BIOMASS CROP ASSISTANCE PROGRAM

Environmental Assessment

Proposed BCAP Giant Miscanthus (Miscanthus X giganteus) 

Establishment and Production in Arkansas, Missouri, Ohio, and 

Pennsylvania 

Sponsored by Aloterra Energy LLC and MFA Oil Biomass LLC 

 

United States Department of Agriculture

Farm Service Agency

April 2011

DRAFT
 
NOTICE OF AVAILABILITY

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 

NOTICE OF AVAILABILITY 

DRAFT ENVIRONMENTAL ASSESSMENT

Proposed BCAP Giant Miscanthus Establishment and Production in Arkansas, Missouri, Ohio and 

Pennsylvania

Farm Service Agency

U.S. Department of Agriculture

This notice announces the availability of a Draft Environmental Assessment (EA) for the 

proposed establishment and production of giant miscanthus (Miscanthus X giganteus) as a 

dedicated energy crop for energy production to be grown in the Aloterra Energy and MFA 

Oil Biomass Company (Project Sponsors) proposed project areas in Arkansas, Missouri, 

Ohio, and Pennsylvania under the Biomass Crop Assistance Program (BCAP). This EA is 

being prepared in accordance with the National Environmental Policy Act (NEPA) (Public 

Law [PL] 91-190, 42 U.S. Code [USC] 4321 et seq.); implementing regulations adopted by 

the Council on Environmental Quality (CEQ) (40 Code of Federal Regulations [CFR] 1500-

1508); and FSA implementing regulations, Environmental Quality and Related 

Environmental Concerns – Compliance with NEPA (7 CFR 799). According to CEQ 

guidance, an EA is a “concise document for which a Federal agency is responsible that 

serves to (1) briefly provide sufficient evidence and analysis for determining whether to 

prepare an environmental impact statement (EIS) or a finding of no significant impact 

(FONSI) (40 CFR 1508.9).” Additionally, since this document falls under the guidance of the 

BCAP Final Programmatic EIS (PEIS), which was a broad national-level program document, 

CEQ guidance allows for “tiering.” CEQ guidance defines tiering as, “the coverage of 

general matters in broader EIS with subsequent narrower statements or environmental 

analyses incorporating by reference the general discussions and concentrating solely on the 

issues specific to the statement subsequently prepared (40 CFR 1508.28). The Draft EA 

provides a means for the public to voice any concerns they may have about the proposed 

BCAP project area.

The Farm Service Agency (FSA), on behalf of the Commodity Credit Corporation (CCC), 

invites comments on the Draft EA. We will consider comments that we receive by 09 May 

2011. Comments submitted after this date will be considered to the extent possible.
NOTICE OF AVAILABILITY

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 

To comment on this Draft EA, please use one of the following methods:

Federal eRulemaking Portal: Go to http://www.regulations.gov. Follow the online 

instructions for submitting comments.

E-Mail: GiantMiscanthusEAComments@intenvsol.com.

Fax: 972-562-7673 ATTN: Giant Miscanthus EA Comments.

Mail: Giant Miscanthus EA Comments

Integrated Environmental Solutions, LLC

2150 S Central Expy Ste 110

McKinney, TX 75070

Hand Delivery or Courier: Deliver comments to the above address.

Comments may be inspected in the Office of the Director, CEPD, FSA, USDA, Room 4709 

South Building, Washington, D.C., between 8:00 a.m. and 4:30 p.m., Monday through 

Friday, except holidays. A copy of this notice is available through the FSA home page at 

http://www.fsa.usda.gov/.

For additional information, please contact: 

USDA/FSA/CEPD

Matthew T. Ponish

National Environmental Compliance Manager

1400 Independence Ave. SW

Mail Stop 0513

Washington, D.C. 20250

(202) 720-6853

matthew.ponish@wdc.usda.gov
EXECUTIVE SUMMARY

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production ES- 1 -

1 EXECUTIVE SUMMARY 

2 INTRODUCTION AND BACKGROUND

3 The United States Department of Agriculture (USDA) Commodity Credit Corporation (CCC) 

4 implements the Biomass Crop Assistance Program (BCAP) authorized by the Food, 

5 Conservation, and Energy Act of 2008 (the 2008 Farm Bill). On October 27, 2010, the CCC 

6 published the Record of Decision (ROD) for the BCAP Final Programmatic Environmental 

7 Impact Statement (PEIS) and the BCAP Final Rule (7 Code of Federal Regulations [CFR] 

8 Part 1450) in the Federal Register (FR 75:207, 65995-66007; 66202-66243). As part of the 

9 mitigation measures detailed in the ROD, each project proposal is subject to a National 

10 Environmental Policy Act (NEPA) (Public Law [PL] 91-190, 42 U.S. Code [USC] 4321 et 

11 seq.) analysis prior to approval of the project area proposal. The initial environmental 

12 evaluation of a project area proposal is developed through the completion of Forms BCAP13 19, BCAP-20, BCAP-21, and BCAP-22 and supporting information. After this initial 

14 evaluation FSA can conclude that no additional environmental analyses are applicable due 

15 to no potential for the proposed BCAP activity to significantly impact the environment or that 

16 additional environmental analyses in the form of an environmental assessment (EA) or 

17 environmental impact statement (EIS) are necessary, depending upon the potential level of 

18 significance. 

19 This Environmental Assessment (EA) analyzes the proposed establishment of BCAP project 

20 areas supporting the proposed establishment and production of giant miscanthus hybrid 

21 (Miscanthus X giganteus) by the Aloterra Energy LLC and MFA Oil Biomass Company LLC 

22 (Project Sponsors) in Arkansas, Missouri, Ohio, and Pennsylvania, which is being completed 

23 to meet the requirements of the NEPA environmental evaluation of the BCAP or to 

24 determine if an EIS would be required. 

25 PURPOSE AND NEED

26 The primary purpose of BCAP is to promote the cultivation of perennial bioenergy crops and 

27 annual bioenergy crops that show exceptional promise for producing bioenergy or biofuels 

28 that preserve natural resources and that are not primarily grown for food or animal feed. 

29 The purpose of the Proposed Action is to support the establishment and production of giant 

30 miscanthus as a crop for energy production to be grown by BCAP participants in the project 

31 areas proposed in Arkansas, Missouri, Ohio, and Pennsylvania. The need for the Proposed 
EXECUTIVE SUMMARY

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production ES- 2 -

1 Action is to provide renewable biomass feedstock to a Biomass Conversion Facility (BCF)

2 for use in energy production with and potentially outside the immediate region(s).

3 ALTERNATIVES

4 As part of the BCAP Project Area Selection Process, the Project Sponsors develop a 

5 proposal application for submittal to FSA. Prior to this submittal, the Project Sponsors have 

6 likely determined the economic feasibility of their proposal, including developing alternatives 

7 for location and crop species. The Project Sponsors developed selection criteria to meet the 

8 overall purpose and need for the Proposed Action, the establishment and production of giant 

9 miscanthus as a dedicated energy crop for energy production under the incentives of the 

10 BCAP. As part of the alternatives development process the Project Sponsors analyzed both 

11 alternative crops and alternative locations for the proposed project areas; however, each of 

12 these was determined not to be feasible. As such, this EA is analyzing the implementation 

13 of the Proposed Action or the selection of the No Action Alternative, that FSA would not 

14 establish the proposed project areas supporting the establishment and production of giant 

15 miscanthus. 

16 PROPOSED ACTION

17 Aloterra Energy LLC and MFA Oil Biomass LLC (Project Sponsors) are proposing that FSA 

18 establish BCAP project areas that support the establishment and production of giant 

19 miscanthus on 50,000 acres per proposed project area (200,000 total acres) by 2014, with 

20 crop longevity of 20 to 30 years. The acreage projected to be enrolled within the proposed 

21 project areas are marginal croplands and pastureland. The proposed project areas are 

22 located in four states in four distinct proposed project areas. Missouri contains two 

23 proposed project areas; Columbia and Aurora. Arkansas contains one proposed project 

24 area Paragould. Ohio and Pennsylvania contain the final proposed project area, Ashtabula. 

25 Each proposed project area is named for the approximate location of the BCF that will be 

26 utilized to process the giant miscanthus biomass into pellets to be shipped to other facilities 

27 or users for use in bioenergy products. Each proposed project area was developed as an 

28 approximate 50-mile radius from the approximate location of each BCF. The establishment 

29 and production of giant miscanthus would begin with centralized propagation acres on each 

30 farm, which would be distributed to plantation acres during the next growing season. During 

31 this planting season (2011), this initial establishment would require a centralized location 

32 within each proposed project area with center-pivot irrigation due to the timing of planting 
EXECUTIVE SUMMARY

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production ES- 3 -

1 and current climatic conditions occurring during this growing season. This centralized 

2 propagation area for the entire proposed project area would only occur the 2011 planting 

3 season; all other planting season would follow the on-farm model with the initial 

4 establishment of propagation acres, followed by plantation acres the following growing 

5 season. Equipment to be used to establish giant miscanthus would be modified equipment 

6 from existing perennial grass industries. Equipment used to harvest and bale giant 

7 miscanthus would be similar to existing types of agricultural machinery used for hay crops;

8 however, they would need to be more heavy-duty due to the increased biomass amounts 

9 being harvested and baled. Table ES-1 lists the proposed propagation and planting 

10 schedule within each of the proposed project areas, totaling 50,000 acres per proposed 

11 project area by 2014, which is the maximum planting goal under this action. 

12 Table ES-1. Proposed Giant Miscanthus Acres Added by Growing Season 2011-2014

Project Area

2011 2012 2013 2014 Total 

Acres 

2011-2014

Propagation 

Acres Range Total Giant Miscanthus Acres Added

Ashtabula 50-300 2,275 13,500 35,000 50,000

Aurora 100-400 7,950 13,500 31,000 50,000

Columbia 100-300 6,450 13,500 33,000 50,000

Paragould 100-600 10,850 13,500 28,400 50,000

13 NOTE: 2011 is the only year that will have only propagation acres planted, total additional acreage per year 

14 includes both propagation acres and plantation acres (2012-2014)

15 ENVIRONMENTAL CONSEQUENCES

16 Table ES-2 provides a tabular summary of the potential effects from both the Proposed 

17 Action and No Action Alternative. Implementing the Proposed Action would result in minor 

18 positive and negative effects to the local and regional area; however, many of these effects 

19 would be minimized through the use of the Mitigation and Monitoring Plan (MMP). FSA has 

20 a framework for defining the components of the MMP that will be required for this project, 

21 but has not yet finalized the plan to consider all public input on the draft EA prior to making a 

22 final plan recommendation.

23 The Proposed Action would result in additional diversified income for a participating 

24 producers, as well as technical assistance from the Project Sponsors in the production and 

25 harvesting of giant miscanthus. The Project Sponsors have proposed a BCF in each of the 

26 proposed project areas ensuring that producers will have a demand for their products. Also, 

27 ancillary agricultural services should expect an increase due to the Project Sponsors goal of 

28 primarily contracting idle acres and not active cropland. The Proposed Action would result 

29 in a changed local landscape with the addition of the giant miscanthus fields; however, most 

30
EXECUTIVE SUMMARY

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production ES- 4 -

1 Table ES-2. Comparison of the Alternatives

Resource Area Proposed Action No Action Alternative

Socioeconomics + minor 0

Land Use - minor 0

Biological Resources

Vegetation - minor 0

Wildlife - minor 0

Protected Species 0 0

Soil Resources + minor (primarily during 

establishment)

0/- minor

Water Quality/Quantity

Water Quality + minor 0

Water Quantity +/- minor 0

2 Note: +=positive -=negative 0=neutral

3 contract acreage would range in size between 38 to 100 acres. The MMP would be used to 

4 ensure that adverse effects from this new crop are minimized or avoided. Similarly, minor 

5 negative effects would be anticipated for biological diversity as pastureland is converted into

6 giant miscanthus croplands. The MMP would be essential to provide mechanisms such as 

7 reasonable and economically feasible buffers and field edges to provide for continued 

8 wildlife and vegetative diversity in these areas. Recent research has indicated that giant 

9 miscanthus is susceptible to some plant pests; the MMP monitoring and buffer efforts would 

10 be essential to ensure that any occurrence is identified and treated early to avoid 

11 transmission to local croplands, such as corn. Giant miscanthus, which has an extensive 

12 perennial root system, would be anticipated to have positive effects on soil retention, soil 

13 organic matter, and soil carbon sequestration, as well as increased water quality related to 

14 nutrient leaching and transported sediments. Also, due to its growth patterns, giant 

15 miscanthus would be anticipated to require more water than annual crops, such as corn; 

16 however, giant miscanthus has much higher water use efficiency, generating high amounts 

17 of biomass per volume of water consumed. 

18 The No Action Alternative would result in no adverse effects to the local and regional area 

19 since there would be no giant miscanthus planted in any of the proposed project areas as 

20 described in this BCAP Project Proposal. However, the No Action Alternative would not 

21 assist in meeting the overall goal of BCAP, which is to develop dedicated energy crops for 

22 conversion to bioenergy.

23
EXECUTIVE SUMMARY

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production ES- 5 -

1 DATA GAPS IN CURRENT UNITED STATES ESTABLISHMENT AND PRODUCTION

2 Giant miscanthus is a new agronomic crop species in the United States, and also still 

3 relatively new in Europe, where the oldest cultivation areas are approximately 30 years old 

4 or less. The Miscanthus genus was introduced to the United States over 100 years ago in 

5 ornamental plantings. Several universities (i.e., University of Illinois, Mississippi State 

6 University, University of Wisconsin, Michigan State University, and the University of 

7 Georgia) in the United States are currently cultivating giant miscanthus on a trial basis or 

8 conducting research on giant miscanthus or the Miscanthus genus. Additionally, large-scale 

9 acreages of giant miscanthus have not been cultivated in the United States; although 

10 commercial production of giant miscanthus for bioenergy production in co-fired systems are 

11 in the beginning stages in the United Kingdom. Given, that giant miscanthus has only been 

12 grown in large-scale trials in Europe the data on giant miscanthus planting in the United 

13 States is more limited in scope. 

14 In light of the lack of data applicable to the proposed project areas, an adaptive MMP is 

15 being developed, which will include best management practices (BMP) for the establishment 

16 and production of giant miscanthus to ensure avoidance and minimization of potential 

17 effects to the immediate environment and the larger landscape. The MMP will be a living 

18 document that is highly dependent on routine monitoring of the fields to determine the 

19 success of giant miscanthus plantings, its overall effects to the immediate environment, and 

20 any potential effects to the larger landscape based on observation and measurement. This 

21 document would contain information on appropriate and effective eradication methods that 

22 would develop over time as new data become available. Likewise, other metrics or 

23 observable measurements would adapt over time based on past observations, new 

24 research findings, and new regulations. 

25 The following information has been found to lack complete detail in relation to growth and 

26 production of giant miscanthus in the United States. 

27 Potential effects to socioeconomics focused on the information provided in the pro 

28 forma analyses of the Project Sponsors. Data from Europe indicates a high cost of 

29 establishment due to the vegetative propagation of the species; however, the BCAP 

30 combined with the model undertaken by the Project Sponsors addresses most of 

31 these concerns, along with technical assistance to be provided to producers. 
EXECUTIVE SUMMARY

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production ES- 6 -

1 Landscape scale analyses of giant miscanthus are generally lacking since there 

2 have not been any commercial-scale field trials in the United States. 

3 Literature documenting the potential for invasiveness of the fertile species of the 

4 Miscanthus genus has been discussed along with documentation supporting that 

5 giant miscanthus should not be considered invasive due to its sterility and slow 

6 rhizome spread within the United States. 

7 Literature discussing potential plant pests has been recently published relating to the 

8 western corn root worm, several species, of aphids, and rust; those studies along 

9 with recommendations have been included.

10 There is little peer-reviewed literature concerning the effects of giant miscanthus 

11 plantings on biological diversity in the United States; however, some specific studies 

12 have been published in Europe. These studies primarily focused on bird species 

13 with some small mammal observations. These studies also looked at young-aged 

14 giant miscanthus stands, so there was little information available on biodiversity 

15 found in mature stands.

16 Information concerning the nutrient uptake, nutrient addition trials, and root structure 

17 has been included to discuss the potential for soil erosion, soil organic matter, and 

18 soil carbon sequestration based on the available literature.

19 Literature concerning nutrient uptake, water use efficiency, and irrigation needs 

20 during establishment has been discussed based on the available literature. 

21
TABLE OF CONTENTS

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production i

1 TABLE OF CONTENTS 

2 NOTICE OF AVAILABILITY ...................................................................................................................... - 1 -

3 EXECUTIVE SUMMARY.......................................................................................................................ES- 1 -

4 INTRODUCTION AND BACKGROUND.....................................................................................................ES- 1 -

5 PURPOSE AND NEED ...........................................................................................................................ES- 1 -

6 ALTERNATIVES.....................................................................................................................................ES- 2 -

7 PROPOSED ACTION..............................................................................................................................ES- 2 -

8 ENVIRONMENTAL CONSEQUENCES......................................................................................................ES- 3 -

9 DATA GAPS IN CURRENT UNITED STATES ESTABLISHMENT AND PRODUCTION ......................................ES- 5 -

10 1 PURPOSE AND NEED FOR THE PROPOSED ACTION .................................................................2-1

11 1.1 INTRODUCTION AND BACKGROUND ............................................................................................ 2-1

12 1.2 USDA NEPA GUIDANCE/AUTHORITY............................................................................................. 2-2

13 1.3 PURPOSE AND NEED FOR THE PROPOSED ACTION....................................................................... 2-3

14 1.4 ORGANIZATION OF THE DOCUMENT............................................................................................. 2-3

15 2 ALTERNATIVES INCLUDING THE PROPOSED ACTION ...............................................................2-1

16 2.1 ALTERNATIVES DEVELOPMENT..................................................................................................... 2-1

17 2.1.1 Proposed Crop Alternatives – Alternatives Analyzed and Eliminated ..................................... 2-1

18 2.1.2 Proposed Project Area Locations – Alternatives Analyzed and Eliminated ............................. 2-3

19 2.2 ALTERNATIVES TO BE ANALYZED.................................................................................................. 2-5

20 2.2.1 No Action Alternative........................................................................................................... 2-5

21 2.2.2 Proposed Action.................................................................................................................. 2-6

22 2.2.2.1 Methods for Establishment and Production of Giant Miscanthus...................................... 2-8

23 2.2.2.2 Ashtabula Proposed Project Area .................................................................................. 2-11

24 2.2.2.3 Aurora Proposed Project Area........................................................................................ 2-12

25 2.2.2.4 Columbia Proposed Project Area ................................................................................... 2-12

26 2.2.2.5 Paragould Proposed Project Area .................................................................................. 2-12

27 2.3 RESOURCES CONSIDERED BUT ELIMINATED FROM DETAILED ANALYSIS.................................... 2-13

28 2.4 COMPARISONS OF THE ALTERNATIVES ...................................................................................... 2-16

29 3 AFFECTED ENVIRONMENT (BY RESOURCE AREA).....................................................................3-1

30 3.1 SOCIOECONOMICS ..................................................................................................................... 3-1

31 3.1.1 Definition of the Resource ................................................................................................... 3-1

32 3.1.2 Existing Conditions ............................................................................................................. 3-1

33 3.1.2.1 Number of Farms and Land in Farms................................................................................ 3-1

34 3.1.2.2 Primary Field Crops......................................................................................................... 3-3
TABLE OF CONTENTS

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production ii

1 3.1.2.3 Primary Livestock Industries.............................................................................................3-6

2 3.1.2.4 Rural Population Trends...................................................................................................3-8

3 3.1.2.5 Farm Income and Cost.....................................................................................................3-8

4 3.2 LAND USE....................................................................................................................................3-8

5 3.2.1 Definition of the Resource....................................................................................................3-8

6 3.2.2 Existing Conditions..............................................................................................................3-9

7 3.3 BIOLOGICAL RESOURCES.......................................................................................................... 3-18

8 3.3.1 Vegetation........................................................................................................................ 3-18

9 3.3.1.1 Definition of the Resource............................................................................................. 3-18

10 3.3.1.2 Existing Conditions....................................................................................................... 3-18

11 3.3.2 Wildlife............................................................................................................................. 3-22

12 3.3.2.1 Definition of the Resource............................................................................................. 3-22

13 3.3.2.2 Existing Conditions....................................................................................................... 3-22

14 3.3.3 Protected Species............................................................................................................. 3-23

15 3.3.3.1 Definition of the Resource............................................................................................. 3-23

16 3.3.3.2 Existing Conditions....................................................................................................... 3-23

17 3.4 SOIL RESOURCES ..................................................................................................................... 3-29

18 3.4.1 Definition of the Resource................................................................................................. 3-29

19 3.4.2 Existing Conditions........................................................................................................... 3-30

20 3.4.2.1 Ashtabula Proposed Project Area .................................................................................. 3-30

21 3.4.2.2 Aurora Proposed Project Area ....................................................................................... 3-30

22 3.4.2.3 Columbia Proposed Project Area................................................................................... 3-30

23 3.4.2.4 Paragould Proposed Project Area.................................................................................. 3-32

24 3.5 WATER QUALITY AND QUANTITY ................................................................................................. 3-32

25 3.5.1 Water Quality.................................................................................................................... 3-32

26 3.5.1.1 Definition of the Resource............................................................................................. 3-32

27 3.5.1.2 Existing Conditions....................................................................................................... 3-33

28 3.5.2 Water Quantity.................................................................................................................. 3-35

29 3.5.2.1 Definition of the Resource............................................................................................. 3-35

30 3.5.2.2 Existing Conditions....................................................................................................... 3-35

31 4 ENVIRONMENTAL CONSEQUENCES............................................................................................. 4-1

32 4.1 DATA GAPS ..................................................................................................................................4-1

33 4.2 SOCIOECONOMICS ......................................................................................................................4-2

34 4.2.1 Significance Threshold.........................................................................................................4-2

35 4.2.2 Proposed Action ..................................................................................................................4-3
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DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production iii

1 4.2.2.1 Ashtabula Proposed Project Area .................................................................................... 4-6

2 4.2.2.2 Aurora Proposed Project Area.......................................................................................... 4-6

3 4.2.2.3 Columbia Proposed Project Area ..................................................................................... 4-6

4 4.2.2.4 Paragould Proposed Project Area .................................................................................... 4-6

5 4.2.3 No Action Alternative........................................................................................................... 4-7

6 4.3 LAND USE ................................................................................................................................... 4-7

7 4.3.1 Significance Threshold........................................................................................................ 4-7

8 4.3.2 Proposed Action.................................................................................................................. 4-7

9 4.3.3 No Action Alternative........................................................................................................... 4-8

10 4.4 BIOLOGICAL RESOURCES............................................................................................................ 4-8

11 4.4.1 Vegetation .......................................................................................................................... 4-8

12 4.4.1.1 Significance Threshold.................................................................................................... 4-8

13 4.4.1.2 Proposed Action ............................................................................................................. 4-9

14 4.4.1.3 No Action Alternative .................................................................................................... 4-13

15 4.4.2 Wildlife............................................................................................................................. 4-13

16 4.4.2.1 Significance Threshold.................................................................................................. 4-13

17 4.4.2.2 Proposed Action ........................................................................................................... 4-13

18 4.4.2.3 No Action Alternative .................................................................................................... 4-15

19 4.4.3 Protected Species............................................................................................................. 4-15

20 4.4.3.1 Significance Threshold.................................................................................................. 4-15

21 4.4.3.2 Proposed Action ........................................................................................................... 4-15

22 4.4.3.3 No Action Alternative .................................................................................................... 4-16

23 4.5 SOIL RESOURCES ..................................................................................................................... 4-16

24 4.5.1 Significance Threshold...................................................................................................... 4-16

25 4.5.2 Proposed Action................................................................................................................ 4-16

26 4.5.3 No Action Alternative......................................................................................................... 4-17

27 4.6 WATER QUALITY AND QUANTITY.................................................................................................. 4-17

28 4.6.1 Water Quality.................................................................................................................... 4-17

29 4.6.1.1 Significance Threshold.................................................................................................. 4-17

30 4.6.1.2 Proposed Action ........................................................................................................... 4-17

31 4.6.1.3 No Action Alternative .................................................................................................... 4-18

32 4.6.2 Water Quantity.................................................................................................................. 4-18

33 4.6.2.1 Significance Threshold.................................................................................................. 4-18

34 4.6.2.2 Proposed Action ........................................................................................................... 4-18

35 4.6.2.3 No Action Alternative .................................................................................................... 4-20
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DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production iv

1 4.7 ALTERNATIVES COMPARISON.................................................................................................... 4-20

2 4.7.1 Proposed Action ............................................................................................................... 4-21

3 4.7.2 No Action.......................................................................................................................... 4-22

4 5 CUMULATIVE IMPACTS ASSESSMENT ......................................................................................... 5-1

5 5.1 DEFINITION..................................................................................................................................5-1

6 5.2 CUMULATIVE IMPACTS ANALYSIS BY RESOURCE AREA .................................................................5-1

7 5.2.1 Socioeconomics..................................................................................................................5-1

8 5.2.2 Land Use .............................................................................................................................5-2

9 5.2.3 Biological Resources ...........................................................................................................5-3

10 5.2.4 Soil Resources.....................................................................................................................5-4

11 5.2.5 Water Quality and Quantity...................................................................................................5-4

12 6 MITIGATION AND MONITORING.................................................................................................... 6-1

13 6.1 INTRODUCTION............................................................................................................................6-1

14 6.2 ROLES AND RESPONSIBILITIES ....................................................................................................6-1

15 6.3 MITIGATION AND MONITORING RECOMMENDATIONS ...................................................................6-2

16 6.3.1 Socioeconomics..................................................................................................................6-4

17 6.3.2 Land Use .............................................................................................................................6-4

18 6.3.3 Biological Resources...........................................................................................................6-4

19 6.3.3.1 Vegetation.......................................................................................................................6-4

20 6.3.3.2 Wildlife............................................................................................................................6-5

21 6.3.3.3 Protected Species ...........................................................................................................6-6

22 6.3.4 Soil Resources.....................................................................................................................6-6

23 6.3.5 Water Quality and Quantity...................................................................................................6-7

24 6.3.5.1 Water Quality...................................................................................................................6-7

25 6.3.5.2 Water Quantity.................................................................................................................6-8

26 7 REFERENCES................................................................................................................................... 7-1

27 8 PREPARERS..................................................................................................................................... 8-1

28 9 PERSONS AND AGENCIES CONTACTED ...................................................................................... 9-1

29

30
TABLE OF CONTENTS

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production v

1 LIST OF TABLES

2

3 Table ES-1. Proposed Giant Miscanthus Acres Added by Growing Season 2011-

4 2014 .......................................................................................................ES- 3 -

5 Table ES-2. Comparison of the Alternatives ...............................................................ES- 4 -

6 Table 2-1. Proposed Establishment and Production Methods for Giant Miscanthus.....2-10

7 Table 2-2. Proposed Giant Miscanthus Acres Added by Growing Season 2011-

8 2014 ...........................................................................................................2-11

9 Table 2-3. Estimated Biomass Tonnage by Production Year 2013-2017......................2-11

10 Table 2-4. Comparison of the Alternatives ...................................................................2-16

11 Table 3-1. Number of Farms by Farm Typology, 2007 ...................................................3-2

12 Table 3-2. Planted Acres, Harvested Acres, and Production of Select Field Crops 

13 in the Project Counties (2010). .....................................................................3-4

14 Table 3-3. Primary Livestock Activities by County within the Proposed Project 

15 Areas............................................................................................................3-7

16 Table 3-4. Farmland Land Use Categories and Sub-Categories for the Ashtabula 

17 Proposed Project Area................................................................................3-10

18 Table 3-5. Farmland Land Use Categories and Sub-Categories for the Aurora 

19 Proposed Project Area (2007) ....................................................................3-11

20 Table 3-6. Farmland Land Use Categories and Sub-Categories for the Columbia 

21 Proposed Project Area (2007) ....................................................................3-12

22 Table 3-7. Farmland Land Use Categories and Sub-Categories for the Paragould 

23 Proposed Project Area (2007) ....................................................................3-13

24 Table 3-8. Farmland Enrolled in CRP, WRP, Farmable Wetlands, or CREP in the 

25 proposed project areas...............................................................................3-16

