = incremental yield-irrigation relationship from Crop Water Allocator (CWA); 

Ymu = user entered maximum yield; and 

Ymc = maximum yield for CWA yield-irrigation relationship. 

When using the tool, the field, location, and irrigation information are input first. Crop prices and 

maximum yield per acre should reflect the historical information collected for the specific area 

and irrigation data used. While the tool is specifically designed to be an economic decisionmaking tool for producers, the model offers potential for use as the basis of a new Limited 

Irrigation Crop Insurance Program model due to its use of the KSWB and careful consideration of 

irrigation events applied to annual precipitation. Not only will the model assist in allowing RMA 

to develop a more effective program but use of the tool itself will help producers make the best 

water efficiency decisions to help sustain the aquifer, and their livelihood in general. 

AgriLogic has concluded that the CWA tool has the potential to be very useful in the proposed 

pilot program. However, it should be taken into consideration that updates and/or modifications 

would still be necessary before incorporating the model in a refined pilot program. For example, 

it needs to be updated with yield data representative of the newer varieties of corn and other 

crops as well as performing a test of the model under different precipitation and irrigation 

conditions in the pilot area(s). High level models such as this are more accurate when developed 

using data for a specific area. The developer, Jonathan Aguilar, is located at the Garden City 

Kansas State University research and extension center and has indicated via phone call a strong 

interest in working on modifying the model as a tool for Limited Irrigation Crop Insurance 

Program. Additional personnel recommended for further modifications of the model are 

Agricultural Engineers Allen Schlegel and Dr. Freddie Lamm, as well as economists Bill Golden and 

Dan O’Brien. 

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Figure 19. Crop Water Allocator Screenshot 

Source: KSU Research & Extension Mobile Irrigation Lab, 2014 

However, if RMA chooses to continue to utilize the UNL model—or while a new model is being 

selected and refined—AgriLogic would ask RMA to consider the modified version of the Deficit 

Irrigation Template developed by AgriLogic during completion of this project. In lieu of the 

current format, which uses a lookup table, the modified format allows the producer to enter the 

state, county, crop, irrigation system, historical water use, and water use reduction. This 

template could be maintained as a database and updated annually. The spreadsheet was 

designed to produce a one-to-one relationship between the “RMA Deficit Irrigation Template -

Final_.xlsx” results and those in the revised version. Both result in no (or, more precisely, “N/A” 

or not available) estimated reduction in yield. If the database were to be maintained with 

numeric fields for the indicated variables, then these would be placeholder values for locations 

and crops in which one crop (e.g. corn) was available for estimation but the other included crops 

(e.g. soybean) produce no recommendation. If it is preferred to completely exclude location and 

crops for which yield reductions are not estimable, then these could be removed from the 

spreadsheet. The revised template is being submitted as a separate Excel file with this report 

submission. 

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ENHANCE LIMITED IRRIGATION PROGRAM PARTICIPATION THROUGH INSURED SPECIFIC 

ECONOMIC ASSESSMENT 

Providing recommendations to encourage producers to carry out limited, 

reduced, and water conservation practices. 

The most effective way to increase producer participation in the program is to provide an 

incentive for them to do so. Under the current program, there is essentially a disincentive for 

producers to participate. If a producer chooses to participate, the yield guarantee will be reduced 

in addition to paying a slightly higher premium rate for the insured liability. Two things are 

required to provide a positive incentive for participation: 

1) The (state and or local water) entity regulating water use must first decide whether to 

reduce the amount of water available to producers; and 

2) There must be an economic incentive for the producer to participate. 

The mindset of producers needs to change from maximizing yield to maximizing long-term 

profitability. This equates to water-use-efficiency in preserving and enhancing their properties’ 

long-term economic values. The Kansas State University Research and Extension Service Crop 

Water Allocator (CWA) is a valuable tool in demonstrating to insureds that a reduced water 

utilization may lead to enhanced profitability and moderated risk for their operation. It assists 

producers in analyzing the most profitable allocation of water among various cropping decisions. 

This is an area in which university extension personnel could fill a valuable role in educating 

insureds. 

A common example that producers in Western Kansas are facing today is the selection of crops 

for optimal profitability. Producers must decide if they should change the crop selection to a 

more water efficient alternative, continue to grow the crop with a higher water requirement 

under a more limited irrigation methodology (e.g. deficient irrigation), or grow the crop on 

reduced acreage. This will likely lead to lower yield expectations while optimizing expected 

profitability, which could be an excellent fit for the limited irrigation production practice. The 

optimum choice will vary between insureds and potentially from year to year depending on 

current and expected environmental conditions and commodity prices. While the solution to this 

issue will not be the same for every producer, a limited irrigation option should be available for 

those in the areas with serious water limitations. If the insurance program offerings are restricted 

to solely non-irrigated or fully irrigated production practices, it will miss a significant portion of 

the insureds’ optimal strategies for long-term financial stability. 

The extent of producer participation in this program will depend on the accuracy of the 

production yield curve model, the current and expected weather pattern for a particular year, 

and the effectiveness of the education and outreach on the refined offering. Crop insurance is 

not the only factor in a producer’s decision, but a limited irrigation option could provide a 

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valuable tool to those insureds whose optimum profitability model is best suited to a limited 

irrigation practice. 

