NSAC's Blog

Comments on the VAPG Interim Final Rule Due Monday

April 22, 2011

On February 23, the USDA released its interim final rule (IFR) for the Value-Added Producer Grant (VAPG) program.  The public comment period on the rule closes on Monday.  NSAC will submit its comments then.  We encourage those interested in the program to read on for information regarding the contents of the interim final rule and, if so inclined, to submit comments on Monday.

We also expect USDA to issue the notice that it will be accepting new VAPG grant proposals soon, perhaps as early as next week.  There is likely to be a 60 day turnaround time for submitting proposals.  We will let readers know as soon as the notice is made public.

NSAC supports  many of USDA’s decisions in the interim rule.  We support the decision to allow producers to count their time as an in-kind “sweat equity” contribution for up to 25 percent of total project costs for matching purposes, but urge that it be monitored and increased as may prove necessary.  We support the commitment to prioritize statutorily-designated priority groups (small and medium-sized family farms, beginning farmers, and socially disadvantaged farmers) when applicants’ proposals are equally ranked.  In implementing the set-aside for beginning farmers, NSAC welcomes the acknowledgement that producer networks and cooperatives are rarely comprised entirely of beginning farmers and ranchers, but we urge USDA to clarify the very confusing language provided in the IFR definition and to further reduce the minimum percentage of beginning producers required in an applicant’s group to qualify for this priority category.

We strongly disagree with four decisive changes in the interim rule.  First, we adamantly oppose the IFR provision to make non-actively engaged landlords and passive investors eligible for grants.  This radical change violates the letter and spirit of the law and reverses the Proposed Rule and the guidelines for the program over the past decade.  It should be reversed in a second IFR or the Final Rule.

Second, NSAC objects to the complete removal of limitations on branding activities as a percentage of total projects costs.  We are concerned that such a move could result in a large portion of VAPG funds being used for advertising budgets for large firms.  A modified version of the Proposed Rule provision should be crafted for inclusion in a second IFR or the Final Rule.

Third, NSAC believes that project proposals in support of the statutory priority groups must be awarded more than the 10 points to which the Agency reduced the scoring designation, a point value that makes a mockery of the statute and congressional goals for the program.  We believe this needs urgent attention and should be corrected in a second IFR or the Final Rule.

Finally, we disagree with the removal of priority points for rural projects and want to see these reinstated in a second IFR or the Final Rule.  While we do not believe the program should be limited to rural areas, we do believe priority points are in keeping with the goals of the program.

The deadline to comment on this rule is this Monday, April 25.

Written comments may be submitted online at http://www.regulations.gov; or by courier to Branch Chief, Regulations and Paperwork Management Branch, U.S. Department of Agriculture, 300 7th Street, SW., 7th Floor, Washington, DC 20024.

Categories: Local & Regional Food Systems, Rural Development

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