26 Table 3-9. Federally-Listed Threatened and/or Endangered Species that Could 

27 Potentially occur within the Proposed Project Areas ...................................3-24

28 Table 3-10. Acres of Irrigated Land and Water Withdrawals by County within Each 

29 Proposed Project Area................................................................................3-36

30 Table 4-1. Cost Comparison for Participating Versus Non-Participating Producers 

31 for the Establishment and Production of Giant Miscanthus ...........................4-4

32 Table 4-2. Estimated Acres to be Planted by 2014 to Giant Miscanthus by 

33 Proposed Project Area and Percent of Land Use Type.................................4-8

34 Table 4-3. Characteristics of Ideal Biomass Crop/Weeds.............................................4-11

35 Table 4-4. Comparison of the Alternatives ...................................................................4-21

36 Table 5-1. Land Use by Proposed Project Area with Planted Acres in Crops .................5-3

37

38
TABLE OF CONTENTS

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production vi

1 LIST OF FIGURES

2

3 Figure 2-1. Proposed Project Area Locations..................................................................2-7

4 Figure 2-2. Giant Miscanthus. .........................................................................................2-9

5 Figure 3-1. Percent of Farmland Acres by County in the Proposed Project Areas.........3-14

6 Figure 3-2. Comparison of the Percentage of Harvested Cropland and Total 

7 Pastureland in the Proposed Project Areas. ...............................................3-15

8 Figure 3-3. Percent of Total Acres Enrolled in Conservation Programs, 2007...............3-17

9 Figure 3-4. Level III Ecoregions within and adjacent to the Proposed Project Areas. ....3-19

10 Figure 3-5. Potential Ranges of Federally-listed Threatened and/or Endangered 

11 Birds, Insects and Mammals within and adjacent to the Proposed Project 

12 Areas..........................................................................................................3-25

13 Figure 3-6. Potential Ranges of Federally-listed Threatened and/or Endangered 

14 Fishes and Clams within and adjacent to the Proposed Project Areas. ......3-26

15 Figure 3-7. Potential Ranges of Federally-listed Threatened and/or Endangered 

16 Plants within and adjacent to the Proposed Project Areas..........................3-27

17 Figure 3-8. Percent of Total Land Classified as Highly Erodible by County within the 

18 Proposed Project Areas..............................................................................3-31

19 Figure 3-9. Waters Listed on the State 303(d) Lists for Impaired Waters ......................3-34

20 Figure 4-1. Approximate Locations of Anticipated Producers within the Proposed 

21 Project Areas..............................................................................................4-10

22

23
TABLE OF CONTENTS

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production vii

1 ACRONYMS AND ABBREVIATIONS

2

AHIS Animal and Plant Health Inspection Service

AOSCA Association of Seed Certifying Agencies

ARS Agricultural Research Service

BCAP Biomass Crop Assistance Program

BCF biomass conversion facilities

BMP best management practice

C carbon

CAA Clean Air Act

CCC Commodity Credit Corporation

CEQ Council on Environmental Quality

cm centimeter

CO carbon monoxide

CREP Conservation Reserve Enhancement Program

CRP Conservation Reserve Program

CWA Clean Water Act

EA environmental assessment

EIA Economic Impact Analysis

EIS environmental impact statement

EO Executive Order

EPA U.S. Environmental Protection Agency

ERS Economic Research Service

FONSI finding of no significant impact

FSA Farm Service Agency

g gram

GHG greenhouse gases

HEL highly erodible lands

HILD high-input low diversity

HUC hydrologic unit

IPM integrated pest management

kg kilograms

kPA kilo Pascal

LIHD low-input high diversity
TABLE OF CONTENTS

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production viii

LMM Lower Missouri-Moreau

μg/m3 micrograms per cubic meter

m meter

m2 square meter

MDNRAPCD Missouri Department of Natural Resources Air Pollution Control Division

NAAQS National Ambient Air Quality Standards

NEPA National Environmental Policy Act

NO2 nitrogen dioxide

NRCS Natural Resource Conservation Service

OEPA Ohio Environmental Protection Agency

OSIA Ohio Seed Improvement Association 

Pb lead

PEIS Programmatic Environmental Impact Statement

PM2.5 particulate matter of less than 2.5 microns

PM10 particulate matter of less than 10 microns

PPA Plant Protection Act

QAP Quality Assurance Program

RES Renewable Energy Standard

ROD Record of Decision

ROI Region of Influence

SHPO State Historical Preservation Offices

SO2 sulfur dioxide

TSP Technical Service Providers

USACE United States Army Corp of Engineers

USCB U.S. Census Bureau

USDA United States Department of Agriculture

USFWS U.S. Fish and Wildlife Service

USGS United States Geological Survey

WRA Weed Risk Assessment

WRP Wetland Reserve Program

1

2
PURPOSE AND NEED FOR THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-1

1 1 PURPOSE AND NEED FOR THE PROPOSED ACTION 

2 1.1 INTRODUCTION AND BACKGROUND

3 The United States Department of Agriculture (USDA) Commodity Credit Corporation (CCC) 

4 implements the Biomass Crop Assistance Program (BCAP) authorized by the Food, 

5 Conservation, and Energy Act of 2008 (the 2008 Farm Bill). This legislation, which was 

6 passed into law on June 18, 2008, creates the BCAP and authorizes the program through 

7 September 30, 2012. BCAP is intended to assist agricultural and forest land owners and 

8 operators with the establishment and production of eligible crops including woody biomass 

9 in selected project areas for conversion to bioenergy, and the collection, harvest, storage, 

10 and transportation of eligible material to designated biomass conversion facilities (BCF) that 

11 produce or intending to produce heat, power, biobased products, or advanced biofuels. The 

12 BCAP is administered by the Deputy Administrator for Farm Programs of the Farm Service 

13 Agency (FSA) on behalf of the CCC with the support of other Federal and local agencies. 

14 On October 27, 2010, the CCC published the Record of Decision (ROD) for the BCAP Final 

15 Programmatic Environmental Impact Statement (PEIS) and the BCAP Final Rule (7 Code of 

16 Federal Regulations [CFR] Part 1450) in the Federal Register (FR 75:207, 65995-66007; 

17 66202-66243). 

18 As part of the mitigation measures detailed in the ROD, each project proposal is subject to a 

19 National Environmental Policy Act (NEPA) (Public Law [PL] 91-190, 42 U.S. Code [USC] 

20 4321 et seq.) analysis prior to approval of the project area proposal. The initial 

21 environmental evaluation of a project area proposal is developed through the completion of 

22 Forms BCAP-19, BCAP-20, BCAP-21, and BCAP-22 and supporting information. After this 

23 initial evaluation FSA can conclude that no additional environmental analyses are applicable 

24 due to no potential for the proposed BCAP activity to significantly impact the environment or 

25 that additional environmental analyses in the form of an environmental assessment (EA) or 

26 environmental impact statement (EIS) are necessary, depending upon the potential level of 

27 significance. 

28 This Environmental Assessment (EA) analyzes the proposed establishment of BCAP project 

29 areas supporting the proposed establishment and production of giant miscanthus hybrid 

30 (Miscanthus X giganteus) by the Aloterra Energy LLC and MFA Oil Biomass Company LLC 

31 (Project Sponsors) in Arkansas, Missouri, Ohio, and Pennsylvania, which is being completed 
PURPOSE AND NEED FOR THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-2

1 to meet the requirements of the NEPA environmental evaluation of the BCAP or to 

2 determine if an EIS would be required.

3 In 2008, the owners of Aloterra Energy LLC began laying the groundwork to expand their 

4 fuel marketing, distribution, and logistics operations into the emerging biomass renewable 

5 energy market. In 2010, Aloterra Energy’s owners purchased a farm in Conneaut, Ohio and, 

6 with the help of an enthusiastic community, planted stock giant miscanthus. During this 

7 same period, Aloterra Energy secured the largest stock of giant miscanthus rhizomes in the 

8 United States and combined that with specialized giant miscanthus rhizome harvesting and 

9 planting equipment manufactured in the United States. Aloterra Energy’s owners are now 

10 leveraging four decades of commodities and energy experience to form a vertically 

11 integrated energy supply chain, focused on giant miscanthus. Aloterra Energy’s proposed 

12 project area will provide farmers an energy crop rhizome source, harvesting and planting 

13 equipment for the crop’s rhizomes, specialty harvesting for the mature cane, processing 

14 technology, and marketing services for the cooperative’s biomass fuel.

15 Formed in 1929, MFA Oil Company is the largest farmer owned energy cooperative in the 

16 State of Missouri. In 2008, MFA Oil began laying the groundwork to expand its energy 

17 services into the emerging biomass renewable energy market. That initiative came to fruition 

18 in 2010 as MFA Oil teamed up with Aloterra Energy LLC to form MFA Oil Biomass LLC to 

19 lead the cooperative into the biomass energy field. MFA is leveraging its knowledge in 

20 farming and in the energy markets to form a vertically integrated renewable energy supply 

21 chain. MFA’s proposed project area will provide farmers an energy crop source, harvesting 

22 and planting equipment for the crop’s rhizomes, specialty harvesting for the mature cane, 

23 processing technology, and marketing services for the cooperative’s biomass fuel.

24 1.2 USDA NEPA GUIDANCE/AUTHORITY

25 This EA is being prepared in accordance with the NEPA (PL 91-190, 42 USC 4321 et seq.); 

26 implementing regulations adopted by the Council on Environmental Quality (CEQ) (40 CFR 

27 1500-1508); and FSA implementing regulations, Environmental Quality and Related 

28 Environmental Concerns – Compliance with NEPA (7 CFR 799). According to CEQ 

29 guidance, an EA is a “concise document for which a Federal agency is responsible that 

30 serves to (1) briefly provide sufficient evidence and analysis for determining whether to 

31 prepare an EIS or a finding of no significant impact (FONSI) (40 CFR 1508.9).” Additionally, 

32 since this document falls under the guidance of the BCAP Final PEIS, which was a broad 

33 national-level program document, CEQ guidance allows for “tiering.” CEQ guidance defines 
PURPOSE AND NEED FOR THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-3

1 tiering as, “the coverage of general matters in broader EIS with subsequent narrower 

2 statements or environmental analyses incorporating by reference the general discussions 

3 and concentrating solely on the issues specific to the statement subsequently prepared 

4 (40CFR 1508.28). 

5 1.3 PURPOSE AND NEED FOR THE PROPOSED ACTION

6 The primary purpose of BCAP is to promote the cultivation of perennial bioenergy crops and 

7 annual bioenergy crops that show exceptional promise for producing bioenergy or biofuels 

8 that preserve natural resources and that are not primarily grown for food or animal feed. 

9 The purpose of the Proposed Action is to support the establishment and production of giant 

10 miscanthus as a crop for energy production to be grown by BCAP participants in the project 

11 areas proposed in Arkansas, Missouri, Ohio, and Pennsylvania. The need for the Proposed 

12 Action is to provide renewable biomass feedstock to a Biomass Conversion Facility (BCF) 

13 for use in energy production with and potentially outside the immediate region(s).

14 1.4 ORGANIZATION OF THE DOCUMENT

15 This EA assesses the potential impacts of the Proposed Action and No Action Alternatives 

16 on the potentially affected environmental and socioeconomic resources.

17 Section 1 provides background information relevant to the Proposed Action, and 

18 discusses its purpose and need.

19 Section 2 describes the alternatives, including the Proposed Action, and compares 

20 the alternatives.

21 Section 3 describes the baseline conditions (i.e., the conditions against which 

22 potential impacts of the Proposed Action and alternatives are measured) for each of 

23 the potentially affected resources.

24 Section 4 describes potential environmental consequences on these resources.

25 Section 5 includes analysis of cumulative impacts and irreversible and irretrievable 

26 resource commitments.

27 Section 6 discusses mitigation measures.

28 Section 7 is a list of references cited in the EA.

29 Section 8 lists the preparers of this document. 

30 Section 9 contains a list of persons and agencies receiving this document and 

31 contacted during the preparation of this document.

32
PURPOSE AND NEED FOR THE PROPOSED ACTION

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ALTERNATIVE INCLUDING THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-1

1 2 ALTERNATIVES INCLUDING THE PROPOSED ACTION 

2 2.1 ALTERNATIVES DEVELOPMENT

3 As part of the BCAP Project Area Selection Process, the Project Sponsors develop a 

4 proposal application for submittal to FSA. Prior to this submittal, the Project Sponsors have 

5 likely determined the economic feasibility of their proposal, including developing alternatives 

6 for location and crop species. The Project Sponsors developed selection criteria to meet the 

7 overall purpose and need for the Proposed Action, the establishment and production of giant 

8 miscanthus as a dedicated energy crop for energy production under the incentives of the 

9 BCAP. As part of the alternatives development process the Project Sponsors analyzed both 

10 alternative crops and alternative locations for the proposed project areas. The following 

11 sections describe each of these processes that were under taken by the Project Sponsors 

12 during their planning phases and why certain aspects were eliminated as unfeasible 

13 alternatives.

14 2.1.1 Proposed Crop Alternatives – Alternatives Analyzed and Eliminated

15 The Project Sponsors utilized two primary criteria to determine the proposed crop 

16 alternatives within the proposed project areas. These selection criteria included:

17 (1) Potential Biomass Yield in Tonnage Produced per Acre – This selection 

18 criterion was closely tied to economic feasibility because obtaining a sufficient 

19 annual harvest is necessary to make the proposed project economically viable for 

20 the Project Sponsors. Prior to the passage of the 2008 Farm Bill, the Project 

21 Sponsors were considering the results of a three-year study conducted by the Ohio 

22 Seed Improvement Association (OSIA). When the 2008 Farm Bill was authorized, 

23 the Project Sponsors felt the economic feasibility for United States markets had 

24 reached the threshold necessary to make the proposed project viable. The Project 

25 Sponsors were also concurrently reviewing data from the OSIA study that 

26 evaluated the annual tonnage yield for the perennial grass giant reed (Arundo 

27 donax) that is a native of Europe, several varieties of the perennial native 

28 switchgrass (Panicum virgatum varieties), and the perennial hybrid grass native to 

29 Asia, giant miscanthus. The results of the three-year study with harvesting 

30 conducted between 2007 and 2010 indicated that giant miscanthus was the 

31 superior biomass producer of the eight crops or varieties tested and provided 

32 approximately 1.5 to two times more annual tonnage of biomass than switchgrass;
ALTERNATIVE INCLUDING THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-2

1 (2) Potential for Invasiveness – The Project Sponsors subsequently became a 

2 member of the OSIA and worked with them as an independent, third party, to 

3 develop a voluntary Quality Assurance Program (QAP) that included site visits at 

4 their propagation locations, genetic tracing of their stock, and a records audit. In 

5 their letter to the Project Sponsors dated March 4, 2010 that was submitted as part 

6 of their BCAP application, OSIA concluded that the Project Sponsors proposed 

7 giant miscanthus was a sterile triploid hybrid producing no viable seed at the 

8 Conneaut, Ohio and Kansas propagation locations inspected. Furthermore, the 

9 Project Sponsors’ QAP was submitted to the Association of Official Seed Certifying 

10 Agencies (AOSCA), which is the national authority for seed certification for 

11 additional verification. 

12 Other crop types were eliminated from detailed study within this EA due to the increased 

13 potential for environmental impacts associated with additional land use or conversion for 

14 less efficient species or hybrids, potential additional water supply or demand requirements 

15 for propagation and planting purposes, potential impacts on water quantity due to continual 

16 irrigation needs, potential water quality impacts due to higher nutrient requirements, 

17 potentially higher air emissions of criteria pollutants and greenhouse gases (GHG) due to 

18 additional transportation, harvesting (e.g., ethanol production typically uses multiple harvest 

19 passes per field), and feedstock drying (e.g., associated with crop choices with more 

20 moisture content when harvested) sources. 

21 The Project Sponsors also considered the use of corn stover or residuals, which are heavily 

22 used in the production of corn ethanol-based biofuels (e.g. included in the BCAP, but not as 

23 an advanced biofuel). However, this option was not considered economically viable 

24 because of the infrastructure required and time to acquire and construct this infrastructure, 

25 which the Project Sponsors are not well positioned to obtain on an economically viable 

26 basis. The presence of other established market competitors already producing corn 

27 ethanol-based biofuels in the Midwest with multiple harvest passes per planted field that 

28 have this infrastructure in place, is another reason that the corn option was considered but 

29 not pursued. 

30
ALTERNATIVE INCLUDING THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-3

1 2.1.2 Proposed Project Area Locations – Alternatives Analyzed and Eliminated

2 The Project Sponsors utilized several criteria to determine the proposed project locations. 

3 These selection criteria included:

4 (1) Regional Location - The Midwest was selected because the growing 

5 requirements of giant miscanthus include rainfall of generally more than 30 inches 

6 per year and winter conditions that would trigger plant dormancy, generally less 

7 than 32°F, usually associated with adequate snow cover to protect the rhizomes. 

8 Additionally, the Project Sponsors also have a history within this region, which 

9 provided familiarity with the region and the conditions, including climatic,

10 agricultural economy, use of renewable energy or the desire for the use of 

11 renewable energy, and willingness to participate in the BCAP. Therefore, the 

12 Project Sponsors considered Midwestern locations because this region provided 

13 the only suitable match for the growing requirements of the proposed advanced 

14 biofuels feedstock in the United States; 

15 (2) Availability of Adequate Rainfall to Support Planting Propagation Acres –

16 More specific locations within the Midwest were selected through the second 

17 selection criterion, adequate rainfall to primarily support planting of propagation 

18 acres, but also to support the longer term growth of planted giant miscanthus after 

19 propagation. As indicated above, a minimum of 30 inches per year of rainfall is 

20 considered the minimum along with adequate snow cover to support this species. 

21 Within the Midwest, the Project Sponsors selected the proposed project areas 

22 because they all receive the minimum amount of rainfall;

23 (3) Proximity of Infrastructure for Market Transportation - The proposed project 

24 areas adopted the model that the outside borders of the proposed project area 

25 should be located no further than 50 miles from the BCF to reduce emissions and 

26 transportation costs to make the effort economically feasible for the producers. 

27 Therefore, the BCF locations were carefully chosen to be the center point of the 

28 50-mile radius within each proposed project area and the BCF location must 

29 include access to rail, highway, and be within reasonable distance of ports for 

30 water connection. The proposed Ashtabula project area was selected due to the 

31 established Aloterra Energy farm in Conneaut, Ashtabula County, Ohio which was 

32 in proximity of the Port of Ashtabula and rail connections to local pellet markets. 

33 The other proposed project areas were selected for their proximity to current 
ALTERNATIVE INCLUDING THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-4

1 highway and rail transportation to support existing agricultural transport 

2 mechanisms from cotton, corn, beans, and poultry farming; 

3 (4) Economic Feasibility - The Project Sponsors used economic feasibility based on 

4 the current dominant agricultural land use in the region and the value of that land 

5 use in relation to potential yields for giant miscanthus payments under the BCAP. 

6 For example, throughout large parts of all four states corn, beans, beef, and poultry 

7 are the dominant agricultural products based on the return price for individual 

8 producers. 

9 As a result, the Project Sponsors selected individual proposed project areas in 

10 those states where there was a large amount of marginal land not currently under 

11 production in any of the dominant agricultural products to avoid competition 

12 between a potentially more economically feasible option (e.g. the current 

13 agricultural use) and what the Project Sponsors are proposing. Due to the higher 

14 return on more arable land in conventional crops or livestock, the Project Sponsors 

15 recognized the importance of targeting marginal croplands and current pastureland 

16 where returns for participating producers would be higher than the existing land 

17 use, which could encourage greater participation. Additionally, based on existing 

18 research and internal economic analyses the Project Sponsors determined that 

19 giant miscanthus could economically produce on smaller acreages, potentially 

20 benefitting a larger group of producers. 

21 In Arkansas, however; in response to specific requests from local participating 

22 farmers, the Project Sponsors are proposing to use some lands that are currently 

23 used for corn or beef but are more marginally productive. The request to plant 

24 giant miscanthus is associated with the desire to reduce runoff from high input food 

25 crops and to mitigate the unsustainable depletion of groundwater from current 

26 farming practices, which could be creating additional costs to these producers;

27 (5) Access to Local Markets – The Project Sponsors decided that access to local 

28 markets was key for developing relationships that would meet the need for future 

29 renewable energy feedstocks. For example, the proposed Ashtabula project area 

30 is within close proximity to the Port of Ashtabula and rail where the Project 

31 Sponsors anticipate meeting the significant needs of the energy industry in Ohio 

32 triggered by Renewable Energy Standard (RES) mandates. However, the 

33 transporting of pellets to both the Canadian and European markets is a viable 
ALTERNATIVE INCLUDING THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-5

1 economic option should biomass supplies exceed regional needs. In central 

2 Missouri, the Project Sponsors anticipate providing their anticipated supply to the 

3 City of Columbia, which passed a local RES for city-owned utilities, and the 

4 University of Missouri, which is in the process of converting their coal-fired power 

5 plant to either a partial co-firing or complete co-firing based on advanced biofuels 

6 feedstocks. In southwestern Missouri, the Project Sponsors anticipate selling the 

7 bulk of their pellet supply to regional poultry producers who primarily rely on 

8 propane gas to heat their poultry producing facilities, but often alter their operations 

9 if the price of propane gas rises beyond economic feasibility thresholds. 

10 Other alternative locations were eliminated from detailed study within this EA due to the 

11 increased potential for environmental impacts associated with increased transportation and 

12 infrastructure impacts, increased air emissions including GHG and other criteria pollutants 

13 regulated under the Clean Air Act (CAA), additional water demand requirements if a 

14 suboptimal climate were chosen with insufficient water supply, additional water quality 

15 impacts if a suboptimal site was chosen with additional nutrient demand that may affect 

16 impaired waters under the Clean Water Act (CWA) in the region, and potential 

17 socioeconomic impacts if a region with an economically superior crop alternative was 

18 selected. 

19 2.2 ALTERNATIVES TO BE ANALYZED

20 Alternatives considered to be reasonably expected to meet the purpose and need for action 

21 include the Proposed Action. Even though the No Action Alternative would not meet the 

22 purpose and need for the proposed action, it is included as the baseline for which the 

23 Proposed Action is compared to determine the potential effects to the human and natural 

24 environment and the potential significance of those effects, both positive and negative. 

25 2.2.1 No Action Alternative

26 Under the No Action Alternative, that FSA would not establish the proposed project areas 

27 supporting the establishment and production of giant miscanthus. This alternative would 

28 leave existing agricultural production practices in place in the proposed project areas. This 

29 alternative would not meet the goals and objectives of the BCAP, as these Project Sponsors 

30 would not enter the voluntary program for the incentive to produce dedicated bioenergy 

31 crops. Also, the No Action Alternative would not meet the purpose and need for the Action 

32 as described in Section 1.3. 
ALTERNATIVE INCLUDING THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-6

1 2.2.2 Proposed Action

2 Aloterra Energy LLC and MFA Oil Biomass LLC (Project Sponsors) are proposing that FSA 

3 establish four separate BCAP project areas to establish and produce giant miscanthus on 

4 50,000 acres per proposed project area (200,000 total acres) over the life of the project (20 

5 years or longer). The acreage targeted for enrollment into the proposed project areas are 

6 marginal croplands and current pastureland. The Project Sponsor defines marginal and idle 

7 lands as the following:

8 Marginal – This refers to the productivity status of the land due to economics, 

9 geographic locations, topography, or other site conditions that render production of 

10 high value food crops such as corn and soybeans not viable.

11 Idle – Land not currently being cropped. 

12 The proposed project areas are located in four states in four distinct proposed project areas 

13 (Figure 2-1). Missouri contains two proposed project areas; Columbia and Aurora.

14 Arkansas contains one proposed project area Paragould. Ohio and Pennsylvania contain 

15 the final proposed project area, Ashtabula. The Project Sponsors have been in discussions 

16 with producers to ensure the economic feasibility of the project proposal to FSA; however, 

17 no producers have been asked to provide commitments to the Project Sponsors or have 

18 entered into a discussion with the FSA to become BCAP participating producers. As such, 

19 the proposed project areas have some approximate locations of acreage to be included 

20 within the first growing season, but those acres are not committed; therefore, the level on 

21 analysis for this EA is based at the combined county proposed project area level. Each 

22 proposed project area is named for the approximate location of the BCF that will be utilized 

23 to process the giant miscanthus biomass into pellets to be shipped to other facilities or users 

24 for use in bioenergy products. Each proposed project area was developed as an 

25 approximate 50-mile radius from the approximate location of each BCF. This 50-mile radius 

26 was developed based on the generalized research findings (as detailed in the BCAP Final 

27 PEIS) that 50-miles was generally considered to be the maximum distance biomass 

28 feedstocks could be transported to a BCF and make the BCF economically viable. Project 

29 acres have been determined to be potentially located anywhere within the 50-mile radius 

30 developed from the proposed BCF located city. 

31
ALTERNATIVE INCLUDING THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-7

1 Figure 2-1. Proposed Project Area Locations.
ALTERNATIVE INCLUDING THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-8

1 The Project Sponsors reserve the right to decline any acres within the eligible project area 

2 that the Project Sponsors, the FSA, or the FSA technical partners’ determine cannot 

3 produce giant miscanthus effectively without substantial environmental effects. This would

4 be determined through one of the following: the Project Sponsors’ initial site evaluations, the 

5 environmental screening process for each participating contract, or through the conservation 

6 or forest stewardship planning processes. The environmental screening process for each 

7 project proposal begins with the completion of Form BCAP-22 Environmental Screening for 

8 the Project Proposal. The conservation planning process for each participating producer 

9 includes the completion of the Natural Resources Conservation Service (NRCS) Form CPA10 052 with the assistance of either NRCS field personnel or a certified technical service 

11 provider (TSP).

12 Additionally, per the BCAP Final PEIS and BCAP Final Rule, the collection, harvest, 

13 storage, and transportation of biomass from the proposed project areas to the BCF are 

14 included within the provisions of the BCAP Matching Payments Program; therefore, those 

15 activities are not being analyzed as part of the Proposed Action (BCAP Final PEIS Chapter 

16 1.3.2, page 1-6). The Matching Payment Program was determined not to be a major 

17 Federal action per the NEPA definition since (1) there was no discretionary authority to 

18 implement the program terms; it was implemented per the direct language of the 2008 Farm 

19 Bill and (2) that the materials collected during the Matching Payment Program were currently 

20 being utilized in the marketplace for a similar, if not the same, purpose.

21 2.2.2.1 Methods for Establishment and Production of Giant Miscanthus

22 The establishment and production of giant miscanthus (Figure 2-2) would begin with 

23 centralized propagation acres on each farm. Rhizomes from the propagation acres would 

24 be distributed to plantation acres during the next growing season. During this planting 

25 season (2011) only, this initial establishment would require a centralized location within each 

26 proposed project area with center-pivot irrigation due to the timing of late in the growing 

27 season. This centralized propagation area for the entire proposed project area would only 

28 occur this planting season; all other planting seasons would follow the on-farm model with 

29 the initial establishment of propagation acres, followed by plantation acres the following 

30 growing season, both without subsequent irrigation beyond 2011.
ALTERNATIVE INCLUDING THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-9

1 Giant miscanthus is a triploid hybrid perennial warm2 season grass developed through the crossing of 

3 Miscanthus sinensis (diploid species) with M. 

4 sacchiflorus (tetraploid species), both of which are

5 native to Southeast Asia. One species, Miscanthus 

6 sinensis was introduced to the United States, as an 

7 ornamental; other species are not frequently being 

8 used, including varieties of giant miscanthus, which

9 is currently being developed as a biofuel feedstock. 

