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

MAY 2011

FINAL
 
MITIGATIED FINDING OF NO SIGNIFICANT IMPACT

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production I

MITIGATED FINDING OF NO SIGNIFICANT IMPACT 

ENVIRONMENTAL ASSESSMENT

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

Pennsylvania

Farm Service Agency

U.S. Department of Agriculture

The United States Department of Agriculture Farm Service Agency (FSA) on behalf of the 

Commodity Credit Corporation (CCC) has prepared an Environmental Assessment (EA) to 

evaluate the environmental consequences associated with establishing Biomass Crop 

Assistance Program (BCAP) project areas that support the establishment and production of 

giant miscanthus (Miscanthus x giganteus) on 50,000 acres per proposed project area 

(200,000 acres total) by 2014. The BCAP is a new program authorized by the Food, 

Conservation, and Energy Act of 2008 (2008 Farm Bill) that provides financial assistance to 

contract producers in approved project areas for the establishment and production of 

perennial bioenergy crops and annual bioenergy crops that show exceptional promise for 

producing bioenergy or biofuels that preserve natural resources and that are not primarily 

grown for food or animal feed. 

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

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

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

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

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

PROPOSED ACTION

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

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

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

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

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

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

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

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

Each proposed project area is named for the approximate location of the BCF that will be 
MITIGATIED FINDING OF NO SIGNIFICANT IMPACT

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production II

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

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

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

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

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

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

within each proposed project area with center-pivot irrigation due to the late planting this 

growing season. This centralized propagation area for the entire proposed project area 

would only occur for the 2011 planting season; all other planting season would follow the onfarm model with the initial establishment of propagation acres, followed by plantation acres 

the following growing season. Equipment to be used to establish giant miscanthus would be 

modified equipment from existing perennial grass industries. Equipment used to harvest 

and bale giant miscanthus would be similar to existing types of agricultural machinery used 

for hay crops; however, they would need to be more heavy-duty due to the increased 

biomass amounts being harvested and baled. 

REASONS FOR MITIGATED FINDING OF NO SIGNIFICANT IMPACT 

In consideration of the analysis documented in the EA and the reasons outlined in this 

Mitigated Finding of No Significant Impact (FONSI), the Proposed Action would not 

constitute a major Federal action that would significantly affect the human environment. 

Therefore, an environmental impact statement will not be prepared. The determination is 

based on the following:

1. The Proposed Action as outlined in the EA would provide minor beneficial effects to 

socioeconomics, soil resources, and water quality and quantity of the local areas due 

to a diversified agricultural production, establishment of perennial vegetation on 

highly erodible soils, and estimated higher water use efficiency of the species to be 

established. 

2. The Proposed Action could result in minor negative effects from land use changes 

associated with marginal and idle croplands and pasturelands returning to 

agricultural production; vegetation composition on pasturelands, which in turn could 

alter wildlife habitat, and water quantity due to increased water use of the species 

when compared to annual species, such as traditional row crops. These potential 

negative effects would be minimized through the use of the Mitigation and Monitoring 

Plan, described in the EA.
MITIGATIED FINDING OF NO SIGNIFICANT IMPACT

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production III

3. The Proposed Action would require site specific environmental screening for each 

producer contract initiated with FSA for inclusion as a producer within the proposed 

project areas, which would identify field level resources that would be need to be 

avoided or the effects could be minimized through mitigation efforts as described in 

the EA.

4. Potential beneficial and adverse impacts of implementing the Proposed Action have 

been fully considered within the EA. No significant adverse direct or indirect effects 

were identified, based on the resource analyses provided. 

5. The Proposed Action would not involve effects to the quality of the human 

environment that are likely to be highly controversial.

6. The Proposed Action would not establish a precedent for future actions with 

significant effects and does not represent a decision in principle about a future 

consideration. 

7. The Proposed Action does not result in cumulative significant impacts when 

considered with other actions that also individually have insignificant impacts. 

Cumulative impacts of implementing the Proposed Action were determined to be not 

significant.

8. The Proposed Action would not have adverse effects on threatened or endangered 

species or designated critical habitat since site specific analyses would be 

undertaken for each producer contract within each proposed BCAP project area to 

avoid adverse effects to these protected species.

9. The Proposed Action does not threaten a violation of Federal, State, or local law or 

requirements imposed for the protection of the environment.

OVERVIEW OF THE MITIGATION AND MONITORING PLAN

To avoid more than minor adverse effects to the human and natural environment, a 

mitigation and monitoring plan was developed to address each of the resource areas 

analyzed in detail within the EA. One of the primary components of the Mitigation and 

Monitoring Plan is producer education. This education component, to be held twice annually 

for active producers with an orientation program for new producers, outlines best practice 

standards across an array of resource areas and topics to ensure effective establishment 

and management of the giant miscanthus fields. In addition to the educational components, 
MITIGATIED FINDING OF NO SIGNIFICANT IMPACT

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production IV

producers would be required to submit annual reports to the Project Sponsors detailing 

many aspects of production and allows for a greater understanding of how this species will 

grow in a production setting. More specifically, FSA with cooperation from the Natural 

Resource Conservation Service (NRCS), the Agricultural Research Service (ARS) and the 

Project Sponsors are proposing the following mitigation and monitoring measures. These 

monitoring and mitigation measures have been developed based on the prevailing literature 

and in some cases, conservative estimates relating to existing standards for other 

conservation programs and practices, but not specific to giant miscanthus.

Biannual Producer meetings to discuss new developments in production, 

management, pest/disease treatment, and eradication;

New Producer orientation to discuss production methods, management activities, 

potential for spread of giant miscanthus, treatment methods, and responsibilities, 

pest/disease identification, treatment methods, and responsibilities, eradication 

methods, if necessary, and reporting requirements;

Producer Conservation Plans to include site specific best management practices 

(BMPs), which could include, but not be limited to, NRCS Conservation Practice 

Standards (CPS) for soil erosion, pesticide use and application, fertilizer use and 

application, and other relevant areas for each specific site; 

Setbacks/buffers to manage the giant miscanthus stand and to prevent unintentional 

spread of the giant miscanthus shall follow all local, State, or Federal regulations for 

containment of biomass plantings in existence at the time of the development of the 

producer’s Conservation Plan or through an amendment of the Conservation Plan 

initiated by the producer and approved by FSA and NRCS, if determined appropriate 

for the site-specific conditions. If no such guidance exists, minimum procedures to 

prevent unintentional spread of giant miscanthus shall include:

o Establish or maintain a minimum 25 feet of setback/border around a giant 

miscanthus stand, unless the field is adjacent to existing cropland or actively 

managed pasture with the same operator.

o Setback/border areas may be planted to an annual row crop such as corn or 

soybeans; may be planted to a site-adapted, perennial cool-season or warmseason forage or turf grass; may be kept in existing vegetation; or kept clear 

by disking, rotovating, or treating with a non-selective burn down herbicide at 
MITIGATIED FINDING OF NO SIGNIFICANT IMPACT

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production V

least once a year. The method used may be dependent on slope and the 

potential for erosion. 

The use of only the sterile variety of giant miscanthus cultivar known as the “Illinois 

Clone” for producers included within the proposed project areas; all Illinois Clone 

cultivars must be approved for planting under Aloterra’s membership through the 

Ohio Seed Improvement Association’s Quality Assurance program;

The initiation of a seed sampling program to determine the on-going sterility of seeds 

produced from the BCAP acres within the project areas. The seed sampling 

program includes recommended actions, including eradication, if a seed sample 

returns viable seed.

Exclusion of planting giant miscanthus on certain acreage within approximately 1,300 

feet from any known Miscanthus sinensis or Miscanthus sacchariflorus to limit the 

potential for cross-pollination resulting in viable seed. 

Exclusion of planting giant miscanthus on certain acreage within the project areas, 

depending upon certain site-specific conditions, like those lands subject to frequent 

flooding events; 

Monitoring program developed to identify (1) spread of giant miscanthus outside of 

planted fields with notification provided to both USDA and the Project Sponsors as 

soon as possible after identification of the issue, (2) identification of diseases and 

pests with notification provided to the Project Sponsors as soon as possible after 

identification of the issue; and (3) wildlife use or changes in use, all to be included in 

the annual producer reporting; a USDA representative will conduct an annual field 

visit to monitor the site and to look for potential spread of giant miscanthus beyond 

the site; the USDA will work with local weed control districts to provide additional 

monitoring/evaluation of these sites as appropriate; and

Annual producer reporting, which would include land use tracking with the average 

and total size of enrolled fields; prior land use; rationale for land use change; spread 

of giant miscanthus outside of planted fields; any pests/diseases identification; the 

use of pesticides/herbicides to control unwanted spread of giant miscanthus or 

pests/diseases; BMP and CPS incorporated into field management, such as erosion 

control structures or materials, vegetative barriers, etc.; fertilizer usage and 

application methods; and cost data.
MITIGATIED FINDING OF NO SIGNIFICANT IMPACT

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production VI

DETERMINATION

In accordance with the National Environmental Policy Act and FSA's environmental 

regulations at 7 Code of Federal Regulations (CFR) part 799 implementing the regulations 

of the Council on Environmental Quality, 40 CFR parts 1500-1508, I find the Proposed 

Action and associated mitigation measures do not constitute a major Federal action 

significantly affecting the quality of the human environment. Therefore, no environmental 

impact statement will be prepared.

_____________________________,

Acting Executive Vice President,

Commodity Credit Corporation, and

Acting Administrator,

Farm Service Agency
EXECUTIVE SUMMARY

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

EXECUTIVE SUMMARY 

INTRODUCTION AND BACKGROUND

The U.S. Department of Agriculture (USDA) Commodity Credit Corporation (CCC) 

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

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

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

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

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

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

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

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

evaluation of a project area proposal is developed through the completion of Forms BCAP19, BCAP-20, BCAP-21, and BCAP-22 and supporting information. After this initial 

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

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

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

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

significance. 

This EA analyzes the proposed establishment of BCAP project areas supporting the 

proposed establishment and production of giant miscanthus hybrid (Miscanthus X 

giganteus) by Aloterra Energy LLC and MFA Oil Biomass LLC (Project Sponsors) in 

Arkansas, Missouri, Ohio, and Pennsylvania, which is being completed to meet the 

requirements of the NEPA environmental evaluation of the BCAP or to determine if an EIS 

would be required. 

PURPOSE AND NEED

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

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

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

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

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

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

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

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

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

ALTERNATIVES

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

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

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

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

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

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

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

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

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

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

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

miscanthus. 

PROPOSED ACTION

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

This centralized propagation area for the entire proposed project area would only occur in 

the 2011 planting season; all other planting seasons would follow the on-farm model with 

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

growing season. No irrigation will be required after 2011. 

Equipment to be used to establish giant miscanthus would be modified equipment from 

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

would be similar to existing types of agricultural machinery used for hay crops; however, 

they would need to be more heavy-duty due to the increased biomass amounts being 

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

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

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

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

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

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

ENVIRONMENTAL CONSEQUENCES

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

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

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

would be minimized through the use of the Mitigation and Monitoring Plan. FSA has a 

framework for defining the components of the Mitigation and Monitoring Plan. The 

Mitigation and Monitoring Plan is included in section 6.0 of this document. 

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

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

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

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

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

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

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

contract acreage would range in size between 38 to 100 acres. 
EXECUTIVE SUMMARY

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

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 0/- minor

Water Quality/Quantity

Water Quality +/- minor 0

Water Quantity +/- minor 0

Note: +=positive -=negative 0=neutral

The Mitigation and Monitoring Plan would be used to ensure that adverse effects from this 

new crop are minimized or avoided. Similarly, minor negative effects would be anticipated 

for biological diversity as pastureland is converted into giant miscanthus croplands. The 

Mitigation and Monitoring Plan would be essential to provide mechanisms such as 

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

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

miscanthus is susceptible to some plant pests; the Mitigation and Monitoring Plan

monitoring and buffer efforts would be essential to ensure that any occurrence is identified 

and treated early to avoid transmission to local croplands, such as corn. 

Giant miscanthus, which has an extensive perennial root system, would be anticipated to 

have positive effects on soil retention, soil organic matter, and soil carbon sequestration. 

Water quality should improve relative to other crops typically grown in the project areas due 

to improved nutrient uptake, low fertilizer requirements, and reduced sediment transport. 

Also, due to its growth patterns, giant miscanthus would be anticipated to require more 

water than corn grown for grain, but less water than grass hay and improved pasture. The 

majority of the acres that enroll in the program are expected to be pastureland and idle 

cropland. The project may also see some conversion of irrigated lands to the non-irrigated 

miscanthus, which will reduce regional water use from those irrigated acres. The plant has 

much higher water use efficiency, generating high amounts of biomass per volume of water 

consumed, indicating it uses rainfall efficiently. 

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

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

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

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

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

conversion to bioenergy. 

DATA GAPS IN CURRENT UNITED STATES ESTABLISHMENT AND PRODUCTION

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

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

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

ornamental plantings and was first described by Beal in 1896 in the Grasses of North 

America. Several universities (i.e., University of Illinois, Mississippi State University, 

University of Wisconsin, Michigan State University, and the University of Georgia) in the 

United States are currently cultivating giant miscanthus on a trial basis or conducting 

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

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

production of giant miscanthus for bioenergy production in co-fired systems have been 

established within the last few years in the United Kingdom. Given, that giant miscanthus 

has only been grown in large-scale trials in Europe, the data on giant miscanthus planting in 

the United States is limited. 

In light of the lack of data applicable to the proposed project areas, an adaptive Mitigation 

and Monitoring Plan has been developed, which includes best management practices 

(BMPs) for the establishment and production of giant miscanthus. These BMPs are 

designed to ensure avoidance and/or minimization of potential effects to the immediate 

environment and the larger landscape. The Mitigation and Monitoring Plan is a living 

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

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

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

document contains information on appropriate and effective eradication methods that would

be updated over time as new data become available. Likewise, other metrics or observable 

measurements will be adapted over time based on past observations, new research 

findings, and new regulations. 

The following information related to the growth and production of giant miscanthus in the 

United States has been found to be lacking complete detail. . 

Potential effects to socioeconomics are focused on the information provided in the 

pro forma analyses of the Project Sponsors. Data from Europe indicates a high cost 
EXECUTIVE SUMMARY

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

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

BCAP combined with the model undertaken by the Project Sponsors and technical 

assistance to be provided to producers addresses most of these concerns. 

Landscape scale analyses of giant miscanthus are generally lacking since there 

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

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

Miscanthus genus has been discussed along with documentation supporting that 

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

rhizome spread within the United States. The growth and management of giant 

miscanthus has been studied extensively by the University of Illinois and 

commercial-scale production has been implemented and monitored in the United 

Kingdom, but commercial-scale production of the plant has not yet been 

implemented in the United States. Although the preponderance of evidence 

indicates that the plant is sterile and slow spreading, documentation of sterility and 

spread is needed for commercial-scale operations in United States’ environments.

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

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

with recommendations have been included.

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

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

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

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

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

found in mature stands.

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

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

soil carbon sequestration based on the available literature.

Literature concerning nutrient uptake, water use efficiency, and irrigation needs (one 

time application in 2011 due to late planting) during establishment has been 

discussed based on the available literature. 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production i

TABLE OF CONTENTS 

MITIGATED FINDING OF NO SIGNIFICANT IMPACT .................................................................................I

PROPOSED ACTION.......................................................................................................................................I

REASONS FOR MITIGATED FINDING OF NO SIGNIFICANT IMPACT..................................................................II

OVERVIEW OF THE MITIGATION AND MONITORING PLAN..............................................................................III

DETERMINATION......................................................................................................................................... VI

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

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

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

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

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

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

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

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

1.1 INTRODUCTION AND BACKGROUND ............................................................................................ 1-1

1.2 USDA NEPA GUIDANCE/AUTHORITY............................................................................................. 1-2

1.3 PURPOSE AND NEED FOR THE PROPOSED ACTION....................................................................... 1-3

1.4 ORGANIZATION OF THE DOCUMENT............................................................................................. 1-3

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

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

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

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

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

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

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

2.2.2.1 Methods for Establishment and Production of Giant Miscanthus...................................... 2-9

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

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

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

2.2.2.5 Paragould Proposed Project Area .................................................................................. 2-13

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

2.4 COMPARISONS OF THE ALTERNATIVES ...................................................................................... 2-20
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production ii

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

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

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

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

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

3.1.2.2 Primary Field Crops..........................................................................................................3-3

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

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

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

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

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

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

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

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

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

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

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

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

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

3.3.3 Protected Species............................................................................................................. 3-24

3.3.3.1 Definition of the Resource............................................................................................. 3-24

3.3.3.2 Existing Conditions....................................................................................................... 3-24

3.4 SOIL RESOURCES ..................................................................................................................... 3-31

3.4.1 Definition of the Resource................................................................................................. 3-31

3.4.2 Existing Conditions........................................................................................................... 3-31

3.4.2.1 Ashtabula Proposed Project Area .................................................................................. 3-31

3.4.2.2 Aurora Proposed Project Area ....................................................................................... 3-33

3.4.2.3 Columbia Proposed Project Area................................................................................... 3-33

3.4.2.4 Paragould Proposed Project Area.................................................................................. 3-33

3.5 WATER QUALITY AND QUANTITY ................................................................................................. 3-34

3.5.1 Water Quality.................................................................................................................... 3-34

3.5.1.1 Definition of the Resource............................................................................................. 3-34

3.5.1.2 Existing Conditions....................................................................................................... 3-36

3.5.2 Water Quantity.................................................................................................................. 3-36

3.5.2.1 Definition of the Resource............................................................................................. 3-36
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production iii

3.5.2.2 Existing Conditions....................................................................................................... 3-37

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

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

4.2 SOCIOECONOMICS ..................................................................................................................... 4-3

4.2.1 Significance Threshold........................................................................................................ 4-3

4.2.2 Proposed Action.................................................................................................................. 4-3

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

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

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

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

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

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

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

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

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

4.4 BIOLOGICAL RESOURCES............................................................................................................ 4-9

4.4.1 Vegetation .......................................................................................................................... 4-9

4.4.1.1 Significance Threshold.................................................................................................... 4-9

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

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

4.4.2 Wildlife............................................................................................................................. 4-14

4.4.2.1 Significance Threshold.................................................................................................. 4-14

4.4.2.2 Proposed Action ........................................................................................................... 4-14

4.4.2.3 No Action Alternative .................................................................................................... 4-16

4.4.3 Protected Species............................................................................................................. 4-17

4.4.3.1 Significance Threshold.................................................................................................. 4-17

4.4.3.2 Proposed Action ........................................................................................................... 4-17

4.4.3.3 No Action Alternative .................................................................................................... 4-17

4.5 SOIL RESOURCES ..................................................................................................................... 4-17

4.5.1 Significance Threshold...................................................................................................... 4-17

4.5.2 Proposed Action................................................................................................................ 4-17

4.5.3 No Action Alternative......................................................................................................... 4-19

4.6 WATER QUALITY AND QUANTITY.................................................................................................. 4-20

4.6.1 Water Quality.................................................................................................................... 4-20

4.6.1.1 Significance Threshold.................................................................................................. 4-20
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production iv

4.6.1.2 Proposed Action ........................................................................................................... 4-20

4.6.1.3 No Action Alternative .................................................................................................... 4-21

4.6.2 Water Quantity.................................................................................................................. 4-22

4.6.2.1 Significance Threshold.................................................................................................. 4-22

4.6.2.2 Proposed Action ........................................................................................................... 4-22

4.6.2.3 No Action Alternative .................................................................................................... 4-26

4.7 ALTERNATIVES COMPARISON.................................................................................................... 4-26

4.7.1 Proposed Action ............................................................................................................... 4-26

4.7.2 No Action.......................................................................................................................... 4-27

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

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

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

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

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

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

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

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

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

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

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

6.3 MITIGATION AND MONITORING RECOMMENDATIONS ...................................................................6-4

6.3.1 Purpose and Overview..........................................................................................................6-5

6.3.2 Meetings with Contract Producers........................................................................................6-6

6.3.3 Socioeconomics..................................................................................................................6-6

6.3.4 Land Use .............................................................................................................................6-7

6.3.5 Biological Resources ...........................................................................................................6-8

6.3.5.1 Vegetation.......................................................................................................................6-8

6.3.5.2 Wildlife......................................................................................................................... 6-13

6.3.5.3 Protected Species ........................................................................................................ 6-14

6.3.6 Soil Resources.................................................................................................................. 6-15

6.3.7 Water Quality and Quantity................................................................................................ 6-16

6.3.7.1 Water Quality................................................................................................................ 6-16

6.3.7.2 Water Quantity.............................................................................................................. 6-17
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7 REFERENCES ...................................................................................................................................7-1

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

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

9.1 TRIBAL CONSULTATION ............................................................................................................... 9-1

9.2 AGENCIES AND PERSONS CONTACTED........................................................................................ 9-3
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production vii

LIST OF TABLES

Table ES-1. Proposed Giant Miscanthus Acres Added by Growing Season 2011-2014....ES- 3 -

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

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

Table 2-2. Proposed Giant Miscanthus Acres Added by Growing Season 2011-2014........2-12

Table 2-3. Estimated Biomass Tonnage by Production Year 2013-2017 .............................2-12

Table 2-4. Comparison of the Alternatives .................................................................................2-20

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

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

Project Counties (2010). .............................................................................................. 3-4

Table 3-3. Primary Livestock Activities by County within the Proposed Project Areas......... 3-7

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

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

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

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

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

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

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

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

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

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

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

Potentially occur within the Proposed Project Areas.............................................3-25

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

Proposed Project Area................................................................................................3-38

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

Establishment and Production of Giant Miscanthus ............................................... 4-4

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

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

Table 4-3. Characteristics of Ideal Biomass Crop/Weeds........................................................4-12

Table 4-4. Summary of Reported Water Use Values (mm) for Miscanthus and Other 

Crops..............................................................................................................................4-23

Table 4-5. Summary of Reported ET Values (mm/day) for Miscanthus and Other Crops .4-24

Table 4-6. Comparison of the Alternatives .................................................................................4-26

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

Table 6-1. Roles and Responsibilities for the Mitigation and Monitoring Plan....................... 6-3
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production viii

LIST OF FIGURES

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

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

Figure 2-3. Percent Minority by County for Each Proposed Project Area................................2-15

Figure 2-4. Percent of the Population Below the Poverty Threshold by County for Each 

Proposed Project Area................................................................................................2-16

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

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

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

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

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

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

Insects and Mammals within and adjacent to the Proposed Project Areas......3-26

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

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

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

within and adjacent to the Proposed Project Areas. .............................................3-28

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

Proposed Project Areas..............................................................................................3-32

Figure 3-9. Waters Listed on the State 303(d) Lists for Impaired Waters..............................3-35

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

Areas .............................................................................................................................4-11
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production ix

ACRONYMS AND ABBREVIATIONS

AOSCA Association of Seed Certifying Agencies

APHIS USDA Animal and Plant Health Inspection Service

ARS USDA Agricultural Research Service

AQCR Air Quality Control Region

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

CDM Clean Development Mechanism

CFR Code of Federal Regulations

cm centimeter

CO carbon monoxide

CPS Conservation Practice Standard

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

ET evapotranspiration

FAO Food and Agricultural Organization

FONSI finding of no significant impact

FR Federal Register

FS USDA Forest Service

FSA USDA Farm Service Agency

g gram
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production x

GHG greenhouse gases

HEL highly erodible lands

HILD high-input low diversity

HUC hydrologic unit

IPCC Intergovernmental Panel on Climate Change

IPM integrated pest management

ISO International Standards Organization

kg kilograms

kPA kilo Pascal

LIHD low-input high diversity

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

MSU Michigan State University

NAAQS National Ambient Air Quality Standards

NEPA National Environmental Policy Act

NISC National Invasive Species Council

NO2 nitrogen dioxide

NRCS USDA Natural Resources Conservation Service

NZERMA New Zealand Environmental Risk Management Authority

OEPA Ohio Environmental Protection Agency

ODNR Ohio Department of Natural Resources

OSIA Ohio Seed Improvement Association 

Pb lead

PEIS Programmatic Environmental Impact Statement

PDD Project Design Documentation

PL Public Law

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
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production xi

ROD Record of Decision

ROI Region of Influence

SHPO State Historical Preservation Offices

SIP State Implementation Plan

SO2 sulfur dioxide

SWAT Soil Water Assessment Tool

tpy tons per year

TSP Technical Service Providers

UNFCCC United Nations Framework Convention on Climate Change

USACE U.S. Army Corp of Engineers

USC U.S. Code

USCB U.S. Census Bureau

USDA U.S. Department of Agriculture

USFWS U.S. Fish and Wildlife Service

USGS U.S. Geological Survey

WRA Weed Risk Assessment

WRI World Resources Institute

WRP Wetland Reserve Program
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PURPOSE AND NEED FOR THE PROPOSED ACTION

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 1-1

1 PURPOSE AND NEED FOR THE PROPOSED ACTION 

1.1 INTRODUCTION AND BACKGROUND

The U.S. Department of Agriculture (USDA) Commodity Credit Corporation (CCC) 

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

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

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

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

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

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

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

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

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

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

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

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

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

66202-66243). 

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

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

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

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

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

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

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

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

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

significance. 

This EA analyzes the proposed establishment of BCAP project areas supporting the 

proposed establishment and production of giant miscanthus hybrid (Miscanthus X 

giganteus) by Aloterra Energy LLC and MFA Oil Biomass LLC (Project Sponsors) in 

Arkansas, Missouri, Ohio, and Pennsylvania, which is being completed to meet the 
PURPOSE AND NEED FOR THE PROPOSED ACTION

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

requirements of the NEPA environmental evaluation of the BCAP or to determine if an EIS 

would be required.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

1.2 USDA NEPA GUIDANCE/AUTHORITY

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

implementing regulations adopted by the Council on Environmental Quality (CEQ) (40 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 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 PEIS, which was a broad 

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

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 1-3

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). 

1.3 PURPOSE AND NEED FOR THE PROPOSED ACTION

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

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

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

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

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

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

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

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

1.4 ORGANIZATION OF THE DOCUMENT

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

on the potentially affected environmental and socioeconomic resources.

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

discusses its purpose and need.

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

the alternatives.

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

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

the potentially affected resources.

Section 4 describes potential environmental consequences on these resources.

Section 5 includes analysis of cumulative impacts and irreversible and irretrievable 

resource commitments.

Section 6 discusses mitigation measures.

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

Section 8 lists the preparers of this document. 

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

contacted during the preparation of this document.
PURPOSE AND NEED FOR THE PROPOSED ACTION

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 1-4

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ALTERNATIVE INCLUDING THE PROPOSED ACTION

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

2 ALTERNATIVES INCLUDING THE PROPOSED ACTION 

2.1 ALTERNATIVES DEVELOPMENT

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

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

have determined the economic feasibility of their proposal, including developing alternatives 

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

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

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

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

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

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

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

alternatives.

2.1.1 Proposed Crop Alternatives – Alternatives Analyzed and Eliminated

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

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

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

criterion was closely tied to economic feasibility because obtaining a sufficient 

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

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

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

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

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

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

Sponsors were also concurrently reviewing data from the OSIA study that 

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

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

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

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

conducted between 2007 and 2010 indicated that giant miscanthus was the 

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

approximately 1.5 to two times more annual tonnage of biomass than switchgrass;
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 2-2

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

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

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

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

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

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

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

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

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

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

additional verification. 

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

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

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

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

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

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

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

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

moisture content when harvested) sources. 

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

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

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

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

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

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

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

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

not pursued. 
ALTERNATIVE INCLUDING THE PROPOSED ACTION

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

2.1.2 Proposed Project Area Locations – Alternatives Analyzed and Eliminated

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

These selection criteria included:

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

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

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

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

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

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

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

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

Project Sponsors considered Midwestern locations because this region provided 

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

biofuels feedstock in the United States; 

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

More specific locations within the Midwest were selected through the second 

selection criterion, adequate rainfall to primarily support planting of propagation 

acres and longer term growth of planted giant miscanthus after propagation. As 

indicated above, a minimum of 30 inches per year of rainfall is considered the 

minimum along with adequate snow cover to support this species. Adequate 

normal rainfall is important to avoid the need for supplementary irrigation. Within 

the Midwest, the Project Sponsors selected the proposed project areas because 

they all receive the minimum amount of rainfall, which avoids the need to irrigate 

the plantings;

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

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

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

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

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

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

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

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

established Aloterra Energy farm in Conneaut, Ashtabula County, Ohio which was 
ALTERNATIVE INCLUDING THE PROPOSED ACTION

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

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

The other proposed project areas were selected for their proximity to current 

highway and rail transportation to support existing agricultural transport 

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

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

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

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

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

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

producers. As a result, the Project Sponsors selected individual proposed project 

areas in those states where there was a large amount of marginal land not

currently under production in any of the dominant agricultural products to avoid 

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

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

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

Sponsors recognized the importance of targeting marginal croplands and current 

pastureland where returns for participating producers would be higher than the 

existing land use, which could encourage greater participation. Additionally, based 

on existing research and internal economic analyses the Project Sponsors 

determined that giant miscanthus could economically produce on smaller 

acreages, potentially benefitting a larger group of producers. 

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

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

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

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

crops and to mitigate the unsustainable depletion of groundwater from current 

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

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

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

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

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

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

triggered by Renewable Energy Standard (RES) mandates. However, the 
ALTERNATIVE INCLUDING THE PROPOSED ACTION

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

transporting of pellets to both the Canadian and European markets is a viable 

economic option should biomass supplies exceed regional needs. In central 

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

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

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

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

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

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

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

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

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

increased potential for environmental impacts associated with increased transportation and 

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

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

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

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

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

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

selected. 

2.2 ALTERNATIVES TO BE ANALYZED

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

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

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

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

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

2.2.1 No Action Alternative

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

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

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

Producers would have the ability, if market conditions exist, to convert acreage into 

traditional crops, leave as is, or provide their acreage for non-agricultural development. This 

alternative would not meet the goals and objectives of the BCAP, as these Project Sponsors 
ALTERNATIVE INCLUDING THE PROPOSED ACTION

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

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

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

as described in Section 1.3. 

2.2.2 Proposed Action

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

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

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

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

marginal croplands and current pastureland. As per the BCAP statute and regulatory 

guidance, native sod would be excluded from any project area. The Project Sponsor 

defines marginal and idle lands as the following:

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

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

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

Idle – Land not currently being cropped. 

All Federal and State-owned land are considered to be ineligible for participation in the 

BCAP program. Other lands considered ineligible to be enrolled under a BCAP contract 

include native sod; and land that is already enrolled in CCC’s CRP, Wetlands Reserve 

Program, or Grassland Reserve Program. Native sod within the proposed BCAP rules is 

land on which the plant cover is composed principally of native grasses, grass like plants, 

forbs, or shrubs suitable for grazing and browsing; and that has never been tilled for the 

production of an annual crops as of the date of the publication of the Final Rule in the 

Federal Register. 

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

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

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

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

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

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

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

the proposed project areas have some approximate locations of acreage to be included 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 2-7

Figure 2-1. Proposed Project Area Locations.
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 2-8

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

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

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

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

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

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

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

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

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

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

developed from the proposed BCF located city. 

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

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

produce giant miscanthus effectively without substantial environmental effects. This would 

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

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

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

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

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

includes the completion of the Natural Resources Conservation Service (NRCS) Form CPA052 with the assistance of either NRCS field personnel or a certified technical service 

provider (TSP).

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

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

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

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

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

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

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

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

being utilized in the marketplace for a similar, if not the same, purpose.
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 2-9

2.2.2.1 Methods for Establishment and Production of Giant Miscanthus

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

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

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

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

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

growing season. This centralized propagation area for the entire proposed project area 

would only occur this planting season; all other planting seasons would follow the on-farm 

model with the initial establishment of propagation acres, followed by plantation acres the 

following growing season, both without subsequent irrigation beyond 2011. No irrigation will 

be required following the 2011 season.

Giant miscanthus is a triploid hybrid perennial warmseason grass developed through the crossing of 

Miscanthus sinensis (diploid species) with M. 

sacchariflorus (tetraploid species), both of which are

native to Southeast Asia. One species, Miscanthus 

sinensis was introduced to the United States, as an 

ornamental; other species are not frequently being 

used, including varieties of giant miscanthus, which is 

currently being developed as a biofuel feedstock. 

Yields in North American research trials have reached 

17 dry tons per acre per year with minimal inputs. The 

species is a sterile hybrid which does not produce 

viable seed and is therefore propagated vegetatively 

by rhizome division (Jørgensen 2011, Gordon et al 

2011). Planting equipment for Bermudagrass 

(Cynodon spp) or specialty vegetable crops has been used to successfully establish giant 

miscanthus in Midwestern United States. Harvesting is done in a manner similar to 

traditional hay crops, but the equipment must be able to handle high-yield crops. Table 2-1

summarizes best practices for the establishment and management of giant miscanthus.

Figure 2-2. Giant Miscanthus.
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 2-10

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.

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

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

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

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

in very poor soil, lacking sufficient soil nutrients for crop growth or readily leaches nutrients 

(e.g., high sand content). In research trials, giant miscanthus has shown tolerance to 

common maize (corn) herbicides, Harness (Acetochlor) and Harness XTRA (Acetochlor + 

Atrazine) are currently the only herbicides labeled for use in giant miscanthus. A complete 

kill of any existing vegetation must be completed before the establishment of the crop. 

Stems of giant miscanthus can be 1⁄2-inch in diameter, 12 feet tall and as dense as 10 stems 

per square foot. 

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

not occur until after first frost when nutrients have been translocated from the stem to 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 2-11

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

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

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

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

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

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

Glyphosate and traditional tillage have been found to be effective eradication methods for 

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

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

(2010) recommend an application of glyphosate after emergence followed by tillage. 

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

living rhizomes after herbicide treatment. 

2.2.2.2 Ashtabula Proposed Project Area

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

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

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

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

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

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

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

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

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

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

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

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

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

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

contracts with a large biomass aggregator and a local residential pellet distributor.
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 2-12

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

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

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

Source: Confidential Application for Proposed BCAP Project Areas, 2011

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

Source: Confidential Application for Proposed BCAP Project Areas, 2011

2.2.2.3 Aurora Proposed Project Area

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

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

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

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

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

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

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

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

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

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

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

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

of biomass.

2.2.2.4 Columbia Proposed Project Area

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

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

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

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

Sponsors’ conversion facility to process 600,000 tons of biomass each year. The Project 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 2-13

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

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

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

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

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

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

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

of biomass.

2.2.2.5 Paragould Proposed Project Area

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

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

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

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

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

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

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

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

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

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

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

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

2.3 RESOURCES CONSIDERED BUT ELIMINATED FROM DETAILED ANALYSIS

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

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

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

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

excluded from this analysis include:

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

wetland is prohibited under BCAP;

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

potential for effect from traditional agricultural production practices in floodplains. 

The Project Sponsors would also exclude or buffer certain areas, depending upon 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 2-14

the site-specific conditions associated with each individual producer contract. Giant 

miscanthus, once established, provides a tight below ground root mass with a low 

likelihood of floodwater movements. Additionally, practices, included as part of the 

Mitigation and Monitoring Plan, and the individual Conservation Plan would minimize 

the potential for vegetative transport of giant miscanthus through flooding; 

Regulated Coastal Zones – were eliminated from detailed analysis in this EA; the 

Project Sponsors have agreed not to plant within regulated coasted zones.

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

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

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

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

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

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

populations. Figures 2-3 and 2-4 provide visual reference to the minority and lowincome populations at the county level within each proposed project area. Two 

counties in Arkansas (e.g., Mississippi and Poinsett) would be considered to be a 

concentrated poverty area based on the 2000 census information;

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

a site specific issue and will be addressed during the completion of the 

environmental evaluation as part of the conservation or forest stewardship planning 

requirement for each individual producer BCAP contract;

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

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

activities currently taking place within the proposed project areas.

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

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

implementation of the Proposed Action or No Action Alternative include:
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 2-15

Figure 2-3. Percent Minority by County for Each Proposed Project Area.
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Figure 2-4. Percent of the Population Below the Poverty Threshold by County for 

Each Proposed Project Area.
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 2-17

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

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

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

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

these counties in agriculture. The additional agricultural use anticipated to be 

produced should not introduce any additional significant emissions. The project is 

not expected to significantly impact the air quality in the proposed project areas. 

A quick analysis of the attainment status based on the National Ambient Air Quality 

Standards (NAAQS) was conducted for each county within the proposed project 

areas. Pennsylvania has designations for the following criteria pollutants: carbon 

monoxide (CO), particulate matter (PM10, PM2.5,) 1-hour ozone, 8-hour ozone, and 

sulfur dioxide (SO2). All counties in the proposed project area are designated as in 

attainment for all criteria pollutants. 

Missouri has designations for the following criteria pollutants: lead (Pb), 8-hour 

ozone, SO2, and PM2.5. All counties in the proposed project areas are designated as 

in attainment for all criteria pollutants. 

Arkansas has designations for the following criteria pollutants: Pb, SO2, nitrogen 

dioxide (NO2), CO, PM10, and PM2.5. All counties in the proposed project area are 

designated as in attainment for all criteria pollutants.

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

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

area were designated as in attainment for 1-hour and 8-hour ozone, PM10, Pb, NO2, 

and CO. Geauga and Trumbull counties are designated as in attainment for PM2.5. 

Lake County is designated as in full non-attainment for PM2.5 and Ashtabula County 

as partial non-attainment for PM2.5. 

Lake County and Ashtabula County are part of the Cleveland-Akron-Lorain Air 

Quality Control Region (AQCR) 174. PM2.5 pollutants are considered fine particles

being less than 2.5 micrometers in diameter. Sources of fine particles include all 

types of combustion, including motor vehicles, power plants, residential wood 

burning, forest fires, agricultural burning, and some industrial processes (U.S. 

Environmental Protection Agency [EPA] 2011). The 2005 Emissions Inventory for 

Ohio (EPA 2006) indicates that Lake County had 3,310 tons per year (tpy) of PM2.5
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 2-18

emissions with electric generating units accounting for greater than 80 percent of the 

pollutant load, non-road emissions (e.g., diesel engines from construction and 

agricultural equipment) accounted for approximately 6.6 percent of pollutant load. In 

Ashtabula County 1,407 tpy were monitored in 2005, with 27.1 percent generated 

from non-road emissions, other stationary sources accounted for 62 percent of the 

pollutant load. 

The Ohio Environmental Protection Agency (OEPA) has requested a Clean Data 

assessment from the EPA to remove the 1997 PM2.5 nonattainment status for 

counties in Ohio (OEPA 2010). The OEPA provided monitoring data from the Lake 

County air quality 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 primary 

NAAQS standard. There are no monitoring stations located in Ashtabula County. 

Overall, it would be anticipated that agricultural equipment necessary for the 

establishment, harvesting, and transportation of giant miscanthus would provide a 

minimum amount of the PM2.5 particulate load within these two counties based on the 

high level of electric generating units in Lake County and the proximity to the 

Cleveland, Ohio metropolitan area. 

A calculation of PM2.5 emissions for traditional agricultural tillage was developed

following the EPA’s Development of Agricultural Dust Emission Inventories for the 

Central State Regional Air Planning Association; it indicated a range of 0.0565 

pounds per acre to 0.1790 pounds per acre (Penfold et al nd., EPA 1998). 

Agricultural tillage would occur for two years on each contract parcel within the 

proposed project area. The first year would be small acreage to accommodate the 

on-site propagation and then the second year would be the rhizome harvest and 

planting on the plantation acres. Based on the acres for the Ashtabula proposed 

project area in Table 2-2, tpy of fine dust particulates generated from agricultural 

tillage within the entire Ashtabula proposed project would range from 0.001 tpy to 

0.027 tpy in 2011, 0.066 tpy to 0.230 tpy in 2012, 0.381 tpy to 1.208 tpy in 2013, and 

0.989 tpy to 3.133 tpy in 2014. Even at the highest amount and assuming that all 

particulates would occur within the Cleveland-Akron-Lorain AQCR, the contribution 

of agricultural tillage from this project would account for approximately 0.2 percent of 

the 2005 emissions in Ashtabula County or 0.09 percent of the 2005 emissions in 

Lake County. The 2008 State Implementation Plan (SIP) for this AQCR indicated 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 2-19

that the 2009 estimated mobile source emissions were 779.15 tpy. When compared, 

the agricultural emissions would contribute 0.4 percent to this total. In the long term, 

PM2.5 emissions should be reduced by the program since lands currently tilled annual 

will no longer be tilled once the rhizomes are planted.

Recreation – was eliminated from detailed analysis in this EA, since the effect to 

outdoor recreation was determined to be minor, on the whole, from the BCAP Final 

PEIS and would be site-specific based on the practices of the individual BCAP 

contract producers. A brief summary of the value of hunting as determined through 

the 2006 National Survey of Fishing, Hunting, and Wildlife Watching (U.S. 

Department of the Interior Fish and Wildlife Service and the U.S. Department of 

Commerce U.S. Census Bureau 2007) in each state is included in the paragraphs 

below.

In Arkansas, approximating 354,000 people 16 years old and older spent 7.9 million 

days hunting. The largest percentage of hunting in Arkansas was for big game (80 

percent), then small game (32 percent), then migratory birds (32 percent). The total 

amount spent on these activities, including trip-related activities, equipment and 

miscellaneous expenditures was over $789 million. The average total expenditures 

in 2006 were $2,108 per hunter with an average trip expenditure of $514. Of the 

types of land, 12 percent of hunters used public land only, 59 percent used private 

land only, and 27 percent used both public and private land. 

In Missouri, approximating 608,000 people 16 years old and older spent 9.7 million

days hunting. The largest percentage of hunting in Missouri was for big game (83 

percent), then small game (39 percent), then migratory birds (14 percent) and other 

animals (6 percent). The total amount spent on these activities, including trip-related 

activities, equipment and miscellaneous expenditures was over $1.1 billion. The 

average total expenditures in 2006 were $1,748 per hunter with an average trip 

expenditure of $483. Of the types of land, nine percent of hunters used public land 

only, 67 percent used private land only, and 22 percent used both public and private 

land. 

