Land Core Submits Comments to USDA and FCIC on Expanding Access to Risk Protection (EARP) Rule
Image Credit: Benjamin Lehman, Unsplash
Submitted to: USDA Under Secretary for Farm Production and Conservation, Richard Fordyce; the United States Department of Agriculture (USDA), and the Federal Crop Insurance Corporation (FCIC)
Re: Request for Public Comment on the Expanding Access to Risk Protection (EARP) Rule
Date: January 27, 2026
“We commend FCIC for expanding eligibility through the EARP Rule and encourage continued efforts to make crop insurance resources accessible to all producers. We appreciate the opportunity to provide these recommendations and stand ready to support FCIC in strengthening risk management tools that serve farmers nationwide. Land Core believes that federal crop insurance is a cornerstone of a modern agricultural economy and the farm safety net. By shifting incentive structures, farmers can build resilience, taxpayer costs can be reduced, and we can realign financial incentives with land management practices that protect both farm profitability and our nation's food and national security.”
Comment Highlights:
Prevented Planting Eligibility (Section II.D)
Land Core supports modernizing prevented planting eligibility and commends the removal of the previously insured requirement, as a path to improving access for beginning and small farmers and those adopting diversified soil-building systems. Additionally, we urge USDA to recognize that cover crops and other soil health practices directly reduce the impact of drought and excess moisture hazards, not only in guidance from NRCS, but in actuarial assessments at RMA. Without incorporating appropriate management practices that build soil health and examine the relative risk of different farming operations, this change may continue to subsidize higher-risk practices and additionally fail to mitigate cropping on degraded or unsuitable land, which would undermine farmers who are building resilient, lower-risk farming systems.
Removal of Prevented Planting “Buy-Up” (Section VI)
The EARP Rule also removes the optional prevented planting “buy-up” (Section VI), which currently acts as an additional 5% of coverage for farmers. Land Core shares concerns about the impacts of this removal with members of the Senate Agriculture Committee (see this letter to Secretary of Agriculture Brooke Rollins signed by 19 senators), and we seek to emphasize that this removal could push farmers (already operating on thin margins and with limited financial resources) to plant in suboptimal soil conditions to maintain their profits. This can result in lower resilience to future severe weather events.
Recognize Risk-Reducing Management Practices
Given the significant evidence supported by Land Core's risk modeling research, we believe RMA should move beyond simply reducing coverage and instead focus on loss mitigation by assessing the risk-reducing benefits of soil health practices such as cover cropping, crop rotation, and reduced tillage. If data demonstrates that producers implementing soil health practices experience decreased risk of loss, premium pricing should be adjusted to incentivize broader adoption of these resilient land management practices. This approach represents a shift from managing losses after they occur to preventing them in the first place. This creates a system that saves money for insurers, FCIC (taxpayers), and producers alike while building long-term agricultural resilience. We urge a focus on proactive risk mitigation rather than reactive coverage reductions. With increasing market volatility and the growing frequency of extreme weather events, farmers need comprehensive support and access to all available risk management tools.
For further information, please contact Aria McLauchlan, Executive Director.
Land Core is a 501(c)3 organization with a mission to advance soil health policies and programs that create value for farmers, businesses and communities. The organization is building the missing infrastructure and market-based incentives that will make the rapid adoption and scalability of soil health possible.