1. Target BCAP Project funding to projects that establish perennial crops and trees, with participating farmers who have a conservation plan approved by USDA’s Natural Resources Conservation Service that addresses soil, water quality, wildlife habitat and other resource concerns.
2. Give a higher priority to BCAP Projects that include local ownership of the biomass facility, demonstrate local economic benefits, and include the participation of beginning or socially disadvantaged farmers.
3. Rein in the wasteful spending on the CHST subsidy. USDA has handed out more than $500 million dollars in subsidies since June of last year with no regard for the economic or environmental consequences. The USDA should either:
- Limit CHST subsidies to land where farmers or foresters are participating in BCAP projects to establish new bioenergy trees and crops and require that the conservation or forest plan for the project includes the CHST activities; or
- If CHST funding is not limited to BCAP project land, CHST funding should only be allowed for new sources of biomass and only in instances where the biomass allows a bioenergy facility to produce additional renewable energy. CHST funding should not be used for residues from any crop that is eligible for Farm Bill commodity program payments.
How to Submit Your Comments:
You can submit your comment directly from our website by clicking here.
You can also submit your comment by email to firstname.lastname@example.org Be sure to include at the beginning of your email a reference to the Proposed Rule for the Biomass Crop Assistance Program at 75 Fed. Reg. 6264 (Feb. 8, 2010).
You can also mail your comment to: Director of CEPD, USDA FSA CEPD, Stop 0513, 1400 Independence Ave., SW, Washington D.C.
The Biomass Crop Assistance Program (BCAP) was established by the 2008 Farm Bill. Congress intended that this program would promote the cultivation of a whole new generation of bioenergy crops for highly energy-efficient bioenergy or biofuels, and to develop those new crops and cropping systems in a manner that preserves natural resources. BCAP funding is not available for corn and other farm program crops that are primarily grown for food or animal feed.
The law provides that farmers participating in a BCAP project will be eligible to enter into a 5-year agreement with USDA to establish annual or perennial crops or a 15-year agreement for woody biomass. BCAP is supposed to provide:
- annual incentive payments for the production of perennial and annual crops;
- cost-share payments to establish perennial biomass crops; and
- a matching payment of up to $45 per ton of eligible biomass to assist with the collection, harvest, storage and transport of a BCAP crop to a biomass conversion facility.
USDA has finally released a proposed rule for BCAP. But the proposed rule does little to ensure that BCAP projects focus on jump starting a new generation of bioenergy crops produced in sustainable systems.
BCAP also includes a Collection, Harvest, Storage and Transport (CHST) subsidy that gives the USDA Secretary the discretion to make short-term payments to those who deliver agricultural or forest biomass to a facility that will convert the biomass to energy. The payments can be made for two years and range from $0 to $45 per ton. USDA has failed its duty to consider the economic and environmental impacts of the CHST subsidy or to limit the total amount of funding provided from the USDA budget.
In 2009, USDA started BCAP off on the wrong foot by giving out CHST payments with no rules and no economic or environmental review. As a result, biomass deliveries are being made to more than 300 facilities without regard to the economic effects on other users of this biomass, especially forest biomass. More than $500 million in USDA funding has been reserved for CHST payments for deliveries just for June 2009 through March 2010, with estimates for future payout as high as $2.1 billion.
Sustainable agriculture and conservation groups are concerned that USDA did no environmental review to determine limits on biomass removal needed to protect forests, agricultural land or other natural resources. Paper and pulp producers, furniture makers and other existing businesses that depend on the same biomass as feedstock for their products have protested that the CHST subsidies are causing the price of the biomass to rise. They are concerned that, without restrictions on the CHST subsidies, biomass available for their products could decrease drastically.