December 5, 2002 

Pandor Hadjy
Assistant Deputy Administrator
Business Programs, RBS,
Room 5050 South Agriculture Building, Stop 3220
1400 Independence Avenue, SW
Washington, D.C. 20250-3220

Re: Implementation of Section 9006 of Farm Security and Rural Investment Act of 2002

To the Rural Business and Cooperative Service:

The Institute for Agriculture and Trade Policy (IATP), a Minnesota-based non-governmental 
organization, fosters economically, socially, and environmentally sustainable communities and 
regions. Renewable energy production is a key component of sustainable economic 
development. We have particular expertise promoting wind energy through our Windustry 
program, which provides technical support and builds collaborations with rural landowners, local 
communities, utilities and state and local government. 
We are pleased with the introduction of an energy title in the Farm Security and Rural 
Investment Act of 2002. We commend USDA for its efforts to involve and receive input from 
interested parties on Section 9006. Please consider the comments below as USDA proceeds with 
implementation.

1.	With the enormous growth in wind energy production, several biomass projects and the 
emergence of several methane digesters, the Upper Midwest is particularly well positioned to 
leverage these funding opportunities. The infrastructure, knowledge and partnerships that 
foster successful projects have already been developed in the Upper Midwest. USDA is 
encouraged to take this geographic comparative advantage into account.
For example, IATP is currently working on a collaborative project in the Blue Earth River 
Basin in south-central Minnesota where farmers are working in collaboration with state and 
federal agencies, university researchers and non-governmental organizations to promote 
greater crop diversity in the basin. Farmers in the basin are very interested in growing switch 
grass and other perennial crops that can be used for biomass energy. These partnerships that 
have already been developed should be the first choice for Section 9006 funding.

2.	Energy crops offer the clear potential of becoming a significant new market for farmers 
across America. Biomass crops can be produced in a variety of different methods, from 
sustainable to input intensive. We recommend that USDA gives preference to biomass 
projects where the crops are grown using sound environmental practices.
3.	Farmers, ranchers, and rural small businesses may apply for grants for assessments of wind 
resources (including meteorological equipment leasing, equipment installation, and data 
analysis services) in rural areas, with a maximum grant of 25% of the total assessment cost. 
Grants of this type should be considered a priority item.
       
4.	Many renewable energy technologies have proven to be economically and environmentally 
beneficial. Section 9006 funding should focus on these technologies that have the best chance 
for success rather than emerging technology.
5.	For distributed generation small-scale renewable energy projects, these funds can provide the 
most benefit by targeting the development of small-scale projects. Grants should be directed 
to projects of less than $100,000 in total cost, with the grants not exceeding $25,000.
6.	Utility-scale wind energy is ready for farmer participation on a local basis. Utility-scale wind 
technology is now one of the most cost-effective renewable energy technologies. We 
recommend that USDA provide technical support for developing business models for local 
ownership.
7.	Farmer education is a critical component of the energy title. In addition to grants that directly 
support renewable energy projects, USDA should also consider proposals that provide 
outreach and education, market development and Internet resources for on-farm energy 
system development. The projects could range in size from 70 kW to 7 MW.
8.	Farmers and rural communities will be best served by Section 9006 funds distributed in the 
form of grants rather than loans. Many farmers are already faced with high debt loads and the 
thought of taking on new debt, no matter how attractive the terms, is not appealing.
9.	Many more farmers, ranchers and rural small businesses will be interested in obtaining 
funding than what will be available through Section 9006. USDA should make efforts to 
leverage Section 9006 funding with other public and private funds available from other 
sources. These partnerships are key to the successful incorporation of renewable energy into 
the rural countryside.
The Institute for Agriculture and Trade Policy commends USDAs efforts and appreciates the 
opportunity to comment on the implementation of Section 9006. We look forward to working 
with USDA to support the incorporation of renewable energy systems in the U.S. 

Sincerely, 


Mark Ritchie, 

President
Institute for Agriculture and Trade Policy
2105 First Avenue South
Minneapolis, Minnesota 55404



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