10 Yields in North American research trials have 

11 reached 17 dry tons per acre per year with minimal 

12 inputs. The species is a sterile hybrid which does 

13 not produce viable seed and is therefore propagated 

14 vegetatively by rhizome division. Planting 

15 equipment for Bermudagrass (Cynodon spp) or 

16 specialty vegetable crops has been used to successfully establish giant miscanthus in 

17 Midwestern United States. Harvesting is done in a manner similar to traditional hay crops, 

18 but the equipment must be able to handle high-yield crops. Table 2-1 summarizes best 

19 practices for the establishment and management of giant miscanthus.

20 At the time of planting, rhizomes should be dormant. Viable rhizomes are firm, tan in color, 

21 weigh 1.0 to 1.5 ounces, and have at least one visible bud. Soil moisture is a key to 

22 establishment and supplemental irrigation in the first growing season is encouraged, but not 

23 required. Fertilizer should not be applied in the first two growing seasons, unless planted on 

24 in very poor soil, indicating one that lacks sufficient soil nutrients for crop growth or is a soil 

25 type that readily leaches nutrients (e.g., high sand content). In research trials, giant 

26 miscanthus has shown tolerance to common maize (corn) herbicides, Harness (Acteochlor) 

27 and Harness XTRA (Acteochlor + Atrazine) are currently the only herbicides labeled for use 

28 in giant miscanthus. A complete kill of any existing vegetation must be completed before 

29 the establishment of the crop. Stems of giant miscanthus can be 1⁄2-inch in diameter, 12 feet 

30 tall and as dense as 10 stems per square foot. 

31

Figure 2-2. Giant Miscanthus.
ALTERNATIVE INCLUDING THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-10

1 Table 2-1. Proposed Establishment and Production Methods for Giant Miscanthus

Former Land Use: Traditional Crops Former Land Use: Currently Idle or Pasture

Crop Establishment Year One

Deep tillage in Fall or early Spring with chisel 

plow.

Perform burn-down using one application of nonselective herbicide.

Tillage immediately prior to planting with disk or 

soil finisher to ensure fine seedbed.

Deep tillage in Fall or early Spring with chisel plow. 

Tillage with disk to break soil clods.

Plant rhizomes at depth of 4 inches and density 

of 6,000 per acre. A post-planting roller may be 

required to ensure solid contact between soil and 

rhizome.

Tillage immediately prior to planting with disk or soil 

finisher to ensure fine seedbed.

Apply Harness© or Harness XTRA© herbicide at 

label rate, prior to emergence of weeds. A 

second application may be made if weeds 

emerge.

Plant rhizomes at depth of 4 inches and density of 

6,000 per acre. A post-planting roller may be 

required to ensure solid contact between soil and 

rhizome.

Mow biomass in late winter/early spring. Apply Harness© or Harness XTRA© herbicide at 

label rate, prior to emergence of weeds. A second 

application may be made if weeds emerge.

Mow biomass in late winter/early spring.

Crop Establishment Year Two

Apply Harness© or Harness XTRA© herbicide at label rate, prior to emergence of weeds. A second 

application may be made if weeds emerge.

Mow, rake, and bale biomass in late Fall/early Spring, prior to emergence of new shoots.

Crop Maintenance (Years 3-15)

Fertilize with Nitrogen (8 lbs. per dry ton of biomass), Phosphorus (1.5 lbs. per dry ton of biomass), and 

Potassium (8 lbs. per dry ton of biomass)

Harvest annually, from December to March, using equipment such as a mower/conditioner and large 

square baler.

Crop Removal

Following final biomass harvest, deep tillage with plow to break apart rhizome mass. Tillage, as 

necessary, to break rhizomes and soil clods.

Plant glyphosate tolerant crop and apply glyphosate during growing season when giant miscanthus 

shoots appear.

2 Harvesting equipment must be able to handle this high yield crop. Biomass harvest should 

3 not occur until after first frost when nutrients have been translocated from the stem to 

4 rhizome. For the 2012 growing season, live rhizomes would be transported from the 

5 centralized propagation acres to the plantation acres within each proposed project area in 

6 bags on pallets contained within enclosed, refrigerated trucks similar to the standard 

7 process used to transport live plant materials long distances. For the 2013 growing, live 

8 rhizomes would be transported from on-farm propagation acres to on-farm plantation acres, 

9 there would not be any long distance transport of live plant materials off farms. 

10 Glyphosate and traditional tillage have been found to be effect eradication methods for giant 

11 miscanthus though it may require more than one growing season for complete eradication 

12 (Caslin et al. 2010, Anderson et al. 2009, Anderson et al. 2011). Caslin et al. (2010) 

13 recommend an application of glyphosate after emergence followed by tillage. Anderson et 
ALTERNATIVE INCLUDING THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-11

1 al. (2009) recommend a tillage depth of at least 10 centimeters to remove any living 

2 rhizomes after herbicide treatment. 

3 2.2.2.2 Ashtabula Proposed Project Area

4 For the spring of 2011, the Project Sponsors have obtained initial commitments from farmers 

5 to plant between 50 to 300 propagation acres of giant miscanthus, which will be replanted 

6 into plantation acres in 2012. A propagation acre is planted densely in order to quickly 

7 generate rhizomes the following year which are then spread to cover additional acres. A 

8 plantation acre is planted less densely and is intended to be used to harvest giant 

9 miscanthus for biomass. The Project Sponsors will scale up to 50,000 acres of giant 

10 miscanthus by 2014, which will enable the Project Sponsors’ conversion facility to process 

11 600,000 tons of biomass each year (Tables 2-2 and 2-3). The Project Sponsors have a 

12 small scale pellet mill in operation. This conversion facility has existing pelletizing 

13 technology that is energy efficient, mobile, easy to maintain, and able to be scaled up by 

14 combining smaller units using one conveyor and control system. As the economic feasibility 

15 establishes, scalability greatly increases the probability of success as expenditures will meet 

16 developing tonnage needs. Pellet markets are diverse and are strong both inside and 

17 outside of the United States. To that point; the Project Sponsors have giant miscanthus 

18 contracts with a large biomass aggregator and a local residential pellet distributor.

19 Table 2-2. Proposed Giant Miscanthus Acres Added by Growing Season 2011-2014

Project Area

2011 2012 2013 2014 Total 

Acres 

2011-2014

Propagation 

Acres Range Total Giant Miscanthus Acres Added

Ashtabula 50-300 2,275 13,500 35,000 50,000

Aurora 100-400 7,950 13,500 31,000 50,000

Columbia 100-300 6,450 13,500 33,000 50,000

Paragould 100-600 10,850 13,500 28,400 50,000

20 NOTE: 2011 is the only year that will have only propagation acres planted, total additional acreage per year 

21 includes both propagation acres and plantation acres (2012-2014).

22 Source: Confidential Application for Proposed BCAP Project Areas, 2011

23 Table 2-3. Estimated Biomass Tonnage by Production Year 2013-2017

Project Area

2013-2014 2014-2015 2015-2016 2016-2017

Total Biomass Tonnage Processed

Ashtabula 12,000 102,000 309,000 600,000

Aurora 42,000 156,000 414,000 600,000

Columbia 32,000 132,000 402,000 600,000

Paragould 57,600 187,200 429,600 600,000

24 Source: Confidential Application for Proposed BCAP Project Areas, 2011
ALTERNATIVE INCLUDING THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-12

1 2.2.2.3 Aurora Proposed Project Area

2 In the spring of 2011, the Project Sponsors have obtained initial commitments from farmers 

3 to plant between 100 to 400 propagation acres of giant miscanthus, which will be replanted 

4 into plantation acres in 2012. MFA Oil Biomass will utilize its 40,000 cooperative members to 

5 scale up to 50,000 acres of giant miscanthus by 2014, which will enable the Project 

6 Sponsors’ conversion facility to process 600,000 tons of biomass each year. The Project

7 Sponsors’ conversion facility is utilizing existing pelletizing technology that is energy 

8 efficient, mobile, flexible in maintenance and product, and able to be scaled by combining 

9 smaller units using one conveyor and control system. As the economic feasibility 

10 establishes, scalability greatly increases the probability of success as expenditures will meet 

11 developing tonnage needs and pellet markets already exist, are diverse, and are inside and 

12 outside of the United States. To that point, the Project Sponsors have giant miscanthus 

13 tonnage contracts with farmers with commercial heating needs, and large scale aggregators 

14 of biomass.

15 2.2.2.4 Columbia Proposed Project Area

16 For the spring of 2011, the Project Sponsors have obtained initial commitments from farmers 

17 to plant between 100 to 300 propagation acres of giant miscanthus, which will be replanted 

18 into plantation acres in 2012. MFA Oil Biomass will utilize its 40,000 cooperative members 

19 to scale up to 50,000 acres of giant miscanthus by 2014, which will enable the Project 

20 Sponsors’ conversion facility to process 600,000 tons of biomass each year. The Project 

21 Sponsors’ conversion facility is utilizing existing pelletizing technology that is energy

22 efficient, mobile, flexible in maintenance and product, and able to be scaled by combining 

23 smaller units using one conveyor and control system. As the economic feasibility 

24 establishes, scalability greatly increases the probability of success as expenditures will meet 

25 developing tonnage needs and pellet markets already exist, are diverse, and are inside and 

26 outside of the United States. To that point, the Project Sponsors have giant miscanthus 

27 tonnage contracts with farmers with commercial heating needs, and large scale aggregators 

28 of biomass.

29 2.2.2.5 Paragould Proposed Project Area

30 In the spring of 2011, the Project Sponsors have obtained initial commitments from farmers 

31 to plant between 100 to 600 propagation acres of giant miscanthus, which will be replanted 

32 into plantation acres in 2012. MFA Oil Biomass will utilize its 40,000 cooperative members 
ALTERNATIVE INCLUDING THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-13

1 to scale up to 50,000 acres of miscanthus by 2014, which will enable the Project Sponsors’ 

2 conversion facility to process 600,000 tons of biomass each year. The Project Sponsors’ 

3 conversion facility is utilizing existing pelletizing technology that is energy efficient, mobile, 

4 flexible in maintenance and product, and able to be scaled by combining smaller units using 

5 one conveyor and control system. As the economic feasibility establishes, scalability greatly

6 increases the probability of success as expenditures will meet developing tonnage needs 

7 and pellet markets already exist, are diverse, and are inside and outside of the United 

8 States. To that point, the Project Sponsors have giant miscanthus tonnage contracts with 

9 farmers with commercial heating needs, and large scale aggregators of biomass.

10 2.3 RESOURCES CONSIDERED BUT ELIMINATED FROM DETAILED ANALYSIS

11 As mentioned previously, this EA is being tiered from the BCAP Final PEIS, as such certain 

12 resource areas are being excluded from this analysis consistent with the BCAP Final PEIS,

13 due to little or no affects to these resource areas due to their absence within the proposed 

14 project areas or limitations on effects by program guidelines. Those resources areas being 

15 excluded from this analysis include:

16 Wetlands – were eliminated from detailed analysis in this EA since the conversion of 

17 wetland is prohibited under BCAP;

18 Floodplains – were eliminated from detailed analysis in this EA, since there is little 

19 potential for effect from agricultural production in floodplains; 

20 Regulated Coastal Zones – were eliminated from detailed analysis in this EA, since 

21 the proposed project areas are not located within any coastal areas or managed 

22 coastal zones; 

23 Prime and Unique Farmland – were eliminated from detailed analysis in this EA, 

24 since they are exempt from coordination with the NRCS due to the continued 

25 agricultural production of these areas rather than conversion into other land uses;

26 Environmental Justice – was eliminated from detailed analysis in this EA, since a 

27 determination at the programmatic level was undertaken in the BCAP Final PEIS and 

28 it was found to not result in any disproportionate effects to minority or low-income 

29 populations;

30 Cultural Resources – was eliminated from detailed analysis in this EA, since this is 

31 a site specific issue and will be addressed during the completion of the 
ALTERNATIVE INCLUDING THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-14

1 environmental evaluation as part of the conservation or forest stewardship planning 

2 requirement for each individual producer BCAP contract;

3 Noise – was eliminated from detailed analysis in this EA, since the effects would be 

4 minor, only temporarily occurring during activities, and would be similar to agricultural 

5 activities currently taking place within the proposed project areas.

6 Additionally, other resources that were analyzed within the BCAP Final PEIS and are being 

7 eliminated in this EA due to the minor and insubstantial effects that could occur from the 

8 implementation of the Proposed Action or No Action Alternative include:

9 Air Quality – was eliminated from detailed analysis in this EA due to the similarity 

10 between the proposed activities within each of the proposed project areas and 

11 existing agricultural activities within those areas. All counties located within the 

12 proposed project areas are rural or semi-rural and the majority of the land use in 

13 these counties in agriculture. As such, the additional agricultural use anticipated to 

14 be produced should not introduce any additional significant emissions. As such, the 

15 project is not expected to significantly impact the air quality in the proposed project 

16 areas. However, a quick analysis of the attainment status based on the National 

17 Ambient Air Quality Standards (NAAQS) was conducted for each county within the 

18 proposed project areas. Pennsylvania has designations for the following criteria 

19 pollutants: carbon monoxide (CO), particulate matter (PM10, PM2.5,) 1-hour ozone, 8-

20 hour ozone, and sulfur dioxide (SO2). All counties in the proposed project area are 

21 designated as in attainment for all criteria pollutants. Missouri has designations for 

the following criteria pollutants: lead (Pb), 8-hour ozone, and PM2.5. 22 According to 

23 Missouri Department of Natural Resources Air Pollution Control Division 

24 (MDNRAPCD), SO2 designations are being released within the next month. All 

25 counties in the proposed project areas are designated as in attainment for all criteria 

26 pollutants including SO2. Arkansas has designations for the following criteria 

pollutants: Pb, SO2, (nitrogen dioxide) NO2, CO, PM10, and PM2.5. 27 All counties in the 

28 proposed project area are designated as in attainment for all criteria pollutants.

29 Ohio has designations for the following criteria pollutants: CO, Pb, NO2, PM10 and 

30 PM2.5, 1-hour ozone, and 8-hour ozone. All Ohio counties in the proposed project 

31 area were designated as in attainment for 1-hour and 8-hour ozone, PM10, Pb, NO2, 

32 and CO. Geauga and Trumbell counties are designated as in attainment for PM2.5. 

33 However, Lake County is designated as in full non-attainment for PM2.5 and 
ALTERNATIVE INCLUDING THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-15

1 Ashtabula County as partial non-attainment for PM2.5. Lake County and Ashtabula 

2 County are part of the Cleveland-Akron-Lorain Air Quality Control Region (AQCR) 

3 174. PM2.5 pollutants are considered fine particles being less than 2.5 micrometers 

4 in diameter. These particles are so small they can be detected only with an electron 

5 microscope. Sources of fine particles include all types of combustion, including 

6 motor vehicles, power plants, residential wood burning, forest fires, agricultural 

7 burning, and some industrial processes (U.S. Environmental Protection Agency 

8 [EPA] 2011). The 2005 Emissions Inventory for Ohio (EPA 2006) indicates that Lake 

9 County had 3,310 tons per year (tpy) of PM2.5 emissions with electric generating 

10 units accounting for greater than 80 percent of the pollutant load, non-road emissions 

11 (e.g., diesel engines from construction and agricultural equipment) accounted for 

12 approximately 6.6 percent of pollutant load. In Ashtabula County 1,407 tpy were 

13 monitored in 2005, with 27.1 percent generated from non-road emissions, other 

14 stationary sources accounted for 62 percent of the pollutant load. The Ohio 

15 Environmental Protection Agency (OEPA) has requested a Clean Data assessment 

16 from the EPA to remove the 1997 PM2.5 nonattainment status for counties in Ohio 

17 (OEPA 2010). The OEPA provided monitoring data from the Lake County air quality 

18 monitoring station that indicated that the three-year average was 11.9 micrograms 

per cubic meter of air (μg/m3

), which is below the 15 μg/m3 19 primary NAAQS 

20 standard. There are no monitoring stations located in Ashtabula County. Overall, it 

21 would be anticipated that agricultural equipment necessary for the establishment, 

22 harvesting, and transportation of giant miscanthus would provide a minimum amount 

23 of the PM2.5 particulate load within these two counties based on the high level of 

24 electric generating units in Lake County and the proximity to the Cleveland, Ohio 

25 metropolitan area. 

26 Recreation – was eliminated from detailed analysis in this EA, since the effect to 

27 outdoor recreation was determined to be minor, on the whole, from the BCAP Final 

28 PEIS and would be site-specific based on the practices of the individual BCAP 

29 contract producers. 

30 
ALTERNATIVE INCLUDING THE PROPOSED ACTION

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 2-16

1 2.4 COMPARISONS OF THE ALTERNATIVES

2 Table 2-4 provides a tabular summary of the potential effects from both the Proposed Action 

3 and No Action Alternative. As described previously, the No Action Alternative would not 

4 meet the purpose and need as described, but is the baseline to which the Proposed Action 

5 is compared to determine effects to the analyzed environmental resource areas. 

6 Table 2-4. Comparison of the Alternatives

Resource Area Proposed Action No Action Alternative

Socioeconomics + minor 0

Land Use - minor 0

Biological Resources

Vegetation - minor 0

Wildlife - minor 0

Protected Species 0 0

Soil Resources + minor (primarily during 

establishment)

0/- minor

Water Quality/Quantity

Water Quality + minor 0

Water Quantity +/- minor 0

7 Note:

8 + =positive - =negative 0 =neutral

9
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-1

1 3 AFFECTED ENVIRONMENT (BY RESOURCE AREA) 

2 3.1 SOCIOECONOMICS

3 3.1.1 Definition of the Resource

4 Socioeconomic analyses generally include detailed investigations of the prevailing 

5 population, income, employment, and housing conditions of a community or Region of 

6 Influence (ROI). The socioeconomic conditions of a ROI could be affected by changes in 

7 the rate of population growth, changes in the demographic characteristics of a ROI, or 

8 changes in employment within the ROI caused by the implementation of the proposed 

9 action.

10 Socioeconomic resources within this document include general agricultural characteristics 

11 associated with number of farms, acres of primary field crops, and revenues generated from 

12 primary field crops. Additionally, a brief analysis of rural population trends is discussed. 

13 3.1.2 Existing Conditions

14 3.1.2.1 Number of Farms and Land in Farms

15 From 1997 to 2007, the number of farms in the United States declined 0.5 percent (USDA 

16 2009b). Most farm categories declined from 1997 to 2007, with the number of acres in 

17 farms declining 3.4 percent, the average size of farms declining by 3.0 percent, the amount 

18 of cropland declining by 8.7 percent, and the amount of harvested cropland acreage 

19 declining by 2.9 percent (Ibid). The average market value of land and buildings increased 

20 approximately 90.2 percent for the average farm and approximately 95.7 for the average 

21 acre (Ibid). Farm production expenses also showed an increase of approximately 52.8 

22 percent over the decade. When compared by type of farm, the largest number of farms in 

23 the United States falls within the small family farm – residential or lifestyle farm. For the 

24 majority, the largest number of farms in the proposed project areas fall within the small 

25 family farm – residential or lifestyle farm (Table 3-1).

26
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-2

1 Table 3-1. Number of Farms by Farm Typology, 2007

Location Item Total 

Small Family Farms 

Large 

family 

Very 

large 

family 

Nonfamily Limited 

resource Retirement 

Residential/ 

lifestyle 

Farming 

occupation/ 

lower sales 

Farming 

occupation/ 

higher sales 

Arkansas

Arkansas

Number 49,346 7,581 9,932 18,434 4,797 953 1,727 4,135 1,787 

% 100 15 20 37 10 2 3 8 4 

Clay

Number 731 104 127 208 78 54 37 88 35 

% 100 14 17 28 11 7 5 12 5 

Craighead

Number 1,191 56 253 111 34 38 545 110 44 

% 100 5 21 9 3 3 46 9 4 

Greene

Number 770 93 164 290 79 26 34 63 21 

% 100 12 21 38 10 3 4 8 3 

Jackson

Number 445 34 59 134 43 39 50 49 37 

% 100 8 13 30 10 9 11 11 8 

Lawrence 

Number 592 67 102 195 74 29 39 58 28 

% 100 11 17 33 13 5 7 10 5 

Mississippi

Number 369 25 31 78 36 15 43 121 20 

% 100 7 8 21 10 4 12 33 5 

Poinsett

Number 418 27 40 88 43 11 62 102 45 

% 100 6 10 21 10 3 15 24 11 

Randolph

Number 766 149 135 340 69 8 12 42 11 

% 100 19 18 44 9 1 2 5 1 

Missouri

Missouri

Number 108,098 15,785 23,491 42,987 12,525 3,931 2,810 2,861 3,708 

% 100 15 22 40 12 4 3 3 3 

Boone

Number 1,322 180 264 648 112 20 23 12 63 

% 100 14 20 49 8 2 2 1 5 

Callaway

Number 1,503 198 374 642 158 29 22 25 55 

% 13 25 43 11 2 1 2 4 

Cole

Number 1,103 163 287 503 95 20 11 7 17 

% 100 15 26 46 9 2 1 1 2 

Cooper

Number 942 110 175 363 114 40 53 34 53 

% 100 12 19 39 12 4 6 4 6 

Howard

Number 867 101 175 373 100 46 26 13 33 

% 100 12 20 43 12 5 3 1 4 

Moniteau

Number 1,138 136 242 477 130 44 25 47 37 

% 100 12 21 42 11 4 2 4 3 

Randolph

Number 1,000 161 232 448 82 23 7 14 33 

% 100 16 23 45 8 2 1 1 3 

Audrain

Number 1,102 96 198 386 157 89 80 57 39 

% 100 9 18 35 14 8 7 5 4 

Monroe

Number 1,036 126 236 402 117 43 28 34 50 

% 100 12 23 39 11 4 3 3 5 

Barry

Number 1,606 239 303 620 174 32 22 165 51 

% 100 15 19 39 11 2 1 10 3 

Christian

Number 1,265 236 311 541 106 22 10 7 32 

% 100 19 25 43 8 2 1 1 3 

Dade

Number 883 124 195 343 129 31 17 21 23 

% 100 14 22 39 15 4 2 2 3 

Jasper

Number 1,369 207 302 546 177 48 14 35 40 

% 100 15 22 40 13 4 1 3 3 

Lawrence

Number 1,873 275 343 802 261 60 24 48 60 

% 100 15 18 43 14 3 1 3 3 

Newton

Number 1,590 244 378 643 168 26 12 84 35 

% 100 15 24 40 11 2 1 5 2 

Stone Number 753 125 147 349 90 10 8 8 16 
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-3

Location Item Total 

Small Family Farms 

Large 

family 

Very 

large 

family 

Nonfamily Limited 

resource Retirement 

Residential/ 

lifestyle 

Farming 

occupation/ 

lower sales 

Farming 

occupation/ 

higher sales 

% 100 17 20 46 12 1 1 1 2 

Ohio

Ohio

Number 75,861 9,670 15,071 30,434 8,989 3,556 3,087 2,781 2,273 

% 100 13 20 40 12 5 4 4 3 

Ashtabula

Number 1,127 193 258 381 182 43 27 19 24 

% 100 17 23 34 16 4 2 2 2 

Geauga

Number 888 152 142 326 202 16 14 7 29 

% 100 17 16 37 23 2 2 1 3 

Lake

Number 259 47 47 78 33 11 7 12 24 

% 100 18 18 30 13 4 3 5 9 

Trumbull

Number 970 170 232 348 127 33 22 9 29 

% 100 18 24 36 13 3 2 1 3 

Pennsylvania

Pennsylvania

Number 63,163 10,230 11,755 22,563 7,533 4,644 2,589 2,003 1,846 

% 100 16 19 36 12 7 4 3 3 

Crawford

Number 1,468 274 249 514 231 90 65 17 28 

% 100 19 17 35 16 6 4 1 2 

Erie

Number 1,609 278 386 604 158 84 38 18 43 

% 100 17 24 38 10 5 2 1 3 

Mercer

Number 1,210 216 253 421 166 76 33 20 25 

% 100 18 21 35 14 6 3 2 2 

1 Source: USDA, 2009

2 3.1.2.2 Primary Field Crops

3 The 2003 National Resources Inventory indicates that approximately 368 million acres 

4 within the United States is cultivated cropland and 58 million acres is uncultivated cropland. 

5 In 1992, those figures were 334 million acres of cultivated cropland and 47 million acres of 

6 uncultivated cropland. Table 3-2 illustrates the amount of acreage planted of select primary 

7 field crops in 2010, along with harvested acres of those crops, and total production of the 

8 crops (USDA 2009). As shown in the table, a majority of the counties had corn (grain) and 

9 soybean planted, harvested and production in 2010. 

