April 22, 2011
On April 19, USDA’s Farm Services Agency (FSA) issued a Notice that the agency was setting a deadline for Biomass Crop Assistance Program (BCAP) project proposals. Farmers participating in approved projects are eligible for payments to establish bioenergy crops as well as an annual payment.
Project proposals must be submitted by May 27 to FSA state offices. FSA state offices have until June 10 to review project proposals, which will then be sent to FSA’s national office for review and a determination if additional environmental review is needed for the proposed project. FSA has until June 24 to make this determination.
Prior to this Notice, FSA was taking BCAP project proposals on a rolling first-come, first-serve basis. But in the recently enacted FY2011 Appropriations measure BCAP was capped at $112 million, a reduction of $29 million. With this limit, FSA has initiated a deadline for project proposals.
The agency, however, has not made clear in its Notices or in the project proposal application what criteria it will use in determining which applications will be funded. The BCAP statutory language in the 2008 Farm Bill includes specific criteria for BCAP project selection, including among others impacts on soil, water and related resources, the inclusion of projects with polyculture crop mixes, and projects in which producers and local investors could participate in the ownership of the biomass conversion facility in the proposed BCAP project area.
The FY2011 funding cap had another consequence for BCAP. FSA has suspended matching payments for the Collection, Harvest, Storage or Transportation (CHST) of woody biomass. The agency indicated that it will announce in mid-summer 2011 whether it will restart these payments based on BCAP funds available and targeted needs or other environmental concerns. Establishment and annual payments will be available for woody biomass that is included in approved BCAP projects.
NSAC approves of some aspects of the notice, especially the decision to suspend the CHST component of the program rather than the project component. But we would have preferred that FSA suspend CHST payments for the removal of corn stover and other commodity crop residues, which will remain eligible for CHST matching payments. FSA has yet to demonstrate that it is requiring adequate protections against increased soil erosion, decreased soil quality, and increased nutrient runoff in its funding for the removal of crop residue from agricultural land. We also remain extremely disappointed in the lack of project selection criteria or any indication the farm bill evaluation criteria will be followed in any meaningful way.
Categories: Conservation, Energy & Environment