In Ohio, approximating 500,000 people 16 years old and older spent 10.6 million 

days hunting. The largest percentage of hunting in Ohio was for big game (86 

percent), then small game (43 percent), and other animals (15 percent). The total 

amount spent on these activities, including trip-related activities, equipment and 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 2-20

miscellaneous expenditures was over $842 million. The average total expenditures 

in 2006 were $1,846 per hunter with an average trip expenditure of $297. Of the 

types of land, 72 percent used private land only, and 19 percent used both public 

and private land. 

In Pennsylvania, approximating 1.0 million people 16 years old and older spent 16.9 

million days hunting. The largest percentage of hunting in Pennsylvania was for big 

game (96 percent), then small game (36 percent), and other animals (15 percent). 

The total amount spent on these activities, including trip-related activities, equipment 

and miscellaneous expenditures was over $1.6 billion. The average total 

expenditures in 2006 were $1,530 per hunter with an average trip expenditure of 

$263. Of the types of land, 21 percent of hunters used public land only, 51 percent 

used private land only, and 26 percent used both public and private land. 

2.4 COMPARISONS OF THE ALTERNATIVES

Table 2-4 provides a tabular summary of the potential effects from both the Proposed Action 

and No Action Alternative. As described previously, the No Action Alternative would not 

meet the purpose and need as described, but is the baseline to which the Proposed Action 

is compared to determine effects to the analyzed environmental resource areas. 

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 0/- minor

Water Quality/Quantity

Water Quality +/- minor 0

Water Quantity +/- minor 0

Note:

+ =positive - =negative 0 =neutral
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-1

3 AFFECTED ENVIRONMENT (BY RESOURCE AREA) 

3.1 SOCIOECONOMICS

3.1.1 Definition of the Resource

Socioeconomic analyses generally include detailed investigations of the prevailing 

population, income, employment, and housing conditions of a community or Region of 

Influence (ROI). The socioeconomic conditions of a ROI could be affected by changes in 

the rate of population growth, changes in the demographic characteristics of a ROI, or 

changes in employment within the ROI caused by the implementation of the proposed 

action.

Socioeconomic resources within this document include general agricultural characteristics 

associated with number of farms, acres of primary field crops, and revenues generated from 

primary field crops. Additionally, a brief analysis of rural population trends is discussed. 

3.1.2 Existing Conditions

3.1.2.1 Number of Farms and Land in Farms

From 1997 to 2007, the number of farms in the United States declined 0.5 percent (USDA 

National Agricultural Statistics Service [NASS] 2009). Most farm categories declined from 

1997 to 2007, with the number of acres in farms declining 3.4 percent, the average size of 

farms declining by 3.0 percent, the amount of cropland declining by 8.7 percent, and the 

amount of harvested cropland acreage declining by 2.9 percent (Ibid). The average market 

value of land and buildings increased approximately 90.2 percent for the average farm and 

approximately 95.7 for the average acre (Ibid). Farm production expenses also showed an 

increase of approximately 52.8 percent over the decade. When compared by type of farm, 

the largest number of farms in the United States falls within the small family farm –

residential or lifestyle farm. For the majority, the largest number of farms in the proposed 

project areas fall within the small family farm – residential or lifestyle farm (Table 3-1).
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-2

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 
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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 

Source: USDA NASS, 2009

3.1.2.2 Primary Field Crops

The 2003 National Resources Inventory indicates that approximately 368 million acres 

within the United States is cultivated cropland and 58 million acres is uncultivated cropland. 

In 1992, those figures were 334 million acres of cultivated cropland and 47 million acres of 

uncultivated cropland. Table 3-2 illustrates the amount of acreage planted of select primary 

field crops in 2010, along with harvested acres of those crops, and total production of the 

crops (USDA NASS 2009). As shown in the table, a majority of the counties had corn 

(grain) and soybean planted, harvested and production in 2010. 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-4

Table 3-2. Planted Acres, Harvested Acres, and 

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
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FINAL - 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
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FINAL - 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 

Corn (Silage) 400,000 7,200,000

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 

Corn (Silage) 8,800 174,000

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 

Corn (Silage) 2,800 47,400

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 NASS 2011

3.1.2.3 Primary Livestock Industries

The primary livestock industries across the proposed project areas are cattle for all states in 

addition to sheep in Ohio and Pennsylvania. Table 3-3 lists the most recent data on 

livestock numbers by type and by county. 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-7

Table 3-3. Primary Livestock Activities by 

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

Source: USDA NASS 2011. 

Only Lake County, Ohio did not contain any reportable or discloseable level of cattle. The

Aurora and Columbia proposed project areas contributed approximately 19.5 percent of all 

cattle in Missouri. Both the Paragould and Ashtabula proposed project areas accounted for 
AFFECTED ENVIRONMENT

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-8

five percent or less for their state totals. The Ashtabula proposed project area accounted for 

approximately three percent of the sheep in Ohio and Pennsylvania. 

3.1.2.4 Rural Population Trends

The USDA Economic Research Service (ERS) found that by 2006 non-metro counties in the 

United States accounted for a population of approximately 50.2 million persons, which is 

approximately 16.8 percent of the total United States population (ERS 2008; U.S. Census 

Bureau [USCB] 2008). The general trend in these counties was a decline in the population 

with over 51 percent of the non-metro counties experiencing population declines of 

approximately 0.5 percent per year from 2000 to 2006. 

3.1.2.5 Farm Income and Cost

The ERS (USDA ERS 2011a) indicated that net farm income in 2011 is projected to be 

above the 2010 forecast by 19.8 percent. Net farm income was estimated to be 

approximately $94.1 billion in 2011 with net cash income of $98.6 billion (Ibid). Total 

expenses in the agricultural sector are anticipated to increase by $20.2 billion, exceeding 

$300 billion for the first time. Crop receipts were estimated to increase to $24.1 billion (Ibid). 

At the household level, the average family farm household income for 2010 was estimated 

to be $83,021, an increase of 7.6 percent from 2009 (USDA ERS 2011b). The ERS 

anticipates that in 2011 approximately 12.9 percent of average family farm household 

income was generated from on-farm sources with an average of approximately $75,178 of 

household income generated from off-farm sources (Ibid).

3.2 LAND USE

3.2.1 Definition of the Resource

Land use analysis primarily details the interactions of humans and their environment, both 

natural and human-induced. Such analyses address how different land uses currently 

interact and if there would be conflict between new and existing land uses. In urban areas, 

land uses are primarily controlled for public health and safety concerns through land use 

zoning mechanisms. In rural areas, land use restrictions may be developed at a county or 

regional scale, or land use restrictions may not exist or be limited to special public health 

and safety concerns. Land use within this document is being described as the acreage 

within cropland and permanent pasture since these lands uses are being proposed for 

conversion into a dedicated energy crop land use. 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-9

3.2.2 Existing Conditions

The 2007 Agricultural Census estimates the amount of land in agricultural land uses in the 

United States. Tables 3-4 through 3-7 illustrate the agricultural lands defined by land use 

categories and sub-categories in the proposed project area counties. From land use 

categories, harvested cropland as a percentage of total land in farms can be derived;

indicating harvested cropland is a dominant land use in the Ashtabula (52.5 percent) and 

Paragould (81.7 percent) proposed project areas. In the Aurora (32.9 percent) and 

Columbia (44.9 percent) proposed project areas, harvested cropland is a prominent land 

use category; however, pastureland, of all types (cropland, pastureland; woodland, 

pastured; and permanent pasture and rangeland) account for 55.4 percent and 29.3 percent 

of the proposed project areas, respectively. 

Figure 3-1 provides an illustration of percentage of total farmland in each of the proposed 

project areas, while Figure 3-2 illustrates the percentage of cropland and pastureland within 

each proposed project area. 

When land use data from the 2002 Agricultural Census and the 2007 Agricultural Census 

are compared by geographic area, some changes in land use become apparent across all 

areas. The number of farms increased in all states, except Ohio, which had a decline of 2.5 

percent. However, acres in farms declined in all states, except Pennsylvania, which had a 

less than one percent increase in land in farms. The average size of farm declined in all 

states, mirroring observations across the United States that the overall decline in farm is 

leveling off and new entrants are younger than the average producer with smaller farms. 

Average farm size within these states ranged from 124 acres in Pennsylvania to 281 acres 

in Arkansas. All states had a decline in cropland and an increase in permanent pasture and 

rangeland. 

At the county level, the Ohio counties within the Ashtabula proposed project area had an 

average decline in the number of farms by 12 percent, which was greater than the state 

level decline of 2.5 percent. Erie County, Pennsylvania had the greatest increase in farm 

numbers (25.4 percent) amongst of the proposed project area counties. All three counties in 

Pennsylvania had a greater than four percent increase in land in farms. 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-10

Table 3-4. Farmland Land Use Categories and 

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

Source: Adapted from USDA NASS 2000
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-11

Table 3-5. Farmland Land Use Categories and 

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 -

Source: Adapted from USDA NASS 2009
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-12

Table 3-6. Farmland Land Use Categories and 

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

Source: Adapted from USDA NASS 2009
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Table 3-7. Farmland Land Use Categories and 

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

Source: Adapted from USDA NASS 2009
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Figure 3-1. Percent of Farmland Acres by County in the Proposed Project Areas.
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Figure 3-2. Comparison of the Percentage of Harvested Cropland and Total 

Pastureland in the Proposed Project Areas.
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Table 3-8 and Figure 3-3 illustrates the farmland Enrolled in Conservation Reserve 

Program (CRP), Wetland Reserve Program (WRP), Farmable Wetlands, or Conservation 

Reserve Enhancement Programs (CREP) in the proposed project areas. There was 

approximately 54,591 acres enrolled into conservation programs within the Paragould 

proposed project area, 168,263 acres within the Columbia proposed project area, 32,209 

acres within the Aurora proposed project area, and 13,796 acres within the Ashtabula 

proposed project area. 

Table 3-8. Farmland Enrolled in CRP, WRP, 

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: Confidential Application for Proposed BCAP Project Areas, 2011
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Figure 3-3. Percent of Total Acres Enrolled in Conservation Programs, 2007.
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3.3 BIOLOGICAL RESOURCES

3.3.1 Vegetation

3.3.1.1 Definition of the Resource

Vegetation refers to the plants, both native and introduced, of a specific region.

3.3.1.2 Existing Conditions

3.3.1.2.1 Ecoregions

For this project, the Level III Ecoregions will be used to illustrate the natural vegetation of 

each proposed project area. Figure 3-4 illustrates the ecoregions within and adjacent to the 

proposed project areas. 

3.3.1.2.1.1 Ashtabula Proposed Project Area

This proposed project area is dominated by the Erie Drift Ecoregion, characterized by low 

rounded hills, scattered end moraines and areas of wetlands. The area was historically 

covered by maple-beech-birch forests but much of the area has been converted to farms. A 

small portion of this proposed project area is also covered by the Eastern Great Lakes and 

Hudson Lowlands Ecoregion. This region is a coastal strip of beach ridges and swales. 

This area has also been converted to farming, with a large percentage of agriculture 

associated with dairy operations (EPA 2011). 

3.3.1.2.1.2 Aurora Proposed Project Area

This proposed project area is located within the Ozark Highlands Ecoregion. Topography 

varies from steep slopes near the large streams to moderate relief hills on the broad 

plateaus or inter-stream areas. The majority of the region is open forest or woodlands, 

dominated by oak or mixed stands of oak and pine. Cleared upland areas are used for 

pasture and livestock (EPA 2011). 

3.3.1.2.1.3 Columbia Proposed Project Area

This proposed project area is covered by three Ecoregions, Central Irregular Plains, Interior 

River Valleys and Hills, and Ozark Highlands. The Central Irregular Plains have a mix of 

land uses. The potential natural vegetation is a grassland/woodland mosaic with wider 

wooded strips along the streams. The grasslands are dominated mostly by tallgrass 

prairies. This area has now been converted to extensive cropland and pastureland. The 
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Figure 3-4. Level III Ecoregions within and adjacent to the Proposed Project Areas.
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Interior River Valleys and Hills Ecoregion is made up of many wide, flat-bottomed, terraced 

valleys, forested valley slopes, and dissected glacial-till plains. This region is generally a 

transitional area between the more forested areas in the Ozarks, and the flatter plains and 

more extensive cropland of regions to the north. The Ozarks Highlands are covered by 

forest or woodlands, dominated by oak or mixed stands of oak and pine (EPA 2011).

3.3.1.2.1.4 Paragould Proposed Project Area

The proposed project area is dominated by the Mississippi Alluvial Plain Ecoregion, and to a 

lesser extent the Mississippi Valley Loess Plain. The Mississippi Alluvial Plain is located 

along the Mississippi River from the confluence of the Ohio and Mississippi rivers southward 

to the Gulf of Mexico. This area is a broad, nearly level, agriculturally-dominated plain that 

provides important habitat for fish and wildlife, and includes the largest continuous system of 

wetlands in North America. The Mississippi Alluvial Plains is also a major bird migration 

corridor used in fall and spring migrations. Historically, the vegetation in this area is

bottomland hardwood forest and woodlands. Today many parts of the Mississippi Alluvial 

Plains have been cleared for cropland.

The Mississippi Valley Loess Plain is a small area in eastern Arkansas is composed of a 

small series of loess-capped hills surrounded by the Mississippi Plain. The area is made up 

of woodland and pastureland dominated by post oak–blackjack oak forest, southern red 

oak–white oak forest and beech–maple forest (EPA 2011).

3.3.1.2.1 Invasive and Noxious Plant Species

Current agricultural and conservation practices include the planting of native and introduced 

species and control or eradication of invasive or noxious species. The Executive Order (EO)

13112, Invasive Species, directs Federal agencies to prevent the introduction of invasive 

species and provide for their control and to minimize the economic, ecological, and human 

health impacts that invasive species cause unless the benefits of the introduction or spread 

of the invasive species clearly outweigh potential harms. In addition, the Plant Protection 

Act (PPA), which became law in June 2000 as part of the Agricultural Risk Protection Act, 

consolidated all or part of 10 existing laws, applicable to USDA activities, into one 

comprehensive law, including the authority to regulate plants, plant products, certain 

biological control organisms, noxious weeds, and plant pests (USDA Animal and Plant 

Health Inspection Service [APHIS] 2002). EO 13112 defines native species as a species 

that, with respect to a particular ecosystem, other than as a result of an introduction, 

historically occurred or currently occurs in that ecosystem. An alien or non-native species is 
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any species, with respect to a particular ecosystem, including its seeds, eggs, spores, or 

other biological material capable of propagating that species, that is not native to that 

ecosystem; an invasive species is a nonnative “species whose introduction does or is likely 

to cause economic or environmental harm or harm to human health” (EO 13112). The PPA 

defines a noxious weed as any plant or plant product that can directly or indirectly bring 

harm to agriculture, the public health, navigation, irrigation, natural resources, or the 

environment; this Act expands the definition of noxious weed from the definition in the 1974 

Federal Noxious Weed Act, which included only weeds that were of foreign origin, new to, or 

not widely prevalent in the United States (APHIS 2002). Noxious weeds are identified and 

listed on State and Federal lists.

Invasive plant species can have significant negative impacts on biological resources 

including decreases in native wildlife and plant species populations, alterations to rare plant 

communities, or changing ecological processes that native plant species and other desirable 

plants and wildlife depend on for survival (including impacts upon native pollinators) 

(National Invasive Species Council [NISC] 2008). Invasive plant species could potentially 

cause or vector decimating plant diseases, prevent native and agricultural species from 

reproducing, suppress the growth of neighboring plants, out-compete desirable species for 

nutrients, light, moisture or other vital resources; and adversely impact erosion rates, 

hydrologic regimes and soil chemistry such as pH and nutrient availability. Natural wildfire 

cycles could also be altered; invasions by fire-promoting grasses could alter entire plant 

communities, eliminating or sharply reducing populations of many native plant species (Ibid). 

Eradication or control of invasive and noxious species can be an arduous task often 

including multiple methods of treatment to be effective. The application of herbicide, 

grazing, burning, mechanical or manual control (cutting, excavating), and mowing are all 

methods that can be used to control and eradicate invasive species. While it may not be 

possible to fully eradicate an invasive plant species, management activities can control 

further spread or takeover. Some species of invasive plants require timed treatment for 

eradication or control such as when the plant is dormant, young, or prior to 

flowering/seeding. Additionally, vegetation may become accustomed to certain methods of 

control and other methods may be required to aid in management (NRCS Conservation 

Practice Standard [CPS] 595, Pest Management).

Giant miscanthus is not listed on any of the proposed project areas State (Arkansas, 

Missouri, Ohio, or Pennsylvania) list of noxious weeds as of March 2011 located through the 
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USDA PLANTS database, this may be partially due to the fact that this species has not had 

widespread distribution in a localized or regional level; however, this is the most recent 

listing for these states. This species is also not listed on the Federal Noxious Weed List as 

of the 2006 list. 

Two species of Miscanthus (M. floridulus and M. sinensis), one of which is a parent species 

of the hybrid being proposed by the Project Sponsors, are listed on the U.S. Weeds species 

list per the USDA PLANTS database. Additionally, the other parent species (M. 

sacchariflorus) is listed as a noxious weed in Massachusetts. The Early Detection and 

Distribution Mapping System (EDDMapS) developed by the University of Georgia Center for 

Invasive Species and Ecosystem Health has compiled distribution records for invasive and 

exotic species down to the county level for the United States. These distribution records do 

not indicate an infestation, rather just a record of occurrence on an exotic species known to 

have infestations in the United States. The distribution maps indicate records for 

Miscanthus sinensis in 12 counties in Pennsylvania (none within the proposed project 

areas), 23 counties in Ohio (including Lake, Ashtabula, and Geauga), and six counties in 

Missouri (including Boone). There were no distribution records for Miscanthus 

sacchariflorus in any of the states within the proposed project areas. 

3.3.2 Wildlife

3.3.2.1 Definition of the Resource

Wildlife refers to the animal species (mammals, birds, amphibians, reptiles, invertebrates, 

and fish/shellfish), both native and introduced, which characterize a region.

3.3.2.2 Existing Conditions

3.3.2.2.1 Ashtabula Proposed Project Area

Major wildlife species in this area include muskrat (Ondatra zibethicus), beaver (Castor 

canadensis), least shrew (Cryptotis parva), least weasel (Mustela nivalis), mink (Mustela 

vison), southern bog lemming (Synaptomys cooperi), Virginia opossum (Didelphis 

virginiana), white tailed deer (Odocoileus virginianus), striped skunk (Mephitis mephitis), 

American bittern (Botaurus lentiginosus), alder flycatcher (Empidonax alnorum), American 

black duck (Anas rubripes), Canada goose (Branta canadensis), great egret (Ardea alba), 

least bittern (Ixobrychus exilis), and least sandpiper (Calidris minutilla). Fish of importance, 

including common game fish, across the area include smallmouth bass (Micropterus 
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dolomieu), common carp (Cyprinus carpio), white sucker (Catostomus commersonii), and 

stonecat madtom (Noturus flavus) (Ohio Department of Natural Resources [ODNR] 2011a).

3.3.2.2.2 Aurora Proposed Project Area

Major wildlife species in the area include white-tailed deer, eastern cottontail (Sylvilagus 

floridanus), raccoon (Procyon lotor), wood duck (Aix sponsa), wild turkey (Meleagris 

gallopavo), smallmouth bass, and largemouth bass (Micropterus salmoides salmoides). 

Several prairie species, such as black-tailed jackrabbits (Lepus californicus) and prairie 

chickens (Tympanuchus cupido), inhabit small areas of the original tall grass prairie 

Confidential Application for Proposed BCAP Project Areas, 2011).

3.3.2.2.3 Columbia Proposed Project Area

Major wildlife species in this Area include white-tailed deer, coyote (Canis latrans), gray fox 

(Urocyon cinereoargenteus), red fox (Vulpes vulpes), beaver, raccoon, skunk, muskrat, 

opossum, mink, rabbit, fox squirrel (Sciurus niger), gray squirrel (Sciurus carolinensis), 

Canada goose, bald eagle (Haliaeetus leucocephalus), turkey vulture (Cathartes aura), 

turkey, woodcock (Scolopax minor), great horned owl (Bubo virginianus), wood duck, 

pileated woodpecker (Dryocopus pileatus), red-bellied woodpecker (Melanerpes carolinus), 

ring-necked pheasant (Phasianus colchicus), and bobwhite quail (Colinus virginianus). Fish 

of importance, including common game fish, across the area include carp (Cyprinus carpio), 

catfish, largemouth bass, smallmouth bass, bluegill (Lepomis macrochirus), crappie 

(Pomoxis sp.), and sunfish (Confidential Application for Proposed BCAP Project Areas, 

2011).

3.3.2.2.4 Paragould Proposed Project Area

Across this are, major wildlife species in this Area include white-tailed deer, coyote, gray fox, 

red fox, raccoon, skunk, muskrat, cottontail rabbit, fox squirrel, bobwhite quail and mourning 

dove. Fish of importance, including common game fish, across the Area include carp, 

bullhead, largemouth bass, smallmouth bass, bluegill, and crappie (Confidential Application 

for Proposed BCAP Project Areas, 2011).
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3.3.3 Protected Species

3.3.3.1 Definition of the Resource

Protected species are those Federally designated as threatened or endangered under the 

ESA or species that are considered candidates for being listed as threatened or 

endangered. Critical habitat is defined as: (1) specific areas within the geographical area 

occupied by the species at the time of listing, if they contain physical or biological features 

essential to conservation, and those features may require special management 

considerations or protection; and (2) specific areas outside the geographical area occupied 

by the species if the agency determines that the area itself is essential for conservation 

(USFWS 2008a).

3.3.3.2 Existing Conditions

Table 3-9 lists the Federally-listed threatened and/or endangered species that could be 

present in the proposed project area counties. Figures 3-5 through 3-7 illustrate the 

potential ranges of Federally-listed species within the proposed project areas. A table of the 

State-listed species that could potentially occur within the proposed project areas is included 

in Appendix A. 

3.3.3.2.1 Ashtabula Proposed Project Area

A review of Federally-listed protected (threatened and/or endangered) species based on the 

U.S. Fish and Wildlife Service (USFWS) data indicate that four Federally-listed endangered 

species have the potential to occur in Ohio counties within the proposed project area. The 

Clubshell mussel (Pleurobema clava) has the potential to occur in Ashtabula and Trumbull 

Counties; the Kirtland’s warbler (Dendroica kirtlandii) and Piping plover (Charadrius 

melodus) have the potential to occur in Ashtabula and Lake Counties; and the Indiana bat 

(Myotis sodalis) has the potential to occur in Ashtabula, Geauga, Lake, and Trumbull 

counties. 

The Clubshell mussel is known from Pymatunig Creek in Ashtabula County, Ohio, but no 

other counties within the proposed project area in Ohio. Kirtland’s warblers are not currently 

known from any of the counties within the proposed project area in Ohio. The Great Lakes 

population of Piping plovers is only known from the Headland Dunes area of coastal Lake 

County, but no other counties within the proposed project area in Ohio. According to the 

Draft Recovery Plan (USFWS 2007) for Indiana bats, there are known summer roosts in 
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Table 3-9. Federally-Listed Threatened and/or Endangered Species that Could 

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

Virginia sneezeweed (Helenium virginicum) T Christian

Running buffalo clover (Trifolium stoloniferum) E Barry, Christian, Dade, Jasper

Mammals

Indiana bat (Myotis sodalis) E Barry, Christian, Stone

Gray bat (Myotis grisescens) E

Barry, Christian, Dade, Jasper, 

Lawrence, Newton, Stone

Columbia

Fishes / 

Clams

Pallid sturgeon (Scaphirhynchus albus) E Boone, Cole, Cooper, Moniteau

Topeka shiner 

(Notropis topeka (=tristis)) E Cooper, Moniteau

Pink mucket (pearly mussel) (Lampsilis abrupta) E Cole

Plants 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

Source: Confidential Application for Proposed BCAP Project Areas, 2011
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Figure 3-5. Potential Ranges of Federally-listed Threatened and/or Endangered 

Birds, Insects and Mammals within and adjacent to the Proposed Project Areas.
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Figure 3-6. Potential Ranges of Federally-listed Threatened and/or Endangered 

Fishes and Clams within and adjacent to the Proposed Project Areas.
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Figure 3-7. Potential Ranges of Federally-listed Threatened and/or Endangered 

Plants within and adjacent to the Proposed Project Areas.
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Ashtabula County in Ohio. Of those Federally-listed species with the potential to occur within 

the proposed project area, only the Federally endangered Piping plover has designated 

Critical Habitat in Ohio in Lake County. However, this Critical Habitat is designated within 

the Headland Dunes Nature Preserve and not in any areas that will be used for agricultural 

purposes. No other Federally-listed endangered species with the potential to occur in the 

Ohio portion of the proposed project areas have designated Critical Habitat in these 

counties (Confidential Application for Proposed BCAP Project Areas, 2011). 

A review of the Pennsylvania Natural Heritage Program Species of Concern List, indicates 

that there 46 State-listed threatened species and 89 State-listed endangered species. Of 

those species, 8 are State-listed endangered birds, 2 are State-listed threatened birds, 7 are 

State-listed threatened fish, 8 are State-listed endangered fish, 36 are State-listed 

threatened plants, 71 are State-listed endangered plants, 1 is a State-listed threatened 

reptile, and 2 are State-listed endangered reptiles within the Pennsylvania counties in the 

Ashtabula proposed project area. The search also indicates that there are 16 species listed 

as rare (plant species which are uncommon within the Commonwealth), 10 species listed as 

extirpated (plant species believed to be extinct within the Commonwealth), and 7 species 

listed as PC (animals that could become endangered or threatened in the future. All of these 

are uncommon, have restricted distribution or are at risk because of certain aspects of their 

biology) within the Pennsylvania counties in the Ashtabula proposed project area. 

A review of Ohio Biodiversity Database State-listed Species indicates that there 60 Statelisted threatened species and 71 State-listed endangered species. Of those species, 2 are 

State-listed threatened birds, 3 are State-listed threatened fish, 2 are State-listed 

endangered fish, 8 are State-listed threatened insects, 8 are State-listed endangered 

insects, 2 are State-listed endangered mammals, 2 are State-listed threatened mussels, 2

are State-listed endangered mussels, 44 are State-listed threatened plants, 56 are Statelisted endangered plants, 1 is a State-listed threatened reptile, and 1 is a State-listed

endangered reptile within the Ohio counties within the Ashtabula proposed project area. 

The search also indicated that 56 species are potentially threatened, 23 are species of 

concern, and six are species of special interest within the Ohio counties within the Ashtabula 

proposed project area.
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3.3.3.2.2 Aurora Proposed Project Area

Three plants on the Federal list of threatened and endangered species are identified within 

grasslands in the proposed project areas. The Missouri bladder pod (Physaria filiformis) has 

been found in glades and pastureland, and the Mead’s milkweed (Asclepias meadii) is found 

in association with tallgrass prairie lands. Geocarpon (Geocarpon minimum) is also 

associated with glades. Many listed plants thrive on periodic disturbance, including mowing 

and burning.

Mammals associated with this proposed project area include three bat species. Both 

Indiana and gray bats forage over bodies of water and use wooded corridors adjacent to 

water as roosting sites. However, the other bat species have been known to overwinter in 

limestone caves (Confidential Application for Proposed BCAP Project Areas, 2011).

A review of the Missouri Heritage Program indicates that there are 4 bird species, 3 mammal 

species, 3 fish species, 1 reptile species, and 5 plant species listed as a State endangered 

species within the counties in the Aurora proposed project area. 

3.3.3.2.3 Columbia Proposed Project Area

Fishes and clams are associated with water and require high water quality. The plant listed 

in association with the Columbia proposed project area is primarily associated with mesic 

areas. Mammals associated with this proposed project area include two bat species, the 

Indiana bat and the gray bat. Both species forage over bodies of water and use wooded 

corridors adjacent to water as roosting sites. Indiana bat may also overwinter in limestone 

caves (Confidential Application for Proposed BCAP Project Areas, 2011).

A review of the Missouri Heritage Program indicates that there are 1 bird species, 3 mammal 

species, 2 mussel species, 5 fish species, and 1 plant species listed as a State endangered 

species within the counties in the Columbia proposed project area. 

3.3.3.2.4 Paragould Proposed Project Area

The listed bird species prefers habitat adjacent to bodies of water that have sandbars or 

sand/gravel pit areas. Listed fishes/clams are associated with water and water quality. The 

Gray bat will forage over bodies of water and use wooded corridors adjacent to water as 

roosting sites (Confidential Application for Proposed BCAP Project Areas, 2011). 

A review of the Arkansas Natural Heritage Commission Rare Species Search indicates there 

are four State-listed endangered plants and five State-listed threatened plants within the 

counties within the Paragould proposed project area. The search also indicates that 129 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-31

species are Inventory Elements (The Arkansas Natural Heritage Commission is currently 

conducting active inventory work on these elements. Available data suggests these 

elements are of conservation concern) within the counties within the Paragould proposed 

project area. 

3.4 SOIL RESOURCES

3.4.1 Definition of the Resource

Soils are a natural body made up of weathered minerals, organic matter, air and water. 

Soils are formed mainly by the weathering of rocks, the decaying of plant matter, and the 

deposition of materials such as chemical and biological fertilizers that are derived from other 

origins. Soils are differentiated based on characteristics such as particle size, texture and 

color, and classified taxonomically into soil orders based on observable properties such as 

organic matter content and degree of soil profile development (Brady and Weil 1996). Soil 

taxonomy was established to classify soils according to the relationship between soils and 

the factors responsible for their character (USDA NRCS 1999). For the purpose of this 

project, the soil resources will be discussed based on the soil classification in the particular 

proposed project area.

Soil erosion is a naturally occurring event and the erosion rates are relatively slow; however, 

human activity can greatly accelerate the rate of erosion. Poor farming practices, loss of 

vegetation through deforestation, overgrazing and the maintenance of agricultural land are 

some of the factors that make soils more susceptible to erosion. For the purpose of this 

document, highly erodible lands (HEL) were used to evaluate the potential for erosion within 

the proposed project areas (Figure 3-8). For more information about HEL, refer to the 

BCAP Final PEIS (Chapter 3.4). 

3.4.2 Existing Conditions

3.4.2.1 Ashtabula Proposed Project Area

In general, soils across this region favor agriculture. The soils in this region are often very 

deep, gently sloping and poorly drained, depending on specific soil type. The soils in this 

area were formed in different textures of glacial till (USDA Ohio NRCS 2007). 

There was approximately 193,410 acres of HEL within the counties of the Ashtabula 

proposed project area (Taylor 2011). Within this proposed project area, Mercer County had 

the highest amount of HEL, covering 11 percent of the county. 
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Figure 3-8. Percent of Total Land Classified as Highly Erodible by County within the 

Proposed Project Areas.
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-33

3.4.2.2 Aurora Proposed Project Area

Soils across this region favor agriculture, including corn, soybean and grains. Soils range 

from well-drained to poorly-drained, depending on specific soil type, land features, and slope 

position. Upland sites are typically better drained than lowlands. At times, clay and silt 

content can create drainage problems (Confidential Application for Proposed BCAP Project 

Areas, 2011). 

There was approximately 1,338,641 acres of HEL within the counties of the Aurora 

proposed project area, with an average of 51 percent of the land being HEL (Confidential 

Application for Proposed BCAP Project Areas, 2011). Within this proposed project area, 

Stone County had the highest amount of HEL, covering 93 percent of the county. 

3.4.2.3 Columbia Proposed Project Area

In general, soils across this region favor agriculture, including corn, soybean and grains. 

Soils range from well-drained to poorly-drained, depending on specific soil type, land 

features, and slope position. At times, clay content can create drainage problems

(Confidential Application for Proposed BCAP Project Areas, 2011). 

There was approximately 1,266,771 acres of HEL within the counties of the Columbia 

proposed project area, with an average of 37 percent of the land being HEL (Confidential 

Application for Proposed BCAP Project Areas, 2011). Within this proposed project area, 

Callaway County had the highest amount of HEL, covering 61 percent of the county. 

3.4.2.4 Paragould Proposed Project Area

Soils range from well-drained to poorly-drained, depending on specific soil type, land 

features, and slope position. Upland sites are typically better drained than lowlands. At 

times, clay and silt content can create drainage problems (Confidential Application for 

Proposed BCAP Project Areas, 2011).

There was approximately 710,118 acres of HEL within the counties of the Paragould 

proposed project area, with an average of 25 percent of the land being HEL (Confidential 

Application for Proposed BCAP Project Areas, 2011). Within this proposed project area, 

Randolph County had the highest amount of HEL, covering 61 percent of the county. 

Mississippi County contains no soil classified as HEL.
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-34

3.5 WATER QUALITY AND QUANTITY

3.5.1 Water Quality

3.5.1.1 Definition of the Resource

Freshwater is necessary for the survival of most terrestrial organisms, and is required by 

humans for drinking and agriculture, among other uses; however, less than one percent of 

Earth’s water is in the form of freshwater that is not bound in ice caps or glaciers. The 

Water Pollution Control Act of 1972, or CWA, Safe Drinking Water Act, and the Water 

Quality Act are the primary Federal laws that protect the nation’s waters. The principal law 

governing pollution of the nation’s surface water resources is the CWA. The Act utilizes 

water quality standards, permitting requirements, and monitoring to protect water quality.

The EPA sets the standards for water pollution abatement for all waters of the United States

under the programs contained in the CWA but, in most cases, delegates the authority to 

issue and enforce permits to qualified States. For this analysis, water resources include 

surface water quality (including lakes, rivers and associated tributaries, and estuaries), 

groundwater quality, and water use/quantity of both surface and groundwater.

Surface water, as defined by the EPA, are waters of the United States, such as rivers, 

streams, creeks, lakes, and reservoirs, supporting everyday life through uses such as 

drinking water and other public uses, irrigation, and industrial uses. Surface runoff from 

rain, snow melt, or irrigation water, can affect surface water quality by depositing sediment, 

minerals, or contaminants into surface water bodies. Surface runoff is influenced by 

meteorological factors such as rainfall intensity and duration, and physical factors such as 

vegetation, soil type, and topography. 

The 303(d) List of Waters reports on streams and lakes identified as impaired for one or 

more pollutants and do not meet one or more water quality standards. The term, "303(d) 

list," is short for the list of impaired waters (stream segments, lakes) that the Clean Water 

Act requires all states to submit for EPA approval every two years. The states identify all 

waters where required pollution controls are not sufficient to attain or maintain applicable 

water quality standards and rank the waters taking into account the uses of the water and 

severity of the pollution problem (EPA 2008). Figure 3-9 illustrates the impaired streams 

and water bodies within each state containing the proposed project areas. 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-35

Figure 3-9. Waters Listed on the State 303(d) Lists for Impaired Waters
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-36

Groundwater is the water that flows underground and is stored in natural geologic 

formations called aquifers. It is ecologically important because it sustains ecosystems by 

releasing a constant supply of water into wetlands and contributes a sizeable amount of flow 

to permanent streams and rivers (USDA FSA 2003).

3.5.1.2 Existing Conditions

3.5.1.2.1 Ashtabula Proposed Project Area

According to the 303(d) list, there are 1,868 impaired stream segments within the Ashtabula 

proposed project area for a total of 3,711.34 miles of impaired streams. There is also a total 

of 56.87 square miles of impaired lakes and reservoirs (EPA 2010). 

3.5.1.2.2 Aurora Proposed Project Area

According to the 303(d) list, there are 328 impaired stream segments within the Aurora 

proposed project area for a total of 557.40 miles of impaired streams (EPA 2010).

3.5.1.2.3 Columbia Proposed Project Area

According to the 303(d) list, there are 314 impaired stream segments within the Columbus 

Project Area for a total of 388.63 miles of impaired streams. There is also a total of 0.30 

square miles of impaired lakes and reservoirs (EPA 2010). 

3.5.1.2.4 Paragould Proposed Project Area

According to the 303(d) list, there are 335 impaired stream segments within the Paragould 

Project Area for a total of 581.71 miles of impaired streams. There is also a total of 5.2 

square miles of impaired lakes and reservoirs (EPA 2010). A majority of the water use relies 

on surface water sources. However, counties closer to the Mississippi River are more likely 

to use groundwater sources. Uses of groundwater include domestic, industry, and irrigation.

3.5.2 Water Quantity

3.5.2.1 Definition of the Resource

Water use/quantity is the specific amount of water used for a given task, such as the 

production of dedicated bioenergy crops. Three types are distinguished: withdrawal, where 

water is taken from a river, or surface or underground reservoir, and after use returned to a 

natural water body; consumptive, which starts with withdrawal but without any return (e.g. 

irrigation) and is no longer available directly for subsequent uses; non-withdrawal, the in situ

use of a water body for, e.g. navigation, fishing, recreation, effluent disposal and power 

generation (Food and Agricultural Organization [FAO] 2005).
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-37

3.5.2.2 Existing Conditions

Table 3-10 summarizes acres of the irrigated cropland by state and county. The table also 

contains a summary of the water withdrawals by source for each county within the proposed 

project area. The EPA defines a watershed as the area of land where all of the water that is 

under it or drains off of it goes into the same place (EPA 2009). Further, the U.S. Geological 

Survey (USGS) defines a watershed as the divide separating one drainage basin from 

another. The USGS has divided and sub-divided the United States using hydrologic units 

(HUC). The hydrologic unit system has four levels of classification (USGS 2011). For this 

project the fourth level of classification, the 8-digit HUC codes, were used to classify the 

watersheds within the proposed project area. 

3.5.2.2.1 Ashtabula Proposed Project Area

Within the counties in Ashtabula proposed project area, three of the four Ohio counties had 

less than 400 acres of irrigated cropland with the exception of Lake County, Ohio, which had 

a total of 2,180 acres of irrigated land (Table 3-10). There was a total of 7.28 million gallons 

of water withdrawn per day in the proposed project area, with an average of 66 percent from 

surface water and 34 percent from groundwater sources (USGS 2010b). 

Eight different watersheds are located within the counties in the Ashtabula proposed project 

area, with the dominate watersheds being Ashtabula-Chagrin and Grand. These eight 

watersheds cover 5,218,511 acres of land in Ohio and Pennsylvania with 26 percent within 

the proposed project area (Seaber 2007). There were approximately 3,600 miles of streams 

and rivers within the Ohio proposed project area and 1,700 miles of streams and rivers 

within the Pennsylvania proposed project area. There were approximately 13,800 acres of 

lakes, ponds and reservoirs within the Ohio proposed project area and 16,200 acres within 

the Pennsylvania proposed project area (USGS 2010a).

3.5.2.2.2 Aurora Proposed Project Area

Within the Aurora proposed project area, there was an average of 2,572 acres of irrigated 

land within the proposed project area. Overall, Missouri had a total of 1.19 million acres of 

irrigated land. There was a total of 10.68 million gallons of water withdrawn per day in the 

proposed project area, with an average of 29 percent from surface water and 71 percent 

from groundwater sources (USGS 2010b).
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-38

Table 3-10. Acres of Irrigated Land and 

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

Source: USDA 2009; USGS 2010b. 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-39

Seven different watersheds impact counties within the Aurora proposed project area;

however, the Sac, Spring, and James watersheds cover most of the area. These three 

watersheds cover 2,567,536 acres of land in Missouri (Confidential Application for Proposed 

BCAP Project Areas, 2011). There were approximately 7,500 miles of streams and rivers 

within this proposed project area. There were approximately 37,600 acres of ponds, lakes 

and reservoirs within this proposed project area (USGS 2010a). Springs are numerous and 

often contribute to the base flow of many area streams.

3.5.2.2.3 Columbia Proposed Project Area

Within the Columbia proposed project area, there was an average of 4,260 acres of irrigated 

land within the proposed project area. Overall, Missouri had a total of 1.19 million acres of 

irrigated land. There was a total of 20.15 million gallons of water withdrawn per day in the 

proposed project area, with an average of 58 percent from surface water and 42 percent 

from groundwater sources (USGS 2010b).

While Columbia proposed project area includes land area in 13 different watersheds, the 

broadest is the Lower Missouri – Moreau (LMM). The Lower Missouri Moreau contacts 

every county in the Project Area, except for Monroe County. It represents land area 

encompassing 2,175,934 acres (Confidential Application for Proposed BCAP Project Areas

2011). There were approximately 11,900 miles of streams and rivers within this proposed 

project area. There were approximately 11,900 acres of ponds, lakes and reservoirs within 

this proposed project area (USGS 2010a).

3.5.2.2.4 Paragould Proposed Project Area

Within the Paragould proposed project area, there was an average of 193,014 acres of 

irrigated land (69 percent of the total acres) which is slightly above the state total of 52.9 

percent of the acres being irrigated. There was an average of 362.56 million gallons of 

water withdrawn per day in the proposed project area, with an average of eight percent from 

surface water and 92 percent from groundwater sources (USGS 2010b).

While Paragould proposed project area includes land area in 11 different watersheds, the 

greatest land area is represented by three of those 11. The Lower St. Francis, Little River 

Ditches, and Cache watersheds encompass a total of 3,471,360 acres and impact all 

counties represented in this proposed project area. The western-most counties, Randolph, 

Jackson, and Lawrence, are impacted by an additional seven watersheds, inclusive. 

However, these watersheds represent a much smaller portion of the proposed project area 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 3-40

(Confidential Application for Proposed BCAP Project Areas 2011). There were 

approximately 14,000 miles of streams and rivers within this proposed project area. There 

were approximately 20,600 acres of ponds, lakes and reservoirs within this proposed project 

area (USGS 2010a).
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 4-1

4 ENVIRONMENTAL CONSEQUENCES 

4.1 DATA GAPS

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

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

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

ornamental plantings and was first described by Beal in 1896 in the Grasses of North 

America. Several universities (i.e., University of Illinois, Mississippi State University, 

University of Wisconsin, Michigan State University, and the University of Georgia) in the 

United States are currently cultivating giant miscanthus on a trial basis or conducting 

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

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

production of giant miscanthus for bioenergy production in co-fired systems have been 

established within the last few years in the United Kingdom. Given, that giant miscanthus 

has only been grown in large-scale trials in Europe, the data on giant miscanthus planting in 

the United States is limited. 