10
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-4

1 Table 3-2. Planted Acres, Harvested Acres, and 

2 Production of Select Field Crops in the Project Counties (2010).

Area Crop Type Planted Acres Harvested Acres Production

Arkansas

Arkansas

State Totals

Corn (Grain) 390,000 380,000 57,000,000 

Cotton, Upland (2008) 620,000 615,000 1,296,000

Sorghum (Grain) 40,000 35,000 2,695,000 

Rice All (2008) 1,401,000 1,395,000 92,938,000

Soybeans 3,190,000 3,150,000 110,250,000 

Wheat All (2008) 1,070,000 980,000 55,860,000

Clay

Corn (Grain) 23,600 23,500 3,666,000 

Cotton Upland, All (2008) 28,500 28,400 60,500

Rice All (2008) 76,200 75,300 5,208,100

Soybeans 103,500 103,000 3,900,000 

Wheat, All (2008) 20,000 17,000 765,000

Craighead

Corn (Grain) 20,200 20,200 3,426,000 

Cotton, Upland (2008) 73,200 72,900 154,000

Rice All (2008) 79,000 78,500 5,385,100

Soybeans 105,500 102,700 3,976,000 

Wheat All (2008) 25,000 23,000 1,220,000

Greene

Corn (Grain) 11,100 11,000 1,749,000 

Cotton, Upland (2008) 8,500 8,400 17,500

Rice All (2008) 80,500 79,900 5,446,300

Soybeans 76,400 75,400 2,405,000 

Wheat All (2008) 19,000 18,000 850,000

Jackson

Corn (Grain) 7,900 7,800 1,170,000 

Rice All (2008) 95,000 93,600 6,229,800

Soybeans 129,000 124,500 3,104,000 

Wheat All (2008) 57,000 52,000 2,330,000

Lawrence

Corn (Grain) 1,800 1,800 288,000 

Sorghum (Grain) 1,200 1,000 30,000 

Rice All (2008) 99,000 98,500 6,08,7,300

Soybeans 65,100 63,900 1,815,000 

Mississippi

Corn (Grain) 19,300 18,900 3,137,000 

Cotton, Upland (2008) 179,500 177,800 371,200

Sorghum (Grain) 1,200 1,100 62,000 

Rice All (2008) 44,300 44,000 3,115,200

Soybeans 255,500 254,700 8,820,000 

Wheat All (2008) 44,000 36,000 2,160,000

Poinsett

Corn (Grain) 10,100 9,800 1,499,000 

Cotton, Upland (2008) 39,800 39,600 88,000

Rice All (2008) 120,000 119,000 8,278,400

Soybeans 170,800 166,900 5,875,000 

Wheat All (2008) 38,000 35,000 1,860,000

Randolph

Corn (Grain) 4,900 4,900 637,000 

Rice All (2008) 33,500 33,400 2,237,800

Soybeans 31,600 31,200 1,063,000 

Missouri

Missouri

State Totals

Corn (Grain) 3,150,000 3,000,000 369,000,000 

Hay All (Dry) (2008) 4,200,000 8,820,000

Sorghum (Grain) 40,000 33,000 2,574,000 

Soybeans 5,150,000 5,070,000 210,405,000 

Wheat All (2008) 1,250,000 1,160,000 55,680,000

Boone

Corn (Grain) 25,700 24,400 2,806,000 

Hay All (Dry) (2008) 44,000 86,000

Sorghum (Grain) 1,000 900 64,800 

Soybeans 40,500 39,900 1,643,000 

Wheat All (2008) 12,400 12,200 569,600
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-5

Area Crop Type Planted Acres Harvested Acres Production

Callaway

Corn (Grain) 30,600 29,800 4,052,000 

Hay All (Dry) (2008) 49,000 99,000

Sorghum (Grain) 1,700 1,500 133,000 

Soybeans 58,400 57,600 2,588,000 

Wheat All (2008) 14,300 13,300 568,100

Cole

Corn (Grain) 5,100 4,600 608,000 

Hay All (Dry) (2008) 41,000 95,000

Soybeans 10,000 9,800 440,000 

Cooper

Corn (Grain) 48,600 47,800 6,231,000 

Hay All (Dry) (2008) 34,000 70,000

Soybeans 70,800 70,400 3,177,000 

Wheat All (2008) 20,900 20,400 1,120,000

Howard

Corn (Grain) 34,700 33,700 4,157,000 

Hay All (Dry) (2008) 28,000 59,000

Soybeans 41,900 41,600 1,839,000 

Wheat All (2008) 10,500 10,300 453,800

Moniteau

Corn (Grain) 11,300 10,800 1,198,000 

Hay All (Dry) (2008) 52,000 112,000

Soybeans 21,200 21,100 981,000 

Wheat All (2008) 7,400 7,000 298,500

Randolph

Corn (Grain) 16,800 14,500 1,403,000 

Hay All (Dry) (2008) 36,000 76,000

Soybeans 45,600 45,200 1,735,000 

Wheat All (2008) 10,300 9,500 453,100

Audrain

Corn (Grain) 94,800 91,500 11,186,000 

Hay All (Dry) (2008) 25,000 57,000

Sorghum (Grain) 4,200 3,900 302,000 

Soybeans 167,000 164,900 7,451,000 

Wheat All (2008) 37,400 36,300 1,785,000

Monroe

Corn (Grain) 56,100 53,500 5,485,000 

Hay All (Dry) (2008) 33,000 72,000

Sorghum (Grain) 1,600 1,400 142,000 

Soybeans 86,800 86,000 3,745,000 

Wheat All (2008) 15,500 15,200 649,100

Barry

Corn (Grain) 3,600 3,000 333,000 

Hay All (Dry) (2008) 72,000 176,000

Soybeans 2,000 1,900 58,000 

Wheat All (2008) 1,300 1,000 38,700

Christian Corn (Grain) 700 600 59,900 

Hay All (Dry) (2008) 46,000 111,000

Dade

Corn (Grain) 15,300 14,400 1,552,000 

Hay All (Dry) (2008) 64,000 114,000

Sorghum (Grain) 1,000 900 80,400 

Soybeans 26,800 26,600 918,000 

Wheat All (2008) 26,500 24,800 1,049,000

Jasper

Corn (Grain) 29,000 28,100 3,615,000 

Hay All (Dry) (2008) 58,000 109,000

Sorghum (Grain) 700 500 38,900 

Soybeans 45,900 45,400 1,532,000 

Wheat All (2008) 28,500 27,500 1,154,000

Lawrence

Corn (Grain) 9,400 8,400 778,000 

Hay All (Dry) (2008) 88,000 202,000

Soybeans 9,400 9,300 278,000 

Wheat All (2008) 6,600 5,100 219,500

Newton Hay All (Dry) (2008) 87,000 204,000

Soybeans 5,100 5,000 137,000 

Wheat All (2008) 4,200 3,100 129,600
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-6

Area Crop Type Planted Acres Harvested Acres Production

Stone Corn (Grain) 500 300 26,800 

Hay All (Dry) (2008) 19,000 34,000

Ohio

Ohio

State Totals

Corn (Grain) 3,450,000 3,270,000 533,010,000 

Hay All (Dry) (2008) 1,140,000 2,802,000

Oats 65,000 50,000 3,500,000 

Soybeans 4,600,000 4,590,000 220,320,000 

Wheat All (2008) 1,120,000 1,090,000 74,120,000

Ashtabula

Corn (Grain) 20,200 19,200 2,965,000 

Hay All (Dry) (2008) 27,000 71,700

Soybeans 32,000 31,800 1,588,000 

Geauga

Corn (Grain) 3,100 2,800 396,000 

Hay All (Dry) (2008) 12,600 31,700

Oats 900 850 68,700 

Lake Hay All (Dry) (2008) 3,200 5,800

Trumbull

Corn (Grain) 19,900 18,600 2,974,000 

Hay All (Dry) (2008) 15,200 36,300

Oats 2,100 2,020 165,000 

Soybeans 26,300 26,200 1,220,000 

Wheat All (2008) 6,000 5,800 400,200

Pennsylvania

Pennsylvania

State Totals

Corn (Grain) 1,350,000 910,000 116,480,000 

Hay, All (Dry) (2008) 1,750,000 3,810,000

Oats 110,000 80,000 4,720,000 

Soybeans 500,000 495,000 20,790,000 

Wheat All (2008) 195,000 185,000 11,840,000

Crawford

Corn (Grain) 35,000 25,600 3,529,000 

Hay All (Dry) (2008) 48,300 116,400

Oats 5,600 4,300 264,000 

Soybeans 20,000 19,900 896,000 

Erie

Corn (Grain) 22,000 18,500 2,536,000 

Oats 3,000 2,500 158,000 

Soybeans 10,500 10,400 441,000 

Wheat All (2008) 3,600 3,400 168,000

Mercer

Corn (Grain) 38,000 32,000 4,677,000 

Hay All (Dry) (2008) 35,700 88,400

Oats 4,300 3,500 208,000 

Soybeans 17,700 17,600 825,000 

Wheat All (2008) 4,200 4,100 214,000

Source: USDA 2009

1 3.1.2.3 Primary Livestock Industries

2 The primary livestock industries across the proposed project areas are cattle for all states in 

3 addition to sheep in Ohio and Pennsylvania. Table 3-3 lists the most recent data on 

4 livestock numbers by type and by county. Only Lake County, Ohio did not contain any 

5 reportable or discloseable level of cattle. The Aurora and Columbia proposed project areas 

6 contributed approximately 19.5 percent of all cattle in Missouri. Both the Paragould and 

7 Ashtabula proposed project areas accounted for five percent or less for their state totals. 

8 The Ashtabula proposed project area accounted for approximately three percent of the 

9 sheep in Ohio and Pennsylvania. 
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-7

1 Table 3-3. Primary Livestock Activities by 

2 County within the Proposed Project Areas

Area Livestock Number of Head

Arkansas

Arkansas State Totals Cattle All (2010) 1,890,000

Clay Cattle All (2010) 8,200

Craighead Cattle All (2010) 12,300

Greene Cattle All (2010) 7,400

Jackson Cattle All (2010) 10,500

Lawrence Cattle All (2010) 18,200

Mississippi Cattle All (2010) 1,700

Poinsett Cattle All (2010) 2,000

Randolph Cattle All (2010) 35,500

Missouri

Missouri State Totals Cattle All (2010) 4,150,000

Boone Cattle All (2010) 30,500

Callaway Cattle All (2010) 39,000

Cole Cattle All (2010) 42,500

Cooper Cattle All (2010) 55,000

Howard Cattle All (2010) 25,500

Moniteau Cattle All (2010) 75,000

Randolph Cattle All (2010) 30,500

Audrain Cattle All (2010) 39,000

Monroe Cattle All (2010) 28,500

Barry Cattle All (2010) 83,000

Christian Cattle All (2010) 49,500

Dade Cattle All (2010) 60,000

Jasper Cattle All (2010) 51,000

Lawrence Cattle All (2010) 100,000

Newton Cattle All (2010) 74,000

Stone Cattle All (2010) 26,500

Ohio

Ohio State Totals Cattle All (2010) 1,280,000

Sheep and Lambs (2008) 125,000

Ashtabula Cattle All (2010) 18,700

Sheep and Lambs (2008) 600

Geauga Cattle All (2010) 7,800

Sheep and Lambs (2008) 1,300

Lake Sheep and Lambs (2008) 200

Trumbull Cattle All (2010) 11,800

Sheep and Lambs (2008) 200

Pennsylvania

Pennsylvania State 

Totals

Cattle All (2010) 1,620,000

Sheep and Lambs (2008) 98,000

Crawford Cattle All (2010) 42,500

Sheep and Lambs (2008) 2,000

Erie Cattle All (2010) 14,200

Sheep and Lambs (2008) 600

Mercer Cattle All (2010) 28,500

Sheep and Lambs (2008) 2,500

3 Source: USDA NASS 2011. 

4
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-8

1 3.1.2.4 Rural Population Trends

2 The USDA Economic Research Service (ERS) found that by 2006 non-metro counties in the 

3 United States accounted for a population of approximately 50.2 million persons, which is 

4 approximately 16.8 percent of the total United States population (ERS 2008; U.S. Census 

5 Bureau [USCB] 2008). The general trend in these counties was a decline in the population 

6 with over 51 percent of the non-metro counties experiencing population declines of 

7 approximately 0.5 percent per year from 2000 to 2006. 

8 3.1.2.5 Farm Income and Cost

9 The ERS (USDA 2011c) indicated that net farm income in 2011 is projected to be above the 

10 2010 forecast by 19.8 percent. Net farm income was estimated to be approximately $94.1 

11 billion in 2011 with net cash income of $98.6 billion. Total expenses in the agricultural 

12 sector are anticipated to increase by $20.2 billion, exceeding $300 billion for the first time. 

13 Crop receipts were estimated to increase to $24.1 billion. 

14 At the household level, the average family farm household income for 2010 was estimated 

15 to be $83,021, an increase of 7.6 percent from 2009. The ERS anticipates that in 2011

16 approximately 12.9 percent of average family farm household income was generated from 

17 on-farm sources with an average of approximately $75,178 of household income generated 

18 from off-farm sources (Ibid).

19 3.2 LAND USE

20 3.2.1 Definition of the Resource

21 Land use analysis primarily details the interactions of humans and their environment, both 

22 natural and human-induced. Such analyses address how different land uses currently 

23 interact and if there would be conflict between new and existing land uses. In urban areas, 

24 land uses are primarily controlled for public health and safety concerns through land use 

25 zoning mechanisms. In rural areas, land use restrictions may be developed at a county or 

26 regional scale, or land use restrictions may not exist or be limited to special public health 

27 and safety concerns. Land use within this document is being described as the acreage 

28 within cropland and permanent pasture since these lands uses are being proposed for 

29 conversion into a dedicated energy crop land use. 
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-9

1 3.2.2 Existing Conditions

2 The 2007 Agricultural Census estimates the amount of land in agricultural land uses in the 

3 United States. Tables 3-4 through 3-7 illustrate the agricultural lands defined by land use 

4 categories and sub-categories in the proposed project area counties. From land use 

5 categories, harvested cropland as a percentage of total land in farms can be derived;

6 indicating harvested cropland is a dominant land use in the Ashtabula (52.5 percent) and 

7 Paragould (81.7 percent) proposed project areas. In the Aurora (32.9 percent) and 

8 Columbia (44.9 percent) proposed project areas, harvested cropland is a prominent land 

9 use category; however, pastureland, of all types (cropland, pastureland; woodland, 

10 pastured; and permanent pasture and rangeland) account for 55.4 percent and 29.3 percent 

11 of the proposed project areas, respectively. 

12 Figure 3-1 provides an illustration of percentage of total farmland in each of the proposed 

13 project areas, while Figure 3-2 illustrates the percentage of cropland and pastureland within 

14 each proposed project area. 
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-10

1 Table 3-4. Farmland Land Use Categories and 

2 Sub-Categories for the Ashtabula Proposed Project Area

Land Use Type

Ohio Ashtabula Geauga Lake Trumbull Pennsylvania Crawford Erie Mercer

(Acres 2007)

Approximate land area 26,149,825 449,244 256,106 146,267 395,084 28,631,687 648,136 509,921 429,980

Land in farms 13,956,563 161,698 56,558 16,065 125,136 7,809,244 232,093 173,125 171,860

Total cropland 10,832,772 106,255 29,541 10,126 87,440 4,870,287 139,526 101,698 111,556

Total woodland 1,473,638 34,898 14,389 2,931 21,631 1,717,791 55,047 41,485 32,028

Permanent pasture and 

rangeland, other than 

cropland and woodland 

pastured 1,046,728 10,461 7,768 1,012 8,962 732,275 21,614 15,495 17,130

Land in farmsteads, 

buildings, livestock 

facilities, ponds, roads, 

wasteland, etc. 603,425 10,084 4,860 1,996 7,103 488,891 15,906 14,447 11,146

Total Cropland 

Harvested cropland 9,991,007 93,639 23,413 7,316 80,484 3,942,079 114,671 77,909 94,618

Cropland used only for 

pasture or grazing 348,923 4,173 2,913 364 2,416 397,131 10,575 7,769 7,174

Other cropland 492,842 8,443 3,215 2,446 4,540 531,077 14,280 16,020 9,764

Cropland on 

which all crops 

failed 42,855 1,252 705 179 576 51,177 1,441 1,691 1,259

Cropland idle or 

used for cover 

crops or soil 

improvement, but 

not harvested and 

not pastured or 

grazed 449,987 7,191 2,510 2,267 3,964 443,785 9,550 13,449 7,404

Cropland in 

cultivated summer 

fallow - - - - - 36,115 3,289 880 1,101

Total Woodland 

Woodland not 

pastured 1,194,513 32,299 12,072 2,772 18,603 1,567,607 49,293 37,227 28,084

Woodland pastured 279,125 2,599 2,317 159 3,028 150,184 5,754 4,258 3,944

Pastureland, All Types 1,674,776 17,233 12,998 1,535 14,406 1,279,590 37,943 27,522 28,248

Permanent pasture 

and rangeland, other 

than cropland and 

woodland pastured 1,046,728 10,461 7,768 1,012 8,962 732,275 21,614 15,495 17,130

Cropland used only 

for pasture or 

grazing 348,923 4,173 2,913 364 2,416 397,131 10,575 7,769 7,174

Woodland pastured 279,125 2,599 2,317 159 3,028 150,184 5,754 4,258 3,944

Conservation Acres -

CRP, WRP, Farmable 

Wetlands, and CREP 385,442 2,181 196 - 1,113 232,543 4,792 3,478 2,036

3 Source: Adapted from USDA NASS 2007

4
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-11

1 Table 3-5. Farmland Land Use Categories and 

2 Sub-Categories for the Aurora Proposed Project Area (2007)

Land Use Type

Missouri Barry Christian Dade Jasper Lawrence Newton Stone

Acres (2007)

Approximate land area 43,974,665 498,075 360,110 313,616 408,645 391,510 399,846 296,980

Land in farms 29,026,573 289,626 189,177 276,229 258,815 322,822 245,892 121,792

Total cropland 16,405,595 114,244 76,040 127,080 135,730 150,703 107,943 36,790

Total woodland 4,414,396 51,481 33,465 28,031 21,199 33,879 33,989 28,625

Permanent pasture and rangeland, 

other than cropland and woodland 

pastured 6,864,391 113,402 71,100 114,815 88,631 126,177 93,902 53,240

Land in farmsteads, buildings, 

livestock facilities, ponds, roads, 

wasteland, etc. 1,342,191 10,499 8,572 6,303 13,255 12,063 10,058 3,137

Total Cropland 

Harvested cropland 12,980,113 77,319 52,185 105,106 110,017 112,839 81,364 22,203

Cropland used only for pasture or 

grazing 1,858,684 31,869 21,001 15,136 14,855 30,001 19,908 12,860

Other cropland 1,566,798 5,056 2,854 6,838 10,858 7,863 6,671 1,727

Cropland on which all crops 

failed 118,387 526 (D) 721 2,039 364 961 224

Cropland idle or used for cover 

crops or soil improvement, but 

not harvested and not pastured 

or grazed 1,374,183 4,212 2,213 5,571 8,421 6,779 5,540 1,503

Cropland in cultivated summer 

fallow 74,228 318 - 546 398 720 170 -

Total Woodland 

Woodland not pastured 2,548,059 20,690 14,363 7,466 9,159 15,156 14,288 12,122

Woodland pastured 1,866,337 30,791 19,102 20,565 12,040 18,723 19,701 16,503

Pastureland, All Types 10,589,412 176,062 111,203 150,516 115,526 174,901 133,511 82,603

Permanent pasture and rangeland, 

other than cropland and woodland 

pastured 6,864,391 113,402 71,100 114,815 88,631 126,177 93,902 53,240

Cropland used only for pasture or 

grazing 1,858,684 31,869 21,001 15,136 14,855 30,001 19,908 12,860

Woodland pastured 1,866,337 30,791 19,102 20,565 12,040 18,723 19,701 16,503

Conservation Acres - CRP, WRP, 

Farmable Wetlands, and CREP 1,691,694 978 855 5,902 12,551 7,968 3,955 -

3 Source: Adapted from USDA NASS 2007

4
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-12

1 Table 3-6. Farmland Land Use Categories and 

2 Sub-Categories for the Columbia Proposed Project Area (2007)

Land Use Type

Missouri Audrain Boone Callaway Cole Cooper Howard Moniteau Monroe Randolph

(Acres 2007)

Approximate land 

area 43,974,665 443,029 438,428 534,121 250,525 360,999 296,862 265,616 414,507 308,737

Land in farms 29,026,573 424,880 258,734 322,929 180,840 302,429 276,590 242,946 288,293 221,647

Total cropland 16,405,595 337,854 152,527 166,339 79,523 189,065 172,316 122,630 183,346 119,856

Total woodland 4,414,396 26,308 38,532 63,853 42,655 39,984 38,944 37,496 44,391 37,022

Permanent pasture 

and rangeland, other 

than cropland and 

woodland pastured 6,864,391 42,271 54,510 77,798 50,769 62,895 49,924 69,372 44,555 51,331

Land in farmsteads, 

buildings, livestock 

facilities, ponds, 

roads, wasteland, 

etc. 1,342,191 18,447 13,165 14,939 7,893 10,485 15,406 13,448 16,001 13,438

Total Cropland 

Harvested cropland 12,980,113 308,285 121,717 135,285 59,816 151,755 131,709 89,403 142,075 86,479

Cropland used only 

for pasture or 

grazing 1,858,684 11,727 17,088 16,106 15,319 19,234 17,289 22,918 15,445 11,727

Other cropland 1,566,798 17,842 13,722 14,948 4,388 18,076 23,318 10,309 25,826 21,650

Cropland on 

which all crops 

failed 118,387 498 3,150 711 276 580 290 1,308 723 495

Cropland idle 

or used for 

cover crops or 

soil 

improvement, 

but not 

harvested and 

not pastured or 

grazed 1,374,183 16,053 9,865 13,287 3,346 15,641 22,468 8,634 24,016 20,626

Cropland in 

cultivated 

summer fallow 74,228 1,291 707 950 766 1,855 560 367 1,087 529

Total Woodland 

Woodland not 

pastured 2,548,059 18,201 25,395 42,574 16,492 21,187 26,166 14,153 30,449 25,164

Woodland 

pastured 1,866,337 8,107 13,137 21,279 26,163 18,797 12,778 23,343 13,942 11,858

Pastureland, All 

Types 10,589,412 62,105 84,735 115,183 92,251 100,926 79,991 115,633 73,942 74,916

Permanent 

pasture and 

rangeland, other 

than cropland and 

woodland 

pastured 6,864,391 42,271 54,510 77,798 50,769 62,895 49,924 69,372 44,555 51,331

Cropland used 

only for pasture or 

grazing 1,858,684 11,727 17,088 16,106 15,319 19,234 17,289 22,918 15,445 11,727

Woodland 

pastured 1,866,337 8,107 13,137 21,279 26,163 18,797 12,778 23,343 13,942 11,858

Conservation Acres

- CRP, WRP, 

Farmable Wetlands, 

and CREP 1,691,694 18,310 9,958 15,199 3,367 19,998 25,125 11,486 34,628 30,192

3 Source: Adapted from USDA NASS 2007
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-13

1 Table 3-7. Farmland Land Use Categories and 

2 Sub-Categories for the Paragould Proposed Project Area (2007)

Land Use Type

Arkansas Clay Craighead Greene Jackson Lawrence Mississippi Poinsett Randolph

(acres, 2007)

Approximate land area 33,287,812 409,126 452,604 369,640 405,455 375,429 575,122 484,998 417,184

Land in farms 13,872,862 330,464 336,919 267,263 302,125 263,615 461,328 340,704 252,325

Total cropland 8,432,221 293,353 301,734 229,272 266,354 200,765 451,917 322,991 135,019

Total woodland 2,239,119 17,234 15,163 13,945 18,399 27,534 3,742 6,470 52,971

Permanent pasture and 

rangeland, other than 

cropland and woodland 

pastured 2,637,556 13,236 12,381 14,053 12,563 30,408 3,332 4,537 59,884

Land in farmsteads, 

buildings, livestock 

facilities, ponds, roads, 

wasteland, etc. 563,966 6,641 7,641 9,993 4,809 4,908 2,337 6,706 4,451

Total Cropland 

Harvested cropland 7,367,068 279,480 290,968 215,891 250,327 184,410 440,967 316,213 109,715

Cropland used only for 

pasture or grazing 724,044 4,331 4,046 4,649 5,964 10,727 5,288 4,005 21,438

Other cropland 341,109 9,542 6,720 8,732 10,063 5,628 5,662 2,773 3,866

Cropland on 

which all crops 

failed 47,770 935 1,296 849 1,699 785 1,812 568 217

Cropland idle or 

used for cover 

crops or soil 

improvement, but 

not harvested and 

not pastured or 

grazed 259,318 8,478 4,135 6,058 6,769 3,963 1,843 1,484 3,431

Cropland in 

cultivated 

summer fallow 34,021 129 1,289 1,825 1,595 880 2,007 721 218

Total Woodland 

Woodland not 

pastured 1,496,471 13,107 12,879 9,153 15,092 16,614 3,657 5,068 29,190

Woodland pastured 742,648 4,127 2,284 4,792 3,307 10,920 85 1,402 23,781

Pastureland, All Types 4,104,248 21,694 18,711 23,494 21,834 52,055 8,705 9,944 105,103

Permanent pasture 

and rangeland, other 

than cropland and 

woodland pastured 2,637,556 13,236 12,381 14,053 12,563 30,408 3,332 4,537 59,884

Cropland used only 

for pasture or 

grazing 724,044 4,331 4,046 4,649 5,964 10,727 5,288 4,005 21,438

Woodland pastured 742,648 4,127 2,284 4,792 3,307 10,920 85 1,402 23,781

Conservation Acres -

CRP, WRP, Farmable 

Wetlands, and CREP 441,655 11,054 2,647 3,366 6,575 4,389 14,477 1,810 10,273

3 Source: Adapted from USDA NASS 2007

4
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-14

1 Figure 3-1. Percent of Farmland Acres by County in the Proposed Project Areas.
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-15

1 Figure 3-2. Comparison of the Percentage of Harvested Cropland and Total 

2 Pastureland in the Proposed Project Areas.
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DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-16

1 Table 3-8 and Figure 3-3 illustrates the farmland Enrolled in Conservation Reserve 

2 Program (CRP), Wetland Reserve Program (WRP), Farmable Wetlands, or Conservation 

3 Reserve Enhancement Programs (CREP) in the proposed project areas. There was 

4 approximately 54,591 acres enrolled into conservation programs within the Paragould 

5 proposed project area, 168,263 acres within the Columbia proposed project area, 32,209 

6 acres within the Aurora proposed project area, and 13,796 acres within the Ashtabula 

7 proposed project area. 

8 Table 3-8. Farmland Enrolled in CRP, WRP, 

9 Farmable Wetlands, or CREP in the proposed project areas.

County Acres enrolled in Conservation Practices Percent of total acres 

Arkansas

Clay 11,054 2.7 

Craighead 2,647 0.6 

Greene 3,366 0.9 

Jackson 6,575 1.6 

Lawrence 4,389 1.2 

Mississippi 14,477 2.5 

Poinsett 1,810 0.4 

Randolph 10,273 2.5 

Missouri

Audrain 18,310 4.1 

Boone 9,958 2.3 

Callaway 15,199 2.8 

Cole 3,367 1.3 

Cooper 19,998 5.5 

Howard 25,125 8.4 

Moniteau 11,486 4.3 

Monroe 34,628 8.4 

Randolph 30,192 9.8 

Barry 978 0.2 

Christian 855 0.2 

Dade 5,902 1.9 

Jasper 12,551 3.1 

Lawrence 7,968 2.0 

Newton 3,955 1.0 

Stone 0 0.0 

Ohio

Ashtabula 2,181 0.5

Geauga 196 0.1

Lake 0 0.0

Trumbull 1,113 0.3

Pennsylvania

Crawford 4,792 0.7 

Erie 3,478 0.7 

Mercer 2,036 0.5 

Source: Adapted from PAPO 2011a, PAPO 2011b, PAPO 2011c, PAPO 2011d

10
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DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-17

1 Figure 3-3. Percent of Total Acres Enrolled in Conservation Programs, 2007.
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-18

1 3.3 BIOLOGICAL RESOURCES

2 3.3.1 Vegetation

3 3.3.1.1 Definition of the Resource

4 Vegetation refers to the plants, both native and introduced, of a specific region.

5 3.3.1.2 Existing Conditions

6 3.3.1.2.1 Ecoregions

7 For this project, the Level III Ecoregions will be used to illustrate the natural vegetation of 

8 each proposed project area. Figure 3-4 illustrates the ecoregions within and adjacent to the 

9 proposed project areas. 

10 3.3.1.2.1.1 Ashtabula Proposed Project Area

11 This proposed project area is dominated by the Erie Drift Ecoregion, characterized by low 

12 rounded hills, scattered end moraines and areas of wetlands. The area was historically 

13 covered by maple-beech-birch forests but much of the area has been converted to farms. A 

14 small portion of this proposed project area is also covered by the Eastern Great Lakes and 

15 Hudson Lowlands Ecoregion. This region is a coastal strip of beach ridges and swales. 

16 This area has also been converted to farming, with a large percentage of agriculture 

17 associated with dairy operations (EPA 2011). 

18 3.3.1.2.1.2 Aurora Proposed Project Area

19 This proposed project area is located within the Ozark Highlands Ecoregion. Topography 

20 varies from steep slopes near the large streams to moderate relief hills on the broad 

21 plateaus or inter-stream areas. The majority of the region is open forest or woodlands, 

22 dominated by oak or mixed stands of oak and pine. Cleared upland areas are used for 

23 pasture and livestock (EPA 2011). 

24 3.3.1.2.1.3 Columbia Proposed Project Area

25 This proposed project area is covered by three Ecoregions, Central Irregular Plains, Interior 

26 River Valleys and Hills, and Ozark Highlands. The Central Irregular Plains have a mix of 

27 land uses. The potential natural vegetation is a grassland/woodland mosaic with wider 

28 wooded strips along the streams. The grasslands are dominated mostly by tallgrass 

29 prairies. This area has now been converted to extensive cropland and pastureland. The 

30
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DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-19

1 Figure 3-4. Level III Ecoregions within and adjacent to the Proposed Project Areas.
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-20

1 Interior River Valleys and Hills Ecoregion is made up of many wide, flat-bottomed, terraced 

2 valleys, forested valley slopes, and dissected glacial-till plains. This region is generally a 

3 transitional area between the more forested areas in the Ozarks, and the flatter plains and 

4 more extensive cropland of regions to the north. The Ozarks Highlands are covered by 

5 forest or woodlands, dominated by oak or mixed stands of oak and pine (EPA 2011).

6 3.3.1.2.1.4 Paragould Proposed Project Area

7 The proposed project area is dominated by the Mississippi Alluvial Plain Ecoregion, and to a 

8 lesser extent the Mississippi Valley Loess Plain. The Mississippi Alluvial Plain is located 

9 along the Mississippi River from the confluence of the Ohio and Mississippi rivers southward 

10 to the Gulf of Mexico. This area is a broad, nearly level, agriculturally-dominated plain that 

11 provides important habitat for fish and wildlife, and includes the largest continuous system of 

12 wetlands in North America. The Mississippi Alluvial Plains is also a major bird migration 

13 corridor used in fall and spring migrations. Historically, the vegetation in this area is

14 bottomland hardwood forest and woodlands. Today many parts of the Mississippi Alluvial 

15 Plains have been cleared for cropland.

16 The Mississippi Valley Loess Plain is a small area in eastern Arkansas is composed of a 

17 small series of loess-capped hills surrounded by the Mississippi Plain. The area is made up 

18 of woodland and pastureland dominated by post oak–blackjack oak forest, southern red 

19 oak–white oak forest and beech–maple forest (EPA 2011).