As previously described, guidelines regarding what constitutes a limited irrigation practice 

continue to be vague and, in some cases, vary between producers. While AgriLogic recognizes 

that the current definition of limited irrigation is anything less than what constitutes fully 

irrigated, having a defined set of procedures that the GMD Board could follow in providing 

recommendations for thresholds in their region would provide more transparency to insureds as 

to when they should be converting from a fully to a limited irrigation production practice. 

PAPERWORK MANAGEMENT/ADMINISTRATIVE STREAMLINING 

Written agreements have the advantage of the flexibility needed initially for implementation of 

the refined pilot program in order to adequately recognize unique and enhanced characteristics 

for individual producers. The goal should be to make the written agreement process as 

streamlined as possible. RMA and the RMA regional office would be responsible for developing 

the applicable written agreement requirements and approval standards. The RMA regional office 

and AIP would be responsible for administering the written agreement process. 

If it is the goal of RMA to eventually get to a point where a standard limited irrigation practice 

can be published in the actuarial documents, RMA will need to develop on its own or in 

conjunction with NASS a limited irrigation yield series similar to the yield series for other crops in 

the target areas and used to establish insured practices. At this time, this seems possible only if 

RMA proxies off the existing irrigated yield series for the areas where a limited irrigation practice 

would be offered. If, on the other hand, the goal is to establish a standard protocol to establish 

APH yields specific to limited irrigations practices, then an extended period of continued written 

agreements is needed. If a proxied-limited irrigated yield series derived from modeling or other 

means is not acceptable, the yields reported under the pilot over time would be the primary 

means to develop a relevant applicable yield series that could be utilized for both individual 

producers and those within the same LEMA. 

Developing web-based applications, in consultation with RMA, to streamline access to 

coverage for producers electing to conserve water use on irrigated crops. 

AgriLogic sought clarification on what was expected to fulfill the task order requirements 

pertaining to this item and received the following response from RMA on March 10, 2020: 

“There isn’t anything needed to build from the ground up. However, the report 

could have suggestions on how to incorporate any suggestions or improvements 

into the cost estimator for limited irrigation. Given the RMA documentation tool 

created through the Kansas Water Office grant, maybe suggestion on whether this 

needs to be in the cost estimator. The yield curves were established for CO, KS, and 

NE. As for OK and TX, would there be enough information to establish yield curves 

for those areas, along with water use (i.e. meters) data?” 

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According to RMA, the cost estimator for limited irrigation written agreements is the same cost 

estimator used for all other insurance programs, located on the RMA website4. AgriLogic began 

by understanding the interaction between limited irrigation written agreements and the cost 

estimator. 

The information that is input into the cost estimator would reflect all the typical information 

required to generate a quote for an irrigated practice, with the primary difference being the entry 

of the ‘expected yield’ calculated from the RMA Documentation Tool (Column 27) being used in 

place of the ‘approved yield’ and ‘rate yield’. RMA stated that the reference yield and rating 

factors are the same for the limited irrigation quotes as they are for irrigated quotes. It was 

further explained that no additional yield adjustments (e.g. TA, YA, YC) apply to the limited 

irrigation quotes. AgriLogic has noted that this is a negative benefit to the producer, since the 

producer will not be able to get the same benefit on his/her limited irrigation policy as would be 

available on irrigated or non-irrigated policies in the event of a zero yield, etc. In fact, in an 

extreme scenario, a non-irrigated yield could be as high as the limited irrigation approved yield 

due to the exclusion of this adjustment procedure; this protocol may need to be reconsidered by 

RMA. 

The resulting expected yield (e.g. 168 bu/ac) generated from the RMA Documentation Tool, 

based on a single amount of ‘proposed water applied’ (e.g. 11 inches) will establish the limited 

irrigation T-yield for the first four years of the new database, which will be updated annually 

going forward with the producers’ actual limited irrigation yields replacing the T-yields as they 

are made known. There is no option for the producer to enter multiple years of varying water 

reduction levels (e.g. stepwise water reduction for multiple years) into the decision tool at this 

time; in other words, the reduction in water is assumed to be a one-time change that will level 

off and remain constant until actual yields replace T-yields. RMA stated that if continuing water 

restrictions required an even more reduced yield estimate (and associated T-yields), a separate 

database would need to be established to maintain that data. In summary, at first glance, there 

does not appear to be an opportunity at this time to ‘streamline’ the cost estimator for limited 

irrigation written agreement policies and AgriLogic believes that the cost estimator and resulting 

premium quotes are functioning at the most efficient level possible, considering the way the 

policies have been designed. 

AgriLogic then sought to review the RMA Documentation Tool itself. The tool is user-friendly and 

self-explanatory with the exception of several fields. For example, Column 20 (Yield), has the 

following parenthetical which should be removed based on discussions with RMA: “(After trend, 

substitution, exclusion, as applicable)”. According to RMA, the information entered in this 

column should be the ‘actual yields’ harvested by the producer, not the ‘adjusted yields’ as the 

parenthetical implies. The deletion of this language, in addition to built-in instructions clarifying 

4 https://ewebapp rma.usda.gov/apps/costestimator/Estimates/DetailedEstimate.aspx 

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what the user should enter in varying input fields would greatly reduce the level of confusion 

(albeit minor) that currently exists. 