In light of the lack of data applicable to the proposed project areas, an adaptive Mitigation 

and Monitoring Plan has been developed, which includes best management practices 

(BMPs) for the establishment and production of giant miscanthus. These BMPs are 

designed to ensure avoidance and/or minimization of potential effects to the immediate 

environment and the larger landscape. The Mitigation and Monitoring Plan is a living 

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

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

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

document contains information on appropriate and effective eradication methods that would 

be updated over time as new data become available. Likewise, other metrics or observable 

measurements will be adapted over time based on past observations, new research 

findings, and new regulations. 

The following information related to the growth and production of giant miscanthus in the 

United States has been found to be lacking complete detail. . 

Potential effects to socioeconomics are focused on the information provided in the 

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

of establishment due to the vegetative propagation of the species; however, the 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 4-2

BCAP combined with the model undertaken by the Project Sponsors and technical 

assistance to be provided to producers addresses most of these concerns. 

Landscape scale analyses of giant miscanthus are generally lacking since there 

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

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

Miscanthus genus has been discussed along with documentation supporting that 

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

rhizome spread within the United States. The growth and management of giant 

miscanthus has been studied extensively by the University of Illinois and 

commercial-scale production has been implemented and monitored in the United 

Kingdom, but commercial-scale production of the plant has not yet been 

implemented in the United States. Although the preponderance of evidence 

indicates that the plant is sterile and slow spreading, documentation of sterility and 

spread is needed for commercial-scale operations in United States’ environments.

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

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

with recommendations have been included.

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

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

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

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

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

found in mature stands.

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

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

soil carbon sequestration based on the available literature.

Literature concerning nutrient uptake, water use efficiency, and irrigation needs (one 

time application in 2011 due to late planting) during establishment has been 

discussed based on the available literature.
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 4-3

4.2 SOCIOECONOMICS

4.2.1 Significance Threshold

The significance thresholds for socioeconomics include a substantial change in farm 

income, which could lead to wider community effects such as employment loss and 

population declines. 

4.2.2 Proposed Action

Implementing the Proposed Action would not result in significant adverse effects to the 

socioeconomic conditions of any of the proposed project areas. The Proposed Action would 

provide a positive cash-flow stream to producers and an economically viable product 

through the BCF to local, regional, and potentially out of region sales according to the BCAP 

project area application documents. Giant miscanthus would require some level of inputs 

(e.g., herbicides) during the establishment phases, with minimal fertilizer inputs annually 

beginning in year three of the maintenance period to replace nutrients lost through biomass 

production; thereby, maintaining the existing agricultural products stream, with the potential 

for creating new markets for more species-specific agricultural chemicals. Agricultural 

services would be maintained in the short-term, with the potential creation of new services 

streams for heavier-duty equipment manufacture and contract farming for harvesting, baling, 

and transportation of baled products to the BCF. Overall, the maintenance of existing higher 

value cropland acres with the inclusion of smaller dedicated energy crop production should 

maintain or enhance farm household and agricultural services-related household incomes. 

BCAP was developed to provide assistance to participating producer to offset a portion of 

the costs associated with establishing and producing dedicated energy crops. Table 4-1

lists the estimated establishment and production costs for giant miscanthus with a 

comparison of the BCAP payments to participating producers. The value of BCAP to 

participating producers was estimated using a crop budget analysis based on information 

from the Michigan State University (MSU) Extension.” The MSU miscanthus budgets 

provide an analysis of both ‘cheap’ and market rate rhizomes. Under MSU’s analysis with 

“market rhizomes” after 10 years the producer is still cash flow negative over $6,000 on 

each acre planted. If the rhizome costs were reduced to only 25 percent of MSU’s estimate, 

the producer would still need 10 years to break even. Under MSU’s analysis, producers 
ENVIRONMENTAL CONSEQUENCES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 4-4

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

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

Notes: 

All cost estimates derived from MSU miscanthus budget (James et al. 2009)

The average rental rate for CRP as of February 2011 in each state containing proposed project areas 

are: Arkansas = $59.53/acre; Missouri = $74.16/acre; Ohio = $118.87/acre; Pennsylvania = 

$102.85/acre. The average rental rate for these four states = $88.85 (USDA FSA 2011a)

A reduction in the annual BCAP payment was estimated at 25 percent for biomass sold for heat, power, 

or biobased products (USDA FSA 2011b). 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 4-5

would have little incentive to establish energy crops. However, with “cheap rhizomes,” the 

producer is cash flow positive after the third year. BCAP provides enough incentive, per the 

MSU cost and revenue values, that a producer would begin realizing a profit in year nine or 

in year eight, if the matching payment were delayed until a full harvest was collected. 

The Project Sponsors have been very successful in finding producers willing to plant energy 

crops on less productive land when shown BCAP incentives that create positive cash flows 

in comparison to establishment without BCAP. Importantly, producer commitments are 

contingent upon BCAP funding, which indicates that the short term incentives provided by 

BCAP create a viable energy crop market. MSU’s research supports the Project Sponsors’ 

experience with actual producers in proposed project areas that without BCAP incentives in 

an approved project area, producer interest under current market conditions declines 

dramatically.

Under the Proposed Action, the Project Sponsors propose to establish and produce giant 

miscanthus in the proposed project areas with a maximum acreage of 50,000 acres per 

project area by 2014. The Project Sponsors estimate that approximately 20 percent of the 

total acreage in the proposed project areas for Aurora, Columbia, and Paragould would be 

marginal cropland with the remainder being non-cropland, such as pastureland. In the 

Ashtabula proposed project area, 10 percent of the total acreage would be marginal 

cropland. The Project Sponsors have a goal of minimizing the amount of arable cropland to 

be included in the contract acreage, thereby maximizing producer incomes through 

diversification of a small amount of marginal croplands or idle lands, such as pastureland. 

On average, contract acreage would be estimated to be in a range between 38 to 100 acres 

per contract. The BCAP Final PEIS (Table 3.1-5) lists the national average farm size for 

different farm types; overall the majority of farms within the United States are considered 

small family farms with average farm size between 137 acres (Limited Resource) to 1,040 

acres (Farming Occupation/Higher Sales). In each of the states included within the 

proposed project areas, greater than 84 percent of the farms would be considered small 

family farms. The Project Sponsors, through small acreage enrollments, would provide an 

incentive for small farms to enter a BCAP contract, especially with the producer assistance 

to be provided as part of the proposed project area models. 

To determine the economic viability of the Proposed Action, the Project Sponsors developed 

an Economic Impact Analysis (EIA) for each proposed project area. For each proposed 

project area region, the 20 year project time-frame from the giant miscanthus acres 
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produced under BCAP, the anticipated economic impact to the region would total more than 

$750 million (US$2011). The EIA estimated the annual value to the producers in each 

proposed project area to be approximately $33 million for the approximately 600,000 tons 

anticipated to be produced annually at full production (2017). The Project Sponsors’ BCF 

would be estimated to directly create six positions in 2014, 78 positions in 2016, and 114 

positions in 2017. 

4.2.2.1 Ashtabula Proposed Project Area

In Ashtabula, at full scale production in 2017 the local BCF developed by the Project 

Sponsors would create 1,210 new positions (i.e., direct, indirect, and induced across all 

related economic sectors) and bring approximately $49.9 million into the region annually. 

Economic modeling was performed to analysis the contribution of the Proposed Action for 

each proposed project area as part of the Project Sponsors’ confidential project area 

application. 

4.2.2.2 Aurora Proposed Project Area

In Aurora, at full scale production in 2017 the local BCF developed by the Project Sponsors 

would create 960 new positions (i.e., direct, indirect, and induced across all related 

economic sectors) and bring approximately $49.2 million into the region annually. Economic 

modeling was performed to analysis the contribution of the Proposed Action for each 

proposed project area as part of the Project Sponsors’ confidential project area application. 

4.2.2.3 Columbia Proposed Project Area

In Columbia, at full scale production in 2017 the local BCF developed by the Project 

Sponsors would create 980 new positions (i.e., direct, indirect, and induced across all 

related economic sectors) and bring approximately $50.9 million into the region annually. 

Economic modeling was performed to analysis the contribution of the Proposed Action for 

each proposed project area as part of the Project Sponsors’ confidential project area 

application. 

4.2.2.4 Paragould Proposed Project Area

In Paragould, at full scale production in 2017 the local BCF developed by the Project 

Sponsors would create 750 new positions (i.e., direct, indirect, and induced across all 

related economic sectors) and bring approximately $50.0 million into the region annually. 

Economic modeling was performed to analysis the contribution of the Proposed Action for 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 4-7

each proposed project area as part of the Project Sponsors’ confidential project area 

application. 

4.2.3 No Action Alternative

The selection of the No Action Alternative would not result in significant adverse effects to 

the socioeconomic conditions of the proposed project areas. Under this alternative, the 

Project Sponsors would not undertake the establishment and production of giant miscanthus 

in the proposed project areas. The agricultural conditions would remain as described in 

Section 3.1 and would follow projected demand and production aspects. This alternative 

would not create a small acreage diversification into dedicated energy crops, nor would a 

new services market be developed for heavy-duty machinery associated with high-yielding 

biomass crops, such as giant miscanthus. 

4.3 LAND USE

4.3.1 Significance Threshold

For land use the significance thresholds include a substantial change in land use type that 

could trigger the development of agricultural lands into other non-agricultural land use types 

within the region or adjacent to the region. 

4.3.2 Proposed Action

Implementing the Proposed Action would not result in significant changes in land use types 

that could trigger development of agricultural lands into other non-agricultural land use types 

nor would it create a substantial loss of arable cropland within the proposed project areas. 

Under the Proposed Action, the Project Sponsors propose to establish and produce giant 

miscanthus in the proposed project areas with a maximum total acreage of 50,000 acres per 

project area by 2014. The Project Sponsors estimate that approximately 20 percent of the 

total acreage in the proposed project areas for Aurora, Columbia, and Paragould would be 

marginal cropland or cropland with the remainder being non-cropland, such as pastureland

(Confidential Application for Proposed BCAP Project Areas, 2011). In the Ashtabula 

proposed project area, 10 percent of the total acreage would be marginal cropland

(Confidential Application for Proposed BCAP Project Areas, 2011). On average, contract 

acreage would be estimated to be in a range between 38 to 100 acres. However, all 

estimates are preliminary and percentages could change over time depending upon the 

individual parcels that become enrolled. 
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The conversion of pastureland could negatively affect livestock production within the 

proposed project areas, if sufficient grazing acreage was converted. The Ashtabula 

proposed project area accounts for approximately 3.0 percent of all cattle and 1.8 percent of 

sheep and lambs in Ohio and just over five percent of cattle and sheep and lambs in 

Pennsylvania. The Aurora and Columbia proposed project areas account for approximately 

18.7 percent of all cattle in Missouri; while the counties within the Paragould proposed 

project area accounts for 5.1 percent of all cattle in Arkansas. The most productive (i.e., 

highest stocking rate forage availability) pastureland would not be converted into giant 

miscanthus, unless the individual producer determined that the net return would be higher 

from giant miscanthus per acre than from cattle or sheep production. 

Table 4-2 lists the estimated total acres that could be planted by each land use type, 

cropland (harvested cropland and other cropland) or pastureland (pastureland, all types) by 

proposed project area and that estimated percentage by either cropland or pastureland.

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

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

Source: Adapted from USDA NASS 2009, Confidential Application for Proposed BCAP Project Areas, 2011

The Project Sponsors have a priority of using marginal or idle croplands in place of highervalue harvested croplands and pasturelands. The Ashtabula proposed project area would 

include the greatest percentage of giant miscanthus plantings in the combined acreage of 

the pastureland and other cropland land use types (25.2 percent) due to the smaller area in 

other cropland and pastureland land use types, when compared to the other proposed 

project areas. The Paragould proposed project area would be anticipated to have 

approximately 15.9 percent of combined pastureland and other cropland planted in giant 

miscanthus; however, due to issues related to nutrient use and leaching, water use, and soil 

erosion, more acres of productive cropland could be utilized for giant miscanthus production; 

thereby lowering the percentage of marginal lands used. In the Aurora and Columbia 

proposed project areas, the percentage of marginal land (other cropland and pastureland) 

anticipated to be planted into giant miscanthus is slightly over five percent for both areas.
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4.3.3 No Action Alternative

The selection of the No Action Alternative would not result in significant adverse effects to 

the land use within the proposed project areas. Under this alternative, the Project Sponsors 

would not undertake the establishment and production of giant miscanthus in the proposed 

project areas. The agricultural conditions would remain as described in Section 3.1 and 

would follow projected demand and production aspects. This alternative would not create a 

small acreage diversification into dedicated energy crops. 

4.4 BIOLOGICAL RESOURCES

4.4.1 Vegetation

4.4.1.1 Significance Threshold

For vegetation, a significant effect would be a finding of invasiveness for the species, that it 

had a high likelihood of being a vector for a plant pathogen or insect harmful to native 

species, or that it was extremely difficult to eradicate once established. 

4.4.1.2 Proposed Action

Implementing the Proposed Action, in association with the Mitigation and Monitoring Plan, 

(Section 6) would be anticipated to result in minor effects to local and regional vegetation

due to the change in vegetation from the existing cover to giant miscanthus. The Mitigation 

and Monitoring Plan addresses measures to avoid and minimize effects to vegetation. 

Some of these measures include exclusions from planting within sensitive segments of 100-

year floodplains and floodways, to minimize the potential for vegetative spread through 

rhizome or active stalks transported via stormwater flows or wind and active management to 

provide eradication in adjacent areas, if necessary. 

As mentioned previously, the Project Sponsors anticipate that most of the acreage for giant 

miscanthus would be idle lands, which are being considered as pastureland for this analysis. 

Pasturelands throughout the proposed project areas could be in fallow agricultural fields with 

annual vegetation or a mix of annual and perennial vegetation, in permanent improved 

pasture, or rangeland. Twenty percent or less of the giant miscanthus acreage is 

anticipated to be marginal cropland, which could be currently fallow or in traditional row 

crops. Vegetation species diversity is highly site specific and part of the larger local 

landscape. 
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Figure 4-1 provides the approximate locations of the anticipated current producers, which 

are spread throughout the proposed project areas. The Project Sponsors have estimated 

that individual contracts for giant miscanthus production would range between 38 to 100 

acres; the minimum acreage is considered by the Project Sponsors to be the lower end of 

acreage size that would be economically viable for the producer. These small patches of 

fields should assist in the minimization of the loss of landscape level vegetation biodiversity 

and richness along with anticipated buffers to riparian areas and wildlife corridors through 

the Mitigation and Monitoring Plan. 

Jørgensen (2011) indicates a potential fire risk associated with senesced stands of giant 

miscanthus. To reduce potential fire risk, the Mitigation and Monitoring Plan includes a 

minimum buffer width and a more site-specific buffer width to be included in the individual 

contract producer’s Conservation Plan, which would take into account landscape features 

(e.g., habitable structures, farmsteads, communities within close proximity), normal fire 

frequency within the areas, normal conditions during the fall/winter standing dead plant 

material), and adjacent land uses, which could contribute to increased fire risk. Additionally, 

early harvest could be conducted, if unforeseen circumstances increased the risk to human 

health and.

Two components of concern associated with giant miscanthus include its potential for 

invasiveness and as a vector for disease or plant pests. The following sections detail each 

of these areas. 

4.4.1.2.1 Invasiveness

Overall, the existing literature indicates that giant miscanthus is not likely to become 

invasive; however, this has not been tested through scale field–sized trials in the United 

States. The very components that make a species ideal for a biomass feedstock are often 

the same characteristics that are described of weedy invasive species (Table 4-3). Giant 

miscanthus is a naturally occurring hybrid species that is vegetatively propagated and does 

not produce viable seeds. One of its parent species is Miscanthus sinensis, which is 

considered an invasive species in the United States, and the other parent species (M. 

sacchariflorus) is not included on any Federal or State lists of noxious or invasive species. 
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Figure 4-1. Approximate Locations of 

Anticipated Producers within the Proposed Project Areas 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 4-12

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

Source: Raghu et al. 2006 

Raghu et al. (2006) indicated that aspects of the genetics (i.e., the parent species) 

associated with giant miscanthus could indicate the potential for this species to be invasive it 

has the ability to resprout from belowground, rapid growth, and efficient photosynthetic 

pathways. Jørgensen (2011) indicates that rhizome spread of giant miscanthus occurs only 

at about 10 centimeters (cm) per year from observation of intentionally planted areas, which 

is relatively slow. There have been no documented unintentionally spreading of giant 

miscanthus in Europe, where the species has been studied for over 30 years. In the event 

that giant miscanthus rhizomes in intentionally planted areas spread beyond the planted 

fields, Jørgensen (2011) indicates that rhizomes transported accidentally by man, soil 

erosion, or flooding could be easily eradicated using commercially available herbicides (see 

Section 2.2.2.1). In contrast, Jørgensen (2011) indicates that Miscanthus sacchariflorus

(i.e., a parent species of giant miscanthus) has creeping rhizomes that spread several 

meters (m) in a few years with high adaptability to riparian areas, which has a higher 

potential for translocation via erosion and water transport.

Gordon et al (2011) assessed the potential invasiveness of several potential dedicated 

energy crop species using the Australian Weed Risk Assessment (WRA). The WRA is a 

tool that has been used in Australia and New Zealand for over a decade to determine if plant 

species should be considered for use in those countries. The WRA has been shown to be 

90 percent accurate in indentifying invasive species, 70 percent accurate in non-invaders, 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 4-13

with approximately 10 percent of non-invaders incorrectly predicted to be invasive (Gordon 

et al. 2011). Gordon et al (2011) performed the WRA on 12 potential dedicated energy 

crops, not native to Florida, for Florida and the United States. Based on the WRA results 

they found that only four species (giant miscanthus, plume grass, sugarcane, and sweet 

sorghum) should be accepted as potential dedicated energy crops, one species (cabbage 

gum) should be further evaluated, and the remainder rejected (giant reed, Red River gum, 

rose gum, jatropha, leadtree, elephantgrass, and castor bean). Gordon et al. (2011) did 

indicate that since both giant miscanthus and sweet sorghum had parent genetics from 

documented invasive species, production should be carefully monitored for changes in 

fertility or other traits. Barney and DiTomaso (2008) also performed a WRA on giant 

miscanthus and found it to be acceptable for a dedicated energy crop. 

Davis et al. (2010) suggests that using the WRA may not be sufficient as a stand-alone tool 

provided that the chance of an inadvertent approval of an invasive species could be 1:10 or 

1:20. Davis et al. (2010) suggest a nested approach where an initial screen, such as WRA, 

is used to determine if a pre-entry evaluation of a species is warranted. The Davis et al 

(2010) evaluation would analyze data from the species home range for its potential for 

invasiveness; if approved after this step, and then a post-entry evaluation would be 

conducted. The post-entry evaluation would include quarantined field trials to determine if 

release of a species is appropriate. 

4.4.1.2.2 Disease Vector, Host for Plant Pathogens, Host for Plant Pests

Another potential for vegetative effects is the movement of diseases and plant pests from 

one species to another, such as from giant miscanthus to corn. Recently published 

literature in the United States does indicate that giant miscanthus could provide a refuge or 

reservoir for plant pests, especially for corn and sorghum, depending upon location. 

Jørgensen (2011) indicates that the western corn rootworm has been found in giant 

miscanthus, while Stewart and Cromey (2011) indicated that reports of diseases such as 

barley yellow dwarf virus, rust (Puccinia emaculata) and smut (Tilletia maclaganii) in 

miscanthus and switchgrass. Additionally, Spenser and Raghu (2009) found that in 

greenhouse and field studies there was significant emergence of western corn rootworm 

from giant miscanthus placed near corn fields. Bradshaw et al. (2010) found two species of 

aphids (yellow sugarcane aphid and corn leaf aphid) in samples taken from giant 

miscanthus fields in four states with stands ranging from one year to 21-years old. The 

yellow sugarcane aphid was located in seven samples across the four states and the corn 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 4-14

leaf aphid was located in four samples in four states. According to Bradshaw et al. (2010) 

the presence of aphids in giant miscanthus is of concern since aphids can transmit plant 

viruses. The research in this area is somewhat lacking as these are new reports and steps 

should be taken to monitor for any plant diseases or pests within established stands of giant 

miscanthus. The Mitigation and Monitoring Plan includes integrated pest management 

(IPM) programs associated with dedicated energy crops that will provide protection equal or 

greater than IPM programs for crops within the project areas. . 

4.4.1.3 No Action Alternative

Selecting the No Action Alternative would not result in significant effects to the local or 

regional vegetation within the proposed project areas, as the Project Sponsors would not 

establish and produce giant miscanthus in those areas. Current agricultural activities would 

remain similar or along the current projected trends for those regions. 

4.4.2 Wildlife

4.4.2.1 Significance Threshold

For wildlife, a significant effect would be a finding of substantial decline in biodiversity or 

species richness for the local area or the region.

4.4.2.2 Proposed Action

Implementing the Proposed Action, in association with the Mitigation and Monitoring Plan, 

would be anticipated to result in minor negative effects to wildlife diversity. Wildlife diversity 

effects would be contingent upon the type of previous land use the acreage was in prior to 

conversion into giant miscanthus stands. There could be adverse effects to larger wildlife as 

giant miscanthus stands mature when compared to pasturelands; however, data related to 

larger species is lacking; therefore, the implementation of appropriate BMPs, as developed 

in the Mitigation and Monitoring Plan, would be essential to gauge short and longer-term 

effects on local larger wildlife. Field margins and wildlife buffers would provide continued 

access in areas where larger wildlife species are known to occur. Fernando et al (2010) 

indicates that monocultures are not generally as diverse as polycultures, but that biodiversity 

levels depend on the crop and the environmental setting (i.e., the overall landscape diversity 

and the lands being converted). They also indicate that perennial rhizomatous grasses 

require less tillage, lower agrochemicals and high above- and below-ground biomass, which 

are beneficial for soil microfauna and provide cover to invertebrates and birds. Fernando et 

al (2010) indicate that according to their weighted-model, no significant differences related 
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to a suite of environmental impacts was observed for the perennial species supported for 

dedicated energy crops. They suggested that compared to cultivated fields (e.g., potato and 

wheat), all perennial dedicated energy crops had fewer environmental impacts; however, 

they had greater impacts than fallow fields when considered on the whole. 

4.4.2.2.1 Birds

Studies from Europe indicate a neutral to positive effect for young-aged stands of giant 

miscanthus on bird species richness, depending upon the previous vegetation cover. 

Bellamy et al (2009) provide some preliminary information on the abundance and diversity of 

birds in giant miscanthus and winter wheat in the United Kingdom. They found a greater 

abundance and diversity of birds in fields (study field size of three hectare = 7.41 acres) with 

giant miscanthus aged between one to three years than in the control wheat fields. Bellamy 

et al. (2009) hypothesized that the reasons for greater diversity in giant miscanthus could 

have been the contribution to shelter provided by giant miscanthus during the winter and the 

abundance of non-crop plants (e.g., weeds) in these early stage giant miscanthus fields. 

Bellamy et al. (2009) surmised that on-going management for wildlife would be necessary to 

ensure continued biodiversity as the giant miscanthus plants matured and the crop structure 

developed. 

Similarly, Semere and Slater (2007a) found that young giant miscanthus fields in 

Herefordshire, England have a greater variety and abundance of open-ground bird than 

reed canary grass fields; however, the abundance and diversity of birds and small mammals 

was higher at the edges of both type of perennial biomass fields than in the fields 

themselves. Semere and Slater (2007a) indicate that perennial biomass grasses could 

provide improved wildlife habitat due to the lower input of agricultural chemicals relative to 

traditionally managed row crops. Sage et al. (2010) found that the number of birds in 

miscanthus grown in southwestern England was approximately equivalent to the number of 

birds found in grasslands. They found bird use to be variable and dependent on many 

factors such as region, weediness, crop structure, and patchiness. 

Fargione (2010) in a review of literature indicated that researchers found potential for a loss 

of bird biodiversity in high-input low diversity (HILD) bioenergy crops, such as corn and 

soybeans, while in low-input high diversity (LIHD) bioenergy crops, such as native prairie, 

bird species richness increased. They also found that the magnitude of changes was more 

than double for species of concern than for generalist species. Fargione (2010) indicates a 

lack of specific data availability for crops such as giant miscanthus, which has a different 
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structure than native prairie grass species in the United States, indicating a need for more 

research on these species. Jørgensen (2011) indicates that very few species directly feed 

on miscanthus so diversity indicators are due in part to the lack of continual tilling, reduced 

pesticide levels, and provision of cover. At maturity, these stands could have a decline in 

biodiversity if the fields become so successful that weeds are fully suppressed or large field 

are planted which would reduce the quantity of field margin habitat (Ibid.). 

In the United States, plantings of the Illinois clone have been observed for wildlife 

interactions. Several reed nesting bird species, established nests in the two-year old fields; 

while indications of ringneck pheasant utilization during the winter was observed (Caveny 

2011). 

4.4.2.2.2 Insects

In a study of invertebrates, Semere and Slater (2007b) found that more invertebrates utilized 

miscanthus fields than areas dominated by reed canary-grass but less than field margins, in 

large part due to the increased presence of weeds within the establishing fields. They 

surmise that the more mature fields of reed canary-grass observed in these studies could be 

an approximation in terms of the generalized potential for biodiversity effects from mature 

stands of giant miscanthus since data for biodiversity is lacking for the mature age class of 

giant miscanthus (Ibid.). As such, field buffers would provide necessary wildlife habitat and 

edge to ameliorate the loss of biodiversity from maturing stands of giant miscanthus. Landis 

and Werling (2010) provided a review of relevant literature related to arthropods and biofuel 

production, indicating a general lack of data associated with mature giant miscanthus stands 

and arthropod interactions. Gardiner et al. (2010) analyzed arthropods in three different 

types of potential biofuel crops, corn (planted for grain), switchgrass (planted for CRP), and 

mixed prairie (planted for CRP). They found that insects responded more positively to 

greater landscape diversity, provided by switchgrass and mixed prairie; however, if 

switchgrass was planted and managed for biomass feedstock, the overall insect diversity 

could increase with a decline in plant diversity. 

4.4.2.3 No Action Alternative

Selecting the No Action Alternative would not result in significant effects to the local or 

regional wildlife within the proposed project areas, as the Project Sponsors would not 

establish and produce giant miscanthus in those areas. Current wildlife communities would 

remain similar for those regions. 
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4.4.3 Protected Species

4.4.3.1 Significance Threshold

For protected species, both for vegetation and wildlife, a significant effect would be a finding 

of substantial decline in the number or range of species for the local area or the region 

directly attributable to the Proposed Action.

4.4.3.2 Proposed Action

Implementing the Proposed Action would not result in significant effects to any protected 

species, Federally-listed as threatened and/or endangered, primarily due to the lack of those 

species within the proposed project areas. Some species, such as the Indiana bat, may 

occur while commuting or migrating along waterways that serve as corridors between roost 

areas and other habitats, but existing crop and idle lands do not provide suitable habitat 

within the proposed project areas. Other concerns would be for fish, clams, and 

invertebrates located in streams near giant miscanthus plantings. The Mitigation and 

Monitoring Plan specifies buffers between plantings and streams and riparian areas. These 

buffers will ensure that effects to any aquatic and riparian species will be minimized or 

avoided. 

4.4.3.3 No Action Alternative

Selecting the No Action Alternative would not result in significant effects to the local or 

regional protected species within the proposed project areas, as the Project Sponsors would 

not establish and produce giant miscanthus in those areas. Current agricultural activities 

would remain similar or along the current projected trends for those regions. 

4.5 SOIL RESOURCES

4.5.1 Significance Threshold

Impacts to soil resources would be considered significant if implementation of an action 

resulted in permanently increasing erosion, altered soil characteristics that threaten the 

viability of the cover, or affected unique soil conditions.

4.5.2 Proposed Action

Implementing the Proposed Action would result in a positive reduction in the soil erosion

through abundant below ground biomass with soil retaining abilities. Giant miscanthus 

produces abundant above and below ground biomass. The top soil layer (0 to 30 

centimeters [cm]) contains around 28 percent of the root biomass, while nearly half of the 
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total roots were present in the deeper soils layers (below 90 cm) (Neukirchen et al 1999). 

The extensive deep root system can improve soil qualities by improving water storage, 

microbial process, and soil organic carbon storage (Blanco-Canqui 2010). In a 10-year 

study of giant miscanthus in Illinois, Davis et al. (2010) found that giant miscanthus 

produced greater above ground carbon (C) (1,606 to 2,426 grams [g] C/ square meter [m2

]) 

when compared to switchgrass, native prairie, (344 to 705 g C/m2

) and corn (405 to 717 g 

C/m2

). Davis et al. (2010) also indicated that giant miscanthus could produce soil C at a 

faster rate due in part to greater litter fall and below ground plant production (root system). 

Hansen et al. (2004) indicated that between 26 to 29 percent of accumulated C input was 

retained in the soil in soil samples taken from 9-year old and 16-year old giant miscanthus 

plants in Denmark. 

Initial preparation of land for giant miscanthus establishment could result in the soil 

disturbance similar to traditional tillage of commodity crops. The preparation process could 

cause erosion following rainfall events until the giant miscanthus becomes established

(Donnelly et al 2010). Soil tillage for giant miscanthus establishment can redistribute the 

organic matter and nutrients that accumulate at the surface of soils and create beneficial 

effects for the soil quality by mixing the soils and organic matter (Donnelly et al 2010). Firstyear harvesting of rhizomes would have similar soil disturbances as the initial planting; 

however, later year’s harvesting would be similar to activities for hay production that only 

minimally effect soil layers. Likewise, the eradication of the crop would result in additional 

tillage, similar to the establishment phase and traditional row crop tillage, which would 

redistribute soil organic matter, but would leave the soil bare until a new cover crop was 

established. The crop is expected to have a 10 to 15 year lifetime. Once the plant is 

established, the dense root and rhizome system is expected to minimize the potential for soil 

erosion. In the long term, the potential for soil erosion will be significantly reduced relative to 

other regional crops and will likely be reduced relative to pasture land, which is disturbed by 

grazing stock. 

Pimental and Kounang (1998) reviewed the literature to determine average soil erosion 

rates for different land types. They found that the average soil erosion rate on U.S. 

croplands was 13 tons per hectare per year or approximately 5.3 tons per acre per year 

(Ibid.). Pastureland was found to be have a soil erosion rate approximately half that of 

cropland (six tons per hectare per year or 2.4 tons per acre per year) (Ibid.). They also cited 

that the natural soil formation rate is approximately 0.5 to 1.0 tons per hectare per year (0.2 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 4-19

to 0.4 tons per acre per year) (Ibid.). Triplett and Dick (2008) found that traditional tillage, 

when compared to a no tillage system for corn production in Ohio over 42 years, resulted in 

a difference of over 13.4 tons of soil lost per acre per year from traditional tillage acres. 

Overall, soil loss due to erosion greatly exceeds natural soil formation in most areas.

Once established, giant miscanthus fields would generate soil conservation benefits 

associated with a large perennial root system and no tillage production. The combined root 

system and high litter accumulation on the soil surface would reduce the wind and water soil 

erosion. During the establishment period, traditional tillage practices would be undertaken 

for a maximum of two years on select acres (i.e., propagation acres) within the project areas 

and for one year on the majority of acres (i.e., plantation acres) within the project areas. 

Pyter et al. (nd.) indicated that under ideal conditions one-year rhizomes clumps can yield 

seven to 10 harvestable rhizomes and two-year rhizomes clumps could yield 25 or more 

harvestable rhizomes. Thus, it would be reasonable to determine that approximately five

percent of acreage within each proposed project area would be used for propagation 

acreage, thus only a relatively small portion of the total acreage would be traditionally tilled 

more than once. 

Overall, there could be a positive result of soil quality and reduction of soil erosion for the 

Proposed Action. Giant miscanthus can produce an ample amount of above and below 

ground biomass allowing for reduction in soil loss which would reduce the potential for 

sediment to move from fields carrying pesticides and nutrients to the surface water bodies. 

This also is expected to reduce the sediment runoff which could be deposited off-site or

runoff directly into water bodies. 

4.5.3 No Action Alternative

Selecting the No Action Alternative would be unlikely to change current practices. Under this 

alternative, the Project Sponsors would not undertake the establishment and production of 

giant miscanthus in the proposed project areas. The proposed project areas would not 

receive the potential soil benefits that could be provided by giant miscanthus and could 

potentially receive negative effects to soil quality through continued traditional crop 

management. 
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4.6 WATER QUALITY AND QUANTITY

4.6.1 Water Quality

4.6.1.1 Significance Threshold

An accounting of increases or reductions in input use such as fertilizer, herbicides, and 

pesticides is performed to evaluate potential changes in water quality.

4.6.1.2 Proposed Action

Implementing the Proposed Action would not result in a significant decline in surface water 

quality or groundwater quality within the proposed project areas. Over the productive life of 

the plantation acres, inputs of fertilizer, herbicides, and pesticides would be anticipated to be 

lower when compared to inputs for traditional row crops and higher for unimproved pasture. 

Since giant miscanthus is expected to be an excellent nutrient scavenger and recycles 

nutrients back to the root system, and provides excellent soil surface cover to prevent 

erosion losses, off-site movement of nitrogen and phosphorus would be expected to be low. 

As indicated earlier, fertilization of giant miscanthus would not begin until year three when 

significant biomass is produced. Cadoux et al. (2011) indicate that biomass harvest of 

miscanthus removes approximately 4.9 grams per kilogram (g/kg) of dry matter, 0.45 g/kg, 

and 7.0 g/kg of nitrogen, phosphorus, and potassium, respectively, which should indicate a 

maximum replenishment rate for fertilizer applications. Average recommended rates would 

be eight pounds of nitrogen and potassium fertilizer and 1.5 pounds of phosphorus fertilizer 

per ton of biomass produced. For an acre of giant miscanthus producing 12 tons of 

biomass, this would indicate an application of 96 pounds of nitrogen and potassium 

fertilizers and 18 pounds of phosphorus fertilizer. When compared to corn, in 2005 the 

average acre of corn was treated with 138 pounds of nitrogen, 58 pounds of phosphorus, 

and 84 pounds of potassium fertilizers. Additionally, recommended fertilization in 

Pennsylvania included 180 pounds of nitrogen, 115 pounds of phosphorus, and 260 pounds 

of potassium for corn grown for forage (Roth and Heinrichs 2001). No fertilizer treatments

are recommended during the establishment or propagation phase for giant miscanthus, 

thereby reducing the potential for nutrient losses through stormwater flows on exposed or on 

partially covered acreage. 

Research also suggests that, once established, giant miscanthus can lead to low levels of 

nitrate leaching and as a result improve groundwater quality relative to other crops 

(Christian and Riche 1998). Further, Love and Nejadhashemi (2011), through modeling with 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 4-21

the Soil and Water Assessment Tool (SWAT) for scenarios of crop conversions in Michigan,

found that perennial grasses (e.g., miscanthus, native grasses, and switchgrass) would 

improve water quality over traditional crops for sediment and phosphorus loading, but could 

slightly increase nitrogen. On lands with existing high nitrogen levels within the study area,

that are currently cultivated with other crops (e.g., sugarbeets, potatoes, dry beans, and fruit

crops) or lands considered marginal for crop production, the authors determined these areas 

would not be suitable for bioenergy production, as all herbaceous species modeled 

increased nitrogen loading. The authors did find that on these land types with less nitrogen 

concerns, miscanthus and native grasses would be suitable crops for bioenergy production 

(Ibid). Ng et al. (2010) found using SWAT that a 10 percent land use change to miscanthus 

from a corn and soybean rotation in Illinois reduced nitrate export by 6.4 percent; while at a 

50 percent conversion, up to a 30 percent decrease in nitrate export could be obtained. 

The conversion of formerly cropped acres to giant miscanthus production would reduce 

runoff, sediment loss, and nutrient loss due to the high ground cover provided by the plant

after it has established and the reduced need for nutrient application. This reduction in 

sediment and nutrient loss in runoff could enhance water bodies and water quality, 

especially in sensitive watersheds. In marginal areas, sediment runoff could be affected 

during the establishment of giant miscanthus; however, that would be contingent upon the 

quality of vegetation cover on the marginal lands. Fertilization of giant miscanthus during 

establishment is neither recommended or needed. For lower quality vegetation, such as a 

previously disturbed site dominated by annual or early successional species, these areas 

would be anticipated to receive water quality benefits as giant miscanthus establishes 

perennial groundcover on the previous short-term or spare vegetative cover. For areas with 

improved perennial pasture, there could be short-term increases in off-site runoff, until giant 

miscanthus becomes established. Site-specific BMPs would be incorporated into the 

producer Conservation Plan to minimize these effects. 

4.6.1.3 No Action Alternative

Selecting the No Action Alternative, would not produce a significant change in water quality, 

unless there was a substantial increase in land use toward traditional commodity crops. 

Based on agricultural crop production projections, planted corn acreage is anticipated to 

increase by approximately 5.4 percent between 2008 and 2017; however, all other primary 

field crop planted acreage is anticipated to decline. Overall, the change in land use through 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 4-22

the selection of the No Action Alternative would not indicate increased acreage with a need 

for increased agricultural chemicals.

4.6.2 Water Quantity

4.6.2.1 Significance Threshold

Water quantity changes could result in positive or negative effects on total water use in the 

short-term and over the life of the crop compared to other cropping systems depending on 

the regional climate. Land use and water use changes would affect hydrology relative to 

runoff and stream flow.

4.6.2.2 Proposed Action

Miscanthus has a higher efficiency of water use per biomass yield than corn or sorghum 

crops. Typically, giant miscanthus requires between 100 to 300 liters of water 

(approximately 26 to 79 gallons) to produce one kilogram (kg) (approximately 2.2 pounds) of 

biomass depending upon location of production with average anticipated to be 

approximately 200 liters per kg (approximately 500 millimeters [mm] equivalent precipitation 

per year) (Heaton et al 2010). 

Although miscanthus uses less water per unit of biomass than traditional crops in the project 

area, the net water use per acre may be higher. This is due to the higher biomass per acre, 

than corn, soybeans, and switchgrass, and a longer growing season than corn and 

soybeans 

Annual water use and water losses associated with evapotranspiration (ET) for giant 

miscanthus differs from those documented for annual row crops and pasturelands. Hall 

(2003) estimated that perennial energy grasses would use between 500 to 600 mm (20 to 

24 inches) of water annually. Hall determined that giant miscanthus had approximately a 20 

percent interception loss, indicating that a giant miscanthus crop, to be productive would 

need approximately 28 inches per year in precipitation. Grass hay, alfalfa, or pasture which 

typically require between 30 and 39 inches of water annually and corn typically requires 21 

to 29 inches of water annually (Schneekloth and Andales 2009). Table 4-4 summarizes 

literature associated with seasonal water use by crop type.
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Table 4-4. Summary of Reported 

Water Use Values (mm) for Miscanthus and Other Crops

Crop

Estimated Water Use

(mm) Location Source(s)

Miscanthus 200 England Heaton et al. (2010)

500 United 

Kingdom

Long and Beale (2001) as cited

in Teoh et al. (2011)

954.6 Illinois Hickman et al. (2010)

347.9 to 391.7 Italy Consentino et al. (2006)

Alfalfa 763.0 to 999.2 Colorado Schneekloth and Andales 2009

Barley 288 to 297 –

monoculture and rotation

Spain Álvaro-Fuentes et al. (2009)

Coastal Bermudagrass 680 Texas Marsalis et al. (2007)

Corn 146 to 316 Colorado Nielsen et al. (2006)

551 to 584 Kansas Hattendorf et al. (1988)

255 to 422 – dry matter

293 to 448 - grain

South Dakota Olson (1971)

520.4 to 681.0 Colorado Schneekloth and Andales 2009

444 to 480 Kansas Norwood (2001)

611.9 Illinois Hickman et al. (2010)

Giant Amaranth 261 to 282 North Dakota Johnson and Henderson (2002)

Grain Sorghum 339 to 374 Nebraska Maman et al. (2003)

451 to 523 Kansas Hattendorf et al. (1988)

453 to 477 Kansas Stone et al. (2001)

202 to 424 – dry matter

296 to 443 - grain

South Dakota Olson (1971)

406.1 to 640.1 Colorado Schneekloth and Andales 2009

Grass hay/pasture 661.4 to 880.4 Colorado Schneekloth and Andales 2009

Pearl Millet 336 to 370 Nebraska Maman et al. (2003)

70 to 266 Colorado Nielsen et al. (2006)

441 to 529 Kansas Hattendorf et al. (1988)

Soybean 441 to 596 Kansas Hattendorf et al. (1988)

Sunflower 476 to 584 Kansas Hattendorf et al. (1988)

565 to 580 Kansas Stone et al. (2001)

Sweet Sorghum 152 to 268 Arizona Miller and Ottman (2010)

272 to 390 South Dakota Olson (1971)

Switchgrass 764.3 Illinois Hickman et al. (2010)

Triticale 86 to 330 Colorado Nielsen et al. (2006)

Wheat 317 to 342 Australia Angus and Herwaarden (2001)

318.3 to 499.1 Colorado Schneekloth and Andales 2009

300 to 345 –

monoculture and rotation

Spain Álvaro-Fuentes et al. (2009)

Beale et al. (1999) indicated that water use efficiency for giant miscanthus, when normalized 

by the daily maximum vapor pressure deficit, were within the range of C4 crops over several 

environments (7.3 grams per kiloPascal per kilogram [g kPA/kg] – 9.4 g kPA/kg) and based 

on literature would be similar to corn (8.2 to 12.0 g kPA/kg) and pearl millet (8.4 to 10.6 g 

kPA/kg). Although the proportion of corn and pasture/idle land that will be enrolled in the 

program is unknown, the project sponsors expect that 80 percent or more of the enrolled 

lands will be lands currently in pasture or idle land. Since some pastureland species use 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 4-24

more water annually than miscanthus; depending upon land use cover of pastureland, total 

water use could be reduced somewhat through implementation of the project areas.