20 3.3.1.2.1 Invasive and Noxious Plant Species

21 Current agricultural and conservation practices include the planting of native and introduced 

22 species and control or eradication of invasive or noxious species. The Executive Order (EO)

23 13112, Invasive Species, directs Federal agencies to prevent the introduction of invasive 

24 species and provide for their control and to minimize the economic, ecological, and human 

25 health impacts that invasive species cause unless the benefits of the introduction or spread

26 of the invasive species clearly outweigh potential harms. In addition, the Plant Protection 

27 Act (PPA), which became law in June 2000 as part of the Agricultural Risk Protection Act, 

28 consolidated all or part of 10 existing laws, applicable to USDA activities, into one 

29 comprehensive law, including the authority to regulate plants, plant products, certain 

30 biological control organisms, noxious weeds, and plant pests (APHIS 2002). EO 13112 

31 defines native species as a species that, with respect to a particular ecosystem, other than 

32 as a result of an introduction, historically occurred or currently occurs in that ecosystem. An 

33 alien or non-native species is any species, with respect to a particular ecosystem, including 
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DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-21

1 its seeds, eggs, spores, or other biological material capable of propagating that species, that 

2 is not native to that ecosystem; an invasive species is a nonnative “species whose 

3 introduction does or is likely to cause economic or environmental harm or harm to human 

4 health” (EO 13112). The PPA defines a noxious weed as any plant or plant product that can 

5 directly or indirectly bring harm to agriculture, the public health, navigation, irrigation, natural 

6 resources, or the environment; this Act expands the definition of noxious weed from the 

7 definition in the 1974 Federal Noxious Weed Act, which included only weeds that were of 

8 foreign origin, new to, or not widely prevalent in the United States (APHIS 2002). Noxious 

9 weeds are identified and listed on State and Federal lists.

10 Invasive plant species can have significant negative impacts on biological resources 

11 including decreases in native wildlife and plant species populations, alterations to rare plant 

12 communities, or changing ecological processes that native plant species and other desirable 

13 plants and wildlife depend on for survival (including impacts upon native pollinators) (NISC 

14 2008). Invasive plant species could potentially cause or vector decimating plant diseases, 

15 prevent native and agricultural species from reproducing, suppress the growth of 

16 neighboring plants, out-compete desirable species for nutrients, light, moisture or other vital 

17 resources; and adversely impact erosion rates, hydrologic regimes and soil chemistry such 

18 as pH and nutrient availability. Natural wildfire cycles could also be altered; invasions by 

19 fire-promoting grasses could alter entire plant communities, eliminating or sharply reducing 

20 populations of many native plant species (Ibid). 

21 Eradication or control of invasive and noxious species can be an arduous task often 

22 including multiple methods of treatment to be effective. The application of herbicide, 

23 grazing, burning, mechanical or manual control (cutting, excavating), and mowing are all 

24 methods that can be used to control and eradicate invasive species. While it may not be 

25 possible to fully eradicate an invasive plant species, management activities can control 

26 further spread or takeover. Some species of invasive plants require timed treatment for 

27 eradication or control such as when the plant is dormant, young, or prior to 

28 flowering/seeding. Additionally, vegetation may become accustomed to certain methods of 

29 control and other methods may be required to aid in management (NRCS Practice Standard 

30 595, Pest Management).

31 Giant miscanthus is not listed on any of the proposed project areas State (Arkansas, 

32 Missouri, Ohio, or Pennsylvania) list of noxious weeds as of March 2011, this may be 

33 partially due to the fact that this species has not had widespread distribution in a localized or 
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1 regional level; however, this is the most recent listing for these states. This species is also 

2 not listed on the Federal Noxious Weed List as of March 2011. Two species of Miscanthus 

3 (M. floridulus and M. sinensis), one of which is a parent species of the hybrid being 

4 proposed by the Project Sponsors, are listed on the Federal Invasive species list as of 

5 March 2011.

6 3.3.2 Wildlife

7 3.3.2.1 Definition of the Resource

8 Wildlife refers to the animal species (mammals, birds, amphibians, reptiles, invertebrates, 

9 and fish/shellfish), both native and introduced, which characterize a region.

10 3.3.2.2 Existing Conditions

11 3.3.2.2.1 Ashtabula Proposed Project Area

12 Major wildlife species in this area include muskrat (Ondatra zibethicus), beaver (Castor 

13 canadensis), least shrew (Cryptotis parva), least weasel (Mustela nivalis), mink (Mustela 

14 vison), southern bog lemming (Synaptomys cooperi), Virginia opossum (Didelphis 

15 virginiana), white tailed deer (Odocoileus virginianus), striped skunk (Mephitis mephitis), 

16 American bittern (Botaurus lentiginosus), alder flycatcher (Empidonax alnorum), American 

17 black duck (Anas rubripes), Canada goose (Branta canadensis), great egret (Ardea alba), 

18 least bittern (Ixobrychus exilis), and least sandpiper (Calidris minutilla). Fish of importance, 

19 including common game fish, across the area include smallmouth bass (Micropterus 

20 dolomieu), common carp (Cyprinus carpio), white sucker (Catostomus commersonii), and 

21 stonecat madtom (Noturus flavus) (ODNR 2011a).

22 3.3.2.2.2 Aurora Proposed Project Area

23 Major wildlife species in the area include white-tailed deer, eastern cottontail (Sylvilagus 

24 floridanus), raccoon (Procyon lotor), wood duck (Aix sponsa), wild turkey (Meleagris 

25 gallopavo), smallmouth bass, and largemouth bass (Micropterus salmoides salmoides). 

26 Several prairie species, such as black-tailed jackrabbits (Lepus californicus) and prairie 

27 chickens (Tympanuchus cupido), inhabit small areas of the original tall grass prairie 

28 Confidential Application for Proposed BCAP Project Areas, 2011).

29 3.3.2.2.3 Columbia Proposed Project Area

30 Major wildlife species in this Area include white-tailed deer, coyote (Canis latrans), gray fox 

31 (Urocyon cinereoargenteus), red fox (Vulpes vulpes), beaver, raccoon, skunk, muskrat, 
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1 opossum, mink, rabbit, fox squirrel (Sciurus niger), gray squirrel (Sciurus carolinensis), 

2 Canada goose, bald eagle (Haliaeetus leucocephalus), turkey vulture (Cathartes aura), 

3 turkey, woodcock (Scolopax minor), great horned owl (Bubo virginianus), wood duck, 

4 pileated woodpecker (Dryocopus pileatus), red-bellied woodpecker (Melanerpes carolinus), 

5 ring-necked pheasant (Phasianus colchicus), and bobwhite quail (Colinus virginianus). Fish 

6 of importance, including common game fish, across the area include carp (Cyprinus carpio), 

7 catfish, largemouth bass, smallmouth bass, bluegill (Lepomis macrochirus), crappie 

8 (Pomoxis sp.), and sunfish (Confidential Application for Proposed BCAP Project Areas, 

9 2011).

10 3.3.2.2.4 Paragould Proposed Project Area

11 Across this are, major wildlife species in this Area include white-tailed deer, coyote, gray fox, 

12 red fox, raccoon, skunk, muskrat, cottontail rabbit, fox squirrel, bobwhite quail and mourning 

13 dove. Fish of importance, including common game fish, across the Area include carp, 

14 bullhead, largemouth bass, smallmouth bass, bluegill, and crappie (Confidential Application 

15 for Proposed BCAP Project Areas, 2011).

16 3.3.3 Protected Species

17 3.3.3.1 Definition of the Resource

18 Protected species are those Federally designated as threatened or endangered under the 

19 ESA or species that are considered candidates for being listed as threatened or 

20 endangered. Critical habitat is defined as: (1) specific areas within the geographical area 

21 occupied by the species at the time of listing, if they contain physical or biological features 

22 essential to conservation, and those features may require special management 

23 considerations or protection; and (2) specific areas outside the geographical area occupied 

24 by the species if the agency determines that the area itself is essential for conservation 

25 (USFWS 2008a).

26 3.3.3.2 Existing Conditions

27 Table 3-9 lists the Federally-listed threatened and/or endangered species that could be 

28 present in the proposed project area counties. Figures 3-5 through 3-7 illustrate the 

29 potential ranges of Federally-listed species within the proposed project areas. 

30
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1 Table 3-9. Federally-Listed Threatened and/or Endangered Species that Could 

2 Potentially occur within the Proposed Project Areas

Category

Species –

Common Name (Scientific Name) T/E Counties

Aurora

Fishes / 

Clams

Ozark cavefish 

(Amblyopsis rosae) T

Barry, Jasper, Lawrence, Newton, 

Stone

Neosho madtom (Noturus placidus) T Jasper

Plants

Missouri bladderpod (Physaria filiformis) T Christian, Dade, Lawrence

Mead's milkweed (Asclepias meadii) T Dade

No common name (Geocarpon minimum) T Dade, Jasper, Lawrence

Western prairie fringed Orchid 

(Plantanthera praeclara) T Jasper, Lawrence

Running buffalo clover (Trifolium stoloniferum) E Barry, Christian, Dade, Jasper

Mammals

Ozark big-eared bat 

(Corynorhinus(=Plecotus) townsendii ingens) E Barry, Stone

Indiana bat (Myotis sodalis) E Barry, Christian, Stone

Gray bat (Myotis grisescens) E

Barry, Christian, Dade, Jasper, 

Lawrence, Newton, Stone

Insects American burying beetle (Nicrophorus americanus) E Newton

Columbia

Fishes / 

Clams

Pallid sturgeon (Scaphirhynchus albus) E Boone, Cole, Cooper, Moniteau

Topeka shiner 

(Notropis topeka (=tristis)) E

Boone, Cole, Cooper, Moniteau, 

Randolph

Pink mucket (pearly mussel) (Lampsilis abrupta) E Cole

Plants Virginia sneezeweed (Helenium virginicum) T Boone

Running buffalo clover (Trifolium stoloniferum) E Boone, Cole, Cooper, Moniteau

Mammals

Indiana bat 

(Myotis sodalis) E

Audrain, Boone, Cooper, Monroe, 

Randolph

Gray bat (Myotis grisescens) E Boone, Cole

Paragould

Birds Interior Least Tern (Sterna antillarum athalassos) E Mississippi

Fishes / 

Clams

Pink mucket (pearly mussel) (Lampsilis abrupta) E Clay, Randolph, Lawrence, Jackson

Fat pocketbook (Potamilus capax) E Craighead, Mississippi, Poinsett

Curtis pearlymussel (Epioblasma florentina curtisii) E Lawrence

Scaleshell mussel (Leptodea leptodon) E Lawrence

Pallid sturgeon (Scaphirhynchus albus) E Mississippi

Plants Pondberry (Lindera melissifolia) E Lawrence

Mammals Gray bat (Myotis grisescens) E Lawrence

Ashtabula

Birds Kirtland's Warbler (Dendroica kirtlandii) E Ashtabula, Lake, Crawford, Erie

Piping Plover (Charadrius melodus) E Ashtabula, Lake, Erie

Fishes / 

Clams

Clubshell mussel 

(Pleurobema clava) E

Ashtabula, Trumbull, Crawford, Erie, 

Mercer

Northern riffeshell mussel 

(Epioblasma torulosa rangiana) E Crawford, Erie, Mercer

Mammals

Indiana bat 

(Myotis sodalis) E

Ashtabula, Geauga, Lake, Trumbull, 

Crawford, Erie, Mercer

3 Source: Adapted from PAPO 2011a, PAPO 2011b, PAPO 2011c, PAPO 2011d
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1 Figure 3-5. Potential Ranges of Federally-listed Threatened and/or Endangered 

2 Birds, Insects and Mammals within and adjacent to the Proposed Project Areas.
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1 Figure 3-6. Potential Ranges of Federally-listed Threatened and/or Endangered 

2 Fishes and Clams within and adjacent to the Proposed Project Areas.
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1 Figure 3-7. Potential Ranges of Federally-listed Threatened and/or Endangered 

2 Plants within and adjacent to the Proposed Project Areas.
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1 3.3.3.2.1 Ashtabula Proposed Project Area

2 A review of Federally-listed protected (threatened and/or endangered) species based on the 

3 U.S. Fish and Wildlife Service (USFWS) data indicate that four Federally-listed endangered 

4 species have the potential to occur in Ohio counties within the proposed project area. The 

5 Clubshell mussel (Pleurobema clava) has the potential to occur in Ashtabula and Trumbull 

6 Counties; the Kirtland’s warbler (Dendroica kirtlandii) and Piping plover (Charadrius 

7 melodus) have the potential to occur in Ashtabula and Lake Counties; and the Indiana bat 

8 (Myotis sodalis) has the potential to occur in Ashtabula, Geauga, Lake, and Trumbull 

9 counties. 

10 The Clubshell mussel is known from Pymatunig Creek in Ashtabula County, Ohio, but no 

11 other counties within the proposed project area in Ohio. Kirtland’s warblers are not currently 

12 known from any of the counties within the proposed project area in Ohio. The Great Lakes 

13 population of Piping plovers is only known from the Headland Dunes area of coastal Lake 

14 County, but no other counties within the proposed project area in Ohio. According to the 

15 Draft Recovery Plan (USFWS 2007) for Indiana bats, there are known summer roosts in 

16 Ashtabula County in Ohio. Of those Federally-listed species with the potential to occur within 

17 the proposed project area, only the Federally endangered Piping plover has designated 

18 Critical Habitat in Ohio in Lake County. However, this Critical Habitat is designated within 

19 the Headland Dunes Nature Preserve and not in any areas that will be used for agricultural 

20 purposes. No other Federally-listed endangered species with the potential to occur in the 

21 Ohio portion of the proposed project areas have designated Critical Habitat in these 

22 counties (Confidential Application for Proposed BCAP Project Areas, 2011). 

23 3.3.3.2.2 Aurora Proposed Project Area

24 Three plants on the Federal list of threatened and endangered species are identified within 

25 grasslands in the proposed project areas. The Missouri bladder pod (Physaria filiformis) has 

26 been found in glades and pastureland, and the Mead’s milkweed (Asclepias meadii) is found 

27 in association with tallgrass prairie lands. Western prairie fringed orchid (Platanthera 

28 praeclara) is also associated with grasslands, specifically damp, tallgrass prairies. 

29 Geocarpon (Geocarpon minimum) is also associated with glades. Many listed plants thrive 

30 on periodic disturbance, including mowing and burning.

31 Mammals associated with this proposed project area include three bat species. Both 

32 Indiana and gray bats forage over bodies of water and use wooded corridors adjacent to 

33 water as roosting sites. The Ozark big-eared bat (Corynorhinus townsendii ingens) may no 
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1 longer exist in Missouri. However, the other bat species have been known to overwinter in 

2 limestone caves (Confidential Application for Proposed BCAP Project Areas, 2011).

3 3.3.3.2.3 Columbia Proposed Project Area

4 Fishes and clams are associated with water and require high water quality. Plants listed in 

5 association with the Columbia proposed project area are primarily associated with mesic 

6 areas. Mammals associated with this proposed project area include two bat species, the 

7 Indiana bat and the Gray bat (Myotis grisescens). Both species forage over bodies of water 

8 and use wooded corridors adjacent to water as roosting sites. Indiana bat may also 

9 overwinter in limestone caves (Confidential Application for Proposed BCAP Project Areas, 

10 2011).

11 3.3.3.2.4 Paragould Proposed Project Area

12 The listed bird species prefers habitat adjacent to bodies of water that have sandbars or 

13 sand/gravel pit areas. Listed fishes/clams are associated with water and water quality. The 

14 Gray bat will forage over bodies of water and use wooded corridors adjacent to water as 

15 roosting sites (Confidential Application for Proposed BCAP Project Areas, 2011). 

16 3.4 SOIL RESOURCES

17 3.4.1 Definition of the Resource

18 Soils are a natural body made up of weathered minerals, organic matter, air and water. 

19 Soils are formed mainly by the weathering of rocks, the decaying of plant matter, and the 

20 deposition of materials such as chemical and biological fertilizers that are derived from other 

21 origins. Soils are differentiated based on characteristics such as particle size, texture and 

22 color, and classified taxonomically into soil orders based on observable properties such as 

23 organic matter content and degree of soil profile development (Brady and Weil 1996). Soil 

24 taxonomy was established to classify soils according to the relationship between soils and 

25 the factors responsible for their character (NRCS 1999). For the purpose of this project, the 

26 soil resources will be discussed based on the soil classification in the particular proposed 

27 project area.

28 Soil erosion is a naturally occurring event and the erosion rates are relatively slow; however, 

29 human activity can greatly accelerate the rate of erosion. Poor farming practices, loss of 

30 vegetation through deforestation, overgrazing and the maintenance of agricultural land are 

31 some of the factors that make soils more susceptible to erosion. For the purpose of this 

32 document, highly erodible lands (HEL) were used to evaluate the potential for erosion within 
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1 the proposed project areas (Figure 3-8). For more information about HEL, refer to the 

2 BCAP Final PEIS (Chapter 3.4). 

3 3.4.2 Existing Conditions

4 3.4.2.1 Ashtabula Proposed Project Area

5 In general, soils across this region favor agriculture. The soils in this region are often very 

6 deep, gently sloping and poorly drained, depending on specific soil type. The soils in this 

7 area were formed in different textures of glacial till (USDA 2007). 

8 There was approximately 193,410 acres of HEL within the counties of the Ashtabula 

9 proposed project area (Taylor 2011). Within this proposed project area, Mercer County had 

10 the highest amount of HEL, covering 11 percent of the county. 

11 3.4.2.2 Aurora Proposed Project Area

12 Soils across this region favor agriculture, including corn, soybean and grains. Soils range 

13 from well-drained to poorly-drained, depending on specific soil type, land features, and slope 

14 position. Upland sites are typically better drained than lowlands. At times, clay and silt 

15 content can create drainage problems (Confidential Application for Proposed BCAP Project 

16 Areas, 2011). 

17 There was approximately 1,338,641 acres of HEL within the counties of the Aurora 

18 proposed project area, with an average of 51 percent of the land being HEL (Confidential 

19 Application for Proposed BCAP Project Areas, 2011). Within this proposed project area, 

20 Stone County had the highest amount of HEL, covering 93 percent of the county. 

21 3.4.2.3 Columbia Proposed Project Area

22 In general, soils across this region favor agriculture, including corn, soybean and grains. 

23 Soils range from well-drained to poorly-drained, depending on specific soil type, land 

24 features, and slope position. At times, clay content can create drainage problems

25 (Confidential Application for Proposed BCAP Project Areas, 2011). 

26 There was approximately 1,266,771 acres of HEL within the counties of the Columbia 

27 proposed project area, with an average of 37 percent of the land being HEL (Confidential 

28 Application for Proposed BCAP Project Areas, 2011). Within this proposed project area, 

29 Callaway County had the highest amount of HEL, covering 61 percent of the county. 
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1 Figure 3-8. Percent of Total Land Classified as Highly Erodible by County within the 

2 Proposed Project Areas.
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1 3.4.2.4 Paragould Proposed Project Area

2 Soils range from well-drained to poorly-drained, depending on specific soil type, land 

3 features, and slope position. Upland sites are typically better drained than lowlands. At 

4 times, clay and silt content can create drainage problems (Confidential Application for 

5 Proposed BCAP Project Areas, 2011).

6 There was approximately 710,118 acres of HEL within the counties of the Paragould 

7 proposed project area, with an average of 25 percent of the land being HEL (Confidential 

8 Application for Proposed BCAP Project Areas, 2011). Within this proposed project area, 

9 Randolph County had the highest amount of HEL, covering 61 percent of the county. 

10 Mississippi County contains no soil classified as HEL.

11 3.5 WATER QUALITY AND QUANTITY

12 3.5.1 Water Quality

13 3.5.1.1 Definition of the Resource

14 Freshwater is necessary for the survival of most terrestrial organisms, and is required by 

15 humans for drinking and agriculture, among other uses; however, less than one percent of 

16 Earth’s water is in the form of freshwater that is not bound in ice caps or glaciers. The 

17 Water Pollution Control Act of 1972, or CWA, Safe Drinking Water Act, and the Water 

18 Quality Act are the primary Federal laws that protect the nation’s waters. The principal law 

19 governing pollution of the nation’s surface water resources is the CWA. The Act utilizes 

20 water quality standards, permitting requirements, and monitoring to protect water quality.

21 The EPA sets the standards for water pollution abatement for all waters of the United States

22 under the programs contained in the CWA but, in most cases, delegates the authority to 

23 issue and enforce permits to qualified States. For this analysis, water resources include 

24 surface water quality (including lakes, rivers and associated tributaries, and estuaries), 

25 groundwater quality, and water use/quantity of both surface and groundwater.

26 Surface water, as defined by the EPA, are waters of the United States, such as rivers, 

27 streams, creeks, lakes, and reservoirs, supporting everyday life through uses such as 

28 drinking water and other public uses, irrigation, and industrial uses. Surface runoff from 

29 rain, snow melt, or irrigation water, can affect surface water quality by depositing sediment, 

30 minerals, or contaminants into surface water bodies. Surface runoff is influenced by 

31 meteorological factors such as rainfall intensity and duration, and physical factors such as 

32 vegetation, soil type, and topography. 
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1 The 303(d) List of Waters reports on streams and lakes identified as impaired for one or 

2 more pollutants and do not meet one or more water quality standards. The term, "303(d) 

3 list," is short for the list of impaired waters (stream segments, lakes) that the Clean Water 

4 Act requires all states to submit for EPA approval every two years. The states identify all 

5 waters where required pollution controls are not sufficient to attain or maintain applicable 

6 water quality standards and rank the waters taking into account the uses of the water and 

7 severity of the pollution problem (EPA 2008). Figure 3-9 illustrates the impaired streams 

8 and water bodies within each state containing the proposed project areas. 

9 Groundwater is the water that flows underground and is stored in natural geologic 

10 formations called aquifers. It is ecologically important because it sustains ecosystems by 

11 releasing a constant supply of water into wetlands and contributes a sizeable amount of flow 

12 to permanent streams and rivers (FSA 2003).

13 3.5.1.2 Existing Conditions

14 3.5.1.2.1 Ashtabula Proposed Project Area

15 According to the 303(d) list, there are 1,868 impaired stream segments within the Ashtabula 

16 proposed project area for a total of 3,711.34 miles of impaired streams. There is also a total 

17 of 56.87 square miles of impaired lakes and reservoirs (EPA 2010). 

18 3.5.1.2.2 Aurora Proposed Project Area

19 According to the 303(d) list, there are 328 impaired stream segments within the Aurora 

20 proposed project area for a total of 557.40 miles of impaired streams (EPA 2010).

21 3.5.1.2.3 Columbia Proposed Project Area

22 According to the 303(d) list, there are 314 impaired stream segments within the Columbus 

23 Project Area for a total of 388.63 miles of impaired streams. There is also a total of 0.30 

24 square miles of impaired lakes and reservoirs (EPA 2010). 

25 3.5.1.2.4 Paragould Proposed Project Area

26 According to the 303(d) list, there are 335 impaired stream segments within the Paragould 

27 Project Area for a total of 581.71 miles of impaired streams. There is also a total of 5.2 

28 square miles of impaired lakes and reservoirs (EPA 2010). A majority of the water use relies 

29 on surface water sources. However, counties closer to the Mississippi River are more likely 

30 to use groundwater sources. Uses of groundwater include domestic, industry, and irrigation.

31
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1 Figure 3-9. Waters Listed on the State 303(d) Lists for Impaired Waters
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1 3.5.2 Water Quantity

2 3.5.2.1 Definition of the Resource

3 Water use/quantity is the specific amount of water used for a given task, such as the 

4 production of dedicated bioenergy crops. Three types are distinguished: withdrawal, where 

5 water is taken from a river, or surface or underground reservoir, and after use returned to a 

6 natural water body; consumptive, which starts with withdrawal but without any return (e.g. 

7 irrigation) and is no longer available directly for subsequent uses; non-withdrawal, the in situ

8 use of a water body for, e.g. navigation, fishing, recreation, effluent disposal and power 

9 generation. (FAO 2005).

10 3.5.2.2 Existing Conditions

11 Table 3-9 illustrates the amount of acres of the cropland that are irrigated. The table also 

12 illustrates the water withdrawals by source for each county within the proposed project area. 

13 The EPA defines a watershed as the area of land where all of the water that is under it or 

14 drains off of it goes into the same place (EPA 2009). Further, the USGS defines a 

15 watershed as the divide separating one drainage basin from another. The USGS has 

16 divided and sub-divided the United States using hydrologic units (HUC). The hydrologic unit 

17 system has four levels of classification (USGS 2011). For this project the fourth level of 

18 classification, the 8-digit HUC codes, were used to classify the watersheds within the 

19 proposed project area. 

20 3.5.2.2.1 Ashtabula Proposed Project Area

21 Within the counties in Ashtabula proposed project area, three of the four Ohio counties had 

22 less than 400 acres of irrigated cropland with the exception of Lake County, Ohio that had a 

23 total of 2,180 acres of irrigated land (Table 3-10). There was a total of 7.28 million gallons 

24 of water withdrawn per day in the proposed project area, with an average of 66 percent from 

25 surface water and 34 percent from groundwater sources (USGS 2010b). 

26 Eight different watersheds are located within the counties in the Ashtabula proposed project 

27 area, with the dominate watersheds being Ashtabula-Chagrin and Grand. These eight 

28 watersheds cover 5,218,511 acres of land in Ohio and Pennsylvania with 26 percent within 

29 the proposed project area (Seaber 2007). There were approximately 3,600 miles of streams 

30 and rivers within the Ohio proposed project area and 1,700 miles of streams and rivers 

31

32
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1 Table 3-10. Acres of Irrigated Land and 

2 Water Withdrawals by County within Each Proposed Project Area

County

Total Cropland Irrigated Land Percent 

Irrigated 

Acres

Withdrawals 

(in million gallons per day)

By source

(acres) Total

GroundwaterSurface 

water

Arkansas

Arkansas 8,432,221 4,460,682 52.9 7,020 1,510 8,530

Clay 293,353 227,000 77.4 466.08 9.36 475.44

Craighead 301,734 244,365 81.0 350.76 44.61 395.37

Greene 229,272 164,615 71.8 206.17 3.81 209.98

Jackson 266,354 178,101 66.9 378.04 22.54 400.58

Lawrence 200,765 130,983 65.2 220.99 24.21 245.20

Mississippi 451,917 269,564 59.6 270.57 2.12 272.69

Poinsett 322,991 262,180 81.2 672.02 90.36 762.38

Randolph 135,019 67,301 49.8 101.46 37.38 138.84

Missouri

Missouri 16,405,595 1,199,981 7.3 1,340 38.9 1,370

Audrain 337,854 15,462 4.6 2.27 7.86 10.13

Boone 152,527 3,596 2.4 0.99 0.61 1.60

Callaway 166,339 4,025 2.4 2.67 2.26 4.93

Cole 79,523 448 0.6 0.00 0.06 0.06

Cooper 189,065 393 0.2 0.15 0.00 0.15

Howard 172,316 12,049 7.0 1.90 0.00 1.90

Moniteau 122,630 160 0.1 0.28 0.00 0.28

Monroe 183,346 1,473 0.8 0.00 0.81 0.81

Randolph 119,856 738 0.6 0.29 0.00 0.29

Barry 114,244 416 0.4 0.06 0.00 0.06

Christian 76,040 158 0.2 0.04 0.00 0.04

Dade 127,080 8,621 6.8 3.03 0.73 3.76

Jasper 135,730 5,169 3.8 2.33 1.65 3.98

Lawrence 150,703 2,416 1.6 0.19 0.70 0.89

Newton 107,943 1,150 1.1 1.93 0.00 1.93

Stone 36,790 74 0.2 0.02 0.00 0.02

Ohio

Ohio 10,832,772 37,959 0.4 17.7 24.9 42.6

Ashtabula 106,255 352 0.3 0.01 0.10 0.11

Geauga 29,541 355 1.2 0.04 0.29 0.33

Lake 10,126 2,180 21.5 0.38 4.43 4.81

Trumbull 87,440 152 0.2 0.16 0.54 0.70

Pennsylvania

Pennsylvania 4,870,287 37,786 0.8 8.29 16 24.3

Crawford 139,526 564 0.4 0.07 0.09 0.16

Erie 101,698 1,397 1.4 0.30 0.69 0.99

Mercer 111,556 195 0.2 0.08 0.10 0.18

3 Source: USDA 2009; USGS 2010b. 

4
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1 within the Pennsylvania proposed project area. There were approximately 13,800 acres of

2 lakes, ponds and reservoirs within the Ohio proposed project area and 16,200 acres within 

3 the Pennsylvania proposed project area (USGS 2010a).