RMA has been making improvements to the Written Agreement process for several years now, 

with the goal of developing a more electronic process for the agreements through a SharePoint 

portal between RMA and AIPs. There are some additional considerations included in the list 

below that RMA should consider to ensure that the application process for a limited irrigation 

written agreement is as simple as possible, and does not cause undue administrative burden on 

producers who have already been insured under a fully irrigated policy on the same acreage in 

the past. The steps required of a producer in order to obtain a limited irrigation written 

agreement, while not complicated once the process is known, are somewhat piecemeal and 

require multiple manual steps including the use of several different tools and websites. It is 

assumed that the process is a joint effort between the producer and his/her agent, but that much 

of the administrative responsibility falls on the agent. The items required include: 

1) A completed request for Actuarial Change form; 

This should be combined with the Documentation Tool for Limited Irrigation in a prefillable web-based form that can be printed and signed. 

2) A complete APH; 

RMA should already have access to this information assuming the producer has 

participated in another insurance program previously for the same crop and county. AIPs 

are required to transmit yield data on P15/15A records through PASS so RMA is able to 

validate the APH used in establishing producer coverage. However, this could also be 

included with the completed application packet as well. 

3) The legal description of the land and FSA aerial photographs of legible maps delineating 

field boundaries where the applicant intends to plant the crop for which insurance is 

requested; 

Producers must transmit ground covered by CLU (common land unit) designation. While 

not photographic, CLUs do represent geographic boundaries of fields established by FSA 

and used by producers to report acreage. CLUs are already used under other insurance 

plans, so should not be an issue to include in this program. However, this could also be 

included with the completed application packet as well. 

4) Local Enhanced Management Area (LEMA) order from the Chief Engineer or delegate; 

This will continue to be provided by the producer as part of the application. 

5) A completed “Documentation Tool for Limited Irrigation”; 

AgriLogic would propose that this form (Excel/PDF) be combined with the Request for 

Actuarial Change and the water use records in a pre-fillable web-based form that can be 

printed and signed; and 

6) Hard copy documents verifying water use. 

AgriLogic is unaware if the water use information being pre-populated into the RMA 

Documentation Tool is considered ‘verifiable records’. The information is provided from 

the Kansas Department of Agriculture via the WIMAS to the Kansas Water Office. If so, 

integrating this water use history into the pre-fillable web-based form described in items 

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1 and 5 would satisfy this requirement and remove another step, further simplifying the 

process. 

If RMA could access Items 2 and 3 from its internal databases for the applicant, and Items 1, 5 

and 6 could integrated into a single pre-fillable web-based form, then regardless of who 

completes the necessary documentation, a significant amount of administrative burden could be 

mitigated. With minimal modification, the Documentation Tool in this way could become not 

only a decision tool, but also an ‘Electronic Written Agreement Application’ for potential limited 

irrigation policies. 

LOCAL ADVISORY COMMITTEE EXPERTISE 

The importance of utilizing local knowledge and expertise for limited irrigation requires that RMA 

make extensive use of an advisory committee in any pilot effort. For multiple reasons the Limited 

Irrigation Crop Insurance Program in Sheridan 6 lacked support from the producers in the area 

as evidenced by their lack of participation. The creation of an advisory committee will help 

develop more “local buy-in” for the next pilot effort. The initial advisory committee and RMA 

would need to agree on the final design of the refined pilot program based on the previously 

recommended criteria. 

Individual irrigation districts were established by the state to apply state water laws and federal 

programs to fit the groundwater needs and conditions of their local area. Due to the variation in 

weather patterns, soil types, and regulations between these districts, it is difficult to offer a broad 

program that accurately addresses a specific region’s needs. An active advisory committee for 

the locality would be an important tool to ensure a Limited Irrigation Crop Insurance Program is 

appropriately designed to meet the needs of a local area. 

The initial advisory committee should include representatives of producer organizations 

including the Kansas Corn Growers, state water/irrigation scientists with Kansas State University, 

Kansas Water Office and the RMA (including at least one representative from the Topeka 

Regional Office). After the pilot area is selected, several local stakeholders should be added to 

the advisory committee including staff of irrigation districts, producers (potentially irrigation 

district board members), and local irrigation and agronomic experts. Some of the specific 

responsibilities of the advisory committee would include: 

1) Develop the overall design for the refined pilot program in their area; 

2) Establish a process to review and recommend changes to the CWA model (or a similar 

model if this model is not selected); 

3) For the pilot area, the advisory committee should recommend the scope and structure of 

the training and outreach program for the pilot area. An effective education and outreach 

program will be essential for the successful implementation of the program. 

4) The advisory committee should meet at least annually after the program is launched to 

continue to monitor, evaluate and potentially make adjustment to the program as 

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frequently as once a year. Producers and other stakeholders on the advisory committee 

need to know that they will have an important role in making this program work. 

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