The majority of the data on ET comes from England where the plant has been grown in 

production for over a decade. Estimated ET for miscanthus is highly variable between 

studies (Table 4-5). In general, ET in miscanthus fields is two to three times lower than the 

values measured in corn, similar to switchgrass, and somewhat higher than winter wheat 

and grasslands. 

Table 4-5. Summary of Reported 

ET Values (mm/day) for Miscanthus and Other Crops

Crop

Estimated ET

(mm/day) Location Source(s)

Miscanthus 2.3 England Beale et al. (1999)

1.2 to 1.6 England Cranfield University (2001) as 

cited in Finch et al. (2009)

1.9 to 3.1 Italy Cosentino et al. (2007) 

3.2 England Finch and Riche (2008) as cited 

in Finch et al. (2009)

3.7 to 3.9 Illinois McIsaac et al. (2010)1

Corn 6.8 to 7.4

(43 year average)

Kansas Lamm et al. (2007)

6 to 10 Texas Howell et al. (1996)

1.8-3.0 – no till

1.7-3.1 – chisel plow

Wisconsin Brye et al. (2000)

Corn – Soybean 1.4 to 2.3 Illinois McIsaac et al. (2010)1

Soybeans 4.1 to 5.1 – irrigated

3.4 to 4.6 – nonirrigated

Siberia Maksimovic et al. (2005)

3.4 – irrigated

3.2 - rainfed

Nebraska Suyker and Verma (2009)

Switchgrass 2.5 to 2.6 Illinois McIsaac et al. (2010) 1

Winter Wheat 1.3 – drought crop 2.0 

– rain fed crop

England Weir and Barraclough (1986) as 

cited in Finch et al. (2009)

1.5 to 1.7 England Scott et al. (1994) as cited in 

Finch et al. (2009)

Alfalfa 7.9 to 8.1 Texas Tolk et al. (2006)

Grasslands 1.4 England Calder et al. (2003) as cited in 

Finch et al. (2009)

3

1.1 England, 

riparian areas

Finch and Harding (1988) as 

cited in Finch et al. (2009)

Native Prairie 2.6-2.7 North Dakota Frank (2003)

2.4-2.5 Wisconsin Brye et al.(2000)

3.2-3.4 Kansas Bremer et al. (2001)

Western Wheatgrass 2.8 North Dakota Frank (2003)

1/ Publication reported total annual ET; values converted to daily ET

2/ Publication indicated corn/soybeans were 104 mm less per growing season which is equivalent to 0.9 mm/day 

less. Number in table is value for miscanthus reported by the author minus 0.9 mm/day

3/ Grasslands in England have a longer growing season than Miscanthus
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 4-25

VanLoocke et al. (2010) indicated that through their modeling giant miscanthus at 100 

percent cover that ET increased by over 200 mm per year and drainage declined between 

50 to 250 mm per year. The model included the entire Midwest (11 states) with over 324 

million acres of agricultural land and average precipitation ranging from 15 to 40 inches per 

year (west to east). At 10 percent cover (estimated more than 32 million acres) changes to 

ET and drainage were minimal compared to existing cover (Ibid.). The project is expected to 

enroll considerably less than 10 percent of the total agricultural lands in each of the 

production areas, so no significant regional change in ET is expected. VanLoocke et al. 

(2010) also indicate that past studies have shown that conversion from native grasslands to 

annual crop dominated cover could have reduced ET in Corn Belt of the United States by 

approximately 75 mm per year, indicating that giant miscanthus could have ET rates more in 

line with past vegetative cover in prime farming areas than current crop cover. 

Giant miscanthus, as a result of the deep root system and large leaf area, likely has higher 

infiltration rates during rain events allowing for a reduced run-off and the reduced peak 

flows, which could reduce the effects of flooding in certain areas (Smeets 2008).

The proposed project would only require irrigation in this first year (2011) due to late planting 

of the crop and would not require irrigation after the first propagation year. Therefore, the 

Proposed Action would transfer some irrigated cropland to irrigated giant miscanthus 

propagation acres during 2011, resulting in irrigation use approximately equal to previous 

years within the proposed project areas. Therefore, impacts to water quantity used in one 

year or irrigation would be negligible. All of the proposed project areas have, on average, 

greater than 30 inches per year of precipitation, which is sufficient to support the growth of 

miscanthus; therefore, irrigation after 2011 would not be required. 

Under the Proposed Action the implementation schedule, plant propagation acres would be 

planted in 2011 that would produce 9,600 propagation acres in 2012, with an overall the 

goal of planting 50,000 acres total per proposed project area. By 2014, the portion of these 

acres that are currently irrigated will not be known until producers sign up for the program. 

The Ashtabula, Aurora and Columbia proposed project areas have less than 10 percent 

irrigated lands (USDA 2009). The project is targeting use of pasture land, and marginal and 

idle croplands. Therefore, the number of acres converted from irrigated crops to miscanthus 

in these three project areas will likely be negligible. The Paragould proposed project area 

irrigates a much larger percentage of the cropland; an average of 70.1 percent of the 

cropland is irrigated. In this area, water use exceeds water recharge and aquifers are being 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 4-26

depleted. Some of the more marginal acres that are currently irrigated may be converted to 

miscanthus. The targeted 50,000 acres represents 2.0 percent of the total acres of farmland 

in the Paragould proposed project area. Some unknown proportion of these areas will be 

irrigated lands. The conversion of irrigated lands to miscanthus will reduce water use in the 

area.

4.6.2.3 No Action Alternative

The selection of the No Action Alternative would not result in significant adverse effects to 

the water quantity within the proposed project areas. Under this alternative, the Project 

Sponsors would not undertake the establishment and production of giant miscanthus in the 

proposed project areas. The change in land use through the selection of the No Action 

Alternative would not indicate increased acreage with a need for increased agricultural 

irrigation.

4.7 ALTERNATIVES COMPARISON

This section of the EA provides a brief comparison for the potential effects associated with 

both the Proposed Action and the No Action Alternative. Table 4-6 lists the qualitative 

comparison of the alternatives.

Table 4-6. 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 0/- minor

Water Quality/Quantity

Water Quality +/- minor 0

Water Quantity +/- minor 0

Note:

+ =positive - =negative 0 =neutral

4.7.1 Proposed Action

Implementing the Proposed Action would result in minor positive and negative effects to the 

local and regional area; however, many of these effects would be minimized through the use 

of the Mitigation and Monitoring Plan. The Proposed Action could result in additional 

diversified income for the contract producer, as well as technical assistance from the Project 

Sponsors in the production and harvesting of giant miscanthus. The Project Sponsors have 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 4-27

a proposed BCF in each of the proposed project areas ensuring that producers will have a 

demand for their products. Also, ancillary agricultural services should expect an increase 

due to the Project Sponsors goal of primarily contracting idle acres and not active cropland. 

The Proposed Action would result in a changed local landscape with the addition of the giant 

miscanthus fields; however, most contract acreage would be small between 38 to 100 acres. 

The Mitigation and Monitoring Plan will be used to ensure that adverse effects from this new 

crop are minimized or avoided. 

Minor negative effects would be anticipated for biological diversity as pastureland is 

converted in giant miscanthus croplands. The Mitigation and Monitoring Plan will be 

essential to provide mechanisms such as buffers and field edges to support continued 

wildlife and vegetative diversity in these areas and control of rhizome and vegetative spread. 

Recent research has indicated that giant miscanthus can function as a source of plant pests

to conventional crops; the Mitigation and Monitoring Plan monitoring and buffer will be 

essential to ensure that any pests/diseases are identified and treated early to avoid 

transmission to local croplands, such as corn. 

Giant miscanthus, which has an extensive perennial root system, would be anticipated to 

have positive effects on soil retention, soil organic matter, and conversion to soil carbon, as 

well as increased water quality due to reduced nutrient leaching and transported sediments. 

Giant miscanthus would be anticipated to require more water than annual crops, such as 

corn; however, giant miscanthus has much higher water use efficiency, generating high 

amounts of biomass per volume of water consumed. 

4.7.2 No Action

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

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

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

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

use into the conversion of bioenergy. 
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CUMULATIVE IMPACTS ASSESSMENT

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5 CUMULATIVE IMPACTS ASSESSMENT 

5.1 DEFINITION

The CEQ regulations stipulate that cumulative effects analysis consider the potential 

environmental impacts resulting from “the incremental impacts of the action when added to 

other past, present and reasonably foreseeable actions regardless of what agency or person 

undertakes such other actions.” Cumulative effects most likely arise when a relationship 

exists between a proposed action and other actions expected to occur in a similar location 

or during a similar time period. Actions overlapping with or in proximity to the proposed 

action would be expected to have more potential for a relationship than those more 

geographically separated. Similarly, actions that coincide, even partially, in time tend to 

have potential for cumulative effects. 

The Proposed Action is to establish BCAP project areas supporting the establishment and 

production of giant miscanthus as a dedicated energy crops for bioenergy production. The 

scale of this action is regional and includes counties within Arkansas, Missouri, Ohio, and 

Pennsylvania. Given the action is to produce an alternative crop on existing agricultural 

lands, identifying past, present, and reasonably foreseeable future actions is based on 

existing cropland production, projected future cropland production, existing CRP acres 

within each county, future expirations of CRP acres within each county, and the potential for 

additional BCAP project acres within these proposed project areas. 

5.2 CUMULATIVE IMPACTS ANALYSIS BY RESOURCE AREA

5.2.1 Socioeconomics

In the United States, average farm operator household income from 2007 to 2009 has been 

consistently higher than the average United States household income; however, the 

percentage difference has been declining from a high of 31.1 percent higher to 13.5 percent 

higher (USDA ERS 2011b). Farming activities have contributed approximately 11.3 percent 

to household income, with the projected average being 12.5 percent in 2010 (Ibid). After 

two declining years of total household income of farm operators, the forecast for 2010 and 

2011 indicate an increase, which will be record levels (Ibid). Traditional commodity crops 

continue to be high-value for associated land production capabilities providing a substantial 

proportion of farm operator household income for many areas. Combined with the 

foreseeable high commodity prices associated with recent natural occurrences that have 

impacted food crops globally and the driver for alternative fuels and energy sources from 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 5-2

renewable resources, traditional crops such as corn and soybean would be anticipated to 

continue as the dominant agricultural land uses within these proposed project areas. 

Under the Proposed Action, contract producers would be creating a diversified crop profile 

with the inclusion of giant miscanthus on their marginal or idle lands. Given the infancy of 

industry for biomass feedstock production, large acreages are not anticipated to be 

converted into dedicated biomass crops with the short-time frame associated with BCAP. 

The Project Sponsors are anticipating a total combined acreage across all proposed project 

areas to be 200,000 acres by 2014. The potential for dedicated energy crops exists through 

many regions of the United States; however, one of the primary limiting factors is 

accessibility to a BCF that (1) provides a market to producers for their biomass feedstock 

and (2) has a market for sale of the bioenergy product produced at that facility. Overall, the 

cumulative effects to socioeconomics associated with the Proposed Action and No Action 

Alternative would be minor, given the high commodity prices associated with traditional 

crops and the lack of adequate BCF with enough demand in the region to convert more than 

a modest amount of agricultural lands to dedicated energy crop production away from 

traditional crops. 

5.2.2 Land Use

The combined proposed project areas include approximately 6.5 million acres of cropland 

and pastureland with varying degrees of activity (Table 5-1). Overall, soybeans are the 

most cultivated crop accounting for less than 1.7 million acres within the combined proposed 

project areas. Corn followed with 0.6 million planted acres in the combined proposed 

project areas. Projections from the USDA Agricultural Projections to 2020 indicate that 

increased United States planted acres of soybeans and corn would, on average, remain 

relatively flat, with some short-term increase in corn (USDA 2011). 

Of the land in farms, approximately 191,000 acres are in CRP as of 2010 (13.7 percent of 

permanent pasture or rangeland), with approximately 66,500 acres expiring from CRP 

between 2012 to 2014. Currently, there are approximately 31.2 million acres enrolled in 

CRP practices in the United States, with 4.4 million expiring at the end of Fiscal Year 2011

(14 percent). Overall, the cumulative effects to land use associated with the Proposed 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 5-3

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%

Source: USDA NASS 2009, 2011

Action and No Action Alternative would be minor, given the high commodity prices 

associated with traditional crops and the lack of adequate BCF with enough demand in the 

region to convert more than a modest amount of agricultural lands to dedicated energy crop 

production away from traditional crops. 

5.2.3 Biological Resources

Cumulative effects from the Proposed Action would be minimized through the use of the 

Mitigation and Monitoring Plan to ensure that overall biodiversity would be maintained and 

the potential for plant pests would be minimized. The potential cumulative effects of 

establishment of a biomass crop would impact wildlife as habitats are fragmented, 

degraded, or destroyed from dedicated energy crop establishment; however, the amount of 

acreage within any of the proposed project areas would be minor and would be mitigated 

through the Mitigation and Monitoring Plan. The establishment of new dedicated energy 

crops in areas previously fallow or cropped for a different style of agriculture may itself 

cause some direct mortality and range shifting at the local scale of wildlife. Direct effects are 

likely to occur during the establishment phase, but would be similar to traditional agricultural 

cropping of fallowed or idle lands. During the short term, species using pastureland could 

relocate to marginal areas or wildlife corridors. Overall, the cumulative effects to biological 

resources associated with the Proposed Action and No Action Alternative would be minor, 

given the high commodity prices associated with traditional crops and the lack of adequate 

BCF with enough demand in the region to convert more than a modest amount of 

agricultural lands to dedicated energy crop production away from traditional crops. The use 

of the Mitigation and Monitoring Plan for the Proposed Action would also minimize effects to 

biological resources and provide mechanisms for adaptive management should the need 

arise based on crop monitoring.
CUMULATIVE IMPACTS ASSESSMENT

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 5-4

5.2.4 Soil Resources

The Proposed Action would be anticipated to have positive effects on soils at multiple levels, 

including a reduction of soil erosion, and increase in soil organic matter, and soil carbon 

deposition, relative to traditional crops or fallowed land under annual species. Overall, the 

cumulative effects to soils resources associated with the Proposed Action and No Action 

Alternative would be minor, given the high commodity prices associated with traditional 

crops and the lack of adequate BCF with enough demand in the region to convert more than 

a modest amount of agricultural lands to dedicated energy crop production away from 

traditional crops. 

5.2.5 Water Quality and Quantity

The conversion to a perennial dedicated energy crop provides greater water use efficiency 

than traditional row crops such as corn, thereby indicating a more productive choice for 

biomass production. Giant miscanthus would be anticipated to use more water than 

fallowed or idle lands with permanent pasture, rangeland, or annual species. Taken in 

combination with traditional crops in the proposed project areas, there could be greater use 

of groundwater supplies or effects on groundwater recharge. However, these effects would 

be mitigated through monitoring and BMPs associated with the Mitigation and Monitoring 

Plan. The conversion from traditional crops to dedicated energy crops would be anticipated 

to limit runoff from agricultural fields and potential need for irrigation past the initial 

establishment period. Potential plant pests newly associated with giant miscanthus could 

require more pesticide use or greater IPM than potentially anticipated based on existing 

literature from Europe, but should be less than traditional row crops. Overall, the cumulative 

effects to water quality and quantity associated with the Proposed Action and No Action 

Alternative would be minor, given the high commodity prices associated with traditional 

crops and the lack of adequate BCF with enough demand in the region to convert more than 

a modest amount of agricultural lands to dedicated energy crop production away from 

traditional crops.
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6 MITIGATION AND MONITORING 

6.1 INTRODUCTION

The CEQ issued revised guidance for mitigation and monitoring to be included in NEPA 

decision documents that include three general types of scenarios including: (1) mitigation 

incorporated into project design; (2) mitigation alternatives for NEPA decision documents 

(i.e., EA and EIS); and (3) mitigation commitments analyzed in EAs to support a Mitigated 

FONSI (CEQ 2011). The purpose of mitigation in this EA is the first type, which is 

incorporation into project design following the original intent of the definition of mitigation 

provided by CEQ that includes:

Avoiding an impact by not taking a certain action or parts of an action;

Minimizing the impact by limiting the degree or magnitude of the action and its 

implementation;

Rectifying an impact by repairing, rehabilitating, or restoring the affected 

environment;

Reducing or eliminating an impact over time, through preservation and maintenance 

operations during the life of the action; and

Compensating for an impact by replacing or providing substitute resources or 

environments.

The recently revised CEQ guidance also explicitly specifies that adaptive management, or 

the potential for the lead agency under NEPA to take corrective actions if the originally 

committed mitigation measures fail to address the target potential impacts, is allowable and 

desirable to both protect the environment and help a Federal agency meet their stated 

goals. 

6.2 ROLES AND RESPONSIBILITIES

The revised CEQ guidance on mitigation and monitoring explicitly requires each federal lead 

agency under NEPA, or FSA in this case, to identify mitigation tracking mechanisms, 

commitments for any mitigation proposed; responsibility for implementation particularly if 

shared, reasonably foreseeable circumstances regarding anticipated or projected funding 

availability to implement mitigation commitments; and the identification of any outside 

entities that may be responsible for assisting the lead agency through financial or other 
MITIGATION AND MONITORING

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

means to implement the committed mitigations. In BCAP, the lead agency under NEPA is 

FSA with technical support provided by the USDA Rural Development, APHIS, the Forest 

Service (FS), and the NRCS, as described in the Final PEIS (USDA FSA 2010). FSA will to 

have primary responsibility for implementation and tracking of the mitigation and monitoring 

program. FSA has signed a Memorandum of Understanding (MOU) with NRCS to provide 

BCAP technical assistance for producers on an individual contract basis. FSA will ensure 

each producer complies with existing requirements of BCAP including completion of the 

Environmental Screening worksheet, completion of a Conservation Plan with appropriate 

BMPs and/or NRCS CPS, as adopted by FSA for the BCAP. Based on comments received 

on the Draft EA and to ensure the best possible results for this mitigation and monitoring 

plan, FSA has signed a MOU with the Project Sponsors defining their roles and 

responsibilities in implementing this Mitigation and Monitoring Plan. The Project Sponsors 

will provide the appropriate financial assistance associated with implementation of the 

monitoring program to assess the effectiveness of mitigation and provide financial 

assistance for any eradication efforts outside of the intentionally planted areas. The Project 

Sponsors will continue the Mitigation and Monitoring Plan through the life of the contract 

between the producer and the Project Sponsor, which can be renewed in perpetuity.

Based on the comments submitted on the Draft EA, in consultation with NRCS and ARS, 

FSA has developed a mitigation and monitoring plan that will be applied to this BCAP 

project. Additionally, FSA is aware of on-going research for giant miscanthus; however, 

publication of some of those results has not yet been provided. FSA will continually review 

and monitor newly developed and available data for inclusion into the mitigation and 

monitoring plan within this BCAP project area annually. Table 6-1 summarizes the 

responsible party for different mitigation and monitoring activities per this plan. 
MITIGATION AND MONITORING

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 6-3

Table 6-1. Roles and Responsibilities for the Mitigation and Monitoring Plan

Activity Responsible 

Party

Comment

Biannual Producer meetings to discuss new developments in 

production, management, pest/disease treatment, and eradication.

Project Sponsor Project Sponsor 

will coordinate 

with FSA, NRCS, 

ARS, and local 

extension as 

presenters as 

those parties are 

available. 

New Producer orientation to discuss production methods, management 

activities, potential for spread of giant miscanthus, treatment methods, 

and responsibilities, pest/disease identification, treatment methods, and 

responsibilities, eradication methods, if necessary, and reporting 

requirements.

Project Sponsor Project Sponsor 

will coordinate 

with FSA, NRCS, 

ARS, and local 

extension as 

presenters as 

those parties are 

available.

Producer Conservation Plans to include site specific best management 

practices (BMPs), which could included, but not be limited to, Natural 

Resources Conservation Services (NRCS) Conservation Practice 

Standards (CPS) and mitigation measures identified on the 

Environmental Evaluation CPA-52for soil erosion, pesticide use and 

application, fertilizer use and application, and other areas for each 

specific site.

NRCS

Monitoring program developed to identify spread of giant miscanthus 

outside of planted fields with notification provided to the FSA County 

Office, local Weed Control Board, and Project Sponsors as soon as 

possible after identification of the issue. Producer will eradicate the 

portion of the miscanthus that has moved outside of the edge of the 

field.

Producer Project Sponsor 

will provide 

confirmation to 

FSA, ARS, and 

NRCS of 

eradication.

Once notified of spread of miscanthus referenced above, Project 

Sponsor will confirm with Producer that elimination has been 

completed. If Producer refuses or cannot treat the miscanthus growth, 

Project Sponsors will eliminate the portion that has spread beyond the 

field boundary. FSA and/or NRCS will make a site visit to ensure 

compliance.

Project Sponsor Project Sponsor 

will provide 

confirmation to 

FSA, ARS, and 

NRCS of 

eradication.

Monitoring program developed to identify diseases and pests with 

notification provided to the Project Sponsors as soon as possible after 

identification of the issue. Producer will treat the disease or pest in the 

BCAP contract acres. 

Producer Project Sponsor 

will consult with 

FSA, NRCS, and 

ARS to ensure 

monitoring 

program is 

capturing the 

appropriate 

structured data 

that will facilitate 

accurate annual 

reporting.

Once notified of disease or pests referenced above, if Producer refuses 

or cannot treat for the disease or pest, Project Sponsor will treat the 

producer’s BCAP contracted acres in the field and notify FSA and/or 

NRCS who shall make a site visit to ensure compliance. 

Project Sponsor
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 6-4

Activity Responsible 

Party

Comment

Monitoring program developed to monitor wildlife use or changes in 

use. Environmental Evaluation CPA-52 may need to be revised to 

capture changes and any new mitigation to be implemented.

Project Sponsor This will require 

coordination. 

Project Sponsor 

will handle report 

and consult with 

FSA, NRCS, and 

ARS to ensure 

appropriate 

structured data is 

being collected 

that will facilitate 

accurate annual 

reporting.

Project Sponsors will verify that Producers will only establish giant 

miscanthus that (1) is an Illinois Clone variety and (2) has been 

incorporated into Aloterra’s Quality Assurance Program administered by 

the third party Ohio Seed Improvement Association (OSIA).

Project Sponsor

Data gathering to include (1) land use tracking (2) average and total 

size of enrolled fields (3) prior land use (4) rationale for land use change 

(4) spread of giant miscanthus outside of planted fields (5) any 

pests/diseases identification (6) the use of pesticides/herbicides to 

control unwanted spread of giant miscanthus or pests/diseases (6) BMP 

and CPS incorporated into field management, such as erosion control 

structures or materials, vegetative barriers, (7) fertilizer usage and 

application methods, and (8) cost data.

Project Sponsor This will require 

coordination. 

Project Sponsor 

will handle report, 

and work with 

NRCS, ARS, FSA 

and local 

extension to 

improve data 

collection.

Annual Report. Draft report summarizing information gathered 

immediately above and submit to the FSA and other agencies that 

would like the information such as the NRCS and ARS.

Project Sponsor

Initiation of a seed sampling program to determine the on-going sterility 

of seeds produced from the BCAP acres within the project areas. The 

seed sampling program includes recommended actions, including 

halting harvesting of material from the field, additional testing to verify 

findings, additional testing to fields in the region, and an eradication 

plan for that field.

Project Sponsor Project Sponsor 

intends to 

coordinate these 

activities with the 

OSIA and ARS

Exclusion of planting giant miscanthus on certain acreage within 400 m 

(approximately 1,300 feet) from any know Miscanthus sinensis or 

Miscanthus sacchariflorus to limit the potential for cross-pollination 

resulting in viable seed.

Project Sponsor Will coordinate 

with NRCS 

Conservation Plan 

efforts.

Exclusion of planting giant miscanthus on certain acreage within the

project areas, depending upon certain site-specific conditions. This is 

beyond the Conservation Plan and will also consider economics and 

other considerations. 

Project Sponsor Will coordinate 

with NRCS 

Conservation Plan 

efforts

6.3 MITIGATION AND MONITORING RECOMMENDATIONS

General mitigation and monitoring recommendations for BCAP, as a national program with 

numerous feedstock options, were detailed in the Final PEIS including common BMPs to 

address potential adverse impacts of energy crop establishment. Examples of the common 

BMPs include conservation buffers strips, no-till or reduced till planting methods, avoiding 

the primary nesting season to protect grassland bird populations, and work window 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 6-5

avoidance for energy crop establishment to avoid establishment during high precipitation or 

rainfall events. 

6.3.1 Purpose and Overview

The purpose of this mitigation and monitoring plan is to provide project-specific mitigation 

measures that FSA is proposing to implement as part of the approval of the proposed BCAP

project area. An inherent part of that process includes a site-specific environmental review 

by FSA through the use of an Environmental Screening worksheet to determine whether 

environmentally sensitive resources such as Federally threatened or endangered species or 

wetlands are present and could be potentially affected. Where possible, implementation of 

appropriate BMPs and/or CPS identified during the conservation planning process would 

mitigate or reduce any potential environmental impacts on key resources addressed within 

the scope of this EA. In the event sensitive resources have the potential to be present, FSA 

will be the lead agency in conducting any and all appropriate consultations with the resource 

regulatory agencies such as the USFWS, U.S. Army Corps of Engineers (USACE), and 

State Historic Preservation Offices (SHPO). 

In general, potential environmental impacts associated with establishment and cultivation of 

giant miscanthus as proposed by the Project Sponsors are likely to be temporary in nature 

and variable in scale from local to regional depending on existing characteristics of the 

individual producer’s total land acreage being enrolled, their current land use, the 

surrounding mix of agricultural uses in each of the four proposed project areas, and the year 

in the growth cycle (i.e., establishment in year one or two or maintenance in years three to 

15). Potential localized impacts are more likely to be in areas where the average farm size 

or the portion of total land holdings an individual producer is enrolling in the project area is 

small. In areas with large farm sizes and/or large portions of total land holdings are 

enrolled, impacts could be more regional in nature, potential impacts are also likely to vary 

by current land use. Impacts will be less where cropped lands are currently in traditional row 

crops and potentially greater where lands are currently idle or in pastureland then converted 

into giant miscanthus. Potential impacts are also likely to vary depending on the 

surrounding character of farmland; areas dominated by a single agricultural use (e.g., corn 

or beans) that have a large proportion of land converted to BCAP may have greater impacts 

than regions dominated by a variety of agricultural uses where land conversions to BCAP 

cover a smaller area. Finally, impacts are likely to vary by phases of the growth cycle. 

Establishment in year one (propagation) and year two (plantation planting) may have greater 
MITIGATION AND MONITORING

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 6-6

impacts than maintenance (years three to 15) related to soil erosion and loss, water quality 

and quantity impacts, and herbicide application for weed control. 

All proposed site-specific mitigation measures will rely on adaptive management and 

monitoring to ensure that proposed mitigation commitments are met, and, in the event they 

do not prevent the intended potential impacts, that additional corrective measures are 

implemented to rectify the situation as required by the recent CEQ guidance (CEQ 2011). 

Adaptive management and monitoring is also useful for assessing the effectiveness of 

particular mitigation actions and addressing any uncertainty regarding whether a proposed 

method of mitigation is likely to address the intended potential environmental impact. 

6.3.2 Meetings with Contract Producers

The Project Sponsors shall hold regional meetings with the BCAP contract producers within 

the proposed project areas at least twice per year. These meetings will be used to 

disseminate information of interest to the producers and will also be used to provide 

information and resources regarding the latest recommendations and developments in the 

use of appropriate approved fertilizer, the control of pests and disease, erosion control, 

control options in the event of a potential spread of giant miscanthus, and other related 

topics. Additionally, new enrollees will be required to attend an orientation meeting, which 

will include training similar to the information presented at the biannual meetings with 

greater focus on the overall basics of establishment, maintenance, and production. The 

implementation of the actions contained in this section would be required of the producers. 

6.3.3 Socioeconomics

The proposed project has the potential to impact socioeconomics by converting land 

currently enrolled in food crops to energy crops. However, this potential impact is primarily 

expected to be localized to the Paragould proposed project area associated with 

sustainability issues regarding current agricultural row crop use raised by producers who 

have expressed interest in enrolling in BCAP so they can convert the more marginally 

productive areas (low economic viability with existing crops), currently in corn or beans, into 

a more sustainable crop. Potential impacts are expected to be mitigated by minimizing the 

conversion of food to energy crops and when that conversion does occur, focusing on the 

marginally productive lands currently in food crop production. The Project Sponsors have 

worked with FSA, the USDA Agricultural Research Service (ARS), and NRCS to develop 
MITIGATION AND MONITORING

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 6-7

appropriate metrics for tracking conversion of lands currently enrolled in food production and 

tracking documentation of their productive status. 

Contract Producer Application Forms - The Project Sponsors will develop an 

application form that documents the prior use of enrolled land (e.g., cropland, idle 

cropland, pasture, or hayland) and the reason the applicant wishes to convert to 

giant miscanthus production. If the applicant identifies current land use as cropland 

for food production, additional questions will provide insight into the economic 

rationale for the desired conversion (e.g., marginally productive cropland). 

Contract Producer Annual Report and Project Area Annual Reporting – Annual

reporting to FSA will include the number of producers that enrolled, average and total 

enrolled field size, their prior land use, rationale for applying, and a summary of 

economic rationales where appropriate. After review of the annual reporting effort, 

FSA will determine whether an unexpectedly high proportion of food crop acres may 

be converted, the rationale, and whether restrictions on land conversion may be 

necessary as part of adaptive management and monitoring to mitigate potential 

environmental impacts. 

6.3.4 Land Use

Potential impacts on land use may include conversion of land use types such as the 

conversion from traditional row crops to giant miscanthus as discussed above or the 

conversion of idle land, pastureland, or hayland into giant miscanthus. The BCAP program 

does not allow conversion of native sod into BCAP; therefore, areas meeting this definition 

were excluded from this analysis because they will not be eligible for enrollment. Potential 

mitigation measures as discussed above for tracking the conversion of land types and their 

productive status are also expected to mitigate potential adverse impacts on land change. If 

adaptive monitoring indicates large-scale or regional land use conversions are both 

occurring, and are having a negative effect, then additional restrictions on land use 

conversion will be considered and implemented. Annual reporting to FSA following the 

methods described above in Section 6.3.1 will also be used to monitor any potentially 

unexpected changes in land use. In the event any unexpected changes in land use are 

detected, FSA will determine whether additional requirements are necessary to mitigate 

potential environmental impacts on land use.
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 6-8

6.3.5 Biological Resources

6.3.5.1 Vegetation

A potential impact of giant miscanthus establishment relates to the potential for fertile seed 

production and the potential to spread beyond the intended plantation and propagation 

acres. All published research, including detailed genetic studies of giant miscanthus, 

indicate it is a sterile triploid (i.e., meaning three sets of genetic material) hybrid that 

reproduces vegetatively through rhizomes and does not produce sterile seed (LindeLaursen 1993, Lewandowski et al. 2000). The New Zealand Environmental Risk 

Management Authority (NZERMA) approved giant miscanthus for use as a biomass 

feedstock in 2007 after an extensive process of literature review, risk assessment 

methodology, and contact with researchers (NZERMA 2007). The NZERMA concluded, 

through literature and contact with researchers, that giant miscanthus is a triploid hybrid that 

does not produce seed or viable pollen; however, it will produce inflorescences in warmer 

climates (NZERMA 2007). 

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. The OSIA has been monitoring the flower unit of OSIA’s giant 

miscanthus selection for pollen and seed production by observation and microscopic 

examination (Armstrong 2011 – Appendix A). Accordingly, neither pollen nor seed has been 

produced (Ibid). 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 (Ibid). In addition, there 

have been no observed volunteer seedlings emerging in observation plot areas adjacent to 

the giant miscanthus selection (Ibid). 

Exclusion of Acreage Near Other Miscanthus Species - As to seed dispersal, the 

Project Sponsors would take steps necessary to minimize the unintentional 

development of viable seed from giant miscanthus. The Project Sponsors would be 

willing to exclude acreage within 400 m (approximately 1,300 feet) from any known 

Miscanthus sinensis or Miscanthus sacchariflorus to limit the potential for crosspollination resulting in viable seed. This distance is the maximum distance observed 

in Quinn et al. 2011. 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 6-9

Seed Sampling Program – Based on comments received on the Draft EA and 

recommendations of ARS, a seed sampling program will be undertaken by the 

Project Sponsors to determine if the Illinois clone being used within the proposed 

project areas could produce viable seed. Seed samples at a rate of 50 to 100 

inflorescences from four samples in each proposed project area would be provided 

to either a third party verification or ARS to determine the viability of the seeds.

Samples would be taken to represent a range of environmental variability, such as 

land positions, slope, soil moisture, soil types, etc. If viable seed are found through 

the seed sampling program these additional steps could be undertaken, which

include (1) halting any harvest of the identified field with no off-site movement of any 

material harvested from that field, (2) immediate removal of existing inflorescences in 

the field that was found to contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an approximate percent of 

inflorescences that produced viable seeds, (4) sampling of fields in the immediate 

region to determine if additional viable seed is occurring, (5) a commitment by the 

project sponsor to recommend eradication of that field, if it is determined that the 

percentage of viability is outside a safe range.

Quality Assurance Program overseen by OSIA - Participation in the Ohio Seed 

Improvement Association’s Quality Assurance Program is voluntary and illustrates a

company's efforts to use effective quality control in rhizome production and 

marketing. The services and records generated under this system provide quality 

assurance for every customer. This program provides an unbiased quality control 

system of the items described below and rhizomes carrying the green "QA" tag have

met the minimum standards set out below and in Appendix D. Aloterra Energy’s 

“limited membership” designation and participation in OSIA’s Quality Assurance 

program is based only on the genetic purity of the miscanthus giganteus and 

includes Aloterra’s commitment to follow specific quality control measures in the 

harvest, transport, and planting of its rhizomes. Specifically, Aloterra has agreed to 

the items set out in Appendix D, which include field inspections, botanical

description and origin confirmation, field history, agreed distance from other 

miscanthus varieties, the proper cleaning and storage of equipment, head sample 

collection to test for viability, and proper record keeping of all of the above with an 

agreement to inspections without notice. 
MITIGATION AND MONITORING

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 6-10

Another potential impact of giant miscanthus plantings is the potential for spread or invasion 

in areas that are not intentionally planted or propagated. Based on numerous published 

studies, the likelihood of rapid growth in intentionally planted areas or invasion to areas 

where giant miscanthus has not been deliberately planted appears low. For example, weed 

risk assessments conducted on giant miscanthus compared to other potential bioenergy 

crops such as giant reed, switchgrass, Eucalyptus species, and Jatropha (i.e., a deciduous 

succulent plant) have concluded the risk of invasiveness in the United States is low (Barney 

and DiTomaso 2008, Gordon et al. 2011). 

Published research studies have shown a slow growth rate of intentionally planted giant 

miscanthus rhizomes of approximately five cm per year (approximately two inches) in 

Europe (Jørgensen 2011), but those studies focused on rhizome growth from deliberately 

planted giant miscanthus, which is an expected characteristic in deliberately planted areas 

and not consistent with an invasion. Unpublished data provided by ARS indicates giant 

miscanthus tillers and rhizomes have a potential maximum rate of growth in Illinois from

established plants of 1.2 meters (m) per year (approximately four feet) (Davis, unpublished 

data, 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). 

Another potential, but secondary impact, is the potential for giant miscanthus plantings to 

provide an additional host plant for crop pests such as the western corn rootworm. Results 

of a recent greenhouse and field study showed that planted giant miscanthus may support 

emergence of western corn rootworm eggs, although emergence on giant miscanthus was 

reduced compared to corn in field studies (Spencer and Raghu 2009). 

The Project Sponsors will rely on a tiered approach coupled with adaptive management to 

monitor and manage any potential spread of giant miscanthus. 

Contract Producer Trainings - The Project Sponsors will coordinate biannual 

producer community trainings and resource sessions with local extension and TSPs 

to provide specific training on identification of western corn rootworm incidents. 
MITIGATION AND MONITORING

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 6-11

Equipment Sanitizing – As part of the agreement with the OSIA for quality 

assurance the Project Sponsors have agreed that all equipment will be cleaned to 

ensure that no unintentional release of rhizomes would occur during or after 

transport of live rhizomes. All rhizomes would be contained within bags on pallets for 

shipments that leave a producer’s property destined for any other location.

Monitoring of Buffer Areas by Contract Producers- The first tier will rely on 

individual producers to monitor and report any detections of giant miscanthus spread 

beyond a specified monitoring buffer outside the planted areas. The Project 

Sponsors have indicated that typical fields have an existing buffer of woody 

vegetation or other areas that are not actively planted up to the fence or property 

line, so a monitoring buffer of a minimum width beyond the planted areas with 

maximum buffer width determined by site-specific conditions as determined within 

the Conservation Plan, these buffers will be monitored every other year, at a 

minimum. 

Minimum Setback/Buffer Distance - Although published data on the maximum rate 

of giant miscanthus rhizome spread indicates five cm per year (two inches) may be 

expected, the FSA, in consultation with both NRCS and ARS, have elected to 

implement the following setbacks for giant miscanthus with the purpose of the 

setback/buffer being to manage the giant miscanthus stand to prevent unintentional 

spread. The contract producer would follow all local, State, and/or Federal 

regulations for containment of biomass plantings in existence at the time of the 

development of the producer’s Conservation Plan or through an amendment of the 

Conservation Plan initiated by the producer and approved by FSA and NRCS, if 

determined appropriate for the site-specific conditions. If no such guidance exists, 

minimum procedures to prevent unintentional spread of giant miscanthus shall 

include:

o Establish or maintain a minimum 25 feet of setback/buffer around a giant 

miscanthus stand, unless the field is adjacent to existing cropland or actively 

managed pasture with the same producer.

o Setback/buffer areas may be planted to an annual row crop such as corn or 

soybeans; may be planted to a site-adapted, perennial cool-season or warm 

season forage or turf grass; may be kept in existing vegetation, or kept clear 

by disking, rotovating, or treating with a non-selective burn down herbicide at 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 6-12

least once a year. The method used may be dependent on slope and the 

potential for erosion.

Action if Unintentionally Spread is Identified - In the event that giant miscanthus

is detected within the field monitoring buffer, each enrolled producer will be 

contractually obligated to report this to the Project Sponsors, along with their plans 

for control and eradication. In the event the producer is unable or unwilling to 

implement control efforts, a second tier will be followed, whereby the Project

Sponsors assume responsibility for applying chemical control on the producer’s 

acres enrolled under BCAP and will subsequently deduct the associated cost from 

the producer’s yield payment as described in the producer’s enrollment contract. All 

chemical treatment applications would be applied during proper environmental 

conditions under the supervision of a licensed or trained pesticide applicator

consistent with Federal and State guidelines. 

Contract Producer Annual Report and Project Area Annual Reporting –

Beginning in year two after the first monitoring cycle is complete, annual monitoring 

reports will include the number of producers where potential giant miscanthus

spreads were documented, the distance detected from areas planted, years since 

planting, and any additional structured data determined appropriate by ARS as 

continual monitoring occurs. FSA, NRCS, ARS, and the Project Sponsors will 

evaluate data on the potential spread of giant miscanthus and determine whether 

additional adaptive monitoring and management is required to mitigate potential 

environmental impacts. 

Long-Term Eradication Strategy - At the end of the project contract or at the 

termination of the contract between the producer and the Project Sponsors, the 

producer contracts would allow for either party, the producer or Project Sponsors, to 

eradicate giant miscanthus within the contracted acres at the termination of the 

contract.

To address potential crop pest and disease outbreaks such as the western corn rootworm, 

an IPM Plan will be developed as part of each producer’s Conservation Plan. The biannual 

producer community meetings will include updates on any new or emerging pests or 

diseases to assist in early detection and reporting for effective treatment. The IPM Plan will 

also follow a tiered approach, similar to that described above for detection of potential 

vegetative spread. 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 6-13

Monitoring of Buffer Areas by Contract Producers - In the first tier, producers will 

be required to annually survey their fields for potential pest and disease outbreaks. 

Contract Producer Treatment of Pest and Diseases - In the event that pests or 

diseases are detected, the producer will be contractually obligated to notify the 

Project Sponsors and to treat or control the pest or disease on the producer’s acres 

enrolled under BCAP. 

Project Sponsors Treatment of Pest and Diseases - In the event that the producer 

is unable or unwilling to control and treat the pest or disease, the second tier 

approach will be for the Project Sponsors to assume responsibility to treat the 

affected producer’s acres enrolled under the BCAP program and to deduct any costs 

from the producer’s yield payment that will be described in the producer’s contract. 

Courtesy notification of immediately adjacent land owners would also be required. 

All chemical treatment applications would be applied during proper environmental 

conditions under the supervision of a licensed or trained pesticide applicator 

consistent with Federal and State guidelines. 

6.3.5.2 Wildlife

Potential impacts on wildlife and biodiversity may include habitat loss associated with 

conversion of lands currently idle, in pasture, or in hay, to giant miscanthus; reduced winter 

cover and food supplies on lands currently enrolled in row crops; impacts on nesting 

grassland bird populations; and additional habitat fragmentation in areas where field sizes 

are larger and more contiguous. Potential impacts due to habitat loss are expected to be 

mitigated using similar measures as described above to assess land use change to track 

and document the current status of any land converted to giant miscanthus under BCAP. 