4 3.5.2.2.2 Aurora Proposed Project Area

5 Within the Aurora proposed project area, there was an average of 2,572 acres of irrigated 

6 land within the proposed project area. Overall, Missouri had a total of 1.19 million acres of 

7 irrigated land. There was a total of 10.68 million gallons of water withdrawn per day in the 

8 proposed project area, with an average of 29 percent from surface water and 71 percent 

9 from groundwater sources (USGS 2010b).

10 Seven different watersheds impact counties within the Aurora proposed project area;

11 however, the Sac, Spring, and James watersheds cover most of the area. These three 

12 watersheds cover 2,567,536 acres of land in Missouri (Confidential Application for Proposed 

13 BCAP Project Areas, 2011). There were approximately 7,500 miles of streams and rivers 

14 within this proposed project area. There were approximately 37,600 acres of ponds, lakes 

15 and reservoirs within this proposed project area (USGS 2010a). Springs are numerous and 

16 often contribute to the base flow of many area streams.

17 3.5.2.2.3 Columbia Proposed Project Area

18 Within the Columbia proposed project area, there was an average of 4,260 acres of irrigated 

19 land within the proposed project area. Overall, Missouri had a total of 1.19 million acres of 

20 irrigated land. There was a total of 20.15 million gallons of water withdrawn per day in the 

21 proposed project area, with an average of 58 percent from surface water and 42 percent 

22 from groundwater sources (USGS 2010b).

23 While Columbia proposed project area includes land area in 13 different watersheds, the 

24 broadest is the Lower Missouri – Moreau (LMM). The Lower Missouri Moreau contacts 

25 every county in the Project Area, except for Monroe County. It represents land area 

26 encompassing 2,175,934 acres (Confidential Application for Proposed BCAP Project Areas, 

27 2011). There were approximately 11,900 miles of streams and rivers within this proposed 

28 project area. There were approximately 11,900 acres of ponds, lakes and reservoirs within 

29 this proposed project area (USGS 2010a).

30 3.5.2.2.4 Paragould Proposed Project Area

31 Within the Paragould proposed project area, there was an average of 193,014 acres of 

32 irrigated land (69 percent of the total acres) which is slightly above the state total of 52.9 
AFFECTED ENVIRONMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 3-38

1 percent of the acres being irrigated. There was an average of 362.56 million gallons of 

2 water withdrawn per day in the proposed project area, with an average of eight percent from 

3 surface water and 92 percent from groundwater sources (USGS 2010b).

4 While Paragould proposed project area includes land area in 11 different watersheds, the 

5 greatest land area is represented by three of those 11. The Lower St. Francis, Little River 

6 Ditches, and Cache watersheds encompass a total of 3,471,360 acres and impact all 

7 counties represented in this proposed project area. The western-most counties, Randolph, 

8 Jackson, and Lawrence, are impacted by an additional seven watersheds, inclusive. 

9 However, these watersheds represent a much smaller portion of the proposed project area 

10 (PAPO 2011d). There were approximately 14,000 miles of streams and rivers within this 

11 proposed project area. There were approximately 20,600 acres of ponds, lakes and 

12 reservoirs within this proposed project area (USGS 2010a).
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-1

1 4 ENVIRONMENTAL CONSEQUENCES 

2 4.1 DATA GAPS

3 Giant miscanthus is a new agronomic crop species in the United States, and also still 

4 relatively new in Europe, where the oldest cultivation areas are approximately 30 years old 

5 or less. The Miscanthus genus was introduced to the United States over 100 years ago in 

6 ornamental plantings. Several universities (i.e., University of Illinois, Mississippi State 

7 University, University of Wisconsin, Michigan State University, and the University of 

8 Georgia) in the United States are currently cultivating giant miscanthus on a trial basis or 

9 conducting research on giant miscanthus or the Miscanthus genus. Additionally, large-scale 

10 acreages of giant miscanthus have not been cultivated in the United States; although 

11 commercial production of giant miscanthus for bioenergy production in co-fired systems are 

12 in the beginning stages in the United Kingdom. Given, that giant miscanthus has only been 

13 grown in large-scale trials in Europe the data on giant miscanthus planting in the United 

14 States is more limited in scope. 

15 In light of the lack of data applicable to the proposed project areas, an adaptive Mitigation 

16 and Monitoring Plan (MMP) is being developed, which will include best management 

17 practices (BMP) for the establishment and production of giant miscanthus to ensure

18 avoidance and minimization of potential effects to the immediate environment and the larger 

19 landscape. The framework for the MMP is included in Section 6. The MMP will be a living 

20 document that is highly dependent on routine monitoring of the fields to determine the 

21 success of giant miscanthus plantings, its overall effects to the immediate environment, and 

22 any potential effects to the larger landscape based on observation and measurement. This 

23 document would contain information on appropriate and effective eradication methods that 

24 would develop over time as new data became available. Likewise, other metrics or 

25 observable measurements would adapt over time based on past observations, new 

26 research finding, and new regulations. 

27 The following information has been found to lack complete detail in relation to growth and 

28 production of giant miscanthus in the United States. 

29 Potential effects to socioeconomics focused on the information provided in the pro 

30 forma analyses of the Project Sponsors. Data from Europe indicates a high cost of 

31 establishment due to the vegetative propagation of the species; however, the BCAP 
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-2

1 combined with the model undertaken by the Project Sponsors addresses most of 

2 these concerns, along with technical assistance to be provided to producers. 

3 Landscape scale analyses of giant miscanthus are generally lacking since there 

4 have not been any commercial-scale field trials in the United States. 

5 Literature documenting the potential for invasiveness of the fertile species of the 

6 Miscanthus genus has been discussed along with documentation supporting that 

7 giant miscanthus should not be considered invasive due to its sterility and slow 

8 rhizome spread within the United States. 

9 Literature discussing potential plant pests has been recently published relating to the 

10 western corn root worm, several species, of aphids, and rust; those studies along 

11 with recommendations have been included.

12 There is little peer-reviewed literature concerning the effects of giant miscanthus 

13 plantings on biological diversity in the United States; however, some specific studies 

14 have been published in Europe. These studies primarily focused on bird species 

15 with some small mammal observations. These studies also looked at young-aged 

16 giant miscanthus stands, so there was little information available on biodiversity 

17 found in mature stands. Also, the literature is lacking on the potential effects to 

18 larger species in either young or mature stands of giant miscanthus. 

19 Information concerning the nutrient uptake, nutrient addition trials, and root structure 

20 has been included to discuss the potential for soil erosion, soil organic matter, and 

21 soil carbon sequestration based on the available literature.

22 Literature concerning nutrient uptake, water use efficiency, and irrigation needs 

23 during establishment has been discussed based on the available literature. 

24 4.2 SOCIOECONOMICS

25 4.2.1 Significance Threshold

26 For socioeconomics the significance thresholds include a substantial change in farm 

27 income, which could lead to wider community effects such as employment loss and 

28 population declines. 
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-3

1 4.2.2 Proposed Action

2 Implementing the Proposed Action would not result in significant adverse effects to the 

3 socioeconomic conditions of any of the proposed project areas. The Proposed Action would 

4 provide a positive cash-flow stream to producers and an economically viable product 

5 through the BCF to local, regional, and potentially out of region sales according to the BCAP 

6 project area application documents. Giant miscanthus would require some level of inputs 

7 (e.g., herbicides) during the establishment phases, with minimal fertilizer inputs annually 

8 beginning in year three of the maintenance period to replace nutrients lost through biomass 

9 production; thereby, maintaining the existing agricultural products stream, with the potential 

10 for creating new markets for more species-specific agricultural chemicals. Agricultural 

11 services would be maintained in the short-term, with the potential creation of new services 

12 streams for heavier-duty equipment manufacture and contract farming for harvesting, baling, 

13 and transportation of baled products to the BCF. Overall, the maintenance of existing higher 

14 value cropland acres with the inclusion of smaller dedicated energy crop production should 

15 maintain or enhance farm household and agricultural services-related household incomes. 

16 BCAP was developed to provide assistance to participating producer to offset a portion of 

17 the costs associated with establishing and producing dedicated energy crops. Table 4.1

18 lists the estimated establishment and production costs for giant miscanthus with a 

19 comparison of the BCAP payments to participating producers. In considering the value of 

20 BCAP to participating producers within the proposed project areas a crop budget analysis 

21 with information from the Michigan State University (MSU) Extension miscanthus estimated 

22 budgets was conducted. The MSU miscanthus budgets provide an analysis of both ‘cheap’ 

23 and market rate rhizomes. Under MSU’s analysis with “market rhizomes” after 10 years the 

24 producer is still cash flow negative over $6,000 on each acre planted. If the rhizome costs 

25 were reduced to only 25 percent of MSU’s estimate, the producer would still need 10 years 

26 to break even. Under MSU’s analysis, producers would have little incentive to establish 

27 energy crops. However, with “cheap rhizomes,” the producer is cash flow positive after the 

28 third year. BCAP provides enough incentive, per the MSU cost and revenue values, that a 

29 producer would begin realizing a profit in year nine or in year eight, if the matching payment 

30 were delayed until a full harvest was collected. 

31
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-4

1 Table 4-1. Cost Comparison for Participating Versus Non-Participating Producers 

2 for the Establishment and Production of Giant Miscanthus

Item

Giant Miscanthus 

Establishment without 

BCAP

Giant Miscanthus 

Establishment with BCAP

Per Acre (all values rounded to the next whole $)

Crop Establishment

Rhizomes ($1.80 ea) $7,290 $7,290

Soil Amendments $0 $0

Pest Control $18 $18

Machinery Cost $67 $67

Labor $3 $3

Total Establishment Cost $7,378 $7,378

BCAP Establishment 

Payment

$0 $5,534

BCAP Annual Payment $0 $89

Revised Establishment Cost $7,378 $1,755

Year 2 Production

Annual Costs – Year 2 $1,133 $1,133

Estimated Revenue – Year 2

(5 tons @ $60/ton)

$300 $300

BCAP Annual Payment $0 $67

BCAP Matching Payment –

Year 1

$0 $225

Profit/Loss Continual -$8,211 -$2,296

Year 3 Production

Annual Costs – Year 3 $343 $343

Estimated Revenue – Year 3 $600 $600

BCAP Annual Payment $0 $67

BCAP Matching Payment –

Year 2

$0 $450

Profit/Loss Continual -$7,954 -$1,522

Year 4 Production

Annual Costs – Year 4 $343 $343

Estimated Revenue – Year 4 $600 $600

BCAP Annual Payment $0 $67

Profit/Loss Continual -$7,697 -$1,198

Year 5 Production

Annual Costs – Year 4 $343 $343

Estimated Revenue – Year 4 $600 $600

BCAP Annual Payment $0 $67

Profit/Loss Continual -$7,440 -$874

3 Notes: 

4 All cost estimates derived from MSU miscanthus budget (James et al. 2009)

5 The average rental rate for CRP as of February 2011 in each state containing proposed project areas 

6 are: Arkansas = $59.53/acre; Missouri = $74.16/acre; Ohio = $118.87/acre; Pennsylvania = 

7 $102.85/acre. The average rental rate for these four states = $88.85 (USDA FSA 2011a)

8 A reduction in the annual BCAP payment was estimated at 25 percent for biomass sold for heat, power, 

9 or biobased products (USDA FSA 2011b). 
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-5

1 The Project Sponsors have been very successful in finding producers willing to plant energy 

2 crops on less productive land when shown BCAP incentives that create positive cash flows 

3 in comparison to establishment without BCAP. Importantly, producer commitments are 

4 contingent upon BCAP funding, which indicates that the short term incentives provided by 

5 BCAP create a viable energy crop market. MSU’s research supports the Project Sponsors’ 

6 experience with actual producers in proposed project areas that without BCAP incentives in 

7 an approved project area, producer interest under current market conditions declines 

8 dramatically.

9 Under the Proposed Action, the Project Sponsors propose to establish and produce giant 

10 miscanthus in the proposed project areas with a maximum acreage of 50,000 acres per 

11 project area by 2014. The Project Sponsors estimate that approximately 20 percent of the 

12 total acreage in the proposed project areas for Aurora, Columbia, and Paragould would be 

13 marginal cropland with the remainder being non-cropland, such as pastureland. In the 

14 Ashtabula proposed project area, 10 percent of the total acreage would be marginal 

15 cropland. The Project Sponsors have a goal of minimizing the amount of arable cropland to 

16 be included in the contract acreage, thereby maximizing producer incomes through 

17 diversification of a small amount of marginal croplands or idle lands, such as pastureland. 

18 On average, contract acreage would be estimated to be in a range between 38 to 100 acres 

19 per contract. The BCAP Final PEIS (Table 3.1-5) lists the national average farm size for 

20 different farm types; overall the majority of farms within the United States are considered 

21 small family farms with average farm size between 137 acres (Limited Resource) to 1,040 

22 acres (Farming Occupation/Higher Sales). In each of the states included within the 

23 proposed project areas, greater than 84 percent of the farms would be considered small 

24 family farms. The Project Sponsors, through small acreage enrollments, would provide an 

25 incentive for small farms to enter a BCAP contract, especially with the producer assistance 

26 to be provided as part of the proposed project area models. 

27 To determine the economic viability of the Proposed Action, the Project Sponsors developed 

28 an Economic Impact Analysis (EIA) for each proposed project area. For each proposed 

29 project area region, the 20 year project time-frame from the giant miscanthus acres 

30 produced under BCAP, the anticipated economic impact to the region would total more than 

31 $750 million (US$2011). The EIA estimated the annual value to the producers in each 

32 proposed project area to be approximately $33 million for the approximately 600,000 tons 

33 anticipated to be produced annually at full production (2017). The Project Sponsors’ BCF 
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-6

1 would be estimated to directly create six positions in 2014, 78 positions in 2016, and 114 

2 positions in 2017. 

3 4.2.2.1 Ashtabula Proposed Project Area

4 In Ashtabula, at full scale production in 2017 the local BCF developed by the Project 

5 Sponsors would create 1,210 new positions (i.e., direct, indirect, and induced across all 

6 related economic sectors) and bring approximately $49.9 million into the region annually. 

7 Economic modeling was performed to analysis the contribution of the Proposed Action for 

8 each proposed project area as part of the Project Sponsors’ confidential project area 

9 application. 

10 4.2.2.2 Aurora Proposed Project Area

11 In Aurora, at full scale production in 2017 the local BCF developed by the Project Sponsors 

12 would create 960 new positions (i.e., direct, indirect, and induced across all related 

13 economic sectors) and bring approximately $49.2 million into the region annually. Economic 

14 modeling was performed to analysis the contribution of the Proposed Action for each 

15 proposed project area as part of the Project Sponsors’ confidential project area application. 

16 4.2.2.3 Columbia Proposed Project Area

17 In Columbia, at full scale production in 2017 the local BCF developed by the Project 

18 Sponsors would create 980 new positions (i.e., direct, indirect, and induced across all 

19 related economic sectors) and bring approximately $50.9 million into the region annually. 

20 Economic modeling was performed to analysis the contribution of the Proposed Action for 

21 each proposed project area as part of the Project Sponsors’ confidential project area 

22 application. 

23 4.2.2.4 Paragould Proposed Project Area

24 In Paragould, at full scale production in 2017 the local BCF developed by the Project 

25 Sponsors would create 750 new positions (i.e., direct, indirect, and induced across all 

26 related economic sectors) and bring approximately $50.0 million into the region annually. 

27 Economic modeling was performed to analysis the contribution of the Proposed Action for 

28 each proposed project area as part of the Project Sponsors’ confidential project area 

29 application. 
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-7

1 4.2.3 No Action Alternative

2 The selection of the No Action Alternative would not result in significant adverse effects to 

3 the socioeconomic conditions of the proposed project areas. Under this alternative, the 

4 Project Sponsors would not undertake the establishment and production of giant miscanthus 

5 in the proposed project areas. The agricultural conditions would remain as described in 

6 Section 3.1 and would follow projected demand and production aspects. This alternative 

7 would not create a small acreage diversification into dedicated energy crops, nor would a 

8 new services market be developed for heavy-duty machinery associated with high-yielding 

9 biomass crops, such as giant miscanthus. 

10 4.3 LAND USE

11 4.3.1 Significance Threshold

12 For land use the significance thresholds include a substantial change in land use type that 

13 could trigger the development of agricultural lands into other non-agricultural land use types 

14 within the region or adjacent to the region. 

15 4.3.2 Proposed Action

16 Implementing the Proposed Action would not result in significant changes in land use types 

17 that could trigger development of agricultural lands into other non-agricultural land use types 

18 nor would it create a substantial loss of arable cropland within the proposed project areas. 

19 Under the Proposed Action, the Project Sponsors propose to establish and produce giant 

20 miscanthus in the proposed project areas with a maximum total acreage of 50,000 acres per 

21 project area by 2014. The Project Sponsors estimate that approximately 20 percent of the 

22 total acreage in the proposed project areas for Aurora, Columbia, and Paragould would be 

23 marginal or cropland with the remainder being non-cropland, such as pastureland

24 (Confidential Application for Proposed BCAP Project Areas, 2011). In the Ashtabula 

25 proposed project area, 10 percent of the total acreage would be marginal cropland

26 (Confidential Application for Proposed BCAP Project Areas, 2011). On average, contract 

27 acreage would be estimated to be in a range between 38 to 100 acres. 

28 Table 4-2 lists the estimated total acres that could be planted by each land use type, 

29 cropland (harvested cropland and other cropland) or pastureland (pastureland, all types) by 

30 proposed project area and that estimated percentage by either cropland or pastureland.

31
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-8

1 Table 4-2. Estimated Acres to be Planted by 2014 to 

2 Giant Miscanthus by Proposed Project Area and Percent of Land Use Type.

Proposed 

Project

Area

Harvested 

Cropland 

Other 

Cropland

Cropland –

Giant 

Miscanthus

Percent of 

Other 

Cropland

Pastureland

All Types

Pastureland 

– Giant 

Miscanthus

Percent of 

Pastureland

All Types

Ashtabula 492,050 58,708 5,000 8.5 139,885 45,000 32.2

Aurora 561,033 41,867 10,000 23.9 944,322 40,000 4.2

Columbia 1,226,524 150,079 10,000 6.7 799,682 40,000 5.0

Paragould 2,087,971 52,986 10,000 18.9 261,540 40,000 15.3

3 Source: Adapted from USDA NASS 2007, Confidential Application for Proposed BCAP Project Areas, 2011

4 The Project Sponsors have a priority of using marginal or idle croplands in place of higher5 value harvested croplands and pasturelands. The Ashtabula proposed project area would 

6 include the greatest percentage of giant miscanthus plantings in the combined acreage of 

7 the pastureland and other cropland land use types (25.2 percent) due to the smaller area in 

8 other cropland and pastureland land use types, when compared to the other proposed 

9 project areas. The Paragould proposed project area would be anticipated to have 

10 approximately 15.9 percent of combined pastureland and other cropland planted in giant 

11 miscanthus; however, due to issues related to nutrient use and leaching, water use, and soil 

12 erosion, more acres of productive cropland could be utilized for giant miscanthus production; 

13 thereby lowering the percentage of marginal lands used. In the Aurora and Columbia 

14 proposed project areas, the percentage of marginal land (other cropland and pastureland) 

15 anticipated to be planted into giant miscanthus is slightly over five percent for both areas.

16 4.3.3 No Action Alternative

17 The selection of the No Action Alternative would not result in significant adverse effects to 

18 the land use within the proposed project areas. Under this alternative, the Project Sponsors 

19 would not undertake the establishment and production of giant miscanthus in the proposed 

20 project areas. The agricultural conditions would remain as described in Section 3.1 and 

21 would follow projected demand and production aspects. This alternative would not create a 

22 small acreage diversification into dedicated energy crops. 

23 4.4 BIOLOGICAL RESOURCES

24 4.4.1 Vegetation

25 4.4.1.1 Significance Threshold

26 For vegetation, a significant effect would be a finding of invasiveness for the species, that it 

27 had a high likelihood of being a vector for a plant pathogen or insect harmful to native 

28 species, or that it was extremely difficult to eradicate once established. 
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-9

1 4.4.1.2 Proposed Action

2 Implementing the Proposed Action, in association with the MMP, (Section 6) would be 

3 anticipated to result in minor effects to local and regional vegetation due to the change in 

4 vegetation from the existing cover to giant miscanthus. As the MMP, is developed based on 

5 comments received on this document and from exploring the BMPs associated with 

6 production of giant miscanthus and associated large-stature perennial grasses, additional 

7 measures to avoid and minimize effects to vegetation would be detailed. Some of these 

8 measures could include exclusions from planting within 100-year floodplains and floodways, 

9 to minimize the potential for vegetative spread through rhizome or active stalks transported 

10 via stormwater flows or wind and active management to provide eradication in adjacent 

11 areas, if necessary. 

12 As mentioned previously, the Project Sponsors anticipated that most of the acreage for giant 

13 miscanthus would be idle lands, which are being considered as pastureland for this analysis. 

14 The data from land use types as reported in the Agricultural Census are from 2007, more 

15 complete data could be collected by the Project Sponsors that indicate a higher percentage 

16 of croplands have been idled or left fallow since 2007, which would alter the percent by land 

17 type included within the project acres. Pasturelands throughout the proposed project areas 

18 could be in fallow agricultural fields with annual vegetation or a mix of annual and perennial 

19 vegetation, in permanent improved pasture, or rangeland. Twenty percent or less of the 

20 giant miscanthus acreage is anticipated to be marginal cropland, which could be currently 

21 fallow or in traditional row crops. Vegetation species diversity is highly site specific and part 

22 of the larger local landscape. Figure 4-1 provides the approximate locations of the 

23 anticipated current producers, which are spread throughout the proposed project areas. 

24 Also, the Project Sponsors have estimated that individual contracts for giant miscanthus 

25 production would range between 38 to 100 acres, with the minimum acreage being what is 

26 considered by the Project Sponsors to be economically viable for the producer. These small 

27 patches of fields should assist in the minimization of the loss of landscape level vegetation 

28 biodiversity and richness along with anticipated buffers to riparian areas and wildlife 

29 corridors through the MMP. 

30 Two components of concern associated with giant miscanthus include its potential for 

31 invasiveness and as a vector for disease or plant pests. The following sections detail each 

32 of these areas. 

33
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-10

1 Figure 4-1. Approximate Locations of 

2 Anticipated Producers within the Proposed Project Areas 
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-11

1 4.4.1.2.1 Invasiveness

2 Overall, the literature concerning giant miscanthus as a potential invasive species indicates 

3 a low likelihood; however, a lack of commercial scale field–sized trials has not occurred in 

4 the United States. The very components that make a species ideal for a biomass feedstock 

5 are often the same characteristics that are described of weedy invasive species (Table 4-3). 

6 Giant miscanthus is a naturally occurring hybrid species that is vegetatively propagated and 

7 does not produce viable seeds with one of the parent species being Miscanthus sinensis, 

8 which is considered an invasive species in the United States; the other parent species (M. 

9 sacchariflorus) is not included on any Federal or State lists of noxious or invasive species. 

10 Table 4-3. Characteristics of Ideal Biomass Crop/Weeds

Type of 

Characteristic Ideal Biomass Crop Ideal Weedy Characteristics

Life History Perennial Perennial

High Aboveground Biomass 

Production

High Aboveground Biomass 

Production

Flowers Late Or Little Allocation to 

Seed Production

Physiology Drought Tolerant Drought Tolerant

Tolerates Low Fertility Soils Tolerates Low Fertility Soils

Tolerates Saline Soils Tolerates Saline Soils

C4 Photosynthetic Pathway C4 Photosynthetic Pathway

High Water/Nutrient Efficiency High Water/Nutrient Efficiency

Other Highly Competitive – Reduces 

Herbicide Use

Highly Competitive – Reduces 

Herbicide Use

Few Resident Pests – Reduces 

Pesticide Use

Few Resident Pests – Reduces 

Pesticide Use

Allelopathic Allelopathic

Re-allocates Nutrients to Roots in 

Fall

11 Source: Raghu et al. 2006 

12 Raghu et al. (2006) indicated that aspects of the genetics (i.e., the parent species) 

13 associated with giant miscanthus could indicate the potential for this species to be invasive, 

14 such as the ability to resprout from belowground, rapid growth, efficient photosynthetic 

15 pathways. JØrgensen (2011) indicates that rhizome spread of giant miscanthus occurs only 

16 at about 10 centimeters (cm) per year from observation of intentionally planted areas, which 

17 is relatively slow. However, there have been no documented unintentionally spreading of 

18 giant miscanthus in Europe, where the species has been studied for over 30 years. In the 

19 event that giant miscanthus rhizomes in intentionally planted areas spread beyond the 

20 planted fields, JØrgensen (2011) indicates that rhizomes transported accidentally by man, 

21 soil erosion, or flooding could be easily eradicated using commercially available herbicides 
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-12

1 (see Section 2.2.2.1) that are shown effective with this strategy. In contrast, JØrgensen 

2 (2011) indicates that M. sacchariflorus (i.e., a parent species of giant miscanthus) has 

3 creeping rhizomes that spread several meters (m) in a few years with high adaptability to 

4 riparian areas, which has a higher potential for translocation via erosion and water transport.

5 Gordon et al (2011) assessed the potential invasiveness of several potential dedicated 

6 energy crop species using the Australian Weed Risk Assessment (WRA). The WRA is a 

7 tool that has been used in Australia and New Zealand for over a decade to determine if plant 

8 species should be considered for use in those countries. The WRA has been shown to be 

9 90 percent accurate in indentifying invasive species, 70 percent accurate in non-invaders, 

10 with approximately 10 percent of non-invaders incorrectly predicted to be invasive (Gordon 

11 et al. 2011). Gordon et al (2011) performed the WRA on 12 potential dedicated energy 

12 crops, not native to Florida, for Florida and the United States. They found that only four 

13 species (giant miscanthus, plume grass, sugarcane, and sweet sorghum) should be 

14 accepted as potential dedicated energy crops based on the WRA results, one species 

15 (cabbage gum) should be further evaluated, and the remainder rejected (giant reed, Red 

16 River gum, rose gum, jatropha, leadtree, elephantgrass, and castor bean). Gordon et al. 

17 (2011) did indicate that since both giant miscanthus and sweet sorghum had parent genetics 

18 from documented invasive species, production should be carefully monitored for changes in 

19 fertility or other traits. Barney and DiTomaso (2008) also performed a WRA on giant 

20 miscanthus and found it to be acceptable for a dedicated energy crop. 

21 Davis et al. (2010) suggests that using the WRA may not be sufficient as a stand-alone tool 

22 provided that the chance of an inadvertent approval of an invasive species could be 1:10 or 

23 1:20. Davis et al. (2010) suggest a nested approach where an initial screen, such as WRA, 

24 is used to determine if a pre-entry evaluation of a species is warranted. This evaluation 

25 would analyze data from the species home range for its potential for invasiveness; if 

26 approved after this step, and then a post-entry evaluation would be conducted. The post27 entry evaluation would include quarantined field trials to determine if release of a species is 

28 appropriate. 

