*Seeking your input/feedback*
*(June 24, 2010)*

*Help Shape the Value-Added Producer Grant Program*

Program Description: *This program offers competitive grants to farmers and
ranchers developing new farm and food-related business enterprises that
boost farm income, create jobs, and increase rural economic opportunity. The
Value-Added Producer Grant Program (VAPG) offers both working capital and
planning grants that strengthen the profitability and competitiveness of
small and medium sized farmers and ranchers.

The USDA is requesting comments on a proposed administrative rule that will
govern the implementation of the VAPG program. There are three areas
described below that require input to ensure that VAPG fulfills its promise.
Please submit your comments by June 28th, 2010.  There are two ways to
submit a comment:

1.  Submit your comments electronically by going to:

Type or paste this identification number into the general search box:
RBS-10-BUSINESS-0018-0001.  Scroll down and at the listing for "Value Added
Producer Grant, Proposed Rule," choose "submit comment."  Then follow the
instructions on the comment page.

2.  Mail your comments to:

Branch Chief
Regulations and Paperwork Management Branch
U.S. Department of Agriculture
Stop 0742
1400 Independence Ave. SW
Washington DC  20250

*Three topics of interest*:

1.  Keep business and enterprise planning of VAPG projects farmer-centered.
The proposed rule includes conflicting provisions on this matter.
Helpfully, it says farmers may count their time spent on development of
business and marketing plans as an in-kind contribution for purposes of
matching funds.  Yet the rule also includes conflict of interest rules and
several program definitions that seem to prohibit active participation by
the producer in project development and planning. This undermines the
fundamental principle of the VAPG program: That farmers and ranchers should
be empowered through these grants to explore creative new businesses that
will increase farm income and create rural wealth.  USDA should ensure that
the final rule is totally consistent on this point - farmers and ranchers
should directly participate in the development of VAPG projects and be
allowed to count their time as a contribution toward the program's matching

2.   Ensure that the legislative priority for projects that targeted to
small and mid-sized family farms and ranches and socially disadvantaged
farmers and ranchers set by the 2008 Farm Bill are clearly expressed in the
final rule and in the scoring/evaluation process.  Congress has spoken -
these are mandated VAPG priorities.  Yet, the proposed rule from USDA would
award only 15 ranking points out of a potential 110 ranking points for
projects targeted to this group.  USDA should ensure the final rule awards
25 total points for the priority group, and should also add clear language
to the effect that proposals which target small, mid-sized and socially
disadvantaged farmers and ranchers should take priority over projects that
are not targeted in that fashion if proposals are otherwise equally ranked.

3.  Allow producer groups or entities made up of more than 25% beginning
farmers and ranchers to apply for the funds reserved by the farm bill
specifically for projects benefiting beginning farmers and ranchers.  The
proposed rule dictates that all members of the farmer group or coop must be
beginning farmers or ranchers, a very unlikely situation in the real world.
The requirement will preclude mentoring opportunities with more experienced
farmers.  USDA should ensure the final rule includes a reasonable standard
to measure significant benefit to beginning farmers.

*Share your ideas for the next 2010 Farm Bill*

Congress will begin negotiating the 2012 Farm Bill in the next year and is
interested in gathering feedback. The Organic Farming Research Foundation
(OFRF) is working on developing their Farm Bill policy platform, identifying
programs and provisions important to the future of organic agriculture. OFRF
has created an online survey to gather feedback from organic or
transitioning farmers, famers interested in transitioning to organic
production, and organic consumers.  The survey can be found at **. *Survey deadline July 9, 2010.*

If you have any questions, contact Tracy Lerman, OFRF Policy Organizer: *
[log in to unmask]*. P: (831) 426-6606 x 108

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