The relatively low residual height left after harvesting giant miscanthus may reduce winter 

cover and affect nesting conditions for grassland birds such as northern bobwhites (Colinus 

virginianus), eastern meadowlarks (Sturnella magna), and grasshopper sparrows 

(Ammodramus savannarum). Finally, conversion of larger areas dominated by a single land 

use type (i.e., idle land, pastureland, or hayland) may have proportionally larger impacts on 

habitat fragmentation in project areas. 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 6-14

Monitoring of Buffer Areas and Fields by Contract Producers - Mitigation 

measures will primarily focus on monitoring the conversion of winter cover and food 

sources for wildlife as a result of reduced residual or crop stubble height after 

harvest. 

Contract Producer Annual Report and Project Area Annual Reporting – As part 

of the enrollment process, individual producers will be asked to report any incidental 

data (e.g., casual observation, hunting data, or supplemental feeding data) or 

existing systematic data (i.e., agency counts or surveys) on wildlife winter cover and 

food use. Annual reporting will include the incidental or existing systematic data on 

wildlife use of winter cover or food use from any of the same data sources along with 

reported residual and stubble height on each field after harvest. In the event that 

unexpected significant changes in wildlife winter cover or winter food sources are 

detected, FSA will work with NRCS and the Project Sponsors and appropriate State 

fish and wildlife agencies to determine additional agreed upon mitigation measures 

to offset potentially significant impacts and how to monitor those agreed upon 

measures.

6.3.5.3 Protected Species

Potential impacts on protected species, such as Federally threatened or endangered 

species are possible in those areas where Critical Habitat has been designated, suitable 

habitat exists within the documented range of the species, or known records have been 

documented. Additionally, state-listed, protected, or tribal-listed species will be analyzed for 

potential impacts, as well. Compliance with existing regulations, including the Endangered 

Species Act, will be accomplished with the assistance of NRCS through the Environmental 

Screening worksheet and subsequent resource agency consultation, if deemed necessary, 

with FSA being the lead agency. 

Contract Producer Conservation Plans - Mitigation measures will follow a tiered 

structure whereby individual producers who enroll land in close proximity to sensitive 

habitat such as streams, wetlands, or riparian zones are required to implement 

additional BMPs and/or NRCS CPS as part of their Conservation Plan and potentially 

work with FSA to complete appropriate resource agency consultations, if necessary. 

Such a tiered approach is expected to be used throughout the monitoring program to 

ensure additional measures are taken when sensitive resources are present or in 

close proximity. Potential examples of BMPs for these areas would include buffers 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 6-15

to maintain specific planting distances, conservation buffer strips or plantings, silt 

fencing or other erosion control measures, potential application of no-till 

establishment methods to address sedimentation impacts, and use of appropriately 

labeled herbicides and/or pesticides to protect aquatic or other sensitive species.

6.3.6 Soil Resources

Potential impacts on soil resources may include soil erosion and loss as a result of field 

preparation and planting in giant miscanthus. Compared to land currently in traditional row 

crops, potential soil erosion and loss is expected to be temporary and short-term, primarily 

associated with the establishment phase compared to more intensive annually tilled crops. 

Compared to land currently idle or in pasture or hay, potential soil erosion and loss may be 

slightly higher but still temporary and short-term associated with establishment. Regardless 

of current land use, long-term benefits of soil retention with established rhizomes and 

carbon soil sequestration towards the middle of the 15-year maintenance period on enrolled 

fields are expected to off-set temporary and short-term increases in soil erosion and loss 

that may also be associated with reduced carbon sequestration. 

Mitigation will include a tiered structure that uses BMPs associated with no-till planting 

methods for proposed project areas in close proximity to sensitive habitats such as streams, 

wetlands, or other water bodies. 

Contract Producer Conservation Plans - Specific mitigation requirements will be 

developed for each producer and included in the producer’s Conservation Plan in 

conjunction with BMPs and/or existing NRCS CPS, applicable to the individual site. 

It is expected that mitigation will be consistent with the BMPS and/or NRCS CPS on 

management of soil erosion, including the guidelines on management within high 

concentration flow areas and HEL. 

Contract Producer Annual Report and Project Area Annual Reporting – The 

Project Sponsors will collect information regarding the BMPs and/or NRCS CPS that 

are being applied by each producer and will include that information in annual 

reports. 

Adaptive monitoring and management is expected to be used to track the effectiveness of 

carbon sequestration over the life of a given giant miscanthus planting (i.e., up to 15 years). 

In addition, the Project Sponsors anticipate selling carbon credits, or similar type credits, 

from the sequestration benefits in markets such as the European Exchange, which will 
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FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 6-16

require independent, third-party verification and data collection for verification. The Project 

Sponsors have designed the project for the purpose of abating emissions of GHG to the 

greatest extent possible. As such, the Project Sponsors have commissioned a GHG 

emission reduction feasibility study to establish technical viability, environmental integrity, 

and optimal registration path for offset development. This process is meant to ensure 

adherence to internationally accepted norms for project based GHG accounting, including 

comprehensive Project Design Documentation (PDD) and third party validation/verification 

procedures, as set out by the World Resources Institute (WRI) GHG Accounting Protocol, 

International Standards Organization (ISO) 14064, Intergovernmental Panel on Climate 

Change (IPCC) Guidelines for GHG Inventories, IPCC Good Practice Guidance for Land 

Use, Land-Use Change and Forestry, and precedents under approved United National 

Framework Convention on Climate Change (UNFCCC) Clean Development Mechanism 

(CDM) modalities and methodologies. As a result, the GHG reduction associated with the 

proposed project will inherently take into account vital programmatic considerations such as 

baseline emissions, implementation management, and planned monitoring of the program 

over their entire crediting periods. Data collected for verification will be provided to FSA, 

and other appropriate USDA agencies, such as ARS and NRCS, as needed, as part of 

annual reporting as soon as it begins and is available.

6.3.7 Water Quality and Quantity

6.3.7.1 Water Quality

Potential impacts on water quality include short-term and temporary increases in nutrient 

and fertilizer runoff during establishment and monitoring. Compared to land currently in 

traditional row crops, conversion to giant miscanthus is expected to result in less nutrient 

and fertilizer runoff. Compared to land currently idle or in pasture or hay, conversion to giant 

miscanthus may result in slight but short-term and temporary increases in nutrient and 

fertilizer runoff. In general, fertilizer application is only recommended starting in year three 

and only on an as-needed basis until the maintenance period begins, so the potential 

temporary increase is further expected to be reduced compared to annual inputs to 

traditional crops. However, long-term declines in nutrient loss (i.e., phosphorus and 

nitrogen) during the maintenance period (years three to 15) are likely to off-set temporary 

and short-term increases in nutrient leaching or runoff. The anticipated fertilizer application 

rate is also expected to be substantially lower compared to traditional row crops, but may be 

higher than idle or pasture or hay land. 
MITIGATION AND MONITORING

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 6-17

Contract Producer Conservation Plans - Potential impacts to water quality will be 

mitigated through the development of the Conservation Plans for each producer 

based on existing BMPs and/or NRCS CPS or newer variants that may be developed 

specifically for BCAP, as adopted by FSA. The less frequent application of fertilizer 

compared to traditional crops will further reduce potential impacts on water quality 

due to runoff. 

Contract Producer Trainings - The Project Sponsors will include training and 

resources on soil testing and fertilizer amendments to minimize unnecessary 

additions during their biannual producer community meetings. 

Contract Producer Annual Report and Project Area Annual Reporting – Annual 

reporting will include the rate, type, frequency, and cost of fertilizer application on a 

per acre basis for each field enrolled. In the event that FSA determines potential 

water quality impacts are not being appropriately mitigated, FSA and the Project 

Sponsors will work with the producer cooperatives to provide further training to 

implement BMPs to minimize unnecessary inputs.

6.3.7.2 Water Quantity

Potential impacts on water quantity may arise from surface or groundwater supply depletion 

if giant miscanthus increases the amount of water withdrawal relative to current land uses 

(traditional row crops or idle, pasture, or hayland). Giant miscanthus is expected to be able 

to attain all the required water for the growing season from within the rooting zone of the 

plant and will not require irrigation at any time except this first program year. This first 

program year requires irrigation due to the late planting of the rhizomes. In this first program 

year, all planted fields would be fields normally irrigated to grow other crops according to the 

Project Sponsors and is part of their criteria for acceptance in this initial year. No increase in 

the volume of water used to irrigate fields is anticipated. In the following years, no irrigation 

will occur. After the first year, giant miscanthus plantings should have either no change to 

the amount irrigated acres in the project areas or result in a net reduction in irrigated acres 

within the project areas; thereby, reducing irrigation water demand, since the plantation 

acres would not be irrigated for giant miscanthus. In the Paragould proposed project area, a 

net reduction in water withdrawal will be particularly important to mitigate existing aquifer 

depletion associated with unsustainable farming practices by traditional row crops (e.g., rice, 

corn, and beans) by providing an economically viable alternative. 
MITIGATION AND MONITORING

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 6-18

Contract Producer Conservation Plans - Mitigation will include BMPs and/or

existing NRCS CPS that minimize water use and will be incorporated into each 

producer’s Conservation Plan. 

Contract Producer Annual Report and Project Area Annual Reporting – Annual 

reporting will include the total number of producers enrolled in each project area, the 

BMPs or existing NRCS CPS utilized, and their average and total yield per field 

enrolled. 
REFERENCES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 7-1

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PREPARERS

FINAL - 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
PREPARERS

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

Name Organization Experience Project Role

Heather Smith ENVIRON 4 years GIS support

B.S. Natural Resource 

Management, Grand Valley 

State University, 2007

Domoni Glass ENVIRON 30 years Mitigation and 

Monitoring Plan, 

Project Review Graduate Studies, Natural 

Resources Management, 

University of Washington

B.S. Fisheries, University of 

Washington, 1982

Laura Moran ENVIRON 24 years Mitigation and 

Monitoring Plan

BSLA/MUP, City University of 

New York, 1987-1988

B.S. Biology, St. Lawrence 

University, 1985

Scott Coye-Huhn Aloterra Energy 

LLC

16 years Project Sponsor, 

Mitigation and 

Monitoring Plan, 

Environmental 

Consequences 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
PREPARERS

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 8-3

Name Organization Experience Project Role

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
PREPARERS

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 8-4

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PERSONS AND AGENCIES CONTACTED

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 9-1

9 PERSONS AND AGENCIES CONTACTED 

9.1 TRIBAL CONSULTATION

This section has been added to the Final EA after reviewing comments received on the Draft 

EA concerning Tribal Consultation. FSA is committed to government-to-government 

consultation. FSA conducts these consultations in a regular and meaningful way that takes 

into account the comments and concerns of American Indian Tribal governments. 

As part of this FSA’s commitment and as required by EO 13175 “Consultation and 

Coordination with Indian Tribal Governments,“ FSA conducted two formal consultations 

with Tribal governments on BCAP prior to the publication of the final rule. Both of the Tribal

consultations were conducted through teleconferences. All Federally recognized Tribes 

were invited to the first consultation, which was held on July 21, 2010. The Forest County 

Potawatomi Community requested a separate government-to-government consultation on 

BCAP, which was held on July 22, 2010. All comments from the government-to-government 

Tribal consultations were addressed in the final rule.

This proposed BCAP project is an action that does not have a “substantial direct effect on 

one or more Indian tribe” (Sec.1 (a) EO 13175). As such, no separate government-togovernment consultations were deemed necessary for this project. The proposed locations 

that were analyzed in this Final EA do not encompass any Tribal lands as defined under 36 

CFR 800.16(x). 

Tribal members may own private lands which would be within the project area of this BCAP 

project and thus may be eligible to apply. These applicants would have the same rights and 

eligibility requirements as any private lands applicant.

Tribal consultation is required for any proposed federal action that may significantly affect 

the human environment according to NEPA Implementing Regulations (40 CFR Part 1500). 

EO 13175, Consultation and Coordination with Indian Tribal Governments, further described 

the obligation of federal agencies to coordinate and consult with federally recognized tribes 

for any proposed federal action that may affect significant cultural or historic resources to 

that tribe. The USDA released a department-wide Action Plan for Tribal Coordination and 

Consultation on February 3, 2010 in response to a memorandum from President Obama on 

November 5, 2009 that required effective tribal consultation in carrying out federal actions 

(USDA 2010). Agency-specific guidance has also been developed by the NRCS within 

USDA that provides the FSA with technical assistance in relation to environmental 
PERSONS AND AGENCIES CONTACTED

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

compliance at the field or contract level on a state basis including tribal consultation (NRCS 

2009). 

Tribal consultation was initiated by FSA as part of the Final BCAP PEIS using a variety of 

teleconferences or follow up individual teleconferences if requested by individual tribes. 

FSA also initiated tribal consultation with three tribes based on the Final BCAP PEIS 

process, which included the Sac and Fox Nation of Oklahoma, Osage Nation of Oklahoma, 

and the Seneca Nation of New York. Each of these three tribes was provided with a copy of 

this Draft EA and invited to comment during the public comment period that opened on April 

8, 2011 with the publication of the Draft EA in the Federal Register. 

The Project Sponsors also completed additional desktop reviews to support the Draft EA 

including a review of publicly available information on Indian lands, the Bureau of Indian 

Affairs (BIA) list of federally recognized tribes and their affiliations, and State Historic 

Preservation Office (SHPO) web sites for the four states within the proposed project areas. 

Based on a review of National Atlas data, there are no Indian reservations or Indian lands in 

any of the four states that include the proposed project areas (National Atlas 2011). Based 

on a review of the BIA list of federally recognized tribes by state that was last updated on 

October 1, 2010, there are no federally recognized tribes currently living in any of the four 

states that include the proposed project areas (BIA 2010). A review of the SHPO web sites 

for additional tribal information provided no additional data for Missouri, Ohio, and 

Pennsylvania, but the Arkansas Historic Preservation Program (AHPP) provided a list of 20 

tribes that were historically associated with land in that state (AHPP 2011). The Osage 

Nation of Oklahoma, which is one of the three tribes that FSA provided a Draft EA to as part 

of further consultation, is also on the list of tribes with historical connections to Arkansas. 

Any specific tribal concerns raised during the public comment period on the Draft EA will be 

further incorporated into the development of conservation plans to avoid and minimize such 

impacts as part of the overall environmental compliance program that NRCS will assist FSA 

with implementing for BCAP enrollees. 
PERSONS AND AGENCIES CONTACTED

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 9-3

9.2 AGENCIES AND PERSONS CONTACTED

Name Organization/Agency

Responsible Agency Officials

Juan M. Garcia Acting Deputy Administrator for Farm Programs, U.S. 

Department of Agriculture, Farm Service 

Agency, Washington D.C.

Martin Lowenfish Associate Director, U.S. Department of Agriculture, Farm 

Service Agency, Conservation and Environmental 

Programs Division, Washington D.C.

Matthew T. Ponish National Environmental Compliance Manager , U.S. 

Department of Agriculture, Farm Service Agency, 

Washington D.C.

Todd Atkinson Senior Policy Advisor, U.S. Department of Agriculture, 

Farm Service Agency, 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

Diane E. Gelbund, PhD, Special Assistant to the 

Chief for Strategic Natural Resource Issues

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
PERSONS AND AGENCIES CONTACTED

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 9-4

Name Organization/Agency

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

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 
PERSONS AND AGENCIES CONTACTED

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 9-5

Name Organization/Agency

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

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

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 9-6

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APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

APPENDICES
APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

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APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

APPENDIX A – State-listed Species that Could Potentially Occur within the 

Proposed Project Areas
APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

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APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

Category Species- Common Name (Scientific name) T/E Counties

Columbia

Bird Greater Prairie-chicken (Tympanuchus cupido) SE Cooper, Moniteau, Audrain, Monroe

Mammal

Black-tailed Jackrabbit (Lepus californicus) SE Moniteau

Gray Bat (Myotis grisescens) SE Cole, Boone, Calloway, Howard

Indiana Bat (Myotis sodalis) SE Boone, Randolph, Audrain, Monroe

Mussel

Ebonyshell (Fusconaia ebena) SE Cole

Elephantear (Elliptio crassidens) SE Cole, Cooper

Fish

Flathead Chub (Platygobio gracilis) SE Cole, Boone, Calloway, Cooper, Howard, Moniteau

Lake Sturgeon (Acipenser fulvescens) SE Cole, Boone, Calloway, Cooper, Howard, Moniteau

Pallid Sturgeon (Scaphirhynchus albus) SE Cole, Boone, Calloway, Cooper, Howard, Moniteau

Pink Mucket (Lampsilis abrupta) SE Cole

Topeka Shiner (Notropis topeka) SE Boone, Calloway, Moniteau

Plant Running Buffalo Clover (Trifolium stoloniferum) SE Boone, Calloway

Aurora

Bird

American Bittern (Botaurus lentiginosus) SE Jasper

Bachman's Sparrow (Aimophila aestivalis) SE Barry

Greater Prairie-chicken (Tympanuchus cupido) SE Lawrence, Dade, Jasper, Newton

Northern Harrier (Circus cyaneus) SE Dade, Jasper, Newton

Fish

Ozark Cavefish (Amblyopsis rosae) SE Barry, Lawrence, Stone< Newton

Redfin Darter (Etheostoma whipplei) SE Lawrence, Jasper

Neosho Madtom (Noturus placidus) SE Jasper

Mammal

Black-tailed Jackrabbit (Lepus californicus) SE

Barry, Lawrence, Dade, Christian, Stone, Jasper, 

Newton

Gray Bat (Myotis grisescens) SE

Barry, Lawrence, Dade, Christian, Stone, Jasper, 

Newton

Plains Spotted Skunk (Spilogale putorius interrupta) SE Christian

Plant

Geocarpon (Geocarpon minimum) SE Lawrence, Dade

Running Buffalo Clover (Trifolium stoloniferum) SE Barry

Missouri Bladder-pod (Physaria filiformis) SE Lawrence, Dade, Christian

Mead's Milkweed (Asclepias meadii) SE Dade

Elephant ear (Elliptio crassidens) SE Stone

Reptile Yellow Mud Turtle (Kinosternon flavescens) SE Barry

Paragould

Plant

Caric sedge (Carex opaca) SE Poinsett

Rose turtlehead (Chelone obliqua var. Speciosa) SE Greene

Pondberry (Lindera melissifolia ) SE Craighead, Jackson, Lawrence, Poinsett

Bigleaf magnolia (Magnolia macrophylla) SE Clay, Mississippi 

Prairie evening primrose (Oenothera pilosella ssp. 

Sessilis) ST Clay

Heartleaf plantain (Plantago cordata ) ST Randolph
APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

Category Species- Common Name (Scientific name) T/E Counties

Northern tubercled-orchid (Platanthera flava var. 

Herbiola) ST Clay

Purple fringeless-orchid (Platanthera peramoena) ST Clay

Purple fringeless-orchid (Platanthera peramoena) ST Craighead, Lawrence

Ashtabula

Bird

American Bittern (Botaurus lentiginosus) SE Erie, Crawford, Mercer

Bald Eagle (Haliaeetus leucocephalus) ST

Ashtabula, Lake, Geauga, Trumbull, Erie, Crawford, 

Mercer

Barn Owl (Tyto alba) ST Ashtabula, Geauga

Black Tern (Chlidonias niger) SE Erie, Crawford

Common Tern (Sterna hirundo) SE Erie

Dickcissel (Spiza americana) SE Erie, Mercer

King Rail (Rallus elegans) SE Crawford, Mercer

Least Bittern (Ixobrychus exilis) ST Lake, Trumbull, Erie, Crawford, Mercer

Least Shrew (Cryptotis parva) SE Crawford, Mercer

Migrant Loggerhead Shrike (Lanius ludovicianus 

migrans) SE Erie, Crawford, Mercer

Northern Harrier (Circus cyaneus) SE Ashtabula, Trumbull

Osprey (Pandion haliaetus) ST Crawford, Mercer

Peregrine Falcon (Falco peregrinus) ST Lake

Sedge Wren (Cistothorus platensis) SE Erie, Crawford, Mercer

Short-eared Owl (Asio flammeus) SE Crawford

Upland Sandpiper (Bartramia longicauda) ST

Ashtabula, Lake, Geauga, Trumbull, Erie, Crawford, 

Mercer

Yellow-bellied Sapsucker (Sphyrapicus varius) SE Ashtabula, Geauga

Fish

Bigmouth Shiner (Notropis dorsalis) ST Crawford

Black Bullhead (Ameiurus melas) SE Mercer

Blackchin Shiner (Notropis heterodon) SE Erie, Crawford

Bluebreast Darter (Etheostoma camurum) ST Erie, Crawford, Mercer

Brindled Madtom (Noturus miurus) ST Erie, Crawford, Mercer

Brook Trout (Salvelinus fontinalis) ST Geauga

Burbot (Lota lota) SE Erie

Cisco (Coregonus artedi) SE Erie

Eastern Sand Darter (Etheostoma pellucida) SE Erie, Crawford

Gilt Darter (Percina evides) ST Erie, Crawford

Iowa Darter (Etheostoma exile) SE Erie

Lake Chubsucker (Erimyzon sucetta) ST Geauga

Lake Sturgeon (Acipenser fulvescens) SE Erie

Longear Sunfish (Lepomis megalotis) SE Mercer

Mountain Brook Lamprey (Ichthyomyzon greeleyi) ST Erie, Crawford, Trumbull

Narrow-leaved Pondweed (Potamogeton strictifolius) SE Erie
APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

Category Species- Common Name (Scientific name) T/E Counties

Northern Brook Lamprey (Ichthyomyzon fossor ) SE Ashtabula, Lake, Trumbull, Erie, Crawford

Northern Madtom (Noturus stigmosus) SE Erie, Crawford, Mercer

Northern Redbelly Dace (Phoxinus eos) SE Erie

Pugnose Minnow (Opsopoeodus emiliae) SE Lake

Redfin Shiner (Lythrurus umbratilis) SE Erie, Crawford, Mercer

Southern Redbelly Dace (Phoxinus erythrogaster) ST Crawford, Mercer

Spotted Darter (Etheostoma maculatum) ST Erie, Crawford, Mercer

Spotted Gar (Lepisosteus oculatus) SE Erie

Spotted Sucker (Minytrema melanops) ST Crawford

Tadpole Madtom (Noturus gyrinus) SE Erie, Crawford

Tippecanoe Darter (Etheostoma tippecanoe) ST Erie, Crawford, Mercer

Mountain Madtom (Noturus eleutherus) SE Erie, Crawford, Mercer

Warmouth (Chaenobryttus gulosus) SE Erie, Crawford, Mercer

Insect

A Burrowing Mayfly (Litobrancha recurvata ) SE Geauga

A Caddisfly (Chimarra socia) SE Ashtabula, Lake

A Caddisfly (Psilotreta indecisa) ST Lake, Geauga, Trumbull

A Midge (Rheopelopia acra) SE Ashtabula, Lake

Boreal Bluet (Enallagma boreale) ST Lake, Geauga

Brush-tipped emerald (Somatochlora walshii) SE Ashtabula

Bug-on-a-stick (Buxbaumia aphylla) ST Ashtabula, Trumbull

Chalk-fronted Corporal (Ladona julia) SE Ashtabula

Graceful Underwing (Catocala gracilis) SE Ashtabula, Trumbull

Green-faced Clubtail (Gomphus viridifrons) ST Ashtabula, Lake

Harlequin Darner (Gomphaeschna furcillata) ST Geauga

Marsh Bluet (Enallagma ebrium) ST Ashtabula, Lake, Geauga

Northern Bluet (Enallagma cyathigerum) ST Lake, Geauga

River Jewelwing (Calopteryx aequabilis) SE Geauga

Tiger Beetle (Cicindela hirticollis) ST Ashtabula

Uhler's Sundragon (Helocordulia uhleri) SE Lake

Mammal

Black Bear (Ursus americanus) SE Ashtabula

Bobcat (Felis rufus) SE Ashtabula, Lake

Mussel

Black Sandshell (Ligumia recta) ST Ashtabula, Lake, Trumbull

Clubshell (Pleurobema clava) SE Erie, Crawford, Mercer

Eastern Pondmussel (Ligumia nasuta) SE Ashtabula, Geauga

Fawnsfoot (Truncilla donaciformis) ST Lake

Northern Riffleshell (Epioblasma torulosa rangiana) SE Erie, Crawford, Mercer

Rabbitsfoot (Quadrula cylindrica) SE Erie, Crawford, Mercer

Salamander Mussel (Simpsonaias ambigua) SE Crawford

Snuffbox (Epioblasma triquetra) SE Ashtabula, Lake, Erie, Crawford, Mercer

Plant American Reed Grass (Phragmites australis) ST Lake
APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

Category Species- Common Name (Scientific name) T/E Counties

Pasture Blue Grass (Poa saltuensis) SE Geauga

Yellow Lady's-slipper (Cypripedium parviflorum) SE Geauga

A Sedge (Carex tetanica) ST Crawford, Mercer

American Beach Grass (Ammophila breviligulata ) ST Ashtabula, Lake

American Beachgrass (Ammophila breviligulata) ST Erie

American Columbo (Swertia caroliniensis) SE Mercer

American Emerald (Cordulia shurtleffii) SE Geauga

American Water-milfoil (Myriophyllum sibiricum) ST Ashtabula, Geauga

Appalachian Blue Violet (Viola appalachiensis) ST Erie, Crawford, Mercer

Appalachian Quillwort (Isoetes engelmannii) SE Trumbull

Aster-like Boltonia (Boltonia asteroides) SE Erie

Autumn Willow (Salix serissima) ST Erie, Crawford, Mercer

Awned Sedge (Carex atherodes) SE Erie

Backward Sedge (Carex retrorsa) SE Erie

Balsam Poplar (Populus balsamifera) SE Ashtabula, Geauga, Erie

Baltic Rush (Juncus arcticus var. littoralis) ST Erie

Beach Peavine (Lathyrus japonicus) ST Erie, Crawford

Beach Wormwood (Artemisia campestris ssp. caudata) SE Erie

Bearded Wheat Grass (Elymus trachycaulus ) ST Ashtabula, Geauga

Bebb's Sedge (Carex bebbii) SE Erie, Crawford

Beck's Water-marigold (Megalodonta beckii) SE Erie, Crawford

Bicknell's Crane's-bill (Geranium bicknellii) SE Ashtabula

Bluebead-lily (Clintonia borealis) SE Ashtabula

Bog Bedstraw (Galium labradoricum) ST Geauga

Bog Bluegrass (Poa paludigena) ST Crawford, Mercer

Bog Willow (Salix pedicellaris) SE Geauga

Branching Bur-reed (Sparganium androcladum) SE Erie, Mercer

Bristly Sarsaparilla (Aralia hispida) SE Lake, Geauga

Bristly Smartweed (Persicaria setacea) SE Ashtabula, Geauga

Broad-leaved Water-milfoil (Myriophyllum 

heterophyllum) SE Erie

Broad-winged Sedge (Carex alata) ST Erie, Crawford

Brook Lobelia (Lobelia kalmii) SE Erie

Brownish Sedge (Carex brunnescens) SE Ashtabula, Geauga

Bunchberry (Cornus canadensis) SE Ashtabula, Geauga

Bushy Aster (Symphyotrichum dumosum) ST Ashtabula

Bushy Cinquefoil (Potentilla paradoxa) ST Ashtabula, Lake, Erie

Bushy Naiad (Najas gracillima) ST Erie, Mercer

Canada Buffalo-berry (Shepherdia canadensis) SE Erie

Canada Hawkweed (Hieracium umbellatum) ST Ashtabula, Lake
APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

Category Species- Common Name (Scientific name) T/E Counties

Canada St. John's-wort (Hypericum canadense ) SE Ashtabula, Lake

Capillary Beaked-rush (Rhynchospora capillacea) SE Erie

Capitate Spike-rush (Eleocharis caribaea) SE Erie

Carey's Smartweed (Polygonum careyi) SE Erie

Carolina Grass-of-parnassus (Parnassia glauca) SE Erie

Cattail Sedge (Carex typhina) SE Crawford, Mercer

Clinton's Wood Fern (Dryopteris clintoniana ) SE Ashtabula

Cluster Fescue (Festuca paradoxa) SE Erie

Coarse Smartweed (Persicaria robustior) ST Ashtabula, Lake, Geauga, Trumbull

Coastal Little Bluestem (Schizachyrium littorale ) SE Ashtabula, Lake

Common Hemicarpa (Lipocarpha micrantha) SE Erie

Common Hop-tree (Ptelea trifoliata) ST Erie

Commons' Panic Grass (Panicum commonsianum ) SE Ashtabula

Cooper's Milk-vetch (Astragalus neglectus) SE Lake, Geauga

Cow-wheat (Melampyrum lineare) ST Ashtabula, Lake, Geauga

Cranesbill (Geranium bicknellii) SE Erie

Crepis Rattlesnake-root (Prenanthes crepidinea) SE Mercer

Cuckooflower (Cardamine pratensis var. palustris) SE Erie, Crawford

Cyperus-like Sedge (Carex pseudocyperus) SE Erie, Crawford

Dark-eyed Junco (Junco hyemalis) ST Lake, Geauga

Downy Willow-herb (Epilobium strictum) SE Erie, Crawford, Mercer

Drooping Wood Sedge (Carex arctata ) SE Geauga

Dwarf Bulrush (Lipocarpha micrantha) ST Lake

Early Buttercup (Ranunculus fascicularis) ST Lake

Early Coral-root (Corallorhiza trifida) SE Ashtabula, Geauga

Ebony Sedge (Carex eburnea) SE Erie

Elephant-ear (Elliptio crassidens) SE Ashtabula

Elk Sedge (Carex garberi) SE Erie

Few-flowered Spike-rush (Eleocharis pauciflora var. 

fernaldii) SE Erie

Few-flowered St. John's-wort (Hypericum ellipticum ) ST Ashtabula, Lake

Few-seeded Sedge (Carex oligosperma) ST Mercer

Fireweed (Epilobium angustifolium) SE Ashtabula, Geauga

Flat-leaved Bladderwort (Utricularia intermedia) ST Erie, Crawford

Flat-stemmed Pondweed (Potamogeton zosteriformis) ST Lake, Geauga

Flat-stemmed Spike-rush (Eleocharis compressa) SE Crawford

Four-angled Spike-rush (Eleocharis quadrangulata) SE Erie, Mercer

Fries' Pondweed (Potamogeton friesii) SE Erie, Crawford

Fuzzy Hypnum Moss (Tomentypnum nitens ) SE Geauga

Golden-fruited Sedge (Carex aurea) SE Erie
APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

Category Species- Common Name (Scientific name) T/E Counties

Grass-pink (Calopogon tuberosus) ST Geauga

Grassy Pondweed (Potamogeton gramineus) SE Erie, Crawford, Mercer

Green Sedge (Carex viridula) SE Erie

Green Spike-rush (Eleocharis flavescens) ST Geauga

Ground Juniper (Juniperus communis) SE Geauga

Harbinger-of-spring (Erigenia bulbosa) ST Erie, Crawford

Hard-stemmed Bulrush (Schoenoplectus acutus) SE Erie, Crawford

Hemlock-parsley (Conioselinum chinense) SE Crawford

Hermit Thrush (Catharus guttatus) ST Lake

Hill's Pondweed (Potamogeton hillii) SE Ashtabula, Geauga, Erie, Crawford

Hispid Gromwell (Lithospermum caroliniense) SE Erie, Mercer

Hoary Willow (Salix candida) ST Erie

Hobblebush (Viburnum alnifolium) ST Ashtabula, Lake, Geauga, Trumbull

Hooded Ladies'-tresses (Spiranthes romanzoffiana) SE Ashtabula, Geauga, Erie, Crawford

Houghton's Flatsedge (Cyperus houghtonii) SE Crawford

Inland Beach Pea (Lathyrus japonicus ) ST Ashtabula, Lake

Keeled Bur-reed (Sparganium androcladum) ST Ashtabula, Lake

Labrador Marsh Bedstraw (Galium labradoricum) SE Erie, Crawford

Large-leaved Mountain-rice (Oryzopsis asperifolia) ST Ashtabula, Lake

Larger Canadian St. John's-wort (Hypericum majus) ST Erie

Leafy Goldenrod (Solidago squarrosa) ST Ashtabula, Lake, Geauga

Leafy White Orchid (Platanthera dilatata) SE Erie, Crawford

Least Spike-rush (Eleocharis parvula) SE Lake

Leathery Grape Fern (Botrychium multifidum ) SE Ashtabula

Lesser Bladderwort (Utricularia minor) ST Geauga

Lesser Panicled Sedge (Carex diandra ) ST Ashtabula, Geauga, Erie, Crawford, Mercer

Little-spike Spike-rush (Eleocharis parvula) SE Erie

Log Fern (Dryopteris celsa) SE Lake

Long-fruited Anemone (Anemone cylindrica) SE Erie

Long-lobed Arrow-head (Sagittaria calycina var. 

spongiosa) SE Erie

Louisiana Sedge (Carex louisianica) SE Ashtabula

Lyre-leaved Rock Cress (Arabis lyrata ) SE Lake

Marsh Bedstraw (Galium palustre) SE Ashtabula

Matted Spike-rush (Eleocharis intermedia) ST Erie, Crawford, Mercer

Mitchell's Sedge (Carex mitchelliana) SE Ashtabula, Crawford

Mountain Bindweed (Fallopia cilinodis) SE Lake, Geauga

Mountain Fly Honeysuckle (Lonicera villosa) SE Crawford

Mud Sedge (Carex limosa) SE Geauga

Navelwort (Hydrocotyle umbellata) SE Geauga
APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

Category Species- Common Name (Scientific name) T/E Counties

Necklace Sedge (Carex projecta) ST Ashtabula, Lake, Geauga, Trumbull

Nodding Sedge (Carex gynandra) SE Geauga

Northeastern Sedge (Carex cryptolepis) ST Crawford

Northern Blue-eyed-grass (Sisyrinchium montanum) ST Ashtabula

Northern Poison-ivy (Toxicodendron rydbergii) SE Ashtabula, Lake

Northern Water-milfoil (Myriophyllum sibiricum) SE Erie, Crawford

Northern Water-plantain (Alisma triviale) SE Erie, Crawford, Mercer

One-coned Club-moss (Lycopodium lagopus) SE Geauga

Painted Trillium (Trillium undulatum) SE Ashtabula

Pinxter-flower (Rhododendron periclymenoides) ST Ashtabula

Pipsissewa (Chimaphila umbellata) ST Ashtabula

Pod-grass (Scheuchzeria palustris) SE Erie

Prairie Sedge (Carex prairea) ST Erie, Crawford, Mercer

Primrose-leaved Violet (Viola primulifolia) SE Ashtabula

Purple Sandgrass (Triplasis purpurea) SE Erie

Racemed Milkwort (Polygala polygama) ST Ashtabula

Red Baneberry (Actaea rubra) ST Ashtabula

Red Currant (Ribes triste) ST Erie, Crawford

Red-head Pondweed (Potamogeton richardsonii) ST Erie, Crawford, Mercer

Richardson's Rush (Juncus alpinoarticulatus ssp. 

nodulosus) ST Erie

Riffle snaketail (Ophiogomphus carolus) ST Lake, Geauga

Riverweed (Podostemum ceratophyllum) SE Ashtabula

Robbins' Pondweed (Potamogeton robbinsii) SE Geauga

Robin-run-away (Dalibarda repens) SE Ashtabula, Geauga

Rose Pogonia (Pogonia ophioglossoides) ST Geauga

Rose Twisted-stalk (Streptopus lanceolatus) SE Ashtabula

Round-fruited Hedge-hyssop (Gratiola virginiana) ST Ashtabula

Rush Aster (Symphyotrichum boreale) SE Erie, Crawford

Schweinitz' Umbrella-sedge (Cyperus schweinitzii) ST Ashtabula

Showy Lady's-slipper (Cypripedium reginae) ST Erie, Crawford, Mercer, Geauga

Showy Mountain-ash (Sorbus decora) SE Erie, Crawford

Shumard's Oak (Quercus shumardii) SE Erie, Crawford

Silverweed (Potentilla anserina) ST Erie

Silvery Sedge (Carex argyrantha) ST Lake, Geauga

Simple Willow-herb (Epilobium strictum) ST Geauga, Trumbull

Slender Cotton-grass (Eriophorum gracile) SE Erie

Slender Spike-rush (Eleocharis elliptica) SE Erie, Crawford, Geauga

Slender Willow (Salix petiolaris) ST Ashtabula

Small Bur-reed (Sparganium emersum) SE Geauga
APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

Category Species- Common Name (Scientific name) T/E Counties

Small Cranberry (Vaccinium oxycoccos) ST Geauga

Small Purple Fringed Orchid (Platanthera psycodes) ST Ashtabula, Geauga

Small Sea-side Spurge (Chamaesyce polygonifolia) ST Erie

Small Yellow Lady's-slipper (Cypripedium calceolus 

var. parviflorum) SE Erie, Crawford, Mercer

Small-flowered False-foxglove (Agalinis paupercula) SE Erie, Mercer

Small-headed Rush (Juncus brachycephalus) ST Erie

Smith's Bulrush (Schoenoplectus smithii) SE Erie

Southern Hairy Panic Grass (Panicum meridionale) ST Ashtabula

Spathulate-leaved Sundew (Drosera intermedia) SE Geauga

Speckled Wood-lily (Clintonia umbellulata) ST Trumbull

Spotted Pondweed (Potamogeton pulcher) SE Crawford

Spreading Globeflower (Trollius laxus) SE Ashtabula, Erie

Stalked Bulrush (Scirpus pedicellatus) ST Erie

Sterile Sedge (Carex sterilis) ST Erie, Mercer

Striped Maple (Acer pensylvanicum) SE Ashtabula

Swamp Fly Honeysuckle (Lonicera oblongifolia) SE Erie, Crawford

Swamp Red Currant (Ribes triste ) SE Ashtabula, Geauga

Swamp-pink (Arethusa bulbosa) SE Erie, Crawford

Sweet Bay Magnolia (Magnolia virginiana) ST Mercer

Sweet Flag (Acorus americanus) SE Erie, Crawford

Sweet-fern (Comptonia peregrina) SE Lake

Thin-leaved Cotton-grass (Eriophorum 

viridicarinatum) ST Erie, Crawford, Mercer

Thread-like Naiad (Najas gracillima) SE Lake

Torrey's Bulrush (Schoenoplectus torreyi) SE Erie

Torrey's Rush (Juncus torreyi) ST Erie, Mercer

Triangle Grape Fern (Botrychium lanceolatum ) ST Ashtabula, Geauga

Tuckerman's Panic-grass (Panicum tuckermanii) ST Erie

Tufted Fescue Sedge (Carex brevior ) ST Ashtabula

Twig Rush (Cladium mariscoides) SE Erie, Crawford

Twinflower (Linnaea borealis) ST Erie

Two-leaved Water-milfoil (Myriophyllum 

heterophyllum) SE Ashtabula

Two-seeded Sedge (Carex disperma) SE Ashtabula

Umbrella Flatsedge (Cyperus diandrus) SE Erie

Highbush-cranberry (Viburnum opulus ) SE Ashtabula, Trumbull, Geauga

Variegated Horsetail (Equisetum variegatum) SE Erie

Variegated Scouring-rush (Equisetum variegatum) SE Geauga

Vasey's Pondweed (Potamogeton vaseyi) SE Erie, Crawford

Velvet-leaved Blueberry (Vaccinium myrtilloides) SE Ashtabula, Geauga, Trumbull
APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

Category Species- Common Name (Scientific name) T/E Counties

Vernal Water-starwort (Callitriche verna) ST Ashtabula, Lake Geauga, Trumbull

Walter's Barnyard-grass (Echinochloa walteri) SE Erie

Walter's St. John's-wort (Triadenum walteri ) ST Ashtabula, Trumbull

Water Sedge (Carex aquatilis) ST Erie

Western Mountain-ash (Sorbus decora) SE Ashtabula, Geauga

White Wood-sorrel (Oxalis montana) SE Ashtabula, Lake

White-stemmed Pondweed (Potamogeton praelongus) SE Geauga

Whorled Nutrush (Scleria verticillata) SE Erie

Whorled Water-milfoil (Myriophyllum verticillatum) SE Erie, Crawford

Wild Rice (Zizania aquatica) ST Geauga

Wild-pea (Lathyrus ochroleucus) ST Crawford

Winged Cudweed (Pseudognaphalium macounii) SE Ashtabula, Geauga

Yellow Sedge (Carex flava) ST Erie, Crawford

Yellow Vetchling (Lathyrus ochroleucus) SE Ashtabula, Lake, Trumbull

Reptile

Bog Turtle (Glyptemys muhlenbergii) SE Crawford, Mercer

Eastern Massasauga (Sistrurus catenatus) SE Ashtabula, Trumbull, Crawford, Mercer

Spotted Turtle (Clemmys guttata) ST Ashtabula, Lake, Geauga, Trumbull
APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

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APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

APPENDIX B – Ohio Seed Improvement Association Data Summary for Giant 

Miscanthus
APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

This Page Intentionally Left Blank


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 

DearScott:

Yourstatementbelowiscorrect.Morespecifically,whatIhavedoneistomonitortheflower

unitofOSIA’sM.xgiganteusselectionforpollenandseedproductionbyobservationandmicroscopic

examination.Todateneitherpollenorseedhasbeenproduced.Theextrudedanthersoftheflowerunit

havebeenshriveledinappearanceandsimilartowhatweseewithmalesterileseedcorninbredlines.

Inaddition,Ihaveobservednovolunteerseedlingsemerginginobservationplotareasadjacenttothe

M.xgiganteusselection.

Furthermore,thefollowingtechnicalreferencesprovideadditionalcommentregardingthe

invasiveissue:

1. CASTCommentary,QTA20071,November2007,“BiofuelFeedstocks:TheRiskof

FutureInvasions”,p.5.

2. Lewandowski,I.,J.C.CliftonBrown,J.M.O.Scurlock,andW.Huisman.2000.

Miscanthus:Europeanexperiencewithanovelenergycrop.BiomassBioenergy

19:209227.

Bestregards.

JohnArmstrong,Sec./Mgr.