29 4.4.1.2.2 Disease Vector, Host for Plant Pathogens, Host for Plant Pests

30 Another potential for vegetative effects is the movement of diseases and plant pests from 

31 one species to another, such as from giant miscanthus to corn. Recently published 

32 literature in the United States does indicate that giant miscanthus could provide a refuge or 

33 reservoir for plant pests, especially for corn. JØrgensen (2011) indicates that the western 
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-13

1 corn rootworm has been found in giant miscanthus, while Stewart and Cromey (2011) 

2 indicated that reports of diseases such as barley yellow dwarf virus, rust (Puccinia 

3 emaculata) and smut (Tilletia maclaganii) in miscanthus and switchgrass. Additionally, 

4 Spenser and Raghu (2009) found that in greenhouse and field studies there was significant 

5 emergence of western corn rootworm from giant miscanthus placed near corn fields. 

6 Bradshaw et al. (2010) found two species of aphids (yellow sugarcane aphid and corn leaf 

7 aphid) in samples taken from giant miscanthus fields in four states with stands ranging from 

8 one year to 21-years old. The yellow sugarcane aphid was located in seven samples across 

9 the four states and the corn lead aphid was located in four samples in four states. 

10 According to Bradshaw et al. (2010) the presence of aphids in giant miscanthus is of 

11 concern since aphids can transmit plant viruses. The research in this area is somewhat

12 lacking as these are new reports and steps should be taken to monitor for any plant 

13 diseases or pests within established stands of giant miscanthus. Future directions to be 

14 included in the MMP may include integrated pest management (IPM) programs associated 

15 with dedicated energy crops or buffers away from existing corn crops. 

16 4.4.1.3 No Action Alternative

17 Selecting the No Action Alternative would not result in significant effects to the local or 

18 regional vegetation within the proposed project areas, as the Project Sponsors would not 

19 establish and produce giant miscanthus in those areas. Current agricultural activities would 

20 remain similar or along the current projected trends for those regions. 

21 4.4.2 Wildlife

22 4.4.2.1 Significance Threshold

23 For wildlife, a significant effect would be a finding of substantial decline in biodiversity or 

24 species richness for the local area or the region.

25 4.4.2.2 Proposed Action

26 Implementing the Proposed Action, in association with the MMP, would be anticipated to 

27 results in minor negative effects to wildlife diversity. Wildlife diversity effects would be 

28 contingent upon the type of previous land use the acreage was in prior to conversion into 

29 giant miscanthus stands. There could be adverse effects to larger wildlife as giant 

30 miscanthus stands mature when compared to pasturelands; however, data related to larger 

31 species is lacking; therefore, the implementation of appropriate BMPs, as developed in the 

32 MMP would be essential to gauge short and longer-term effects on local larger wildlife. 
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-14

1 Field margins and wildlife buffers would provide continued access in areas where larger 

2 wildlife are known to occur. Studies from Europe indicate a neutral to positive effect for 

3 young-aged stands of giant miscanthus on bird species richness depending upon the 

4 previous vegetation cover. Fernando et al (2010) indicates that monocultures are not 

5 generally as diverse, but that biodiversity levels depend on the crop and the environmental 

6 setting. They also indicate that perennial rhizomatous grasses require less tillage, lower 

7 agrochemicals and high above- and below-ground biomass, which are beneficial for soil 

8 microfauna and provide cover to invertebrates and birds. Fernando et al (2010) indicate that 

9 according to their weighted-model, no significant differences related to a suite of 

10 environmental impacts was observed for the perennial species supported for dedicated 

11 energy crops. They suggested that compared to cultivated fields (e.g., potato and wheat), 

12 all perennial dedicated energy crops had fewer environmental impacts; however, they had 

13 greater impacts that fallow fields when considered on the whole. 

14 Bellamy et al (2009) indicated that a comparison of giant miscanthus to winter wheat in the 

15 United Kingdom provided some preliminary information on abundance and diversity of birds. 

16 They found that in fields (study field size of three hectare = 7.41 acres) with giant 

17 miscanthus aged between one to three years, they found a greater abundance and diversity 

18 of birds than in the control wheat fields. Bellamy et al. (2009) hypothesized that the reasons 

19 for this could have been contributed to the shelter provided by giant miscanthus during the 

20 winter and the abundance of non-crop plants in these early stage giant miscanthus fields. 

21 Bellamy et al (2009) surmised that on-going management for wildlife would be necessary to

22 ensure continued biodiversity as the giant miscanthus plants matured and the crop structure 

23 developed. Similarly, Semere and Slater (2007) found that young giant miscanthus fields in 

24 Herefordshire, England have a greater variety and abundance of open-ground bird than 

25 reed canary grass fields; however, the abundance and diversity of birds and small mammals 

26 was higher at the edges of both type of perennial biomass fields than in the fields 

27 themselves. Semere and Slater (2007) indicate that perennial biomass grasses could 

28 provide improved wildlife habitat due to the lower input in relation to traditionally managed 

29 row crops. Sage et al. (2010) found that miscanthus grown in southwestern England was 

30 approximately neutral when compared to grasslands in the number of birds. They found 

31 bird use to be variable and dependent on many factors such as region, weediness, crop 

32 structure, and patchiness. Fargione (2010) indicated that researchers found potential for a 

33 loss of bird biodiversity in high-input low diversity (HILD) bioenergy crops, such as corn 

34 soybeans, while in low-input high diversity (LIHD) bioenergy crops such as native prairie, 
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-15

1 bird species richness increased. They also found that for species of concern the magnitude 

2 of changes was more than double generalist species. Fargione (2010) indicates a lack of 

3 specific data availability for crops such as giant miscanthus, which has a different structure 

4 than native prairie grass species in the United States, indicating a need for more research 

5 on these species. JØrgensen (2011) indicates that very few species directly feed on 

6 miscanthus so diversity indicators are due in part to the lack of continual tilling, reduced 

7 pesticide levels, and provision of cover. At maturity, these stands could have a decline in 

8 biodiversity if field margins shrink as the fields become fully mature. 

9 4.4.2.3 No Action Alternative

10 Selecting the No Action Alternative would not result in significant effects to the local or 

11 regional wildlife within the proposed project areas, as the Project Sponsors would not 

12 establish and produce giant miscanthus in those areas. Current agricultural activities would 

13 remain similar or along the current projected trends for those regions. 

14 4.4.3 Protected Species

15 4.4.3.1 Significance Threshold

16 For protected species, both for vegetation and wildlife, a significant effect would be a finding 

17 of substantial decline in the number or range of species for the local area or the region 

18 directly attributable to the Proposed Action.

19 4.4.3.2 Proposed Action

20 Implementing the Proposed Action would not result in significant effects to any protected 

21 species, Federally-listed as threatened and/or endangered, primarily due to the lack of those 

22 species within the proposed project areas. Some species, such as the Indiana bat, may 

23 occur while commuting or migrating along waterways that serve as corridors between roost 

24 areas and other habitats, but existing crop and idle lands do not provide suitable habitat 

25 within the proposed project areas. Other concerns would be for fish, clams, and 

26 invertebrates located in streams near giant miscanthus plantings. The MMP would develop 

27 an appropriate buffer to ensure that effects to any species that could be located near giant 

28 miscanthus fields would be avoided through BMPs, such as buffer distances to riparian 

29 areas. 
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-16

1 4.4.3.3 No Action Alternative

2 Selecting the No Action Alternative would not result in significant effects to the local or 

3 regional protected species within the proposed project areas, as the Project Sponsors would 

4 not establish and produce giant miscanthus in those areas. Current agricultural activities 

5 would remain similar or along the current projected trends for those regions. 

6 4.5 SOIL RESOURCES

7 4.5.1 Significance Threshold

8 Impacts to soil resources would be considered significant if implementation of an action 

9 resulted in permanently increasing erosion, altered soil characteristics that threaten the 

10 viability of the cover, or affected unique soil conditions.

11 4.5.2 Proposed Action

12 Implementing the Proposed Action would result in a positive reduction in the soil erosion

13 through abundant below ground biomass with soil retaining abilities. Giant miscanthus 

14 produces abundant above and below ground biomass. The top soil layer (0 to 30 cm) 

15 contains around 28 percent of the root biomass, while nearly half of the total roots were 

16 present in the deeper soils layers (below 90 cm) (Neukirchen et al 1999). The extensive 

17 deep root system can improve soil qualities by improving water storage, microbial process, 

18 and soil organic carbon storage (Blanco-Canqui 2010). Davis et al. (2010) found that over a 

19 10-year study of giant miscanthus in Illinois, giant miscanthus produced greater above 

ground carbon (C) (1,606 to 2,426 grams [g] C/ square meter [m2 20 ]) when compared to 

switchgrass, native prairie, (344 to 705 g C/m2

) and corn (405 to 717 g C/m2 21 ). Davis et al. 

22 (2010) also indicated that giant miscanthus could produce soil C at a faster rate due in part 

23 to greater litter fall and below ground plant production (root system). Hansen et al. (2004) 

24 indicated that in soil samples taken from 9-year old and 16-year old giant miscanthus plants 

25 in Denmark that it was estimated that between 26 to 29 percent of accumulated C input was 

26 retained in the soil. The combined root system and high litter accumulation on the soil 

27 surface would reduce the wind and water soil erosion. 

28 Initial preparation of land for giant miscanthus established could result in the soil disturbance

29 similar to traditional tillage of commodity crops. The preparation process could cause an 

30 increase risk of erosion following rainfall events until the giant miscanthus could have time to 

31 establish (Donnelly et al 2010). The soil tillage for giant miscanthus establishment can 

32 redistribute the organic matter and nutrients that accumulate at the surface of soils and 
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-17

1 create beneficial effects for the soil quality by mixing the soils and organic matter (Donnelly

2 et al 2010). First-year harvesting of rhizomes would have similar soil disturbances as the 

3 initial planting; however, later year’s harvesting would be similar to activities for hay 

4 production that only minimally effect soil layers. Likewise, the eradication of the crop would 

5 result in additional tillage, similar to the establishment phase and traditional row crop tillage, 

6 which would redistribute soil organic matter, but would leave the soil bare until a new cover 

7 crop was established. To off-set short-term soil erosion potential associated with 

8 propagation and harvest of rhizome, fields with HEL would be avoided, if possible and other 

9 BMPs per the MMP would be incorporated into this phase. 

10 Overall, there could be a positive result of soil quality and reduction of soil erosion for the 

11 Proposed Action. Giant miscanthus can produce an ample amount of above and below 

12 ground biomass allowing for reduction in soil loss which would reduce the potential for 

13 sediment to move from fields carrying pesticides and nutrients to the surface water bodies. 

14 This could also reduce the sediments being deposited off-site and reduce suspended 

15 sediments that could move with runoff water directly into water bodies. 

16 4.5.3 No Action Alternative

17 Selecting the No Action Alternative would be unlikely to change current practices. Under this 

18 alternative, the Project Sponsors would not undertake the establishment and production of 

19 giant miscanthus in the proposed project areas. The proposed project areas would not 

20 receive the potential soil benefits that could be provided by giant miscanthus and could 

21 potentially receive negative effects to soil quality through continued traditional crop 

22 management. 

23 4.6 WATER QUALITY AND QUANTITY

24 4.6.1 Water Quality

25 4.6.1.1 Significance Threshold

26 An accounting of increases or reductions in input use such as fertilizer, herbicides, and 

27 pesticides is performed to evaluate potential changes in water quality.

28 4.6.1.2 Proposed Action

29 Implementing the Proposed Action would not result in a significant decline in surface water 

30 quality or groundwater quality within the proposed project areas. Over the productive life of 

31 the plantation acres, inputs of fertilizer, herbicides, and pesticides would be anticipated to be 
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-18

1 lower when compared to inputs for traditional row crops; however, since the majority of 

2 acres proposed for plantation acres would be marginal and idle lands there could be an 

3 increase in inputs over the existing vegetation on those areas. 

4 Since giant miscanthus is expected to be an excellent nutrient scavenger and recycles 

5 nutrients back to the root system, and results in excellent soil surface cover to prevent 

6 erosion losses, off-site movement of nitrogen and phosphorus would be expected to be low. 

7 Research also suggests that once established giant miscanthus can lead to low levels of 

8 nitrate leaching and as a result improving groundwater quality when compared to other 

9 crops (Christian and Riche 1998). The conversion of unused acres to giant miscanthus 

10 production would likely reduce runoff, sediment loss, and nutrient loss due to the high 

11 ground cover provided by the plant. This reduction in sediment and nutrient loss in runoff 

12 could enhance water bodies and water quality, especially in sensitive watersheds.

13 4.6.1.3 No Action Alternative

14 Selecting the No Action Alternative, would not produce a significant change in water quality, 

15 unless there was a substantial increase in land use toward traditional commodity crops. 

16 Based on agricultural crop production projections, planted corn acreage is anticipated to 

17 increase by approximately 5.4 percent between 2008 and 2017; however, all other primary 

18 field crop planted acreage is anticipated to decline. Overall, the change in land use through 

19 the selection of the No Action Alternative would not indicate increased acreage with a need 

20 for increased agricultural chemicals.

21 4.6.2 Water Quantity

22 4.6.2.1 Significance Threshold

23 Water quantity changes could result in positive or negative effects on total water use in the 

24 short-term and over the life of the crop compared to other cropping systems depending on 

25 the regional climate. Land use and water use changes would affect hydrology relative to 

26 runoff and stream flow.

27 4.6.2.2 Proposed Action

28 The water use relative to total quantity would be affected by this action only in areas where 

29 there is a high irrigation used to water cropland, where a large amount of acreage may be 

30 converted from irrigated cropland to non-irrigated giant miscanthus, or where short-term 

31 irrigation would be required during this planting season (2011) if irrigation to those 
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-19

1 propagation acres does not currently exist. The Ashtabula, Aurora and Columbia proposed 

2 project areas have less than 10 percent irrigated lands (USDA 2009). The Paragould 

3 proposed project area irrigates a much larger percentage of the cropland; an average of 

4 70.1 percent of the cropland is irrigated. This proposed project area is also a much larger 

5 area, with over 2.5 million acres of farmland. Under the Proposed Action the 

6 implementation schedule would plant propagation acres in 2011 that would produce 9,600 

7 propagation acres in 2012, with the goal to have 50,000 acres total per proposed project 

8 area, accounting for around 2.0 percent of the total acres of farmland in the Paragould 

9 proposed project area by 2014. 

10 Miscanthus has a high efficiency of water use to biomass yield when compared to corn or 

11 sorghum crops. Typically, giant miscanthus required between 100 to 300 liters of water to 

12 produce one kilogram (kg) of biomass (Heaton et al 2010). For comparison, typically a corn 

13 or sorghum crop requires 300 liters per kg of biomass. 

14 The proposed project would only require irrigation in this first year (2011) due to late planting 

15 of the crop and would not require irrigation after the first propagation year. Therefore, the 

16 Proposed Action would be likely to transfer some irrigated cropland to irrigated giant 

17 miscanthus propagation acres during 2011, resulting in irrigation use approximately equal to 

18 previous years within the proposed project areas. Additionally, the Proposed Action would 

19 result in some unirrigated pastureland acres converted into cropland that would require no 

20 irrigation; therefore, impacts to water quantity would be minimal, in relation to existing 

21 irrigation use within the proposed project areas. 

22 The other issue that should be mentioned in relation to water use by the giant miscanthus is 

23 the annual water use and water losses associated with evapotranspiration (ET) when 

24 compared to annual row crops. Giant miscanthus does have higher ET losses when 

25 compared to corn or corn mixes and switchgrass (McIsaac et al. 2010; VanLoocke et al. 

26 2010; Heaton et al. 2010). Giant miscanthus is a perennial plant which leads to a longer 

27 active growing season. VanLoocke et al. (2010) indicated that the growing season for giant 

28 miscanthus with emergence in mid- to late-April continuing into September or October may 

29 explain a portion of the increased ET over annual row crop production. Also, giant 

30 miscanthus has a faster growth rate, larger leaf area, and deep root system when compared 

31 to annual crops, thereby having higher ET rates (Smeets 2008). Rainfall interception is 

32 relatively high for giant miscanthus, as well (Donnelly 2010). 
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-20

1 VanLoocke et al. (2010) also indicate that past studies have shown that conversion to 

2 annual crop dominated cover could have reduced ET in Corn Belt of the United States by 

3 approximately 75 millimeters (mm) per year, indicating that giant miscanthus could have ET 

4 rates more in line with past vegetative cover in prime farming areas than current crop cover. 

5 Beale et al. (1999) indicated that water use efficiency for giant miscanthus, when normalized 

6 by the daily maximum vapor pressure deficit, were within the range of C4 crops over several 

7 environments (7.3 grams per kiloPascal per kilogram [g kPA/kg] – 9.4 g kPA/kg) and based 

8 on literature would be similar to corn (8.2 to 12.0 g kPA/kg) and pearl millet (8.4 to 10.6 g 

9 kPA/kg). The annual water use of giant miscanthus may be higher than corn or sorghum 

10 due to the rainfall interception and transpiration rates. However, as mentioned earlier, the 

11 yield per unit of water produced by giant miscanthus is anticipated to be higher than the 

12 biomass produced by other crops, such as annual crops. Also as a result of the deep root 

13 system and large leaf area, there are higher infiltration rates during rain events allowing for a 

14 reduced run-off and the reduced peak flows (Smeets 2008). 

15 Although, there could be an increased annual water use by the planting of giant miscanthus, 

16 due to the small production area and the overall improvement of infiltration impacts should 

17 be minimal to water quantity from the Proposed Action.

18 4.6.2.3 No Action Alternative

19 The selection of the No Action Alternative would not result in significant adverse effects to 

20 the water quantity within the proposed project areas. Under this alternative, the Project 

21 Sponsors would not undertake the establishment and production of giant miscanthus in the 

22 proposed project areas. The change in land use through the selection of the No Action 

23 Alternative would not indicate increased acreage with a need for increased agricultural 

24 irrigation.

25 4.7 ALTERNATIVES COMPARISON

26 This section of the EA provides a brief comparison for the potential effects associated with 

27 both the Proposed Action and the No Action Alternative. Table 4-4 lists the qualitative 

28 comparison of the alternatives.

29
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-21

1 Table 4-4. Comparison of the Alternatives

Resource Area Proposed Action No Action Alternative

Socioeconomics + minor 0

Land Use - minor 0

Biological Resources

Vegetation - minor 0

Wildlife - minor 0

Protected Species 0 0

Soil Resources + minor (primarily during 

establishment)

0/- minor

Water Quality/Quantity

Water Quality + minor 0

Water Quantity +/- minor 0

2 Note:

3 + =positive - =negative 0 =neutral

4 4.7.1 Proposed Action

5 Implementing the Proposed Action would result in minor positive and negative effects to the 

6 local and regional area; however, many of these effects would be minimized through the use 

7 of the MMP. The Proposed Action could result in additional diversified income for the 

8 contract producer, as well as technical assistance from the Project Sponsors in the 

9 production and harvesting of giant miscanthus. The Project Sponsors have a proposed BCF 

10 in each of the proposed project areas ensuring that producers will have a demand for their 

11 products. Also, ancillary agricultural services should expect an increase due to the Project 

12 Sponsors goal of primarily contracting idle acres and not active cropland. The Proposed 

13 Action would result in a changed local landscape with the addition of the giant miscanthus 

14 fields; however, most contract acreage would be small between 38 to 100 acres. The MMP 

15 would be used to ensure that adverse effects from this new crop are minimized or avoided. 

16 Similarly, minor negative effects would be anticipated for biological diversity as pastureland 

17 is converted in giant miscanthus croplands. The MMP would be essential to provide 

18 mechanisms such as buffers and field edges to provide for continued wildlife and vegetative 

19 diversity in these areas and control of rhizome and vegetative spread. Recent research has 

20 indicated that giant miscanthus can function as a source of plant pests to conventional 

21 crops; the MMP monitoring and buffer would be essential to ensure that any infestation are 

22 identified and treated early to avoid transmission to local croplands, such as corn. Giant 

23 miscanthus, which has an extensive perennial root system, would be anticipated to have 

24 positive effects on soil retention, soil organic matter, and conversion to soil carbon, as well 

25 as increased water quality related to nutrient leaching and transported sediments. Also, due 

26 to its growth patterns, giant miscanthus would be anticipated to require more water than 
ENVIRONMENTAL CONSEQUENCES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 4-22

1 annual crops, such as corn; however, giant miscanthus has much higher water use 

2 efficiency, generating high amounts of biomass per volume of water consumed. 

3 4.7.2 No Action

4 The No Action Alternative would result in no adverse effects to the local and regional area 

5 since there would be no giant miscanthus planted in any of the proposed project areas as 

6 described in this BCAP Project Proposal. However, the No Action Alternative would not 

7 assist in meeting the overall goal of BCAP, which is to develop dedicated energy crops for 

8 use into the conversion of bioenergy. 

9
CUMULATIVE IMPACTS ASSESSMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 5-1

1 5 CUMULATIVE IMPACTS ASSESSMENT 

2 5.1 DEFINITION

3 The CEQ regulations stipulate that cumulative effects analysis consider the potential 

4 environmental impacts resulting from “the incremental impacts of the action when added to 

5 other past, present and reasonably foreseeable actions regardless of what agency or person 

6 undertakes such other actions.” Cumulative effects most likely arise when a relationship 

7 exists between a proposed action and other actions expected to occur in a similar location 

8 or during a similar time period. Actions overlapping with or in proximity to the proposed 

9 action would be expected to have more potential for a relationship than those more 

10 geographically separated. Similarly, actions that coincide, even partially, in time tend to 

11 have potential for cumulative effects. 

12 The Proposed Action is to establish BCAP project areas supporting the establishment and 

13 production of giant miscanthus as a dedicated energy crops for bioenergy production. The 

14 scale of this action is regional and includes counties within Arkansas, Missouri, Ohio, and 

15 Pennsylvania. Given the action is to produce an alternative crop on existing agricultural 

16 lands, identifying past, present, and reasonably foreseeable future actions is based on 

17 existing cropland production, projected future cropland production, existing CRP acres 

18 within each county, future expirations of CRP acres within each county, and the potential for 

19 additional BCAP project acres within these proposed project areas. 

20 5.2 CUMULATIVE IMPACTS ANALYSIS BY RESOURCE AREA

21 5.2.1 Socioeconomics

22 In the United States, average farm operator household income from 2007 to 2009 has been 

23 consistently higher than the average United States household income; however, the 

24 percentage difference has been declining from a high of 31.1 percent higher to 13.5 percent 

25 higher (USDA Economic Research Service [ERS] 2011). Farming activities have 

26 contributed approximately 11.3 percent to household income, with the projected average 

27 being 12.5 percent in 2010 (Ibid). After two declining years of total household income of 

28 farm operators, the forecast for 2010 and 2011 indicate an increase, which will be record 

29 levels (Ibid). Traditional commodity crops continue to be high-value for associated land 

30 production capabilities providing a substantial proportion of farm operator household income 

31 for many areas. Combined with the foreseeable high commodity prices associated with 

32 recent natural occurrences that have impacted food crops globally and the driver for 
CUMULATIVE IMPACTS ASSESSMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 5-2

1 alternative fuels and energy sources from renewable resources, traditional crops such as 

2 corn and soybean would be anticipated to continue as the dominant agricultural land uses 

3 within these proposed project areas. 

4 Under the Proposed Action, contract producers would be creating a diversified crop profile 

5 with the inclusion of giant miscanthus on their marginal or idle lands. Given the infancy of 

6 industry for biomass feedstock production, large acreages are not anticipated to be 

7 converted into dedicated biomass crops with the short-time frame associated with BCAP. 

8 The Project Sponsors are anticipating a total combined acreage across all proposed project 

9 areas to be 200,000 acres by 2014. The potential for dedicated energy crops exists through 

10 many regions of the United States; however, one of the primary limiting factors is 

11 accessibility to a BCF that (1) provides a market to producers for their biomass feedstock 

12 and (2) has a market for sale of the bioenergy product produced at that facility. Overall, the 

13 cumulative effects to socioeconomics associated with the Proposed Action and No Action 

14 Alternative would be minor, given the high commodity prices associated with traditional 

15 crops and the lack of adequate BCF with enough demand in the region to convert more than 

16 a modest amount of agricultural lands to dedicated energy crop production away from 

17 traditional crops. 

18 5.2.2 Land Use

19 The combined proposed project areas include approximately 6.5 million acres of cropland 

20 and pastureland with varying degrees of activity (Table 5-1). Overall, soybeans are the 

21 most cultivated crop accounting for less than 1.7 million acres within the combined proposed 

22 project areas. Corn followed with 0.6 million planted acres in the combined proposed

23 project areas. Projections from the USDA Agricultural Projections to 2020 indicate that 

24 increased United States planted acres of soybeans and corn would, on average, remain 

25 relatively flat, with some short-term increase in corn (USDA World Agricultural Outlook 

26 Board 2011). 

27 Of the land in farms, approximately 191,000 acres are in CRP as of 2010 (13.7 percent of 

28 permanent pasture or rangeland), with approximately 66,500 acres expiring from CRP 

29 between 2012 to 2014. Currently there are approximately 31.2 million acres enrolled in 

30 CRP practices in the United States, with 4.4 million expiring at the end of Fiscal Year 2011

31 (14 percent). Overall, the cumulative effects to land use associated with the Proposed 

32
CUMULATIVE IMPACTS ASSESSMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 5-3

1 Table 5-1. Land Use by Proposed Project Area with Planted Acres in Crops

Proposed 

Project Area

Harvested 

Cropland

(2007)

Total CRP 

Acres 

(2010)

Total 

Pasture

(2007)

Planted Acres (2010)

Percent of Planted Acres within the 

State(s)

Corn Sorghum Oats

Soybeans Corn Sorghum OatsSoybeans

Ashtabula 492,050 8,732 139,885 138,200 0 15,900 106,500 2.9% 0.0% 9.1% 2.1%

Aurora 561,033 20,241 944,322 58,500 1,700 0 89,200 1.9% 4.3% 0.0% 1.7%

Columbia 1,226,524 131,336 799,682 323,700 8,500 0 542,200 10.3% 21.3% 0.0% 10.5%

Paragould 2,087,971 31,505 261,540 98,900 2,400 0 937,400 25.4% 6.0% 0.0% 29.4%

2 Source: USDA NASS 2009, 2011

3 Action and No Action Alternative would be minor, given the high commodity prices 

4 associated with traditional crops and the lack of adequate BCF with enough demand in the 

5 region to convert more than a modest amount of agricultural lands to dedicated energy crop 

6 production away from traditional crops. 

7 5.2.3 Biological Resources

8 Cumulative effects from the Proposed Action would be minimized through the use of the 

9 MMP to ensure that overall biodiversity would be maintained and the potential for plant 

10 pests would be minimized. The potential cumulative effects of establishment of a biomass 

11 crop would impact wildlife as habitats are fragmented, degraded, or destroyed from 

12 dedicated energy crop establishment; however, the amount of acreage within any of the 

13 proposed project areas would be minor and would be mitigated through the MMP. The 

14 establishment of new dedicated energy crops in areas previously fallow or cropped for a 

15 different style of agriculture may itself cause some direct mortality and range shifting at the 

16 local scale of wildlife. Direct effects are likely to occur during the establishment phase, but 

17 would be similar to traditional agricultural cropping of fallowed or idle lands. During the short 

18 term, species using pastureland could relocate to marginal areas or wildlife corridors. 

19 Overall, the cumulative effects to biological resources associated with the Proposed Action 

20 and No Action Alternative would be minor, given the high commodity prices associated with 

21 traditional crops and the lack of adequate BCF with enough demand in the region to convert 

22 more than a modest amount of agricultural lands to dedicated energy crop production away 

23 from traditional crops. The use of the MMP for the Proposed Action would also minimize 

24 effects to biological resources and provide mechanisms for adaptive management should 

25 the need arise based on crop monitoring.

26
CUMULATIVE IMPACTS ASSESSMENT

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 5-4

1 5.2.4 Soil Resources

2 The Proposed Action would be anticipated to create positive effects to soils at multiple 

3 levels, including a reduction of soil erosion, and increase in soil organic matter, and soil 

4 carbon deposition, when compared to traditional crops or fallowed land under annual 

5 species. Overall, the cumulative effects to soils resources associated with the Proposed 

6 Action and No Action Alternative would be minor, given the high commodity prices 

7 associated with traditional crops and the lack of adequate BCF with enough demand in the 

8 region to convert more than a modest amount of agricultural lands to dedicated energy crop 

9 production away from traditional crops. 