OhioSeedImprovementAssociation

61650AveryRoadP.O.477

Dublin,Ohio43017

Ph.6148891136

Fax:6148898979

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 

Areyoucomfortablewiththestatementbelow?Theyarebasingthatonyourobservationsinyour3

yearstudy.

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 
APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

APPENDIX C – Comments on the Draft Environmental Assessment
APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

This Page Intentionally Left Blank
Page 1 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

1 1

these agencies preparing a cheap sloppy ea, 

which nepa requires an eis. also this prepartion 

takes more energy to prepare it than you get 

from using miscanthus for energy. this whole 

ccrappy process is political shenanigans and a 

complete boondoggle. stop any tax dollars of 

american citizens from this usda boondoglle. General Against NJ 08822 Individual None

Comment noted, the NEPA process requires an 

appropriate level of environmental review based on 

the Agency's assessment of the potential for 

significant effects. In this instance, the EA was an 

appropriate NEPA-level evaluation to determine if 

effects would be significant and require the 

preparation of an EIS

2 1

I live in Missouri and a native of South Carolina, 

where I have seen this giant miscanthus overtake 

large areas around the Pee Dee, Waccamaw , 

Black Rivers, in the Georgetown Estuary . A Nonnative, it grows like wildfire, and contributes 

nothing to maintain the flora and fauna of the 

area. It sustains only itself, and now you want to 

make it a crop?? That would be truly opening a 

Pandora's box, once you let it loose..... Missouri 

will have giant carp in it rivers, and giant reeds 

growing on its prairie. PLEASE reconsider the 

proposal.

Invasive, 

Non-Native Against MO 63124 Individual None

Comment noted, this EA was site specific to 

proposed project areas within four states. The 

information provided would be utilized if a BCAP 

project area with miscanthus was proposed in South 

Carolina. More than likely the species of concern 

within South Carolina is another cultivar or species 

of Miscanthus

3 1

I am email to support the BCAP Project Area 

application for Columbia, MO. As a farmer, the 

BCAP program creates enough temporary 

economic incentives to move myself and other 

farmers in my region to commit land to dedicated 

energy crops. Our nation has spent decades 

talking about energy independence and setting 

high goals for transitioning our energy supply 

from foreign sources to domestic sources. No 

group or organization in America is more capable 

of providing this necessary energy supply than 

America’s farmers. Critically, Miscanthus is the 

only energy crop that is perennial, non-invasive, 

and provides enough tons per acre to make 

economic sense. Dedicated energy crops are the 

most practical solution to a number of issues 

facing our nation. It provides my family with a 

new cash crop, will ensure economic 

development in rural communities, and will 

provide a home grown, reliable, base load energy 

supply that America desperately needs. General Support Individual None

Comment noted on the support of the proposed 

action. 
Page 2 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

4 1

I am email to support the BCAP Project Area 

application for Columbia, MO. As a farmer, the 

BCAP program creates enough temporary 

economic incentives to move myself and other 

farmers in my region to commit land to dedicated 

energy crops. Our nation has spent decades 

talking about energy independence and setting 

high goals for transitioning our energy supply 

from foreign sources to domestic sources. No 

group or organization in America is more capable 

of providing this necessary energy supply than 

America’s farmers. Critically, Miscanthus is the 

only energy crop that is perennial, non-invasive, 

and provides enough tons per acre to make 

economic sense. Dedicated energy crops are the 

most practical solution to a number of issues 

facing our nation. It provides my family with a 

new cash crop, will ensure economic 

development in rural communities, and will 

provide a home grown, reliable, base load energy 

supply that America desperately needs. General Support MO 64850 Individual None

Comment noted on the support of the proposed 

action. 

5 1

I am email to support the BCAP Project Area 

application for Columbia, MO. As a farmer, the 

BCAP program creates enough temporary 

economic incentives to move myself and other 

farmers in my region to commit land to dedicated 

energy crops. Our nation has spent decades 

talking about energy independence and setting 

high goals for transitioning our energy supply 

from foreign sources to domestic sources. No 

group or organization in America is more capable 

of providing this necessary energy supply than 

America’s farmers. Critically, Miscanthus is the 

only energy crop that is perennial, non-invasive, 

and provides enough tons per acre to make 

economic sense. Dedicated energy crops are the 

most practical solution to a number of issues 

facing our nation. It provides my family with a 

new cash crop, will ensure economic 

development in rural communities, and will 

provide a home grown, reliable, base load energy 

supply that America desperately needs. General Support MO 65201 Individual None

Comment noted on the support of the proposed 

action. 
Page 3 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

6 1

I am email to support the BCAP Project Area 

application for Columbia, MO. As a farmer, the 

BCAP program creates enough temporary 

economic incentives to move myself and other 

farmers in my region to commit land to dedicated 

energy crops. Our nation has spent decades 

talking about energy independence and setting 

high goals for transitioning our energy supply 

from foreign sources to domestic sources. No 

group or organization in America is more capable 

of providing this necessary energy supply than 

America’s farmers. Critically, Miscanthus is the 

only energy crop that is perennial, non-invasive, 

and provides enough tons per acre to make 

economic sense. Dedicated energy crops are the 

most practical solution to a number of issues 

facing our nation. It provides my family with a 

new cash crop, will ensure economic 

development in rural communities, and will 

provide a home grown, reliable, base load energy 

supply that America desperately needs. General Support Individual None

Comment noted on the support of the proposed 

action. 

7 1

Regional Economic Development, Inc (RDI) is the 

economic development organization for 

Columbia-Boone County Missouri and in that 

capacity is submitting this letter in support for the 

BCAP grant application from MFA Oil Biomass LLC 

and Aloterra Energy LLC. we have had numerous 

briefings on the plans for this exciting opportunity 

and we have reviewed the Environmental 

Assessment provided by the USDA. We believe 

this application clearly meets the stated primary 

purpose of BCAP, which is to promote the 

cultivation of perennial bioenergy crops and 

annual bioenergy crops that show exceptional 

promise for producing bioenergy or biofuels, 

preserving natural resources without 

compromising crops grown for food or animal 

feed. Not only will this project crate an important 

source of bioenergy, it will also create a positive 

economic impact on Columbia and mid-Missouri. General Support MO 65201

RegionalNGO

Regional 

Economic 

Development, Inc.Comment noted on the support of the proposed 

action. 

8 1

One correction regarding invasiveness of giant 

miscanthus parents: Miscanthus sacchariflorus

(Maxim.) Franch. is on the Massachusetts statelisted noxious weeds list, contrary to P4-11 L9 Text 

Correction NA IL Individual

University 

of Illinois at 

UrbanaChampaign Text correction has been included in the Final EA
Page 4 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

9 1

Stewart, A. and M. Cromey. 2011. Identifying 

disease threats and management practices for 

bio-energy crops. Current Opinion in 

Environmental Sustainability, 3:75-80.

Text 

Correction NA FL 32399

RegionalNGO

Florida Fish 

& Wildlife 

Conservation 

Commission Text correction has been included in the Final EA

10 1

I am writing to support the BCAP Project Area 

application for Ashtabula, Ohio. As an economic 

development agency acting in the best interest of 

Ashtabula County, Growth Partnership hopes the 

BCAP program creates enough temporary 

economic incentives to move the farmers in our 

region to commit land to dedicated energy crops. 

We are dedicated to assisting in this process any 

way that we can. Our nation has spent decades 

talking about energy independence and setting 

high goals for transitioning our energy supply 

from foreign sources to domestic sources. No 

group or organization in America is more capable 

of providing this necessary energy supply than 

America’s farmers. Critically, Miscanthus is the 

only energy crop that is perennial, non-invasive, 

and provides enough tons per acre to make 

economic sense. Dedicated energy crops are the 

most practical solution to a number of issues 

facing our nation. It provides Ashtabula County’s 

farmers with a new cash crop that will ensure 

economic development in rural communities, and 

will provide a homegrown, reliable, base load 

energy supply that America desperately needs. General Support OH 44047 Local-NGO

Growth 

Partnership 

for 

Ashtabula 

County

Comment noted on the support of the proposed 

action. 
Page 5 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

11 1

We have reviewed the Environmental 

Assessment for the proposed BCAP Giant 

Miscanthus grass that is to be used by Aloterra 

Energy and MFA Oil Biomass Company LLC in the 

biomass project areas in Missouri, Arkansas, Ohio 

and Pennsylvania. We are very supportive of the 

projects. Based on the environmental 

consequences outlined in the EA document, we 

believe the use of Miscanthus as a dedicated 

energy crop used for the production of energy 

will have little or no environmental impact to any 

area that is to be used in these project areas. 

The establishment of the biomass project areas 

will also provide renewable energy inputs and will 

result in a new complimentary industry for 

agriculture with an enormous economic impact to 

the economy as well as providing a program 

dedicated to reducing our reliance on foreign oil. 

As a former Secretary of Agriculture for Kansas, I 

look forward to this developing industry in our 

neighboring state and hope that biomass projects 

areas will be established in Kansas. General Support KS 67543 Individual

Priddle & 

Associates

Comment noted on the support of the proposed 

action. 

12 1

I have reviewed the Environmental Assessment 

for the proposed BCAP Giant Miscanthus grass 

that is to be used by Aloterra Energy and MFA Oil 

Biomass Company LLC in the biomass project 

areas in Missouri , Arkansas , Ohio and 

Pennsylvania . I, as a member of Corner Poster 

Energy LLC, have participated in the planting, 

harvesting, and baling and digging of rhizomes of 

the giant miscanthus grass. Being a first hand 

observer of the operation, I did not witness any 

environmental issues in growing or harvesting of 

the giant Miscanthus grass. Based on this and the 

negligible environmental consequences outlined 

in the EA document, I believe the use of 

Miscanthus as a dedicated energy crop used for 

the production of energy will have little or no 

environmental impact to any area that is to be 

used in these project areas. General Support Individual

Corner Post 

Energy LLC

Comment noted on the support of the proposed 

action. 
Page 6 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

13 1

I believe this country must, as it has in the past, 

stand up for its own best interest. This country 

needs to produce energy not import it. Energy 

independence means we as a people determine 

our own destiny. We must start somewhere and I 

want that line in the sand to be drawn right here 

in Ashtabula county Ohio! I am writing to 

support the BCAP Project Area application for 

Ashtabula, Ohio. As a farmer, the BCAP program 

creates enough temporary economic incentives 

to move myself and other farmers in my region to 

commit land to dedicated energy crops. Our 

nation has spent decades talking about energy 

independence and setting high goals for 

transitioning our energy supply from foreign 

sources to domestic sources. No group or 

organization in America is more capable of 

providing this necessary energy supply than 

America’s farmers. Critically, Miscanthus is the 

only energy crop that is perennial, non-invasive, 

and provides enough tons per acre to make 

economic sense. Dedicated energy crops are the 

most practical solution to a number of issues 

facing our nation. It provides my family with a 

new cash crop, will ensure economic 

development in rural communities, and will 

provide a home grown, reliable, base load energy 

supply that America desperately needs. General Support OH 44030 Individual None

Comment noted on the support of the proposed 

action. 

14 1

USDA is proposing to support the establishment 

and production of giant miscanthus as a 

dedicated energy crop in Arkansas, Missouri, 

Ohio and Pennsylvania as part of the Biomass 

Crop Assistance Program (BCAP). The Missouri 

Department of Conservation (MDC) is the state 

agency responsible for fish, forest and wildlife 

resources in Missouri. MDC participates in 

project review when projects might affect those 

resources. MDC comments and 

recommendations are for USDA consideration 

and are offered to reduce impacts to natural 

resources in the project area. General NA MO 65102

State 

Agency

Missouri 

Department 

of 

Conservation General statement, no response required.
Page 7 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

14 2

The proposed establishment of 100,000 acres of 

giant miscanthus (Miscanthus x giganteus) and 

another 50,000 acres just across the state line in 

Arkansas represents a significant land conversion 

proposal that will significantly alter ecological 

conditions in the immediate project areas. Land Use NA MO 65102

State 

Agency

Missouri 

Department 

of 

Conservation

The Project Sponsors are targeting existing 

agricultural lands that are considered marginal, 

indicating that traditional crops have failed on those 

acres, or pasturelands, with a potential for a minor 

component of active cropland. In the Missouri 

proposed project areas, the maximum giant 

miscanthus acres (50,000 per proposed project 

area), as part of this project, would account for just 

over five percent of the land area within each 

proposed project area in other cropland and 

pastureland, as described in the 2007 Agricultural 

Census. Within the Arkansas proposed project area, 

a portion of the giant miscanthus acreage would be 

planted on harvestable cropland due to past 

agricultural activities creating generalized 

environmental concerns. Additionally, land 

conversion would be gradual beginning this planting 

season with maximum acres enrolled by 2014. 

14 3

Impacts to wildlife, potential invasiveness of the 

cultivar in large-scale plantings in the central 

United States are largely unknown and the 

dismissal of such concerns as minor for the 

proposed action in the environmental assessment 

reflects largely anecdotal statements with little 

scientific research to back them up. Biodiversity NA MO 65102

State 

Agency

Missouri 

Department 

of 

Conservation

A substantial amount of research has been 

conducted on giant miscanthus in Europe with no 

evidence, even from stands greater than 20 years, 

showing invasiveness from this sterile hybrid. The 

Project Sponsors are committed to producing a safe, 

environmentally sustainable crop with active 

monitoring measures to ensure that there is no 

spread beyond the intentionally planted acres. Field 

buffers will be included as a standard practices for 

all contract acreage enrolled within these proposed 

project areas. As a mitigation measure, any 

vegetative spread beyond the intentionally planted 

acres, will be control with an appropriate herbicide, 

using a spot treatment or treatments. 

14 4

Table ES-2, titled Comparison of Alternatives, 

states there will be only 4 positive benefits of this 

program. Each of these benefits, including the 

socioeconomic category is classified in the table 

as a “minor positive” benefit. Land use and 

biological resources are classified as “minor 

negative” impact. These are questionable 

assessments considering the potential for land 

conversion and the unknown invasiveness nature 

of mass plantings of miscanthus.

Impact 

Analysis NA MO 65102

State 

Agency

Missouri 

Department 

of 

Conservation

The Project Sponsors and FSA have developed a 

Mitigation and Monitoring Plan that addresses 

concerns of invasiveness, pest and disease 

potential, soil erosion during establishment, and 

biodiversity. The active measures would reduce the 

potential for environmental impacts to minor levels. 
Page 8 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

14 5

MDC recommends more substantive research is 

needed to determine potential impacts to wildlife 

and invasiveness of giant miscanthus before the 

federal government funds an extensive, longterm BCAP initiative.

Additional 

Research NA MO 65102

State 

Agency

Missouri 

Department 

of 

Conservation

The BCAP statute does not allow for field trials, test 

plots, or other small-scale demonstration projects. 

The BCAP does allow for reporting of activities 

associated with the establishment and production 

of vegetation on BCAP contracted acreage. The 

Project Sponsors are providing annual reporting to 

the FSA and other USDA agencies are multiple 

aspects associated with establishment and 

production, spread of giant miscanthus outside of 

intentionally planted areas, chemical usage, harvest 

metrics, and other items. 

14 6

USDA must include stipulations that require 

offsite control of escaped plants, sanitary control 

of equipment and trucks hauling miscanthus to 

avoid the spread of plant propagules including 

rhizomes and seeds. As USDA sponsored 

program, BCAP must require that each producer 

have an approved farm conservation or 

stewardship plan which includes requirements for 

producers and suppliers to implement best 

management practices to harvest and manage 

bioenergy fields. In addition, periodic USDA 

inspections or third party audits should be 

completed for continued compliance of 

producers and suppliers under BCAP. These best 

management practices should include practices 

for soil and water conservation, ensuring some 

measure of wildlife habitat protection and to limit 

the spread of giant miscanthus.

Mitigation 

Measures NA MO 65102

State 

Agency

Missouri 

Department 

of 

Conservation

The Mitigation and Monitoring Plan take many of 

these considerations into account and have included 

similar activities as necessary for the contract 

acreage. Active monitoring along field buffers and 

within fields will ensure early detection of a

vegetative spread or pests/diseases. All equipment 

will be sanitized to ensure that no unintentional 

release of rhizomes or propagules would occur 

during or after transport of live rhizomes. All 

rhizomes would be contained within bags and 

contained to wrapped pallets during initial 

shipments. After this growing season, all rhizomes 

would come from on-farm sources, which would not 

require transportation of live rhizomes. 

14 7

USDA should discourage the conversion of native 

prairies, wetlands, woodlands, riparian forests 

and other native ecological communities to 

miscanthus energy fields. Loss of these rare and 

declining biological habitats will decrease 

populations of many species of plants and animal. 

This in turn, creates the possibility that more 

species could be raised to endangered status, 

which will affect agriculture and economic 

opportunity more broadly in agricultural regions.

Native & 

Natural 

Habitats NA MO 65102

State 

Agency

Missouri 

Department 

of 

Conservation

As part of BCAP, native sods and wetlands cannot be 

converted into biomass crop acreage. The Project 

Sponsors are targeting acreage that is either failed 

cropland, marginal cropland with traditional crops, 

or pastureland. It would not be economically 

feasible for producers to converted wooded areas 

to giant miscanthus croplands. Along sensitive 

areas, such as wooded riparian buffers, the 

Conservation Plan would be used on a site-specific 

basis to increase field buffers widths to ensure the 

avoidance and minimization of impacts to these 

sensitive land areas.
Page 9 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

14 8

The use of the terms “idle acres” (page ES-3) and 

“marginal croplands” (page E-2) suggests land 

with less row crop potential has reduced natural 

resource significance. Land categories targeted 

for miscanthus establishment should be clearly 

defined and published in the final environmental 

impact statement, with disclosure of potential 

impacts to prairies, woodlands, wetlands, riparian 

forests and other native ecological communities. 

If lands with significant wildlife habitat are 

converted to miscanthus, then the stated 

conclusion in this draft environmental impact 

statement that the "impacts to wildlife from this 

project are minimal" are unfounded and that this 

determination should to be revised in the final 

version.

Land Use 

Conversion NA MO 65102

State 

Agency

Missouri 

Department 

of 

Conservation

Since contract acreage has not been established 

within each proposed project area, site-specific 

analysis cannot be performed through the 

environmental assessment. The Conservation Plan 

for contract acreage will provide a site specific 

analysis of the potential effects at that localized 

level. The Project Sponsors are currently targeting 

lands that have failed as croplands, only produce 

marginal returns with traditional crops, or are 

currently abandoned or managed pastureland. 

Lands with significant or sensitive features would be 

avoided or not accepted into the project area as the 

discretion of the Project Sponsors of FSA before or 

during the site specific environmental review. 

14 9

USDA must clearly state in the final 

environmental assessment and in the Mitigation 

and Monitoring Plan that USDA is required to 

control escaped miscanthus in surrounding fields 

and transportation routes, and eradicate 

miscanthus populations and specimens that leave 

the dedicated plots. Best management practices 

as required in the Mitigation and Monitoring Plan 

for miscanthus management and wildlife habitat 

must be developed in consultation with federal 

and state fish and wildlife agencies.

Mitigation 

Measures NA MO 65102

State 

Agency

Missouri 

Department 

of 

Conservation

The Mitigation and Monitoring Plan takes into 

account many accepted best management 

practices, as well as NRCS Conservation Practices 

Standards to reduce the potential environmental 

effects. 

14 10

Literature reviews suggest that public research 

institutions have begun development research to 

produce a viable seed version of giant miscanthus 

for energy production. A viable seed cultivar of 

giant miscanthus greatly changes the potential 

for the species to become invasive. USDA 

sponsorship of BCAP which results in the planting 

a viable seed cultivar of miscanthus should trigger 

an immediate, new environmental assessment 

process and public comment period. Viable Seed NA MO 65102

State 

Agency

Missouri 

Department 

of 

Conservation

The Project Sponsors are proposing to only use the 

Illinois clone of giant miscanthus, which is only 

propagated through rhizomes, within the proposed 

project areas. Currently, there are no giant 

miscanthus clones that produce viable seed. FSA 

would undergo additional environmental analyses 

should a viable seed cultivar be proposed for the 

BCAP. 
Page 10 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

14 11

The history of introducing exotic species 

frequently has required expensive control 

measures that often have become pointless, 

because control came too late. The research on 

invasiveness tendencies was not done, or 

frequently was ineffective. USDA promotion of 

miscanthus as an energy crop suggests federal 

responsibility to control potential escapes of 

miscanthus.

Invasive, 

Non-Native NA MO 65102

State 

Agency

Missouri 

Department 

of 

Conservation

A review of literature from Europe and the United 

States has not indicated that this clone of giant 

miscanthus would result in an invasive spread. The 

Mitigation and Monitoring Plan activities would be 

used to ensure that acres intentionally planted as 

part of the proposed project areas would not create 

an unintentional spread of giant miscanthus. The 

field buffers, as well as, an eradication strategy 

would be implemented as part of the Conservation 

Plan.

14 12

The Missouri Department of Conservation is 

prepared to engage USDA and partners in 

developing policy and best management practices 

to limit impacts to fish, forest and wildlife and 

their habitat in the pursuit of renewable and 

efficient alternative energy sources. General NA MO 65102

State 

Agency

Missouri 

Department 

of 

Conservation General statement, no response required.

15 1

I am writing to support the BCAP Project Area 

application for Ashtabula, Ohio. As a farmer, the 

BCAP program creates enough temporary 

economic incentives to move myself and other 

farmers in my region to commit land to dedicated 

energy crops. Our nation has spent decades 

talking about energy independence and setting 

high goals for transitioning our energy supply 

from foreign sources to domestic sources. No 

group or organization in America is more capable 

of providing this necessary energy supply than 

America’s farmers. Critically, Miscanthus is the 

only energy crop that is perennial, non-invasive, 

and provides enough tons per acre to make 

economic sense. Dedicated energy crops are the 

most practical solution to a number of issues

facing our nation. It provides my family with a 

new cash crop, will ensure economic 

development in rural communities, and will 

provide a home grown, reliable, base load energy 

supply that America desperately needs. 

Ashtabula needs this project desperately, as it 

seems the area has been forgotten causing 

businesses to close, and people to become 

unemployed. Just recently we have lost another 

130 jobs from a plant moving to North Carolina. General Support Individual None

Comment noted on the support of the proposed 

action. 
Page 11 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

16 1

We support the approval of Aloterra Energy’s 

BCAP applications. Miscanthus is the most viable 

energy crop solution available today and we 

need to support it for both energy and national 

security reasons. I STRONGLY SUPPORT IT. General Support CO 80203 Individual

Plexus 

Capital, LLC

Comment noted on the support of the proposed 

action. 

17 1

I support the approval of Aloterra Energy’s BCAP 

applications and I support the use of Miscanthus 

as an energy crop to meet America’s renewable 

energy needs. General Support MO Individual None

Comment noted on the support of the proposed 

action. 

18 1

Please give every consideration ,to this very 

important step in the right direction. Thanks. I 

support the approval of Aloterra Energy’s BCAP 

applications and I support the use of Miscanthus 

as an energy crop to meet America’s renewable 

energy needs.” General Support Individual

Clearwater 

Seafood

Comment noted on the support of the proposed 

action. 

19 1

I support the approval of Aloterra Energy’s BCAP 

applications and I support the use of Miscanthus 

as an energy crop to meet America’s renewable 

energy needs. Thank you very much. General Support Individual None

Comment noted on the support of the proposed 

action. 

20 1

I support the approval of Aloterra Energy’s BCAP 

applications and I support the use of Miscanthus 

as an energy crop to meet America’s renewable 

energy needs. This should be looked at as not 

only an alternative, but the main energy source 

for our future. Put energy revenues with our U.S. 

farmers, not the Oil Industry and Middle 

East/Venezuela!!! General Support Individual None

Comment noted on the support of the proposed 

action. 

21 1

I support the approval of Aloterra Energy's BCAP 

applications. And, I support the use of 

Miscanthus as an energy crop to meet our 

country's, U.S.A., renewable energy needs. General Support CO Individual None

Comment noted on the support of the proposed 

action. 
Page 12 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

22 1

Agrosil Energy LLC, while a small company, has 

one of the largest inventories of Miscanthus grass 

(Mxg) rootstock in the United States. We are a 

provider of Mxg rootstock to Aloterra Energy, LLC 

and strongly support the approval of Aloterra's 

BCAP applications and as well support the use of 

Miscanthus as an energy crop to meet America’s 

renewable energy needs. Miscanthus is a 

perennial grass which satisfies multiple criteria 

for the ideal energy crop – namely, high dry 

matter yield; low mineral and moisture content; 

perennial growth; relative low fertilizer demand; 

efficient use of water and other resources; and 

pest and disease resistance. It can be grown on 

lower classes of farm land. The result is a crop 

that is both profitable to farmers and 

environmentally friendly. Importantly, 

Miscanthus x giganteus a sterile and non-invasive 

form. It has a 20 year history of use as a bio-fuel 

in the United Kingdom and other European 

countries. It is an effective feedstock for co-firing 

with coal for electric power generation as well as 

for firing in 100% biomass boilers. Higher farm 

yields per acre in the US can make it more cost 

effective in North American markets. The 

growing of Mxg fuel crops under the BCAP 

program will result in 2 to 3 times less farm land 

being utilized for fuel than the growing of 

switchgrass. We urge your approval of Aloterra's 

BCAP applications. General Support CA 93442

Private 

Company

Agrosil 

Energy, LLC

Comment noted on the support of the proposed 

action. 

23 1

I support the approval of Aloterra Energy’s BCAP 

applications and I support the use of Miscanthus 

to meet America’s renewable energy needs. It 

will help the company to make biomass energy 

crops part of this country’s energy portfolio; it 

can also create new jobs and support the US 

farmers. General Support Individual None

Comment noted on the support of the proposed 

action. 

24 1

I would like to express my support for of approval 

Aloterra Energy's BCAP applications and I support 

the use of Miscanthus as an energy crop to meet 

America's renewable energy needs. General Support WA 98195 Individual

University 

of 

Washington

Department

of MicrobiologyComment noted on the support of the proposed 

action. 
Page 13 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

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Group Response

25 1

The Missouri Department of Agriculture has 

made renewable energy a strong focus in terms 

of priorities for the future. As such, we support 

Missouri's biomass producers in their efforts to 

move Missouri agricultural forward. In 2008, 

Missouri voters approved Proposition C, requiring 

that investor-owned utilities include no less than 

15 percent assets in renewable energy. Projects 

involving biomass will help the state of Missouri 

to meet those requirements. The Renewable 

Fuel Standard 2 (RFS2) and EPA transportation 

rules are likely to contribute to an increase in the 

need for biomass feedstock in the future, 

expanding markets for co-products and byproducts from the renewable fuels industry. The 

Biomass Crop Assistance Program (BCAP) enables 

Missouri farmers to expand energy services into 

emerging biomass renewable energy markets and 

is an opportunity of great interest to the 

Department. Your proposed project provides 

farmers with an energy crop source, unique 

harvesting and planting equipment, specialty 

harvesting services, crop processing technology 

and marketing services. From the information 

provided, the project creates opportunities for 

new crops for our state's farmers, jobs with the 

biomass conversion facility, and advances in 

economic development throughout Missouri. We 

certainly support your efforts and hope your 

project, MFA Oil Biomass LLC, is favorably 

received by USDA, Biomass Crop Assistance 

program. As always, if we can ever be of 

assistance, please do not hesitate to contact us. General Support MO 65102

State 

Agency

Missouri

Department 

of 

Agriculture

Comment noted on the support of the proposed 

action. 

26 1

The Pennsylvania Game Commission has 

reviewed the Draft Environmental Assessment on 

Miscanthus x giganteus in the Federal Register 

notice Vol. 76, No. 68, pg. 19741, April 8, 2011 

and provides the following comments. General NA PA 17110

State 

Agency

Pennsylvania Game 

Commission 

Bureau of 

Wildlife 

Habitat 

Management No response required. 
Page 14 of 128

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Group Response

26 2

The record of containment of "sterile" hybrid 

plant materials has been poor in the past, and we 

do not advocate repeating those mistakes again. 

Specifically, vegetative hybrids have the chance of 

creating viable seed over time if crossed with 

other species of the genus, and the resulting 

escapes of other Miscanthus species in 

Pennsylvania that have infested several hundred 

acres of private lands and public rights-of-way. Seed Sterility Against PA 17110

State 

Agency

Pennsylvania Game 

Commission 

Bureau of 

Wildlife 

Habitat 

Management

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determined within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. 

26 3

A classic example of failed hybrid sterility that has 

severely impacted wildlife habitat is purple 

loosestrife (Lythrum salicaria). Purple loosestrife 

has spread prolifically and outcompeted native 

wetland vegetation resulting in the loss of 

wetland habitat and millions of dollars spent on 

invasive species control. Seed Sterility NA PA 17110

State 

Agency

Pennsylvania Game 

Commission 

Bureau of 

Wildlife 

Habitat 

Management

Many of the species cited were introduced to the 

U.S. in the 19th century or through inadequately 

assessed horticultural varieties prior to many of the 

safeguards that were put in place within the last few 

decades. This clone of giant miscanthus has been 

grown in field trials since 2002 without escape from 

these areas. There is also little evidence from 

European experience of invasive potential for this 

hybrid. 

26 4

We believe that the overall risk to wildlife habitat 

and wildlife in Pennsylvania is not worth the 

federal government funded private industry 

reward in this case, nor the investment of 

American tax dollars in that private industry. In 

1994, invasive plant control costs and related 

losses totaled over $19 billion on agricultural and 

non-agricultural lands nationwide. The private 

industry is shifting the burden of the invasive 

species escape risk to the American tax payer. 

We do not believe the proposed activity should 

be funded, but if it is, the industry should 

contribute more to reducing that risk, as 

described below. 

Invasive, 

Non-Native NA PA 17110

State 

Agency

Pennsylvania Game 

Commission 

Bureau of 

Wildlife 

Habitat 

Management

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. The Project Sponsors have committed to 

long-term management and responsibility for the 

contracted fields within these proposed project 

areas. The overall purpose of BCAP is to provide 

incentive payments for producers to establish and 

producer novel energy crops as biomass feedstock 

for bioenergy and bioproducts. 
Page 15 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

26 5

Specific weaknesses within the DEA include 

portions of section 2-3. Section 2-3 identifies 

resources that were considered but eliminated 

from further analysis. Section 2-3, line 18 with 

reference to Floodplains not needing to be 

evaluated. We feel that despite the unbalanced 

risk of introducing a new invasive species to the 

Pennsylvania environment via seed dispersal, the 

immediate risk of spread of this detrimental 

hybrid is through vegetative dispersal along 

watersheds from the movement of the rhizomes 

via watercourses during normal rain, high flow 

and flood events. We already experience the 

movement of invasive Japanese knotweed via 

rhizomes being dislodged and deposited 

downslope and downstream via waterways. This 

is a real hazard, and if approved should at the 

very least be mitigated by: 1) planting may only 

be done outside of the 100 year floodplain; 2) 

planting shall not be done on sites where any 

portion of the field equals or exceeds an 

Erodibility Index of 8 (i.e. EI<8); and 3) a minimum 

of at least 100 foot field border of unmowed 

native herbaceous vegetation surrounding the 

hybrid planting must be installed serving as a 

rhizome impediment, as well as a sheet flow 

screen for any eroding hybrid rhizomes.

Eliminated 

Resource 

Areas NA PA 17110

State 

Agency

Pennsylvania Game 

Commission 

Bureau of 

Wildlife 

Habitat 

Management

The amount of floodplains within the proposed 

project areas will be detailed within the Final EA. 

Within the Ashtabula area, approximately five to 

seven percent would be within the 100-year 

floodplain. Site-specific Conservation Plans would 

be used to increase buffer widths adjacent to 

sensitive areas, such as wetlands and aquatic areas, 

if the conditions of the contract acreage warrant. 

Floodplains are often used to grow agricultural 

crops and certain portions of the proposed project 

areas have wide 100-year floodplains or higher 

percentages of land within floodplains. Additionally, 

giant miscanthus once established, would provide 

excellent soil holding abilities on HEL due to the high 

biomass yield and large below ground root structure 

this species provides. The Conservation Plan for 

each producer will incorporate the Mitigation and 

Monitoring as the starting conditions for 

development, with greater use of BMPs, depending 

upon the local site conditions. As to seed dispersal, 

the Project Sponsors would take steps necessary to 

minimize the unintentional development of viable 

seed from giant miscanthus. The Project Sponsors 

would be willing to exclude acreage within 400 m 

(approximately 1,300 feet) from any known 

Miscanthus sinensis or Miscanthus sacchariflorus 

invasion to limit the potential for cross-pollination 

resulting in viable seed. This distance is the 

maximum distance observed in Quinn et al. 2011. 

Additionally, the Project Sponsors have committed 

to a seed sampling program to track the potential 

viability of the giant miscanthus acres included 

within their project areas.

26 6

Section 2-3, Line 20 indicates that regulated 

coastal zones were eliminated from consideration 

because the proposed project areas are not 

located within such as zone. Lake Erie, which 

borders several counties in the Ashtabula site, 

and under the authority of the Army Corps of 

Engineers, should be considered a regulated 

coastal zone and as such we suggest that detailed 

analysis be conducted pertaining to regulated 

coastal zones. 

Eliminated 

Resource 

Areas NA PA 17110

State 

Agency

Pennsylvania Game 

Commission 

Bureau of 

Wildlife 

Habitat 

Management

The Project Sponsors will exclude any acreage 

included within the managed coastal zones of Lake 

Erie to ensure compliance with the USACE 

regulations or Coastal Zone Management 

regulations.
Page 16 of 128

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Group Response

26 7

Additionally, in section 2-15, line 26, the 

evaluation that Recreation will not be 

significantly impacted is not sufficiently 

addressed. Fifty thousand acres of wildlife 

habitat and huntable areas will be converted to 

unhuntable M. x giganteus, representing a 

significant percentage of huntable upland small 

game areas in the defined areas of Ohio and 

Pennsylvania. Hunting is a significant economic 

influence in rural areas, and the loss of 50,000 

acres of habitat will result in losses in revenue to 

hotels, motels, gas stations, convenience stores 

and sporting goods stores in and around the 

proposed area. 

Eliminated 

Resource 

Areas NA PA 17110

State 

Agency

Pennsylvania Game 

Commission 

Bureau of 

Wildlife 

Habitat 

Management

Public hunting access on private lands will be 

discussed in greater detail in the Final EA; however, 

lands included under state access programs, such as 

the Cooperative Farm-Game Program in 

Pennsylvania are under contract with the state. This 

contract is for five years or longer and stipulates 

that wildlife management activities must occur on 

those acres in combination with a Conservation 

Plan. As such, it would be unlikely that the state 

would approve the planting of giant miscanthus on 

those acres, and the Project Sponsors would exclude 

those acres for the remaining length of the contract 

period, if the contract is broken. 

26 8

The evaluation that soil will be protected is 

making the assumption that the cover will be 

retained in perpetuity. As we have seen multiple 

times, new industries often fail, and landowners 

change their mind about leasing land to 

producers. As stated in the DEIS, that cover will 

need to be plowed to a depth of 10 inches, and 

repeatedly treated with herbicide to control the 

established hybrid. This will create more erosion 

than most of these lands would normally 

encounter over several years. The combination 

of predominantly glacial till soils that are highly 

erodible in the target area, and the targeted 

"marginal" lands that will be planted, greatly 

increase the risk of severe erosion. We believe, 

this section of the DEIS should be revisited and 

revised to address this concern. This concern also 

further supports the three numbered mitigating 

recommendations listed above, especially 

number 2. Land Use NA PA 17110

State 

Agency

Pennsylvania Game 

Commission 

Bureau of 

Wildlife 

Habitat 

Management

During establishment of giant miscanthus the soil 

will be tilled twice on the propagation acres and 

once on the plantation acres. The initial planting of 

the rhizomes would require disturbing the soil to a 

depth of approximately four inches, similar to 

traditional tillage for annual crops. On the 

propagation acres, a second tillage would occur at a 

depth from six to 10 inches to harvest the rhizome 

for planting on plantation acres. After the 

plantation establishment, tillage would not occur 

again over the productive life of the plant. 

Harvesting of biomass would be similar to activities 

used for the production of hay. The fields would 

only need treatment with herbicides during the 

initial growth period in years one and two, rather 

than yearly compared to traditional crops that must 

be treated with herbicide during the initial growth 

period. 

26 9

The assessment that nutrient losses will be 

reduced is also under the assumption that no or 

minimal nutrient amendments will be used for 

this biomass crop. This is highly unlikely, and we 

recommend that nutrient use be limited to at 

most 50% of tested recommendations, and that 

the application be split into at least two 

applications separated by at least 30 days during 

the growing season, and at least 30 days prior to 

the first fall frost for the area. 

Nutrient 

Application NA PA 17110

State 

Agency

Pennsylvania Game 

Commission 

Bureau of 

Wildlife 

Habitat 

Management

As stated in Section 2.2.2.1, fertilization would be 

required at a recommended rate of approximately, 

eight pounds of nitrogen, 1.5 pounds of

phosphorus, and eight pounds of potassium per dry 

ton of biomass produced. However, soil testings at 

the local level could reduced or increase these 

amounts, due to the variability of soil types, 

moisture content, and conditions across the project 

areas. These rates are the average recommended 

for this crop based on field trials and European 

experience. 
Page 17 of 128

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No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

26 10

Because of the implementation costs of 

contracting and establishing the Conservation 

Reserve and Enhancement Program (CREP) and 

the local, state and federal investment in the 

program, and the targeted goals of water quality 

improvement and grassland nesting bird habitat 

of the Pennsylvania CREP, we request that no 

CREP contract acres be permitted to be enrolled 

in BCAP either by breaking the contract or within 

one full year following a contract expiration. CREP acres NA PA 17110

State 

Agency

Pennsylvania Game 

Commission 

Bureau of 

Wildlife 

Habitat 

Management

This is a CREP contract issue and not a BCAP 

contract issue. FSA has no control over producers 

that have had acreage expire from a conservation 

program once the contract is complete, unless it has 

been written into the specific producer contract for 

those conservation acres. 

26 11

Further, because of the unknown outcome of 

seed viability over time, we recommend 

establishing a restoration and eradication fund, 

funded by the participating private entities, that 

equals at a minimum, the established custom 

rates for three herbicide sprays and one deep 

plowing treatment for each acre of hybrid 

planted. This fund would be maintained in 

perpetuity and used to treat escapes and restore 

sites, even if the company ceases Miscanthus 

operations. If funding is used from the fund for 

an escape or restoration, the fund will be refunded from the existing entities that are 

participating in BCAP funded Miscanthus biomass 

on a pro-rated acre basis. The fund should be 

administered by the Pennsylvania Department of 

Agriculture with the evaluation and response 

coordinated by the Pennsylvania Invasive Species 

Council. If the industry or project area fails, those 

funds should be retained by the Pennsylvania 

Department of Agriculture for other invasive 

species management.

Additional 

Funding NA PA 17110

State 

Agency

Pennsylvania Game 

Commission 

Bureau of 

Wildlife 

Habitat 

ManagementThe BCAP statute does not allow for perpetual 

funding or bonding for Project Sponsors. 

26 12

Although the use of this hybrid is not advocated, 

and we believe it would have dramatic negative 

effect on wildlife if allowed, we believe that the 

above mitigation measures will at least allow for 

a pro-active approach to permitting an industry 

to operate in a responsible, professional manner. General Against PA 17110

State 

Agency

Pennsylvania Game 

Commission 

Bureau of 

Wildlife 

Habitat 

Management

The Project Sponsors have committed to a 

Mitigation and Monitoring Plan that sets broad 

activities within each project area. More specific or 

stringent activities would be included in each 

producer's Conservation Plan based on the sitespecific conditions and State and local regulations. 
Page 18 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

27 1

On behalf of the National Wildlife Federation 

(NWF) and its four million members and 

supporters, I submit these comments on the 

Environmental Assessment (EA) for the proposed 

establishment and production of giant 

miscanthus (Miscanthus X giganteus) in Arkansas, 

Missouri, Ohio, and Pennsylvania as a project 

under the Biomass Crop Assistance Program 

(BCAP). We thank the agency for considering 

these comments. General NA D.C. 20004 NGO

National 

Wildlife 

Federation No response required. 

27 2

The National Wildlife Federation is concerned 

about the potential for giant miscanthus to 

become invasive. As you know, the 2008 Farm Bill 

specifically excludes “any plant that is invasive or 

noxious or has the potential to become invasive 

or noxious” as an eligible crop for purposes of 

BCAP. The EA appears to conclude that there is a 

“low likelihood” for giant miscanthus to become 

invasive. Yet, the EA acknowledges that there are 

data gaps in the literature on the invasive 

potential on giant miscanthus. It also 

acknowledges that two species of Miscanthus, 

including Miscanthus sinensis, the parent species 

of the hybrid cultivar Miscanthus X giganteus, are 

listed on the Federal Invasive Species List. Invasive NA D.C. 20004 NGO

National 

Wildlife 

Federation

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.
Page 19 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

27 3

While giant miscanthus is a sterile hybrid cultivar, 

there is still concern that it could reproduce, and 

as the EA demonstrates, there are a number of 

features of giant miscanthus that make it an ideal 

invasive weed. If giant miscanthus were indeed 

able to reproduce, the potential for invasion 

would be significant. While the EA dismisses the 

potential for giant miscanthus to reproduce, 

studies have found that triploid sterility can break 

down and result in fertile gametes (Ramsey and 

Schemske 1998). Moreover, the literature has 

reports of the production of fertile seed by the 

so-called sterile giant miscanthus (Quinn et al. 

2011). Other species that were thought to be 

sterile, such as the Bradford pear (Pyrus 

calleryana), have in fact ended up reproducing 

and becoming invasive through cross-pollination 

with other cultivars (Cully and Hardiman 2007). 

Thus, the proximity of the fields that are to be 

planted with giant miscanthus to ornamental 

plantings of M. sinensis and M. sacchariflous

should be taken into account within the EA. 