10 5.2.5 Water Quality and Quantity

11 The conversion to a perennial dedicated energy crop provides greater water use efficiency 

12 than traditional row crops such as corn, thereby indicating a more productive choice for 

13 biomass production. Giant miscanthus would be anticipated to use more water than 

14 fallowed or idle lands with permanent pasture, rangeland, or annual species. Taken in 

15 combination with traditional crops in the proposed project areas, there could be greater use 

16 of groundwater supplies or effects on groundwater recharge. However, these effects would 

17 be mitigated through monitoring and BMPs associated with the MMP. The conversion from 

18 traditional crops to dedicated energy crops would be anticipated to limit runoff from 

19 agricultural fields and potential need for irrigation past the initial establishment period. 

20 Potential plant pests newly associated with giant miscanthus could require more pesticide 

21 use or greater IPM than potentially anticipated based on existing literature from Europe, but 

22 should be less than traditional row crops. Overall, the cumulative effects to water quality 

23 and quantity associated with the Proposed Action and No Action Alternative would be minor, 

24 given the high commodity prices associated with traditional crops and the lack of adequate 

25 BCF with enough demand in the region to convert more than a modest amount of 

26 agricultural lands to dedicated energy crop production away from traditional crops.

27
MITIGATION AND MONITORING

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 6-1

1 6 MITIGATION AND MONITORING 

2 6.1 INTRODUCTION

3 The CEQ issued revised guidance for mitigation and monitoring to be included in NEPA 

4 decision documents that include three general types of scenarios including: (1) mitigation 

5 incorporated into project design; (2) mitigation alternatives for NEPA decision documents 

6 (i.e., EA and EIS); and (3) mitigation commitments analyzed in EAs to support a Mitigated 

7 FONSI (CEQ 2011). The purpose of mitigation in this Draft EA is the first type, which is 

8 incorporation into project design following the original intent of the definition of mitigation 

9 provided by CEQ that includes:

10 Avoiding an impact by not taking a certain action or parts of an action;

11 Minimizing the impact by limiting the degree or magnitude of the action and its 

12 implementation;

13 Rectifying an impact by repairing, rehabilitating, or restoring the affected 

14 environment;

15 Reducing or eliminating an impact over time, through preservation and maintenance 

16 operations during the life of the action; and

17 Compensating for an impact by replacing or providing substitute resources or 

18 environments.

19 The recently revised CEQ guidance also explicitly specifies that adaptive management, or 

20 the potential for the lead agency under NEPA to take corrective action if the originally 

21 committed mitigation measures fail to address the target potential impacts, is allowable and 

22 desirable to both protect the environment and help a Federal agency meet their stated 

23 goals. 

24 6.2 ROLES AND RESPONSIBILITIES

25 The revised CEQ guidance on mitigation and monitoring explicitly requires each federal lead 

26 agency under NEPA, or FSA in this case, to identify mitigation tracking mechanisms, 

27 commitments for any mitigation proposed; responsibility for implementation particularly if 

28 shared, reasonably foreseeable circumstances regarding anticipated or projected funding 

29 availability to implement mitigation commitments; and the identification of any outside 

30 entities that may be responsible for assisting the lead agency through financial or other 
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DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 6-2

1 means to implement the committed mitigations. In BCAP, the lead agency under NEPA is 

2 FSA and the cooperating agencies include the USDA Rural Development, Animal and Plant 

3 Health Inspection Service (APHIS), the USDA United States Forest Service (USFS), and the 

4 NRCS, as described in the Final PEIS (USDA FSA 2010). FSA is expected to have primary 

5 responsibility for implementation and tracking of the mitigation and monitoring program. 

6 FSA is currently developing a Memorandum of Understanding with the NRCS to have NRCS 

7 provide technical support as TSPs on an individual contract basis to ensure each producer 

8 complies with existing requirements of BCAP including completion of the Environmental 

9 Screening worksheet, completion of a Conservation Plan, and compliance with all existing 

10 rules and regulations following BMPs outlined in NRCS Conservation Practice Standards. 

11 The role of the Project Sponsors, are expected to include potential financial assistance with 

12 implementation of the monitoring program to assess the effectiveness of mitigation and 

13 financial assistance for any eradication efforts outside of the intentionally planted areas. 

14 FSA has a framework for defining the components of the MMP that will be required for this 

15 project, but has not yet finalized the plan to consider all public input on the draft EA prior to 

16 making a final plan recommendation. Additionally, FSA is aware of on-going research for 

17 giant miscanthus; however, publication of those results has not yet been provided. FSA will 

18 provide review and monitoring of newly developed and available data for inclusion within this 

19 project and for projects of similar nature for BCAP, as it becomes available. 

20 6.3 MITIGATION AND MONITORING RECOMMENDATIONS

21 General mitigation and monitoring recommendations for BCAP, as a national program with 

22 numerous feedstock options, were detailed in the Final PEIS including common BMPs to 

23 address potential adverse impacts of energy crop establishment. Examples of the common 

24 BMPs include conservation buffers strips, no-till or reduced till planting methods, avoiding 

25 the primary nesting season to protect grassland bird populations, and work window 

26 avoidance for energy crop establishment to avoid establishment during high precipitation or 

27 rainfall events. 

28 The purpose of this mitigation and monitoring plan is to provide project-specific mitigation 

29 measures for the project that FSA is proposing to approve under BCAP. An inherent part of 

30 that process includes site-specific review by TSPs using the Environmental Screening 

31 worksheet to determine whether environmentally sensitive resources such as federally 

32 threatened or endangered species or wetlands are present and could be potentially affected. 

33 Where possible, implementation of BMPs through Conservation Plan development would 
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DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 6-3

1 mitigation any potential environmental impacts on key resources addressed within the scope 

2 of this EA. In the event sensitive resources have the potential to be present, FSA or their 

3 partners will assist each participating producer at the contract level to conduct any and all 

4 appropriate consultations with resource agencies such as the USFWS, U.S. Army Corps of 

5 Engineers (USACE), and State Historic Preservation Offices (SHPO). 

6 In general, potential environmental impacts associated with establishment and cultivation of 

7 giant miscanthus as proposed by the Project Sponsors are likely to be temporary in nature 

8 and variable in scale from local to regional depending on existing characteristics of the 

9 individual producer’s total land acreage being enrolled, their current land use, the 

10 surrounding mix of agricultural uses in each of the four project areas, and the year in the 

11 growth cycle (i.e., establishment in year one or two or maintenance in years three to 15). 

12 Potential impacts are more likely to be localized in areas where average farm size or the 

13 portion of total land holdings an individual producer is enrolling is small compared to areas 

14 with large farm sizes and land holdings where impacts could be more regional in nature. 

15 Potential impacts are also likely to vary by current land use with reduced environmental 

16 impacts on lands currently enrolled in traditional row crops compared to larger potential 

17 impacts on lands currently idle or in pastureland when converted to giant miscanthus. 

18 Potential impacts are also likely to vary depending on the surrounding character of farmland 

19 such that areas dominated by a single agricultural use (e.g., corn or beans) that have a 

20 large proportion of land converted to BCAP may have larger impacts that regions dominated 

21 by a variety of agricultural uses such that any land conversions to BCAP are relatively 

22 diluted. Finally, impacts are likely to vary by phases of the growth cycle such that 

23 establishment in year one (propagation) and year two (plantation planting) cycle may have 

24 larger impacts than maintenance (years 3 to 15) related to soil erosion and loss, water 

25 quality and quantity impacts, and herbicide application for weed control. 

26 All proposed site-specific mitigation measures will rely on adaptive management and 

27 monitoring to ensure that proposed mitigation commitments are met, and that in the event 

28 they do not prevent the intended potential impacts, that additional corrective measures are 

29 implemented to rectify the situation as required by the recent CEQ guidance (CEQ 2011). 

30 Adaptive management and monitoring is also useful for assessing the effectiveness of 

31 particular mitigations and addressing any uncertainty regarding whether a proposed method 

32 of mitigation is likely to address the intended potential environmental impact. 
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DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 6-4

1 6.3.1 Socioeconomics

2 The proposed project has the potential to impact socioeconomics by converting land 

3 currently enrolled in food crops to energy crops. However, this potential impact is primarily 

4 expected to be localized to the Paragould proposed project area associated with 

5 sustainability issues regarding current agricultural row crop use raised by producers who 

6 have expressed interest in enrolling in BCAP with the more marginally productive areas 

7 currently in corn or beans. Potential impacts are expected to be potentially mitigated by 

8 minimizing the conversion of food to energy crops and when that conversion does occur, 

9 focusing only on the marginally productive lands currently enrolled in food crops. The 

10 project sponsors are currently working with FSA, the USDA, Agricultural Research Service 

11 (ARS), and NRCS to develop appropriate metrics for tracking conversion of lands currently 

12 enrolled in food production and tracking documentation of their productive status.

13 6.3.2 Land Use

14 Potential impacts on land use may include conversion of land use types such as the 

15 conversion from traditional row crops to giant miscanthus as discussed above or the 

16 conversion of idle land, pastureland, or hayland into giant miscanthus. Potential mitigation 

17 measures as discussed above for tracking the conversion of land types and their productive 

18 status are also expected to mitigate potential adverse impacts on land change. If adaptive 

19 monitoring indicates large-scale or regional land use conversions are occurring, then 

20 additional restrictions on land use conversion may be necessary. 

21 6.3.3 Biological Resources

22 6.3.3.1 Vegetation

23 The primary potential impacts of giant miscanthus establishment are expected to be the 

24 potential for the hybrid to produce fertile seed and thus spread beyond the extent of the 

25 propagation or planting acres. Based on third-party independent verification by the OSIA

26 (OSIA 2010), the likelihood of giant miscanthus producing fertile seed and spreading beyond 

27 the enrolled fields is expected to be low. The OSIA has been monitoring the flower unit of 

28 OSIA’s giant miscanthus selection for pollen and seed production by observation and 

29 microscopic examination (Armstrong 2011 – Appendix A). Accordingly, neither pollen nor 

30 seed has been produced (Ibid). The extruded anthers of the flower unit have been shriveled 

31 in appearance and similar to what we see with male sterile seed corn inbred lines (Ibid). In 
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DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 6-5

1 addition, there have been no observed volunteer seedlings emerging in observation plot 

2 areas adjacent to the giant miscanthus selection (Ibid).

3 Additional weed risk assessments conducted on giant miscanthus compared to other 

4 potential bioenergy crops such as giant reed, switchgrass, Eucalyptus species, and 

5 Jatropha (i.e., a deciduous succulent plant) have concluded the risk of invasiveness in the 

6 United States is low (Barney and DiTomaso 2008, Gordon et al. 2011). In the event, giant 

7 miscanthus does escape, eradication studies indicate spring tillage followed by glyphosate 

8 application was successful in eliminating 95 percent of aboveground biomass after the first 

9 application (Anderson et al. 2011). 

10 Mitigation is expected to include development of a monitoring protocol on an appropriate 

11 frequency and scale to facilitate early detection and eradication. This mitigation measure is 

12 under development with the project sponsors in conjunction with FSA, ARS, and NRCS, and 

13 may ultimately include integration in national invasive species risk assessments being 

14 conducted by APHIS and USDA. Adaptive monitoring of the potential for escape is 

15 anticipated followed by inclusion of corrective measures involving eradication as described 

16 above, if necessary, may be included.

17 6.3.3.2 Wildlife

18 Potential impacts on wildlife and biodiversity may include habitat loss associated with 

19 conversion of lands currently idle, in pasture, or in hay, to giant miscanthus; reduced winter 

20 cover and food supplies on lands currently enrolled in row crops; impacts on nesting 

21 grassland bird populations; and additional habitat fragmentation in areas where field sizes 

22 are larger and more contiguous. Potential impacts due to habitat loss are expected to be 

23 mitigated using similar measures as described above to assess land use change to track 

24 and document the current status of any land converted to giant miscanthus under BCAP. 

25 The relatively low residual height left after harvesting giant miscanthus may reduce winter 

26 cover and affect nesting conditions for grassland birds such as northern bobwhites (Colinus 

27 virginianus), eastern meadowlarks (Sturnella magna), and grasshopper sparrows 

28 (Ammodramus savannarum). Finally, conversion of larger areas dominated by a single land 

29 use type (i.e., idle land, pastureland, or hayland) may have proportionally larger impacts on 

30 habitat fragmentation in project areas. 

31 Mitigation measures are under development with the project sponsors, FSA, ARS, and 

32 NRCS and may include harvesting windows to avoid impacts on nesting grassland birds, 
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DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 6-6

1 regional tracking of grassland bird populations, installation of conservation buffer strips for 

2 overwinter habitat, and monitoring land use conversions as described above. Existing 

3 sources of data such as the Breeding Bird Survey and other annual surveys conducted by 

4 state wildlife resource agencies (e.g., bobwhite quail counts) may be used to track wildlife 

5 population trends in each project area. Adaptive monitoring is anticipated to be used to 

6 monitor regional wildlife population trends and if necessary, implement corrective measures 

7 to alter land use conversion requirements or other measures to rectify any potentially 

8 unaddressed impacts resulting from the proposed project.

9 6.3.3.3 Protected Species

10 Potential impacts on protected species, such as Federally threatened or endangered 

11 species are possible in those areas where Critical Habitat has been designated, suitable 

12 habitat exists within the documented range of the species, or known records have been 

13 documented. Compliance with existing regulations, including the Endangered Species Act, 

14 will be accomplished with the assistance of TSPs through the Environmental Screening 

15 worksheet and subsequent resource agency consultation if deemed necessary. 

16 Mitigation is under development with the project sponsors, FSA, ARS, and NRCS and is 

17 expected to include a tiered structure whereby individual producers who enroll land in close 

18 proximity to sensitive habitat such as streams, wetlands, or riparian zones are required to 

19 implement additional BMPs as part of their Conservation Plan and potentially work with 

20 TSPs to complete appropriate resource agency consultations if necessary. Such a tiered 

21 approach is expected to be used throughout the monitoring program to make sure additional 

22 measures are taken when sensitive resources are present or in close proximity. Potential 

23 examples of BMPs in close proximity to such sensitive habitats include buffers to maintain 

24 specific planting distances, conservation buffer strips or plantings, silt fencing, potential 

25 application of no tilling establishment methods to address sedimentation impacts, and use of 

26 appropriately labeled herbicides to protect aquatic species. 

27 6.3.4 Soil Resources

28 Potential impacts on soil resources may include soil erosion and loss as a result of field 

29 preparation and planting in giant miscanthus. Compared to land currently in traditional row 

30 crops, potential soil erosion and loss is expected to be temporary and short-term, primarily 

31 associated with the establishment phase compared to more intensive annually tilled crops. 

32 Compared to land currently idle or in pasture or hay, potential soil erosion and loss may be 
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DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 6-7

1 slightly higher but still temporary and short-term associated with establishment. Regardless 

2 of current land use, long-term benefits of soil retention with established rhizomes and 

3 carbon soil sequestration towards the middle of the 15-year maintenance period on enrolled 

4 fields are expected to off-set temporary and short-term increases in soil erosion and loss 

5 that may also be associated with reduced carbon sequestration. 

6 Mitigation is under development with the project sponsors, FSA, ARS, and NRCS and may 

7 include a tiered structure as described above in Section 6.3.3 that uses BMPs associated 

8 with no-till planting methods for project areas in close proximity to sensitive habitats such as 

9 streams, wetlands, or other water bodies. Adaptive monitoring is expected to be used to 

10 track the effectiveness of carbon sequestration over the life of a given giant miscanthus 

11 planting (i.e., up to 15 years) compared to short-term and temporary soil losses associated 

12 with tilling and field preparation. In addition, the project sponsors anticipate selling carbon 

13 credits, or similar type credits, from the sequestration benefits in markets such as the 

14 European Exchange, which will require independent, third-party verification and data 

15 collection for verification. 

16 6.3.5 Water Quality and Quantity

17 6.3.5.1 Water Quality

18 Potential impacts on water quality include short-term and temporary increases in nutrient 

19 and fertilizer runoff during establishment and monitoring. Compared to land currently in 

20 traditional row crops, conversion to giant miscanthus is expected to result in less nutrient 

21 and fertilizer runoff. Compared to land currently idle or in pasture or hay, conversion to giant 

22 miscanthus may result in slight but short-term and temporary increases in nutrient and 

23 fertilizer runoff. However, long-term declines in nutrient loss (i.e., phosphorus and nitrogen) 

24 during the maintenance period (years 3 to 15) are likely to off-set temporary and short-term 

25 increases in nutrient leaching or runoff. The anticipated fertilizer application rate is also 

26 expected to be substantially lower compared to traditional row crops, but may be higher than 

27 idle or pasture or hay land. 

28 Mitigation is being developed with the project sponsors, FSA, ARS, and NRCS and may 

29 include numerous BMPs for integration with the Conservation Plans specifically designed to 

30 address potential short-term and temporary impacts on water quality more likely associated 

31 with conversion of idle or pasture or hayland to giant miscanthus. Adaptive monitoring may 

32 include methods to measure local water quality associated with potential nutrient leaching or 
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DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 6-8

1 fertilizer runoff such as lysimeter installation below the root growth zone to address field2 scale water balances. 

3 6.3.5.2 Water Quantity

4 Potential impacts on water quantity may arise from surface or groundwater supply depletion 

5 as giant miscanthus may increase the amount of withdrawals compared to current land uses 

6 such as traditional row crops or idle, pasture, or hayland. This potential impact is likely to be 

7 greatest in the Paragould proposed project area where participating producers report 

8 interest in enrolling due to unsustainable water demands due to current agricultural 

9 practices dominated by traditional row crops (e.g., corn and beans). 

10 Mitigation is under development with the project sponsors, FSA, ARS, and NRCS and may 

11 include BMPs as part of the Conservation Plan to address potential water quantity impacts 

12 associated with surface or groundwater supply depletion. Potential mitigation may also 

13 include using existing measures of surface and groundwater flow from United State 

14 Geological Survey (USGS) stream gauges or other local monitoring methods. Adaptive 

15 monitoring is expected to be used to determine whether any surface or groundwater 

16 supplies are being affected and if so, implement corrective measures. 

17
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Bioenergy Vol. 35, pp. 637-651.
PREPARERS

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 8-1

8 PREPARERS 

Name Organization Experience Project Role

Rae Lynn Schneider Integrated 

Environmental 

Solutions, LLC

10 years Project 

Management, 

Project Review

M.P.P, Public Policy, Harvard 

University, 2001

B.S., Rangeland Ecology & 

Management, Texas A&M 

University, 1997

Katelyn Kowalczyk Integrated 

Environmental 

Solutions, LLC

2.5 years Affected 

Environment, 

Environmental 

B.S., Environmental Science, Consequences

Stephen F. Austin State 

University, 2008

Ransley Welch Integrated 

Environmental 

Solutions, LLC

6 years GIS Analysis and 

Map Generation

M.S., Geoarchaeology and 

GIS, University of North Texas, 

2008

B.A., Anthropology, University 

of North Texas, 2002

Kimberly Suedkamp Wells ENVIRON 10 years Mitigation and 

Monitoring Plan

Ph.D., Fisheries and Wildlife 

Sciences, University of 

Missouri, 2005

M.S., Fisheries and Wildlife 

Ecology, Oklahoma State 

University, 2000

B.S., Renewable Natural 

Resources, University of 

Arizona, 1998

Heather Smith

B.S. Natural Resource 

Management, Grand Valley 

State University, 2007

ENVIRON 4 years

GIS support
PREPARERS

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 8-2

Name Organization Experience Project Role

Scott Coye-Huhn

J.D. Environmental Law, 

University of Cincinnati Law 

School, 2004

M.S. W. Social Work, St. Louis 

University, 1998

S.W. Social Work, Xavier 

University, 1992

Aloterra Energy 

LLC

16 years

Project Sponsor, 

Mitigation and 

Monitoring Plan, 

Environmental 

Consequences

Gene Garrett University of 

Missouri

30 years Environmental 

Consequences

Ph.D., Forest Ecology, 

University of Missouri, 1970

M.S., Forest Silviculture, 

Southern Illinois University, 

1966

B.S., Forestry, Southern Illinois 

University, 1965

Rich Pyter Consultant for 

Aloterra Energy 

LLC

8 years Environmental 

Consequences

M.S., University of Illinois at 

Champaign-Urbana, Natural 

Resources and Environmental 

Sciences, 2007

B.S., University of Illinois at 

Champaign-Urbana, 

Environmental Geology, 2003
PERSONS AND AGENCIES CONTACTED

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 9-1

9 PERSONS AND AGENCIES CONTACTED 

Name Organization/Agency

Responsible Agency Officials

Brandon Willis Deputy Administrator for Farm Programs, U.S. 

Department of Agriculture, Farm Service Agency,

Conservation and Environmental Programs Division, 

Washington D.C.

Martin Lowenfish Associate Director, U.S. Department of Agriculture, Farm 

Service Agency, Conservation and Environmental 

Programs Division, Washington D.C.

Matthew Ponish National Environmental Compliance Manager , U.S. 

Department of Agriculture, Farm Service Agency, 

Conservation and Environmental Programs Division, 

Washington D.C.

Federal Agencies Contacted

USDA, Agricultural Research Service Adam Davis, Ecologist, Global Change and 

Photosynthesis Research Unit, IL

Seth Dabney

Richard Lowrance, Research Ecologist, GA

John Sadler, Research Leader,, Cropping 

Systems and Water Quality Research Unit, MO

USDA, Animal Plant Health Inspection 

Service

Neil Hoffman, Special Assistant to the Deputy 

Administrator

USDA, Forest Service Joseph Carbone, Assistant Director, Ecosystem 

Management Coordination - NEPA

USDA, Natural Resources Conservation 

Service

Philip Barbour, PhD, Wildlife Biologist

Steve Brady, PhD, Team Leader, National 

Wildlife Technology Development Team

John Englert, National Plants Materials Specialist

Matt Harrington, National Environmental 

Coordinator

C. Wayne Honeycutt, PhD, Deputy Chief for 

Science and Technology

Norm Widman, National Agronomist

USDA, Rural Development Linda Rogers, Deputy Director, Program Support 

Staff

U.S. Environmental Protection Agency

Region 1

Region 2

Region 3

Region 4

Region 5

Region 6

Region 7

Region 8

Region 9

Region 10

Washington, D.C.

Boston, MA

New York, NY

Philadelphia, PA

Atlanta, GA

Chicago, IL

Dallas, TX

Kansas City, KS

Denver, CO

San Francisco, CA

Seattle, WA
PERSONS AND AGENCIES CONTACTED

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 9-2

Name Organization/Agency

U.S. Fish and Wildlife Service

Region 1

Region 2

Region 3

Region 4

Region 5

Region 6

Region 7

Region 9

Portland, OR

Albuquerque, NM

Fort Snelling, MN

Atlanta, GA

Hadley, MA

Denver, CO

Anchorage, AK

Washington, D.C.

State Agencies Contacted

State of Arkansas Terry Griffin, Assistant Professor, University of 

Arkansas

Randy Young, Director, Arkansas Natural 

Resources Commission

State of Missouri Dennis Baird, Deputy Director of Agriculture

Don Day, University of Missouri Extension

Cerry Klein, Sustainable Advantage Director, 

University of Missouri

Sara Parker Pauley, Director, Department of 

Natural Resources

Steve Wyatt, Vice Provost for Economic 

Development, University of Missouri

State of Ohio David Marrison, County Extension Director, Ohio 

State University Extension – Ashtabula County

Local Officials and Interested Parties

Brian Anderson, Executive Director, Growth 

Partnership of Ashtabula County, OH

John Armstrong, Manager, Ohio Seed 

Improvement Association, OH

Dale Arnold, Director, Energy Policy of Ohio 

Farm Bureau Federation, OH

J. Mike Brooks, President, Regional Economic 

Development, Inc. MO

Paula Hertwig Hopkins, Assistant City Manager, 

City of Columbia, MO

Blake Hurst, President, Missouri Farm Bureau 

Federation, MO

Tad Johnson, Director, Columbia Water and 

Light, Columbia, MO 

Bob McDavid, Mayor, City of Columbia, MO

Sue McGowan, Director, Paragould Regional 

Chamber of Commerce, Paragould, AR

John Palo, Director, Conneaut Port Authority, OH

Sean Ratican, Executive Director, Ashtabula 

County Port Authority, OH

Jeff Roskam, Kansas Alliance for Biorefining and 

Bioenergy, KS

Tony Stonecypher, City Manager, City of Aurora, 

MO

Shannon Walker, Director Aurora Chamber of 

Commerce, Aurora, MO
PERSONS AND AGENCIES CONTACTED

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 9-3

Name Organization/Agency

Randy Zook, CEO, Arkansas State Chamber of 

Commerce, AR

Political Officials

Senator Roy Blunt

Senator John Boozman

Senator Sherrod Brown

Representative Rick Crawford

Representative Steven C. LaTourette

Senator Claire McCaskill

Senator Mark Pryor
PERSONS AND AGENCIES CONTACTED

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 9-4

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APPENDICES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 

APPENDICES
APPENDICES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 

This Page Intentionally Left Blank
APPENDICES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 

APPENDIX A – Ohio Seed Improvement Association Data Summary for Giant 

Miscanthus
APPENDICES

DRAFT - Environmental Assessment Giant Miscanthus Establishment and Production 

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From: John Armstrong [mailto:armstrong@ohseed.org] 

Sent: Monday, April 04, 2011 8:17 AM 

To: Scott Coye-Huhn 

Subject: RE: IMPORTANT -please read and respond/call 

Dear Scott:

                Your  statement below is correct. More specifically, what I have done is to monitor the flower

unit of OSIA’s  M. x giganteus selection for pollen and seed production by observation and  microscopic

examination. To date neither pollen or seed has been produced. The extruded anthers of the flower unit

have been shriveled in appearance and similar to what we see with male sterile seed corn inbred lines.

In addition, I have observed no volunteer seedlings emerging in observation plot areas adjacent to the

M. x giganteus selection.  

                Furthermore, the following technical references provide additional comment regarding the

invasive issue:

1. CAST Commentary, QTA2007‐1, November 2007, “Biofuel Feedstocks: The Risk of

Future Invasions”, p. 5.  

2. Lewandowski, I., J. C. Clifton‐Brown, J.M.O. Scurlock, and W. Huisman. 2000.

Miscanthus: European experience with a novel energy crop. Biomass Bioenergy

19:209‐227.

Best regards.

John Armstrong, Sec./Mgr.

Ohio Seed Improvement Association

61650 Avery Road P.O. 477

Dublin, Ohio 43017

Ph. 614‐889‐1136

Fax: 614‐889‐8979

Email: armstrong@ohseed.org

*************************************************************************************

From: Scott Coye-Huhn [mailto:scoyehuhn@aloterraenergy.com] 

Sent: Saturday, April 02, 2011 11:25 AM 

To: John Armstrong 

Subject: IMPORTANT -please read and respond/call 

Importance: High 

Are you comfortable with the statement below? They are basing that on your observations in your 3

year study.  

The primary potential impacts of giant miscanthus establishment are expected to be the 

potential for the hybrid to produce fertile seed and thus spread beyond the extent of the 

propagation or planting acres. Based on third-party independent verification by the OSIA (OSIA 
2010), the likelihood of giant miscanthus producing fertile seed and spreading beyond the 

enrolled fields is expected to be low. Additional weed risk assessments conducted on giant 

miscanthus compared to other potential bioenergy crops such as giant reed, switchgrass 

(Panicum virgatum), Eucalyptus species, and Jatropha (i.e., a deciduous succulent plant) have 

concluded the risk of invasiveness in the United State is low (Barney and DiTomaso 2008, 

Gordon et al. 2011). In the event, giant miscanthus does escape, eradication studies indicate 

spring tillage followed by glyphosate application was successful in eliminating 95 percent of 

aboveground biomass after the first application (Anderson et al. 2011). 

Scott Coye-Huhn 

Director of Business Development 

Aloterra Energy LLC 

8000 Research Forest Drive, Suite 115-176 

The Woodlands, Texas 77382 

713-412-5311