Invasive, 

Non-Native; 

Seed Sterility NA D.C. 20004 NGO

National 

Wildlife 

Federation

The giant miscanthus hybrid has not shown such 

traits based on the on-going field trials are recent 

larger scale plantings in Europe. The Project 

Sponsors are aware of the concern of crosspollination with one of the parent species. As such, 

an exclusion would be included within the producer 

contracts that would not allow giant miscanthus to 

be planted within 400 meters (approximately 1,300 

feet) from an existing infestation of Miscanthus 

sinensis or Miscanthus sacchariflorus or ornamental 

planting of these or other Miscanthus species to 

greatly reduce the probability of cross-pollination

and production of viable seed.

27 4

Few details are given in the EA regarding the 

specifics of the mitigation and monitoring plan. 

New research demonstrates that giant 

miscanthus, in rare circumstances, has the ability 

to travel long distances, in some cases as much as 

300 or 400 meters (Quinn et al. 2011). Thus, the 

monitoring plan would have to take into account 

the possibility for long distance dispersal, as well 

as monitoring of the roadways that lead from the 

fields to the processing facility and to the location 

in which harvesting equipment is kept. 

Monitoring for invasiveness also must occur over 

a longer period of time than the length of project; 

many invasive plants do not show up for several 

years or several decades.

Mitigation 

Measures NA D.C. 20004 NGO

National 

Wildlife 

Federation

As to seed dispersal, the Project Sponsors would 

take steps necessary to minimize the unintentional 

development of viable seed from giant miscanthus. 

The Project Sponsors would be willing to exclude 

acreage within 400 m (approximately 1,300 feet) 

from any known Miscanthus sinensis or Miscanthus 

sacchariflorus invasion to limit the potential for 

cross-pollination resulting in viable seed. This 

distance is the maximum distance observed in 

Quinn et al. 2011. Additionally, the Project 

Sponsors have committed to a seed sampling 

program to track the potential viability of the giant 

miscanthus acres included within their project 

areas. The Project Sponsors, as part of the MMP, 

will outline a long-term monitoring plan for

potential escape and control of giant miscanthus. 

As part of the Quality Assurance Program with the 

OSIA, the Project Sponsors have agreed to 

thoroughly clean equipment used for planting, 

harvesting, and transporting giant miscanthus 

rhizome materials. The MMP will detail, the steps 

to occur if viable seed are found through the seed 

sampling program. 
Page 20 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

27 5

The National Wildlife Federation is also 

concerned about reports of research currently 

being conducted to make the sterile hybrid 

Miscanthus x giganteus produce viable seeds. 

This would obviously alter the potential for giant 

miscanthus to become invasive, and it is of the 

upmost importance that a separate 

environmental assessment be done should 

Aloterra Energy and MFA Oil Biomass Company 

wish to receive BCAP funding to cultivate a 

seeded variety of miscanthus. Overall, we believe 

that the agency must more fully address the 

potential for giant miscanthus to become invasive 

before a BCAP project area is authorized for giant 

miscanthus. Seed Sterility NA D.C. 20004 NGO

National 

Wildlife 

Federation

The Project Sponsors are proposing to only use the 

Illinois clone of giant miscanthus, which is only 

propagated through rhizomes, within the proposed 

project areas. Currently, there are no giant 

miscanthus clones that produce viable seed. FSA 

would undergo additional environmental analyses 

should a viable seed cultivar be proposed for the 

BCAP. 

27 6

As FSA begins to move forward with the BCAP 

program, great care must be taken to avoid 

funding potentially invasive species. Many native, 

non-invasive species are good candidates for 

bioenergy production and should be prioritized 

within the program. For those species for which 

there is little information or there is a potential 

for invasive risk, we support the approach by 

Davis et al. (2010) described in the EA in which a 

weed risk assessment (WRA) tool, such as the 

Australian Weed Risk Assessment is used as an 

initial screen. Those species that pass the WRA 

would then be evaluated based on data from the 

species home range. The final step would include 

quarantined field trials to determine if the species 

should be released. 

Mitigation 

Measures NA D.C. 20004 NGO

National 

Wildlife 

Federation

A WRA has been performed on giant miscanthus 

twice in the United States, both times indicated that 

this species would have a low probability of 

invasiveness. The Project Sponsors have committed 

to a Mitigation and Monitoring Plan that sets broad 

activities within each project area. More specific or 

stringent activities would be included in each 

producer's Conservation Plan based on the sitespecific conditions and State and local regulations. 

The BCAP statute does not allow for field trials, test 

plots, or other small-scale demonstration projects. 

The BCAP does allow for reporting of activities 

associated with the establishment and production 

of vegetation on BCAP contracted acreage. The 

Project Sponsors are providing annual reporting to 

the FSA and other USDA agencies are multiple 

aspects associated with establishment and 

production, spread of giant miscanthus outside of 

intentionally planted areas, chemical usage, harvest 

metrics, and other items. 
Page 21 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

27 7

We thank you for the opportunity to provide 

these comments on the draft EA. We urge the 

agency to more fully address the potential for 

giant miscanthus to become invasive before a 

BCAP project area is authorized for giant 

miscanthus. More generally, we strongly believe 

that the precautionary principle should be used 

when considering whether proposed BCAP crops 

have the potential to become invasive. Once it is 

clear that a species has become invasive, the 

problem has often already gotten out of hand, 

and the costs to the environment and to the 

public are great. Efforts to control purple 

loosestrife, for instance, cost $45 million per year 

(Pimentel et al. 2000). Invasive NA D.C. 20004 NGO

National 

Wildlife 

Federation

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.
Page 22 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

28 1

I am writing to request a three-week extension to 

provide comment on the Draft Environmental 

Assessment (EA) per FR Doc. 2011-8421 

proposing the establishment and production of 

Giant Miscanthus (Miscanthus X giganteus) as a 

dedicated energy crop as part of the Biomass 

Crop Assistance Program (BCAP).

Request for 

Extension NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

Request noted; however, FSA has determined that 

sufficient time was available for all interested 

parties to review and return comments on the 

document. An electronic version of the document 

was available 24-hours prior to the publication of 

the notice of availability in the Federal Register. The 

document could be requested in a hard copy format 

or electronically. All hard copy documents were 

received by the requestors within a short period 

from their request, usually provided the next 

business day. All requests for hard copies via e-mail 

were provided a response of receipt of the request 

and an electronic version of the document for 

immediate review. 

28 2

On behalf of the Association of Fish and Wildlife 

Agencies (Association), of which all 50 states, the 

District of Columbia, and US Territories are 

members, we solicited comments in coordination 

with our Agricultural Conservation and Invasive 

Species Committees. In doing so, we have 

identified a multitude of critically important 

issues with the EA that are inadequately 

addressed. We would greatly appreciate the 

additional time to provide you with more 

detailed, useful comments and guidance for 

addressing these issues prior to a final 

determination on the environmental impacts of 

the proposed projects without additional 

analyses. General NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

Request noted; however, FSA has determined that 

sufficient time was available for all interested 

parties to review and return comments on the 

document. An electronic version of the document 

was available 24-hours prior to the publication of 

the notice of availability in the Federal Register. The 

document could be requested in a hard copy format 

or electronically. All hard copy documents were 

received by the requestors within a short period 

from their request, usually provided the next 

business day. All requests for hard copies via e-mail 

were provided a response of receipt of the request 

and an electronic version of the document for 

immediate review. 

28 3

We present the attached as an overview of our 

compiled comments, though with additional time, 

we can provide much greater detail on specific 

recommendations and guidance to enhance the 

thoroughness of the EA. We hope that the Farm 

Service Agency strongly considers the request 

before making its final determination. Our 

members would be greatly impacted if these 

concerns are not addressed. General NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies No response required. 

28 4

The EA is, as it currently stands, inadequately 

addresses several critical issues. In great part due 

to the inadequate treatment of issues below, the 

EA is not a thorough and objective assessment. 

These issues include: General NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies No response required. 
Page 23 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

28 5

Lack of mention of fire or fire 

management/mitigation in and around project 

areas. Miscanthus is highly flammable, and fire 

breaks would be just one, minimal, mitigation 

option

Fire 

Managemen

t NA D.C. 20001 NGO

Association 

of Fish &

Wildlife 

Agencies

This topic will be included in Section 4.4.1.2, 

Biological Resources, Vegetation. There is at least 

one published article describing the potential for 

fire/flammability of this species due to it drying in 

field before harvest. The minimum buffer width 

could be utilized as a standard fire break, with 

additional width added through the site-specific 

Conservation Plan for each producer. This fire 

break/buffer width would take into account 

landscape features to be protected from wildlife 

(e.g., habitable structures, farmsteads, communities 

within close proximity); normal fire frequency 

within the areas; normal conditions during the 

fall/winter, which could lead to increased fire 

danger associated with standing dead plant 

material; and adjacent land uses, which could 

contribute to increased fire risk. Additionally, early 

harvest could be conducted, if unforeseen 

circumstances increased the risk to human health 

and safety from wildlife potential.

28 6

Insufficient assessment of water use impacts. 

The EA states that miscanthus would require 

more water than annual crops such as corn; corn 

already requires heavy irrigation, thus additional 

water use for miscanthus could have significant 

impact on surrounding environmental resources. Water Use NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

Further clarification will be provided within the Final 

EA. This will include potential irrigation demands of 

this crop as compared to traditional crops (e.g., 

corn) and compared to perennial grass species, 

which were the native communities within the 

proposed project areas. For the vast majority of 

acres included within these proposed project areas, 

irrigation would not occur within the giant 

miscanthus fields. When compared to irrigated 

corn, giant miscanthus would be anticipated to use 

less water. 

28 7

Lack of detail on alternative crops evaluated and 

not considered in the EA including additional and 

specific detail regarding these other areas and 

what led to the justification of the target 

geographies in Arkansas, Missouri, Ohio, and 

Pennsylvania.

Alternatives 

Analyzed NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

The Project Sponsors are proposing a specific 

project for inclusion within the BCAP. The 

reasonable alternatives under consideration are (1) 

the Proposed Action, which implements the Project 

Sponsors plan or (2) the No Action Alternative, 

which would not implement the Project Sponsors 

plan. The Project Sponsors are not required to 

propose alternative species or project locations 

under NEPA.
Page 24 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

28 8

Insufficient assessment of impacts to state-listed 

or state special-concern wildlife, particularly due 

to conversion of pasture to miscanthus given that 

miscanthus is not a food source for wildlife, and 

will affect several species of conservation need, 

including migratory birds, as well as statemanaged game species (e.g., turkey and deer)State-listed 

Species NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

Further clarification would be provided to ensure 

that site-specific conditions do not create adverse 

effects to State-listed species. Species of concern, 

but not protected under State law/regulation, 

Federal laws/regulations, or tribal regulation would 

be considered to the extent of management by the 

appropriate entity. Site specific Conservation 

Planning would address wildlife best management 

practices that meet the needs of locally occurring 

protected species. No taking of a protected species 

would be allowed without appropriate consultation 

with the U.S. Fish and Wildlife Service and the 

appropriate State agency. 

28 9

Conversion of pasture to miscanthus will affect 

some state listed plants, such as Carex pallescens

(pale sedge), and wildlife such as grassland 

nesting birds of the Ashtabula area such as 

bobolink, grasshopper sparrow, and Henslow's 

sparrow, by removing habitat and food sources 

for those species.

State-listed 

Species NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

Further clarification would be provided to ensure 

that site-specific conditions do not create adverse 

effects to State-listed species. Species of concern, 

but not protected under State law/regulation, 

Federal laws/regulations, or tribal regulation would 

be considered to the extent of management by the 

appropriate entity. Site specific Conservation 

Planning would address wildlife best management 

practices that meet the needs of locally occurring 

protected species. No taking of a protected species 

would be allowed without appropriate consultation 

with the U.S. Fish and Wildlife Service and the 

appropriate State agency. 

28 10

Lack of detail regarding plans for long-term 

monitoring for and eradication of escaped plants, 

including specific roles and responsibilities of 

contracted producers, Project Sponsors, or FSA if 

such an escape is detected).

Long-term 

Monitoring NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies See below.
Page 25 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

28 11

Any monitoring to determine if giant miscanthus 

has escaped or become invasive must occur not 

only in those non-project fields in close proximity 

to those planted with miscanthus, but also on the 

roadways that lead to the processing facility, the 

area around the processing facility and the area 

where harvesting equipment is stored. 

Harvesting will occur after seed set and as with 

other invasives, such as spotted knapweed, the 

seed can blow from trucks and harvesting 

equipment while traveling roadways.

Long-term 

Monitoring NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

The Project Sponsors, as part of the MMP, will 

outline a long-term monitoring plan for potential 

escape and control of giant miscanthus. As part of 

the Quality Assurance Program with the OSIA, the 

Project Sponsors have agreed to thoroughly clean 

equipment used for planting, harvesting, and 

transporting giant miscanthus rhizome materials. 

The MMP will detail, the steps to occur if viable 

seed are found through the seed sampling program. 

These steps could include (1) halting any harvest of 

the identified field with no off-site movement of any 

material harvested from that field, (2) immediate 

removal of existing inflorescences in the field that 

was found to contain viable seeds, (3) resampling of 

those inflorescences at a greater rate to determine 

an approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.

28 12

Monitoring for invasiveness should occur over the 

course of 20-40 years, as many invasives manifest 

themselves after several decades have passed. 

There does not appear to be any provisions or 

discussion of long-term monitoring.

Long-term 

Monitoring NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

The Project Sponsors will continue the MMP 

through the life of the contract between the 

producer and the Project Sponsor, which can be 

renewed in perpetuity.

28 13

The EA mentions several times that giant 

miscanthus can be eliminated through a 

combination of tillage and herbicides and that 

herbicides alone may not be effective. This 

presumes that the plants are in an area that can 

be tilled. If they escape onto roadsides, natural 

areas or other idle lands, then tillage is not an 

option and the process for eliminating those 

plants will be long and expensive. There is no 

discussion on who will be responsible for these 

costs of eradication of escaped plants. Eradication NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

As detailed in the MMP, the responsibility for 

control lies with the producer and the Project 

Sponsor, should the producer fail to control any 

spread that is identified during monitoring of the 

fields. The MMP would minimize the potential for 

spread for this species through BMPs, which include 

ongoing seed sampling of inflorescences, and active 

management and monitoring, including the sitespecific Conservation Plan measures. 
Page 26 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

28 14

Insufficient assessment of potential for escape 

and invasion outside of project areas (including 

due to natural causes such as tornados, floods, 

high wind, etc.)

Vectors for 

Escape NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

Anecdotal evidence indicates a low potential of 

vegetative spread through live stems transported 

through natural mechanisms. Additionally, 

published literature indicates a low likelihood of 

rhizome spread outside of intentional plantings, 

since the rhizome is likely to desiccate if transported 

and not planted (i.e., provided adequate soil 

coverage). Site-specific conditions could be 

included in the Conservation Plan to increase buffer 

width or exclude certain land areas from giant 

miscanthus planting, if determined to increase the 

risk of spread outside an acceptable level that can 

be controlled by the producer. 

28 15

Insufficient assessment of the host relationship of 

miscanthus with western corn rootworm, 

including the potential for rootworm spread and 

economic impact on non-project areas and food 

crops (e.g., neighboring cornfields).

Pests & 

Diseases NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

Published literature was cited in the Draft EA 

concerning the potential for western corn rootworm 

to occur in giant miscanthus. Further detail has 

been included in the MMP, which has been drafted 

and revised from consultation with NRCS and ARS. 

Monitoring for pests and diseases is included as part 

of the MMP and would be adjusted accordingly 

based on the site-specific Conservation Plan.

28 16

Inadequate discussion of historic record of 

containment of "sterile" hybrid plant material; 

attempts have been unsuccessful in the past, e.g., 

purple loosestrife, which outcompeted native 

wetland vegetation resulting in the loss of 

wetland habitat, and cost millions of dollars in 

invasive species control. Specifically, vegetative 

hybrids may produce viable seed over time if 

crossed with other species of the same genus; 

resulting escapes could be similar or worse than 

previously documented escapes of other 

miscanthus genera in Pennsylvania affecting 

several hundred acres of private lands and public 

rights of way. Seed Sterility NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

Many of the species cited were introduced to the 

U.S. in the 19th century or through inadequately 

assessed horticultural varieties prior to many of the 

safeguards that were put in place within the last few 

decades. This clone of giant miscanthus has been 

grown in field trials since 2002 without escape from 

these areas. There is also little evidence from 

European experience of invasive potential for this 

hybrid. 
Page 27 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

28 17

Insufficient discussion of ornamental plantings of 

Miscanthus sinensis and M. sacchariflorus or 

other members of the Miscanthus genus in 

Europe and their proximity to established stands 

of giant miscanthus. The literature suggests that 

not all triploid hybrids are sterile even those 

thought to be sterile produce some viable pollen, 

but not enough to pollinate in most cases. It is 

also possible for triploid hybrids to mutate and 

have plants that no longer exhibit the sterility 

trait. Seed Sterility NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

The Project Sponsors would be willing to exclude 

acreage within 400 m (approximately 1,300 feet) 

from any known Miscanthus sinensis or Miscanthus 

sacchariflorus invasion to limit the potential for 

cross-pollination resulting in viable seed. This 

distance is the maximum distance observed in 

Quinn et al. 2011. Additionally, the Project 

Sponsors have committed to a seed sampling 

program to track the potential viability of the giant 

miscanthus acres included within their project 

areas.

28 18

Insufficient assessment of the effects of altering 

the vegetation in "idle or not active" lands on 

both the plant and wildlife communities 

(including specific consideration of state- or 

regionally-protected species, and lands currently 

enrolled Conservation Reserve or related 

Programs). Land Use NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

The Project Sponsors would be willing to exclude 

any acreage currently located within a contracted 

conservation program, in which the producer breaks 

that contract, for the remaining length of that 

contract. Further clarification of the idle land use 

will be provided in the Final EA, to clearly define 

those lands to be included within the contract 

acreage. 

28 19

There is no definition of "idle" and it is a major 

concern, and a potentially major negative impact 

on wildlife, if "idle" lands are those enrolled in 

Conservation Reserve or other conservation 

Program land contracts and serve as wildlife 

habitat. If such habitat will be converted to 

miscanthus, then the conclusion that the 

"impacts to wildlife from this project are 

minimal" are unfounded and that determination 

needs to be revised. Land Use NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

The Project Sponsors would be willing to exclude 

any acreage currently located within a contracted 

conservation program, in which the producer breaks 

that contract, for the remaining length of that 

contract. Further clarification of the idle land use 

will be provided in the Final EA, to clearly define 

those lands to be included within the contract 

acreage. 

28 20

Insufficient assessment of the indirect conversion 

of lands (i.e., pasture converted to Miscanthus, 

and thus forested lands converted to pasture in 

replacement. Land Use NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

Further clarification will be provided in the Final EA, 

to provide an analysis of the livestock industry 

within the project areas that could cause indirect 

land use changes, from NIPF to pasturelands. It 

appears that livestock production in the Paragould 

and Ashtabula project areas accounts for less than 

five percent of the statewide totals for cattle. 
Page 28 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

28 21

Economic considerations beyond agricultural 

entities (e.g., fish and wildlife recreation and 

tourism impacts).

Outdoor 

Recreation NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

Public hunting access on private lands will be 

discussed in greater detail in the Final EA; however, 

lands included under state access programs, such as 

the Cooperative Farm-Game Program in 

Pennsylvania are under contract with the state. This 

contract is for five years or longer and stipulates 

that wildlife management activities must occur on 

those acres in combination with a Conservation 

Plan. As such, it would be unlikely that the state 

would approve the planting of giant miscanthus on 

those acres, and the Project Sponsors would exclude 

those acres for the remaining length of the contract 

period, if the contract is broken. 

28 22

Inadequate assessment of nutrient losses due to 

the assumption that no or minimal nutrient 

amendments will be used for this biomass crop.

Nutrient 

Application NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

Further clarification would be provided to ensure 

that the Final EA clearly indicates the increased 

potential to trap suspended sediment and nutrients 

in stormwater flows by the perennial vegetative 

structure of giant miscanthus. Additionally, more 

detail or clarification would be provided to indicate 

the nutrient requirements and applications for giant 

miscanthus plantings.

28 23

Lack of detail regarding development of BMPs for 

wildlife; these must be developed with and 

approved by state fish and wildlife agency.

Mitigation 

Measures NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

Detailed wildlife BMPs would be included in the 

site-specific Conservation Plan for each producer. 

Unless protected species are located on contract 

acreage, there is no precedent to include State 

wildlife agencies in the Conservation Planning 

process, unless the producer chooses that 

consultation as part of the development of the 

Conservation Plan.

28 24

Insufficient assessment of resources eliminated 

from detailed analysis, including: General NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies No response required. 

28 25

wetlands (these may be invaded by miscanthus 

via rhizomes, and if so, the expense of eliminating 

miscanthus from complex wetland communities 

would be extremely high, and the process would 

be difficult Wetlands NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

Wetlands are excluded acreage per BCAP, as such 

no wetlands would be intentionally planted to giant 

miscanthus. Site-specific Conservation Plans would 

be used to increase buffer widths adjacent to 

sensitive areas, such as wetlands and aquatic areas, 

if the conditions of the contract acreage warrant.
Page 29 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

28 26

potential for rhizomes spread into floodplains by

flooding is great due to vegetative dispersal along 

watersheds by the movement of rhizomes via 

watercourses during normal rain, high flow and 

flood events (Japanese knotweed has spread 

similarly via rhizomes) Floodplains NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

The amount of floodplains within the proposed 

project areas will be detailed within the Final EA. 

Within the Ashtabula area, approximately five to 

seven percent would be within the 100-year 

floodplain. Site-specific Conservation Plans would 

be used to increase buffer widths adjacent to 

sensitive areas, such as wetlands and aquatic areas, 

if the conditions of the contract acreage warrant.

28 27

Lake Erie is considered a regulated coastal zone

under the authority of the Army Corps of 

Engineers, thus it is unclear why these resources 

were eliminated when the proposed project areas 

in Ohio and Pennsylvania border this Lake.

Coastal 

Zones NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

The Project Sponsors will exclude any acreage 

included within the managed coastal zones of Lake 

Erie to ensure compliance with the USACE 

regulations or Coastal Zone Management 

regulations. 

28 28

Fish and wildlife recreation and outdoor tourism 

are strong industries in some of the proposed 

project areas; conversion of large segments of the 

landscape to miscanthus will have a significant 

impact on land cover within the project areas. If 

wildlife habitat and hunting areas are converted 

to M.x giganteus, this would represent a 

significant loss of potential hunting areas for 

upland small games in defined areas of Ohio and 

Pennsylvania. Hunting is a significant economic 

influence in rural areas, and the loss of habitat 

will result in losses in revenue to hotels, motels, 

gas stations, convenience stores and sporting 

goods stores in and around the proposed area. 

Outdoor 

Recreation NA D.C. 20001 NGO

Association 

of Fish & 

Wildlife 

Agencies

Public hunting access on private lands will be 

discussed in greater detail in the Final EA; however, 

lands included under state access programs, such as 

the Cooperative Farm-Game Program in 

Pennsylvania are under contract with the state. This 

contract is for five years or longer and stipulates 

that wildlife management activities must occur on 

those acres in combination with a Conservation 

Plan. As such, it would be unlikely that the state 

would approve the planting of giant miscanthus on 

those acres, and the Project Sponsors would exclude 

those acres for the remaining length of the contract 

period, if the contract is broken. 

29 1

I have been following the use of Miscanthus x 

giganteus as a home grown replacement for fossil 

fuels since the initial publication of the Billion Ton 

Report. General NA CA 93442 Individual None

Comment noted on the support of the proposed 

action. 

29 2

1) Miscanthus has a long history of replacing coal 

in the EU. Currently, over 1 million tons are being 

used annually by Drax power in the UK and there 

are several thousand mature hectares being used 

throughout the Continent to replace solid fossil 

fuels and create liquid fuel via gassification.

Biomass 

Feedstock NA CA 93442 Individual None

Comment noted on the support of the proposed 

action. 

29 3

2) Decades of study in the EU and at universities 

in the US have demonstrated that Miscanthus x 

giganteus is a sterile non-invasive plant that 

requires far less chemical inputs than a crop like 

corn. In fact, Miscanthus has a positive energy 

balance throughout its life cycle from growing to 

end use. Sterility NA CA 93442 Individual None

Comment noted on the support of the proposed 

action. 
Page 30 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

29 4

3) Miscanthus is one of the best plants for 

sequestration of atmospheric carbon, removing 

more CO2 than it emits from growth 

establishment to use. It has a positive carbon 

balance which is not true of corn used for fuel.

Carbon 

Sequestratio

n NA CA 93442 Individual None

Comment noted on the support of the proposed 

action. 

29 5

4) Miscanthus provides sufficient tonnage per 

acre to make it economically viable and 

sustainable for farmers at levels for their own use 

or commercially. 

Economic 

Viability NA CA 93442 Individual None

Comment noted on the support of the proposed 

action. 

29 6

5) Miscanthus could replace a major percentage 

of fossil fuels that are dangerous because of 

unreliable sources and proven environmental 

damage.

Fossil-Fuels 

Replacement NA CA 93442 Individual None

Comment noted on the support of the proposed 

action. 

29 7

6) Miscanthus will provide clean sustainable rural 

economic growth.

Rural 

Economic 

Growth NA CA 93442 Individual None

Comment noted on the support of the proposed 

action. 

29 8

7) Miscanthus supplies yields (2-3 times the Btu 

per acre of corn) that will mean millions of corn 

acres used for ethanol can be returned to food 

and feed production, while still increasing overall 

ethanol production levels. Higher Yields NA CA 93442 Individual None

Comment noted on the support of the proposed 

action. 

29 9

8) Because of its very low need, (if any) for 

applied nitrogen, miscanthus vastly mitigates run 

concerns off and improves soils.

Nutrient 

Application NA CA 93442 Individual None

Comment noted on the support of the proposed 

action. 

29 10

9) Studies have shown that natural habitat is 

enhanced by miscanthus. It requires only one 

annual disturbance in the field. It harbors birds, 

beneficial insects, small mammals and deer. Wildlife NA CA 93442 Individual None

Comment noted on the support of the proposed 

action. 

29 11

In summary, Miscanthus x giganteus can 

significantly and beneficially effect US energy 

independence, energy price stability, rural 

economies, and the environment. BCAP project 

areas should be immediately approved. General Support CA 93442 Individual None

Comment noted on the support of the proposed 

action. 

30 1

“I support the approval of Aloterra Energy’s BCAP 

applications and I support the use of Miscanthus 

as an energy crop to meet America’s renewable 

energy needs.” General Support Individual None

Comment noted on the support of the proposed 

action. 

31 1

I support the approval of Aloterra Energy’s BCAP 

applications and I support the use of Miscanthus 

as an energy crop to meet America’s renewable 

energy needs. This is the best green renewable 

energy source that I am aware of and is one of 

the few that is economically feasible on its own 

merits, which is demonstrated by its use in the UK 

in electric power generation. General Support CO 80123 Individual None

Comment noted on the support of the proposed 

action. 
Page 31 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

32 1

I support the approval of Aloterra Energy’s BCAP 

applications and I support the use of Miscanthus 

as an energy crop to meet America’s renewable 

energy needs. General Support TX 77380 Individual None

Comment noted on the support of the proposed 

action. 

33 1

I urge you to not approve the BCAP 

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, 

(the Draft), and to deny all BCAP subsidies to 

these proposed projects. General Against IN 47432 Individual None No response required. 

33 2

The use proposed for the miscanthus to be 

grown is making fuel pellets of it, pellets which 

will presumably be burned to produce heat. Fuel 

pellets made of cellulosic woody material have 

been used for many, many years in the United 

States as a fuel These pellets are generally made 

of woody material, and are sold virtually across 

the nation as pellet stove heating fuel; thus, the 

market for fuel pellets of woody material is a 

mature market. The biomass proposed to be 

used from Miscanthus is woody material. It is 

proposed to be made into fuel pellets. 7 CFR, 

Section 1450.2, as shown in Federal Register Vol. 

75, No., 207, Wednesday, October 27, 2010, 

Definitions-Biobased Product states: “Products 

that have a mature market...will not be 

considered to be biobased products for the 

purposes of BCAP.”

Biomass 

Products NA IN 47432 Individual None

The BCAP establishment and annual payments are 

provided to the establishment and production of 

bioenergy crops. FSA has no control over the 

materials once it leaves the field for conversion into 

another product. As such the project definition is 

limited to establishment and production of giant 

miscanthus only, not any related downstream issues 

that FSA cannot control or regulate. 

33 3

 In the matter of Liberty Green Renewables 

Indiana, LLC, application for a Title V air operating 

permit, EPA agents made it clear that mere 

change of size of fuel particles did not make the 

LGRI facility a Fuel Conversion Facility; a Fuel 

Conversion Facility would change the nature or 

physical state of the fuel, as in a change from 

solid to gas or liquid. General NA IN 47432 Individual None No response required. 
Page 32 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

33 4

 By the above two paragraphs, the proposed 

Biomass Conversion Facilities will not qualify as 

qualified biomass conversion facilities under 

BCAP. The BCAP BCF qualified list shows only 

three facilities, two in South Dakota and one in 

Iowa; these are not proposed as end consumers 

of the proposed miscanthus. There is no reason 

to further consider this Draft; it should be 

refused, denied, and terminated with prejudice.

Biomass 

Conversion 

Facility NA IN 47432 Individual None

The BCAP establishment and annual payments are 

provided to the establishment and production of 

bioenergy crops. FSA has no control over the 

materials once it leaves the field for conversion into 

another product. As such the project definition is 

limited to establishment and production of giant 

miscanthus only, not any related downstream issues 

that FSA cannot control or regulate. 

33 5

Further, and affirmatively: The sole specified 

possible consumers of the pelletized miscanthus 

are the University of Missouri’s new CHP boiler to 

be operational in 2012, and the State of Missouri 

in some unspecified manner because of its 

renewable energy portfolio. The Univ. of MO’s 

boiler is reported to be anticipated to use 100K 

tons per year of biomass from Missouri, not other 

states, and that biomass is stated to include wood 

chips and wood waste. Miscanthus pellets are 

not mentioned as fuel in reports on the boiler, 

not in an industry report nor in the Mizzou 

Weekly report of 5 May 2011. Mizzou Weekly 

uses a missouri.edu web address; it must be part 

of the university. Thus, the sole specifically cited 

possible combustor-for-domestic-energy 

consumer of these proposed miscanthus pellets 

has no current reported interest in them; the 

market is only a possibility at best. This Draft 

states farmers have signed up, but no BCFs 

independent of MFA Oil Biomass, Llc’s proposed

–only proposed– pelletization operations have 

signed up.

Biomass 

Products NA IN 47432 Individual None

The BCAP establishment and annual payments are 

provided to the establishment and production of 

bioenergy crops. This environmental assessment is

for one particular project area proposal being 

provided by the Project Sponsors. FSA for BCAP 

must either approve the project areas proposal 

after the appropriate processes are complete per 

statute and regulatory guidance or decline to accept 

the project area proposal. The process of approving 

the project area does not need to include specific 

producer acreage, at this point. FSA, after the 

project area has been approved, would solicit 

contract acreage from producers within the project 

areas. The BCAP is a voluntary program that 

producers enter based on their willingness and 

economic viability for production of the project 

areas species. Each producer entering acreage 

under these project areas would be required to 

follow all requirements of the Mitigation and 

Monitoring Plan, in addition to all other BCAP 

requirements within the site-specific Conservation 

Plan.
Page 33 of 128

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33 6

 Land impacts– Pastureland is still productive 

agricultural land, providing animals useful for 

food, wool and leather, and for human activity, 

from draft animals to pleasure horses. The 

Ashtabula project is to be 10% marginal crop 

land, but crop land, nonetheless. Fallow fields, 

which can be part of a crop rotation cycle are 

considered pasture in section 4.4.1.2. Inattention 

to detail on the part of the compiler of this Draft 

is shown in the inclusion of an average of land 

parcels anticipated to be used for miscanthus.

The average is listed as 38-100 acres; an average 

would be a single number, not a range. Land Use NA IN 47432 Individual None

Pastureland, per the USDA NASS definition, includes 

all permanent or rangeland regardless of quality. 

This land type can provide high quality native 

grasslands or it can be previously disturbed early 

successional annual dominated areas. The average

contract size is the average range across all 

proposed projects areas. At this time, there are no 

producers accepted into the project areas, so a 

determination of true average field size cannot be 

determined unless the project areas are approved 

by FSA. After approval, field size will be one metric 

reported during the Annual Report provided by the 

Project Sponsors to FSA, as part of the Final 

Mitigation and Monitoring Plan.
Page 34 of 128

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33 7

 Invasiveness– Even IDEM, the environmental 

management agency of Indiana, the state listed 

by Forbes as next to the worst in environmental 

matters, has published concern about the 

invasiveness of miscanthus giganteus 

(Assessment of Miscanthus sinensis and 

Miscanthus x giganteus in Indiana’s Natural Areas 

Assessment conducted March 20, 2007 by Ellen 

Jacquart, Phil O’Connor, Ken Collins, Dave 

Gorden, Jeff Kiefer, Kate Howe) Invasive NA IN 47432 Individual None

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.
Page 35 of 128

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33 8

Miscanthus giganteus, although presently not 

known to propagate except by rhizome 

extension, has the potential to spontaneously 

change to a fertile invasive species. Such has 

happened before, in a different hybrid. The 

history of the formerly sterile Spartina anglica, 

now an invasive plant, and the biological 

mechanism by which this sterile hybrid grass 

became fertile is available in: Nehring, S. and 

Adsersen, H. (2006): NOBANIS – Invasive Alien 

Species Fact Sheet – Spartina anglica. – From: 

Online Database of the North European and Baltic 

Network on Invasive Alien Species - NOBANIS 

www.nobanis.org, Date of access 05/07/2011. Seed Sterility NA IN 47432 Individual None

Complete history of this species indicates that a 

non-sterile species could have been planted instead 

of the sterile species due to the difficulty in 

separating the two species. Additionally, there had 

been indications that S. anglica reverted to a fertile 

state with relative ease. The giant miscanthus 

hybrid has not shown such traits based on the ongoing field trials are recent larger scale plantings in 

Europe. The Project Sponsors are aware of the 

concern of cross-pollination with one of the parent 

species. As such, an exclusion would be included 

within the producer contracts that would not allow 

giant miscanthus to be planted within 400 meters 

(approximately 1,300 feet) from an existing 

infestation of Miscanthus sinensis or Miscanthus 

sacchariflorus or ornamental planting of these or 

other Miscanthus species to greatly reduce the 

probability of cross-pollination and production of 

viable seed.

33 9

 Control of environmental risks/impacts is to be 

according to an MMP to be developed in the 

future. The MMP should be extant now, with 

revisions to be made as evidence of need arises.

The Draft clearly shows environments will be 

affected by these miscanthus projects. A plan for 

mitigating these effects should exist before the 

projects begin and be available as part of this 

Draft, for public comment now.

Mitigation 

Measures NA IN 47432 Individual None

The Mitigation and Monitoring Plan was provided in 

a draft form in the Draft EA to allow for public input 

and comment on the features to be included. 

Overall, comments from the public and agencies 

have provided a great deal of additional information 

to include in the Mitigation and Monitoring Plan as 

best management practices or exclusions of 

acreage.
Page 36 of 128

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33 10

 Page 4-15, lines 7, 8 state: “At maturity, these 

stands could have a decline in biodiversity if field 

margins shrink as the fields become fully 

mature.” Maturity is at three years. This project 

could reduce biodiversity for a decade and a half 

or more. Could seems a carefully misleading 

choice of word. Since the Draft indicates Europe 

has grown miscanthus for 30 years, the Draft 

should clearly state and cite references for 

whether or not biodiversity has been and will be 

decreased by the crop. Biodiversity NA IN 47432 Individual None

There have been few published studies on the 

effects of biodiversity of this crop at maturity from 

Europe. Of the biodiversity studies, they have 

mostly focused on younger aged stands or 

anecdotal information, such as field observations. 

33 11

 Page 4-14, lines 11-13,states that the impact on 

the environment will be more with miscanthus 

crops than with fallow fields, which the Draft 

indicates comprise fallow land and pastures. Page 

4-16, lines 29-31, shows there will be erosion 

during the first year or three (establishment) of 

the projects, when there is no miscanthus leaf 

mulch. This erosion will be a permanent loss of 

that soil eroded. The Draft does not but should 

state the amount of soil loss to be expected from 

initiation of the projects through the majority of 

the projects, including post-project restoration of 

the land. Further, the crop is bound to sequester 

minerals from the soil. These may be absorbed 

from the subsoil, or they may come from the 

topsoil, in which latter case re-mineralization of 

the project fields will be required for soil fertility 

when the project ends. The Draft should but 

does not address this.

Soil 

Resources NA IN 47432 Individual None

Further clarification has been provided on the 

potential for soil erosion.

33 12

 Page 4-16 raises several questions. Twenty-two 

percent of the root mass is not below ground, 

raising serious concerns about the viability of the 

crop due to frost damage to the root. 

Accumulated carbon input isn’t defined. It is 

impossible to believe 26-29% of the carbon fixed 

by the plant thru photosynthesis is stored in the 

root system. Further, Hansen, et al (2004) only 

estimated, when he should have calculated from 

measurements, soil carbon sequestration. If 

accumulated carbon input does not consist of all 

carbon fixed by the plant, then the Draft should 

state what becomes of the other 71-74% of the 

accumulated carbon input.

Carbon 

Sequestratio

n NA IN 47432 Individual None

Twenty-two percent of the root mass is between 30-

90cm. Hansen et al (2004) provides a description of 

how soil organic carbon contribution of miscanthus 

was calculated from stands of nine year old and 16-

year old plantings. A large portion of accumulated 

carbon from miscanthus is captured in the 

harvestable biomass, the above-ground recycling, 

and the below-ground recycling of biomass. 
Page 37 of 128

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33 13

 Pages 4-17&18, lines 30-3, state fertilizer and 

pesticide pollution of waters could increase from 

the proposed projects, compared to current use.

This shows a clear need for an MMP to be extant 

now, not in the nebulous future, as the Draft 

acknowledges the risk. Twisted Oak Corporation,

for its miscanthus biomass proposal submitted to 

the City of Jasper, Indiana, indicated no fertilizer 

would be necessary for the production of 

miscanthus giganteus. There appears to be 

misinformation disseminated by the industry.

Fertilizer 

Use, 

Mitigation 

Measures NA IN 47432 Individual None

As stated in Section 2.2.2.1, fertilization would be 

required at a recommended rate of approximately, 

eight pounds of nitrogen, 1.5 pounds of 

phosphorus, and eight pounds of potassium per dry 

ton of biomass produced. However, soil testings at 

the local level could reduced or increase these 

amounts, due to the variability of soil types, 

moisture content, and conditions across the project 

areas. These rates are the average recommended 

for this crop based on field trials and European 

experience. 

33 14

 Table 4-4 shows a minor improvement in soil 

resources due to the proposed projects, this 

primarily during the establishment period. This 

directly contradicts the text of pages 4-16, 4-17, 

and 6-3, and calls into question the validity of 

information in this Draft.

Soil 

Resources NA IN 47432 Individual None

Further clarification has been provided on the 

potential for soil erosion. The text error in the table 

has been corrected.

33 15

 Page 5-3. Lines 17-18, state wildlife which use 

land affected by these projects can relocate 

temporarily to other lands. Since miscanthus will 

provide little if any winter cover and no wildlife 

food, as per Draft text, this temporary relocation 

is for the life of these projects: up to 21 years.

The Draft should address this impact, unless this 

wildlife is considered expendable. The impacts 

upon wildlife expressed on page 6-5 sound much 

more severe than those discussed earlier in the 

Draft. Biodiversity NA IN 47432 Individual None

Miscanthus does provide winter cover as indicated 

through information provided by active fields 

observed for wildlife use in Illinois, outside of the 

University of Illinois field trials. 

33 16

Water use, as stated in the Draft, seems 

inaccurate. Page 4-19, Lines 14-15, state 

irrigation would be necessary only in the first 

year. However, should rainfall be insufficient in 

late summer and fall, without irrigation, crop 

yield will plummet. Page 4-18 into 4-19 indicate 

irrigation of even the mature crop will be 

necessary in at least some of the projects’ areas. Water Use NA IN 47432 Individual None

Further clarification to water use has been provided 

in reference to both comparisons of corn for grain 

and corn for silage. There would be no irrigation of 

giant miscanthus within these project areas after 

initial establishment this growing season. There was 

no indication based on available data that these 

project areas contain substantial amount of 

irrigated croplands. Average annual precipitation 

greater than 30 inches should be sufficient for the 

production of giant miscanthus. 
Page 38 of 128

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33 17

 The water usage per kilogram of biomass of 

miscanthus is cited as 100-300 liters. This should 

be a single average number of liters for each 

project area, as 300 liters/kg is the cited average 

water usage of corn and soybeans. In light of 

other equivocal parts of the Draft, this section

could and should be interpreted as showing 

miscanthus is capable of using just as much water 

per kilogram of biomass yield as corn and 

soybeans. Water Use NA IN 47432 Individual None

Water use has been furthered clarified and new 

literature is provided. This also includes a 

comparison with corn for silage, which is a crop that 

has enough data to be released in Pennsylvania. 

This provides a more description range of existing 

water uses within these areas. 

33 18

 Page 4-20, beginning paragraph, compares 

water consumption of the proposed project not 

to existing vegetation but to that preceding 

current land use. This appears to be a deceitful 

ruse that should not be allowed to stand. Water Use NA IN 47432 Individual None

Further clarification to water use has been provided 

in reference to both comparisons of corn for grain 

and corn for silage. There would be no irrigation of 

giant miscanthus within these project areas after 

initial establishment this growing season. There was 

no indication based on available data that these 

project areas contain substantial amount of 

irrigated croplands. Average annual precipitation 

greater than 30 inches should be sufficient for the 

production of giant miscanthus. 

33 19

 For at least the above reasons, I ask and urge 

you to reject both this Draft and these proposed 

projects for BCAP subsidies. Our nation will not 

benefit from deficit spending subsidization of 

combustion of biomass for electricity. That 

industry is neither clean nor, in the absence of 

government subsidies, economically viable on an 

industrial scale. The health care costs and human 

suffering potentially caused by that industry’s 

pollution will further burden our nation. Please 

deny these projects all BCAP approval and 

subsidies. General Against IN 47432 Individual None No response required. 
Page 39 of 128

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34 1

I am writing to support the BCAP Project Area 

application for Ashtabula, Ohio. As a farmowner 

with my brothers in Ashtabula County, I feel the 

BCAP program creates enough temporary 

economic incentives to move my brothers and 

other farmers in my region to commit land to 

dedicated energy crops. Due to the economics 

causing the decline of the small family farm, our 

land has lain fallow for the past 30 years and is 

ready to again produce a cash crop that will 

capture the sun’s energy and water and 

contribute to the area’s rebirth and energy 

supply. Our nation has spent decades talking 

about energy independence and setting high 

goals for transitioning our energy supply from 

foreign sources to domestic sources. No group or 

organization in America is more capable of 

providing this necessary energy supply than 

America’s farmers. Critically, Miscanthus is the 

only energy crop that is perennial, non-invasive, 

and provides enough tons per acre to make 

economic sense. Dedicated energy crops are the 

most practical solution to a number of issues 

facing our nation. It provides my family with a 

new cash crop, will ensure economic 

development in rural communities, and will 

provide a home grown, reliable, base load energy 

supply that America desperately needs. General Support NV 89410 Individual

Shellhammer FarmComment noted on the support of the proposed 

action. 

35 1

I support the approval of Aloterra Energy's BCAP 

applications and I support the use of Miscanthus 

as an energy crop to meet America's renewable 

energy needs. General Support TX 77002 Individual

Seyfarth 

Shaw LLP

Comment noted on the support of the proposed 

action. 

36 1

I support the approval of Aloterra Energy's BCAP 

applications and I support the use of Miscanthus 

as an energy crop to meet America's renewable 

energy needs. General Support OH 43604 Local-NGO

ToledoLucas 

County Port 

Authority

Comment noted on the support of the proposed 

action. 

37 1

I support the approval of Aloterra Energy's BCAP 

applications and I support the use of Miscanthus 

as an energy crop to meet America's renewable 

energy needs. General Support CO 80203 Individual

Plexus 

Capital, LLC

Comment noted on the support of the proposed 

action. 

38 1

I support the approval of Aloterra Energy's BCAP 

applications and I support the use of Miscanthus 

as an energy crop to meet America's renewable 

energy needs. General Support WA Individual None

Comment noted on the support of the proposed 

action. 
Page 40 of 128

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39 1

The EA evaluated Environmental Consequences 

of the Proposed Action in six general areas: 1) 

Data Gaps; 2) Land Use; 3) Socioeconomics; 4) 

Biological Resources; 5) Soil Resources; and 6) 

Water Quality and Quantity. My comments will 

address certain ‘conservation aspects’ of each of 

these areas (except Socioeconomics), as well as 

the Mitigation and Monitoring section. General NA GA 30605 Individual None No response required. 

39 2

Overview: Miscanthus x giganteus is a large, 

clump forming, C4, perennial grass from s.e. Asia. 

It is an almost completely sterile triploid hybrid 

(2n=3x=57) of M. sinensis (diploid; 2n=38) and M. 

sacchariflorus (tetraploid; 2n=76). The hybrid and 

its numerous cultivars have been developed 

artificially, but recent evidence suggests it may be 

a naturally occurring hybrid (Nishiwaki et al. 

2001). Both parents of the hybrid are considered 

invasive in many parts of the world, especially M. 

sinensis which produces viable seed as both a 

species and as numerous cultivars. Although the 

pure species has been largely removed from the 

horticultural trade in the U.S., it was planted as 

an ornamental for nearly 100 years and those 

plants have spread invasively in the eastern U.S. 

Its supposedly ‘sterile’ cultivars can also produce 

viable seed when they cross with each other or 

back cross with the species.

Species 

Information NA GA 30605 Individual None No response required. 

39 3

It has been grown in Europe for about 25-30 

years where there is considerable interest in it as 

a biofuel/biofeedstock. In the U.S. it has been 

primarily cultivated on a trial basis and tested in 

the upper Midwest (e.g., Illinois). The Univ. of 

Georgia is also part of the research effort. General NA GA 30605 Individual None No response required. 
Page 41 of 128

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39 4

I think it’s safe to say that the ‘genie is out of the 

bottle’ as far as the development of biofuels is 

concerned. And there’s no putting it back given 

America’s demand for energy, dwindling 

domestic oil reserves, dependence on foreign 

suppliers (with accompanying political, foreign 

policy, and national security implications), 

concern for addressing climate change and 

reducing carbon footprints, and ramped up 

capital investment and speculation – all greatly 

enabled by the federal renewable fuel standard 

outlined in the Energy Security and Independence 

Act of 2007. There are certainly positive aspects 

to biofuel development and use, but the biofuel 

craze has the potential to become a ‘run-away 

train’. Some advocates of biofuels have labeled 

any objections, cautionary statements, or 

regulations as obstructionist and even “unAmerican..” Some have gone so far as to label 

invasion biologists as “eco-Nazis” (Simberloff 

2003).

Biofuel 

Concerns NA GA 30605 Individual None

The BCAP establishment and annual payments are 

provided to the establishment and production of 

bioenergy crops. The Project Sponsors are 

proposing a specific project for inclusion within the 

BCAP. The reasonable alternatives under 

consideration are (1) the Proposed Action, which 

implements the Project Sponsors plan or (2) the No 

Action Alternative, which would not implement the 

Project Sponsors plan. The Project Sponsors are not 

required to propose alternative species, methods, 

or project locations under NEPA.

39 5

There are essentially two broad issues here: 1) 

the effect on the environment (incl. native plants 

and animals) from the cultivation of biofuels, in 

general, and 2) the specific deleterious effects of 

using non-native species (even mostly sterile 

ones) for this purpose. The first issue is focused 

primarily on land use changes as more acres are 

put into cultivation of biofuel crops. The second 

issue focuses primarily on the potential 

invasiveness of the specific crop species. Both 

issues impact native vegetation, wildlife, and 

soil/water resources. General NA GA 30605 Individual None No response required. 
Page 42 of 128

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39 6

I. Environmental Consequences. A. Data Gaps: 

The EA acknowledges that “certain information 

has been found to lack complete detail in relation 

to growth and production of giant miscanthus in 

the United States.” Almost no peer-reviewed 

literature exists for landscape scale analyses of 

any kind or the specific effects on biological 

diversity in the U.S. Some literature exists for 

potential plant pests, soil related issues (nutrient 

cycling, organic matter, erosion, carbon 

sequestration, etc.), and water related issues 

(water use efficiency and irrigation needs). The 

EA does reference available literature. Although 

the EA states that it has “documentation 

supporting that giant miscanthus should not be 

considered invasive due to its sterility and slow 

rhizome spread”, it nevertheless identifies 

‘invasiveness’ as a category for which the 

literature is incomplete. The last point will be 

discussed in greater detail later. Data Gaps NA GA 30605 Individual None No response required. 

39 7

B. Land Use (Change): This is a critical issue for all 

biofuel-related matters. The EA for this proposal 

states that mostly pasturelands and marginal or 

idle croplands will constitute the 200,000 acres 

planted in giant miscanthus for this project by 

2014. It states that “implementing the Proposed 

Action would not result in significant changes in 

land use types that could trigger development of 

agricultural lands into other non-agricultural land 

use types nor would it create a substantial loss of 

arable cropland within the proposed project 

areas.” The entire focus seems to be on not 

altering the agrarian nature of the project areas 

or in ‘cannibalizing’ high quality cropland 

currently devoted to other crops. However, 

converting idle croplands back to agriculture does 

represent a net-loss for wildlife habitat. The EA 

actually goes so far as to include in its ‘land-use 

algorithm’ the number of Conservation Reserve 

Program (CRP) acres that will be expiring from 

enrollment in 2010-2014. Instead of viewing this 

as an opportunity to facilitate more biofuel crop 

production, the expiration should be seen as an 

opportunity to re-enroll these acres in Farm Bill 

conservation programs. Land Use NA GA 30605 Individual None

FSA has no control over parceling of expiring CRP 

contracts once they leave CRP. Individual producers 

can choose to re-offer those acres to CRP; however, 

that choice is up to the individual producer. The 

Project Sponsors are targeting marginal croplands 

and idle lands to avoid compromising harvestable 

acreage in traditional crops. 
Page 43 of 128

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39 8

The EA further states that “given the high 

commodity prices associated with traditional 

crops and the lack of adequate bioconversion 

facilities (BCF) there would not be enough 

demand in the region to convert more than a 

modest amount of agricultural lands to dedicated 

energy crop production and away from traditional 

crops”. This is disingenuous because one goal of 

the Proposed Action is to ‘grow the market’, as 

evidenced by the mentioning of the “potential for 

additional BCAP project acres within the 

proposed project areas.” Depending on the 

landscape and availability of arable acres, the 

new additional acres may come at the expense of 

wildlife habitat (i.e., woodland, forest, earlysuccessional habitats, etc.). Land Use NA GA 30605 Individual None

Based on the amount of available "other cropland" 

and pastureland within the project areas, there is 

sufficient acreage to avoid the conversion of higher 

quality habitats (e.g., forestlands or woodlands) or 

lands currently included within a Federal or State 

conservation program. BCAP, by statute, provides a 

mechanism to help producers establish and produce 

bioenergy crops. With this program, the Project 

Sponsors are estimating a positive balance for 

producers by Year 6 of production, rather than at 

Year 10 or later without BCAP.

39 9

A Mitigation and Monitoring Plan (MMP) was 

developed for this proposal in accordance with 

Council on Environment Quality (CEQ) guidance 

for National Environmental Policy Act (NEPA) 

decisions. It will attempt to track conversion of 

land use (and their productive status) and 

mitigate potential adverse impacts. It suggests 

additional restrictions on land use conversion 

may be necessary. This is much easier said than 

done. Land use restrictions are difficult to 

achieve and are subject to constitutional 

challenge. In addition, it would not be the 

responsibility of either of the project sponsors, 

Aloterra Energy LLC and MFA Oil Biomass 

Company LLC, to pursue these restrictions that 

would actually run counter to their own longterm investment interests. They may, however, 

be financially obligated to contribute to 

mitigation efforts under terms of the MMP. Land Use NA GA 30605 Individual None

The Project Sponsors are not directing land use 

restrictions, except for producers that entire into 

contracts to establish and produce giant miscanthus 

as part of the project area. The Project Sponsors 

have committed to the Mitigation and Monitoring 

Plan to ensure that this species does not become an 

invasive problem from the project areas. 
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39 10

C. Biological Resources: Potential invasiveness 

and adverse effects on wildlife and natural 

habitats are two primary concerns. With regards 

to invasiveness, it should first be noted that many 

of the very traits that are desirable for biofuel 

species also are associated with invasiveness. 

These include: 1) perennial life history; 2) high 

above-ground biomass production; 3) drought 

tolerance; 4) high soil infertility tolerance ; 5) high 

soil salinity tolerance; 6) high water efficiency; 7) 

high nitrogen efficiency; 8) a C4 photosynthetic 

pathway; 9) highly competitive; 10) relatively free 

of pests and pathogens; and 11) allelopathic.

Giant miscanthus possesses most of these traits. 

Secondly, both parents of the M. x giganteus (M. 

sacchariflorus and M. sinensis) are invasive, 

especially the latter. At the very least, this 

suggests that there is adequate potential for this 

species to become invasive. Invasive NA GA 30605 Individual None

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.
Page 45 of 128

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39 11

Giant miscanthus is purported to be a sterile 

triploid hybrid which does not produce seed or 

viable pollen and is, therefore, sterile. The three 

sets of chromosomes cannot pair and divide 

evenly during meiosis, resulting in unequal 

segregation of the chromosomes and 

consequently sterility. However, if the 

chromosomes fail to segregate, resulting in an 

unreduced gamete with 57 chromosomes, this 

unreduced gamete may be able to fuse with 

either a haploid (1n) gamete from a species such 

as M. sinensis, to produce a tetraploid offspring 

(4n=76), or with another unreduced gamete to 

form a hexaploid offspring (6n=114). The 

tetraploid and the hexaploid progeny could be 

fertile amongst themselves but not amongst the 

triploid parents. It is also possible to produce 

viable propagules through apomixis. Apomixis 

uses asexual reproduction (i.e., no fertilization) to 

produce a seed that is essentially a clone of the 

sporophyte parent. Giant miscanthus is also a 

rhizomatous, clump-forming perennial and is 

capable of vegetative reproduction and, 

therefore, vegetative invasive spreading (at a rate 

of about 10 cm/yr). It is possible that a significant 

disturbance event (i.e., flooding, tornado, etc.) 

could translocate rhizomes to non-project areas 

and thus initiate an infestation (New Zealand 

Environmental Risk Management Authority 

2007). Seed Sterility NA GA 30605 Individual None

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.
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39 12

Past performance of an introduced/potentially 

invasive species reflects past environmental 

conditions and genotypes, and may not be an 

adequate predictor of future performance 

(Simberloff 2008). Although the evidence from 

30 years of trials and study in Europe is the lack of 

any observation of the production of viable seeds 

or pollen, apomixis, or unintentional vegetative 

outbreaks, any of these are theoretically and 

mathematically possible. High densities and 

improved environmental conditions associated 

with cultivation (from the crop’s perspective) 

provide evolutionary pressures for the 

development of novel genotypes, restoration of 

fertility, and creation of self-sustaining 

populations (both sexually and asexually). Seed Sterility NA GA 30605 Individual None

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.
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39 13

It is also critical to mention that research is 

currently underway at the University of Illinois to 

improve the biofuel potential of giant miscanthus 

by genetically engineering a fertile hexaploid (6n) 

variety (Chang et al. 2009). In plants, doubling of 

the chromosome number is often associated with

larger more robust individuals. Restoring fertility 

would also enable future cultivation to employ 

seed, as opposed to the more expensive and 

labor-intensive use of rhizomes. While this might 

improve biofuel economy and yield, it will also 

produce a variety of giant miscanthus that is 

much more likely to become invasive. This 

relates to earlier comments regarding the biofuel 

craze as a ‘runaway train’. Seed Sterility NA GA 30605 Individual None

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.
Page 48 of 128

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39 14

The most widely used predictive tool for 

invasiveness, the Australian Weed Risk 

Assessment WRA), was utilized to evaluate the 

potential invasiveness of giant miscanthus, but 

this may prove inadequate. Several researchers 

(Barney and DiTomaso 2008; Gordon et al. 2011) 

screened giant miscanthus using the WRA and 

pronounced it ‘safe’ for consideration as a 

biofuel. One problem with the WRA is that its 

validation depends on ‘after-the-fact’ analysis. 

Many species remain non-invasive and 

geographically/ecologically constrained for 

decades (or even a century or more) until 

suddenly experiencing exponential growth rates 

and becoming invasive. Even a more 

precautionary approach as developed by Davis, T. 

et al. (2010) that employs the WRA as an initial 

screen to be followed up by more testing and

evaluation may not be able to predict or prevent 

invasiveness. Invasive NA GA 30605 Individual None

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.
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39 15

The EA takes refuge from the issue of potential 

invasiveness in the development and application 

of the MMP and promises successful eradication 

measures. Ostensibly, a properly developed and 

executed MMP would provide for early detection 

and rapid response to an invasive outbreak, 

which could then be “easily eradicated using 

commercially available herbicides.” If the 

outbreak occurred across limited time and spatial 

scales, then eradication may indeed be swift and 

sure. However, if multiple continual outbreaks 

occurred from an adapted invasive genotype then 

eradication might quickly become impossible or 

prohibitively expensive. Eradication measures 

also can have unintended consequences for nontarget species.

Invasive, 

Mitigation 

Measures NA GA 30605 Individual None

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.
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39 16

The impact of the cultivation of biofuels on 

wildlife and wildlife habitat depends upon the use 

and status of the proposed cultivation area prior 

to biofuel conversion. The EA claims that only 

idle/marginal croplands and expiring CRP lands 

will be utilized for this purpose. While this will 

have a lower impact on wildlife than converting 

healthy forest and prairie, it still represents a net 

loss of early successional habitat. Field margins, 

hedgerows, shrubby/herbaceous idle lands, and 

lands in conservation programs are all superior 

for wildlife as compared to a high-density 

cultivated field. The EA states that a cultivated 

biofuel crop will have greater diversity and fewer 

environmental impacts than a traditional 

cultivated field crop, such as corn, wheat, potato, 

soybean, etc. The EA also attempts to argue in 

favor of rhizomatous grasses, even if non-native 

and cultivated in monocultures since they 

“require less tillage, lower agrochemicals, and 

high above and below-ground biomass, which are 

beneficial for soil microfauna and provide cover 

to invertebrates and birds.” This is hardly the 

issue. Early seral habitats and species are under 

assault from succession and conversion. Any 

genuine concern for these would manifest itself 

in a call for increased conservation lands and 

incentives to landowners to manage for earlysuccessional habitat. Biodiversity NA GA 30605 Individual None

Biodiversity information reviewed from European 

literature does suggest that miscanthus can provide 

wildlife and insect habitats when compared to 

traditional crops and some pasture lands. The 

Mitigation and Monitoring developed in 

consultation with NRCS and ARS, provides 

appropriate minimum buffer width for each project 

area, combined with site-specific increases in buffer 

width for adjacency to sensitive areas, to be 

included in the individual Conservation Plan. 

Additional safeguards have been established for 

active producer monitoring and reporting to the 

Project Sponsor for the initiation of appropriate 

control technologies. 

39 17

The EA invokes the MMP as a means to identify 

and offset potential negative impacts on wildlife 

and wildlife habitat. It discusses the use of BMPs, 

adaptive monitoring and management, and 

corrective measures, if necessary, to mitigate for 

unintended negative impacts. While planning for 

these actions is a positive step, it represents the 

minimum of what should be expected from a 

project such as this. Furthermore, planning for 

successful mitigation and delivering successful 

mitigation are two entirely different matters. 

Mitigation 

Measures NA GA 30605 Individual None

The Mitigation and Monitoring Plan was provided in 

a draft form in the Draft EA to allow for public input 

and comment on the features to be included. 

Overall, comments from the public and agencies 

have provided a great deal of additional information 

to include in the Mitigation and Monitoring Plan as 

best management practices or exclusions of 

acreage.
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39 18

Most rare and protected species, and other 

species of conservation-concern would not likely 

be directly affected by the footprint of this 

proposed action due to their absence from the 

project areas. Some migrating protected species 

may be impacted, but this impact would be 

expected to be low given the relatively few acres 

(200,000) involved in this project, at least initially. 

Rare aquatic organisms are probably at greatest 

risk depending upon the impacts of giant 

miscanthus cultivation on soil and water 

resources. Some soil erosion and changes to the 

hydrologic regime should be expected during the 

‘crop establishment’ phase. Longer lasting 

impacts are unknown. Biodiversity NA GA 30605 Individual None

Further clarification would be provided to ensure 

that site-specific conditions do not create adverse 

effects to State-listed species. Species of concern, 

but not protected under State law/regulation, 

Federal laws/regulations, or tribal regulation would 

be considered to the extent of management by the 

appropriate entity. Site specific Conservation 

Planning would address wildlife best management 

practices that meet the needs of locally occurring 

protected species. No taking of a protected species 

would be allowed without appropriate consultation 

with the U.S. Fish and Wildlife Service and the 

appropriate State agency. 

39 19

D. Soil Resources: While there would be both 

positive and negative impacts on soil resources 

associated with land conversion to giant 

miscanthus cultivation, the overall effect would 

likely be neutral to slightly positive. Giant 

miscanthus has abundant above and below 

ground biomass, and a deep root system (50% of 

which is below 90 cm). It produces more above 

ground biomass (and carbon) than other biofuels 

(e.g., switchgrass) and even native prairie (Davis, 

S.C. et al. 2010). Heavier litter fall and more 

extensive root production leads to higher soil 

carbon accumulation levels, and helps reduce soil 

erosion due to wind and water. The greater root 

system also improves water storage and 

microbial processes. There would be potential 

for soil erosion during the establishment phase, 

which BMPs could at least partially address.

Soil 

Resources NA GA 30605 Individual None No response required. 
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39 20

E. Water Resources: Relative impacts to water 

quality are dependent upon whether the 

comparison is to traditional row crop cultivation 

or to idle, marginal or conservation lands. Water 

quality, both above and below ground, is best 

protected by intact habitats of native vegetation. 

That said, however, giant miscanthus cultivation 

should have fewer negative impacts to water 

quality than a row crop. Giant miscanthus is very 

effective at scavenging and recycling nutrients, 

and its thick vegetative mat and substantial litter 

layer control sheet flow of water and erosion 

following rainfall events. These combine to 

reduce off-site movement of nutrients and 

sediments, and to limit nutrient leaching through 

soil, thus potentially improving stream and 

groundwater quality, respectively. However, 

cultivation activities require inputs of fertilizers, 

pesticides, and herbicides, and also generate 

mechanical and internal combustion engine 

residues and leakages (e.g., fuel, oil, lubricants, 

etc.). These additional chemical inputs may 

potentially offset any gains in water quality 

provided by the physiology and growth habits of 

giant miscanthus. 

Water 

Quality NA GA 30605 Individual None

The Mitigation and Monitoring Plan and each 

producers' Conservation Plan will address 

agricultural chemical usage BMPs and guidance. 

The combination ensures that even with the 

conversion of pasture, that stormwater runoff even 

during the establishment period, would result in 

only minor effects to water quality. 
Page 53 of 128

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39 21

Evaluation of impacts to water quantity also 

depend upon the nature of the comparison. 

Since supplemental watering (i.e., irrigation) 

would only be needed in the first year on each 

farm to establish the giant miscanthus centralized 

propagation areas (i.e., rhizome bank for future 

outplantings), water budget considerations are 

only concerned with water use efficiency (WUE) 

and evapotranspiration (ET). Giant miscanthus 

has a relatively high WUE (9.0-10.7 grams dry 

weight/1 kg of water lost (normalized for 

maximum vapor pressure deficit) and is 

comparable to other C4 row crops, such as corn 

(8.2-12.0g/kg) and pearl millet (8.4-10.6g/kg) 

(Beale et al. 1999). Native prairie in north-central 

Oklahoma with a mix of C3 and C4 graminoids and 

herbaceous species has a WUE of 0.2 to 2.2 g/kg 

(not normalized). Comparisons between 

normalized values for miscanthus and unnormalized values for native prairies (Burba 2005) 

are problematic. Water Use NA GA 30605 Individual None

Further clarification will be provided through 

normalized values where available in the literature.
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39 22

However, the issue here is that the EA is 

attempting to justify the cultivation of a nonnative, potentially invasive species by arguing 

that it is at least as efficient at using water to 

produce above ground biomass, if not more so, 

than are other crops that might be cultivated. 

From a conservation perspective the issue is not 

how efficiently giant miscanthus uses water, but 

how much water it uses. McIssac et al. (2010) 

prepared an experimentally derived estimated 

water budget comparing giant miscanthus with 

native switchgrass, and the annual crops corn and 

soybean. They found growing season ET for corn 

and soybean to be approximately 18 mm greater 

than for switchgrass. Estimated ET from giant 

miscanthus was on average 140 mm greater than 

switchgrass and 104 mm greater than corn and 

soybean. They predicted that if giant miscanthus 

was planted extensively in central Illinois that a 

104-mm increase in ET could cause an annual 

reduction in surface water flows of approximately 

32%. This is consistent with the longer growing 

season, faster growth rate, larger leaf area and 

deeper root system of giant miscanthus as 

compared to other annual crops. This not only 

makes a case for the use of native switchgrass, 

but also against the use of non-native giant 

miscanthus. Water Use NA GA 30605 Individual None

Further clarification to water use has been provided 

in reference to both comparisons of corn for grain 

and corn for silage. There would be no irrigation of 

giant miscanthus within these project areas after 

initial establishment this growing season. There was 

no indication based on available data that these 

project areas contain substantial amount of 

irrigated croplands. Average annual precipitation 

greater than 30 inches should be sufficient for the 

production of giant miscanthus. 
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39 23

II. Mitigation and Monitoring Plan The MMP 

(referenced in earlier sections), is the plan that 

addresses the possible identification of 

deleterious impacts resulting from this project, 

and addresses who is responsible for the 

detection, who is responsible for developing the 

plan and procedures for mitigation, who is 

responsible for funding the mitigation, who is 

responsible for performing the mitigation, and 

who will ultimately be held accountable for 

successful mitigation. The EA provides an 

impressive list of agencies involved in this effort: 

the USDA Farm Service Agency (FSA), the USDA 

Rural Development, USDA Animal and Plant 

health Inspection Service (APHIS), USDA 

Agricultural Research Service (ARS), USDA Natural 

Resource Conservation Service (NRCS), USDA 

Forest Service (USFS), US Fish and Wildlife Service 

(USFWS), US Army Corps of Engineers (USACE), 

Ohio Seed Improvement association (OSIA), and 

State Historic Preservation Offices (SHPO). 

Somewhere, lost in all the acronyms, 

bureaucracies, and the promises, good intentions 

and redundancies built into the MMP, is the fact 

that the history of non-native invasions is 

associated with unexpected developments across 

time and spatial gradients, and in indirect ways 

often completely unpredictable (Simberloff 

2008). While the development of a MMP is 

required by law and is meant to demonstrate 

responsibility and preparedness, it is not a 

panacea. It can not guarantee that negative 

impacts will not occur or that they will be 

successfully remedied or mitigated. Although the 

MMP is a necessary document, it provides both 

an insufficient ‘fail-safe’ and insufficient 

justification for this project.

Mitigation 

Measures NA GA 30605 Individual None

The Mitigation and Monitoring Plan was provided in 

a draft form in the Draft EA to allow for public input 

and comment on the features to be included. 

Overall, comments from the public and agencies 

have provided a great deal of additional information 

to include in the Mitigation and Monitoring Plan as 

best management practices or exclusions of 

acreage.
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39 24

III. Finding. The potential for biofuels to become 

an integral part of the nation’s energy supply and 

a focal point of energy policy is undeniable. 

Issues of domestic energy supply vs. demand, 

national security, and global climate change 

ensure the U.S. government’s involvement in 

encouraging biofuel development. Opportunities 

for entrepreneurs, corporations, and capital 

investors to recognize substantial profits explains 

their motivation. The issue is not whether to 

oppose or support biofuel development, but 

rather how to constructively engage the biofuel 

promoters in a manner that protects natural 

vegetation, wildlife, wildlife habitat, and soil and 

water resources. General NA GA 30605 Individual None No response required. 

39 25

As mentioned earlier, the proposed action can be 

evaluated at the levels of biofuels in general, and 

giant miscanthus use, specifically. Biofuels 

derived from existing crop and forestry residues 

would not be expected to impart many negative 

impacts to vegetation, wildlife, water resources, 

etc. However, cultivated biofuels must do so at 

the expense of lands supporting other crops, 

pastures, forests, conservation interests, etc. It is 

the cultivated biofuels that have the potential to 

adversely impact the environment and natural 

history elements. Land that was otherwise 

available to wildlife and native vegetation may be 

converted to biologically sterile (or nearly sterile) 

monocultures that could reduce soil and water 

quality/quantity. The Proposed Action is being 

conducted on a relatively small scale (200,000 

acres), but is utilizing idle lands and expiring 

conservation lands that would better serve native 

vegetation and wildlife if left uncultivated. 

Biofuel projects should be considered acceptable 

only when they replace one monoculture with 

another monoculture.

Biofuel 

Concerns NA GA 30605 Individual None

The Project Sponsors are proposing a specific 

project for inclusion within the BCAP. The 

reasonable alternatives under consideration are (1) 

the Proposed Action, which implements the Project 

Sponsors plan or (2) the No Action Alternative, 

which would not implement the Project Sponsors 

plan. The Project Sponsors are not required to 

propose alternative species, methods, or project 

locations under NEPA.
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39 26

With regards to the specific use of giant 

miscanthus as a biofuel crop, there seem to be 

ample reasons for rejecting it. First, both its 

parents, especially M. sinensis are invasive in 

many parts of the world. Second, many desirable 

qualities possessed by biofuel species (incl. those 

of giant miscanthus) are identical to traits 

associated with invasiveness, such as perennial 

life history, high biomass production, drought 

tolerance, a C4 photosynthetic pathway, high 

water use efficiency, etc. Third, despite the fact 

that it is considered a sterile hybrid triploid, there 

are numerous ‘natural’ genetic mechanisms 

capable of restoring fertility. Given the sheer

number of meiotic divisions associated with the 

millions and billions of 

plants/inflorescences/pollen grains, the 

evolutionary pressures provided by intense 

cultivation, and the numerous opportunities for 

crossing/backcrossing with various Miscanthus

cultivars growing across the landscape, the 

restoration of fertility and/or the creation of a 

novel invasive are more probable than the EA 

allows. Fourth, past ‘good behavior’ of a 

potentially invasive species can not ensure a 

similar performance in the future. The history of 

invasion is fraught with examples of this 

phenomenon, such as Chinese privet (Ligustrum 

sinense) in these U.S. Fifth, while soil resources 

are not likely to experience adverse impacts from 

the cultivation of giant miscanthus, water 

resources, especially water quantity of soils and 

water available to recharge aquifers and streams, 

will decrease. This decrease may be substantial 

in intensely cultivated systems. General Against GA 30605 Individual None

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. 

39 27

In short, the No Action Alternative of the EA 

should be implemented. The FSA should not 

establish the proposed project areas supporting 

the establishment and production of giant 

miscanthus. General Against GA 30605 Individual None No response required. 
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40 1

We have been through the detailed 

Environmental Impact assessment of Miscanthus 

for this project. We fully support this application 

on the basis that the overall environmental 

balance of growing Miscanthus is positive. My 

background is that I have been involved in 

Miscanthus for 15 years and its 

commercialisation in the EU since 2001, planting 

the first large scale commercial crops under the 

UK Government equivalent scheme for 

supporting new biomass crops. As part of this 

expansion we routinely undertook environmental 

impact assessments of for all crops on a field by 

field basis covering all aspects. We were also 

involved in the fundamental studies that 

underpinned these assessments working as the 

industrial partners on University projects 

investigating different areas such as biodiversity, 

water use and public perception. On this basis 

having been involved in Miscanthus and seeing 

things 10 years forward we support fully its 

introduction on this basis as an energy crop. 

Going forward we now produce information on 

crops that are grown to meet current 

sustainability reporting guidelines. With a 

demand for increasing renewables, biomass 

provides things wind and solar cannot, in terms of 

fuels and heat. For this to become a reality far 

larger resources of biomass are needed, that 

demand requires energy crops, Miscanthus has 

been proved as a vital contributor to that. General Support Individual

New Energy 

Farms Ltd.

Comment noted on the support of the proposed 

action. 

41 1

I support the approval of Aloterra Energy’s BCAP 

applications and I support the use of Miscanthus 

as an energy crop to meet America’s renewable 

energy needs. General Support Individual None

Comment noted on the support of the proposed 

action. 
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42 1

Missouri Farm Bureau (MFB), the state's largest 

farm organization, submits the following 

comments regarding the Draft Environmental 

Assessment for the Proposed Giant Miscanthus 

Establishment and Production in Arkansas, 

Missouri, Ohio, and Pennsylvania sponsored by 

Aloterra Energy LLC and MFA Oil Biomass LLC. 

We appreciate the work of the USDA Farm 

Service Agency (FSA) in evaluating the potential 

environmental resource and economic impacts of 

the proposal and offer support for the Proposed 

Action alternative. Our members support 

renewable energy as part of a comprehensive 

energy policy for our nation. The production and 

utilization of biomass harvested from farm, ranch 

and forestlands should be part of the strategy. In 

this particular proposal the project sponsors 

would like to establish two cultivation of giant 

miscanthus. Such action will be positive for 

positive for participating farmers as a source of 

income and rural communities as a result of 

added economic activity - all while accomplishing 

the goals of BCAP. We encourage FSA to 

designate the proposed counties in Missouri and 

other states as BCAP project areas given no 

significant negative impacts were identified. 

Furthermore, we would encourage FSA to work 

closely with the project sponsors and farmers as 

the Mitigation and Monitoring Plan is developed 

and implemented. General Support MO 65102 State NGO

Missouri 

Farm 

Bureau 

Federation

Comment noted on the support of the proposed 

action. 

43 1

Overall, the Environmental Assessment, as 

written, has flaws in logic, uses inappropriate 

comparisons to experience in Europe because of 

the lack of data in the US, dismisses the potential 

for pest problems, invasiveness or impacts on 

wildlife. The lack of input from appropriate 

specialists (agronomists, entomologists, wildlife 

specialists) renders the conclusions suspect. General Against AR 72703 Individual None No response required. 
Page 60 of 128

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43 2

As stated on page 4-1, the oldest cultivation (in 

Europe) has been only 30 years, and large-scale 

cultivation in the United States has not yet 

occurred. Therefore, the data are lacking on 

environmental consequences. The Mitigation 

and Monitoring Plan is an excellent start, but is 

insufficient in its scope and its assumptions.

Specific points include: Data Gaps NA AR 72703 Individual None

The Project Sponsors have made efforts to 

identified available literature associated with the 

production of giant miscanthus, both positively and 

negatively. To ensure avoidance and minimization 

of potential effects the Project Sponsors in 

consultation with USDA have developed a stringent 

Mitigation and Monitoring Plan for broad scale 

efforts across all project areas. Additionally, more 

stringent or broad BMPs could be used at the 

contract acreage level based on State and local 

regulations and site-specific conditions within each 

tract. Those BMPs would be part of each producer's 

Conservation Plan, which would be developed with 

the assistance of Technical Service Providers. The 

Project Sponsors are obligated to provide FSA with 

Annual Report detailing many aspects of 

establishment, production, and control of unwanted 

spread or pests and diseases. Each producer within 

the project area would be contractually obligated to 

the Project Sponsors to provide the necessary 

information from each contract to include within 

the project area Annual Report. If a producer fails 

to monitor or contain an identified issue, the Project 

Sponsor would assume that responsibility for that 

contract, with the producer being billed for those 

activities, if necessary.
Page 61 of 128

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43 3

· On Pages 4-1 and 4-2, the listing of factors 

lacking detail in relation to growth and 

production in the US is extensive enough to 

warrant further documentation of economic 

benefits and no environmental impacts. Data Gaps NA AR 72703 Individual None

The Project Sponsors have made efforts to 

identified available literature associated with the 

production of giant miscanthus, both positively and 

negatively. To ensure avoidance and minimization 

of potential effects the Project Sponsors in 

consultation with USDA have developed a stringent 

Mitigation and Monitoring Plan for broad scale 

efforts across all project areas. Additionally, more 

stringent or broad BMPs could be used at the 

contract acreage level based on State and local 

regulations and site-specific conditions within each 

tract. Those BMPs would be part of each producer's 

Conservation Plan, which would be developed with 

the assistance of Technical Service Providers. The 

Project Sponsors are obligated to provide FSA with 

Annual Report detailing many aspects of 

establishment, production, and control of unwanted 

spread or pests and diseases. Each producer within 

the project area would be contractually obligated to 

the Project Sponsors to provide the necessary 

information from each contract to include within 

the project area Annual Report. If a producer fails 

to monitor or contain an identified issue, the Project 

Sponsor would assume that responsibility for that 

contract, with the producer being billed for those 

activities, if necessary.

43 4

· The socioeconomic information was provided 

by the project sponsors, not from an independent 

source. Given the proposed project would 

introduce a perennial crop plant with a 20-30 

year lifespan, independent analysis is highly 

desirable.

Socioecono

mics NA AR 72703 Individual None

BCAP is a voluntary program that producers join if 

there is enough economic incentive for the 

individual producer to justify the production of a 

bioenergy crop. As such, producers bear the burden 

of determining individual economic viability on their 

contract acres. The Project Sponsors are providing 

technical assistance to the contract producers for 

establishment, production, and harvesting. The 

economic analysis provided in the Draft EA, was 

determined from publicly available data most 

similar to the confidential economic information 

developed by the Project Sponsors as part of the 

application.
Page 62 of 128

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Group Response

43 5

· There is no landscape-level analysis of 

Miscanthus because there is no large-scale 

planting in the US. However, the scale of planting 

is great enough that environmental changes are 

likely to occur. Land Use NA AR 72703 Individual None

The Project Sponsors in consultation with NRCS and 

ARS have developed the Final Mitigation and 

Monitoring Plan to provide project area level 

guidance and best management practices, as well as 

acreage exclusions, control methods, and training 

activities. Site-specific analysis will be undertaken 

for each contract producer to determine the 

potential for effects at that level. Each producer will 

be required to have a Conservation Plan, which 

could be more restrictive than the Mitigation and 

Monitoring Plan guidance.

43 6

· Irrigation is proposed to be used solely for 

establishment; however, Miscanthus yields can 

be doubled with adequate water. Comparisons 

are made to irrigation needs of crop lands, yet 

the proposed project states that pasture and 

marginal land would be used for the project –

therefore, irrigation needs would not replace 

current usage, but add to it. Water Use NA AR 72703 Individual None

Further clarification to water use has been provided 

in reference to both comparisons of corn for grain 

and corn for silage. There would be no irrigation of 

giant miscanthus within these project areas after 

initial establishment this growing season. There was 

no indication based on available data that these 

project areas contain substantial amount of 

irrigated croplands. Average annual precipitation 

greater than 30 inches should be sufficient for the 

production of giant miscanthus. 
Page 63 of 128

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Group Response

43 7

· The statement made (p. 4-2) that literature 

on invasiveness was discussed is lacking detail, 

and the “documentation supporting that giant 

miscanthus should not be considered invasive...” 

is a letter from the Ohio Seed Improvement 

Association – not based on consultation with 

invasion biologists. The reasoning behind the 

conclusion about Miscanthus not being invasive is 

based on the lack of viable seed production.

However, there are other plants that produce no 

seed (e.g.,, giant reed, Arundo donax), yet are 

highly invasive. Further, the recent research 

conducted at the University of Illinois that has 

developed Miscanthus with double the number 

of chromosomes would produce seed (and would 

likely produce higher yields and be more 

productive). There are no safeguards to prevent 

the future use of those fertile varieties. Seed Sterility NA AR 72703 Individual None

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.

43 8

· Another statement (p. 4-2) was made that 

literature discussing potential plant pests has 

been included; however, what was not included 

was the potential impacts of those pests and 

diseases on other crops. For example, crop 

rotation has been used for years to manage corn 

rootworm. Planting a perennial grass crop 

increases the potential for corn rootworm to 

produce pests that will affect corn plantations 

throughout the proposed area. Further, 

Miscanthus is already known to harbor an aphid 

that is a known risk to sorghum.

Pests & 

Diseases NA AR 72703 Individual None

As part of each contract level Conservation Plan, 

pests and diseases for that specific area would be 

included as part of an Integrated Pest Management 

Plan (IPM). Treatment of any identified pests would 

be similar to treating pests in traditional crops or 

through the use of an IPM activities, if feasible for 

giant miscanthus. Each IPM, would be similar to the 

overall Conservation Plan, in that it would be sitespecific. 
Page 64 of 128

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Group Response

43 9

· The statement was made that, because there 

is little peer-reviewed literature on effects of 

giant miscanthus on biological diversity in the US, 

the writers of the proposal used literature 

published in Europe on birds and small mammals 

in young-aged plants. This is inappropriate in at 

least three ways: 1) there will be a great 

difference between young plants and mature 

stands, and plants will be mature for nearly all 

the 20-30 year lifespan of the project; 2) the 

studies were on plots that were too small (7.4 

acres, page 4-14; Arkansas fields will be 38-100 

acres in size) to determine any true effects; and 

3) species differ between Europe and the US, and 

extrapolation of the sort proposed is 

inappropriate. Further, the comparison was 

made that there was greater abundance and 

diversity of birds in miscanthus fields than in 

wheat fields. This is a totally inappropriate 

comparison, as the proposed sites to be used will 

not be replacing wheat production. And the 

reference stating that young miscanthus fields 

had greater abundance and diversity of birds than 

in reed canary grass is again a false comparison 

(let alone that reed canary grass is highly invasive 

in the US, yet is not in England). In addition, the 

reference cited (Semere and Slater 2007) was not 

in the references provided in the document. One 

reference that was provided (Fargione 2010) does 

not support the deployment of low-diversity 

biomass crops. Biodiversity NA AR 72703 Individual None

The NEPA process requires a review of the best 

available data on both positive and negative 

aspects. Given the lack of substantial data on this 

species in the United States, European literature 

was referenced as appropriate. Additionally, since 

no large scale plantings of the Illinois clone of giant 

miscanthus have been undertaken, the Project 

Sponsors, in consultation with NRCS and ARS, 

developed a Mitigation and Monitoring Plan to 

minimize the potential for negative effects. Also, at 

the site-specific level, each producer's acreage 

would undergo environmental screening to identify 

sensitive resources or areas. If affects could not be

mitigated, those acres would not be accepted for 

BCAP. Each individual producer must have a 

Conservation Plan to match the site-specific 

conditions of the acreage. Biodiversity information 

reviewed from European literature does suggest 

that miscanthus can provide wildlife and insect 

habitats when compared to traditional crops and 

some pasture lands. The Mitigation and Monitoring 

developed in consultation with NRCS and ARS, 

provides appropriate minimum buffer width for 

each project area, combined with site-specific 

increases in buffer width for adjacency to sensitive 

areas, to be included in the individual Conservation 

Plan. Additional safeguards have been established 

for active producer monitoring and reporting to the 

Project Sponsor for the initiation of appropriate 

control technologies. 
Page 65 of 128

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Group Response

43 10

The references provided are inadequate and 

could be considered biased toward the positive 

potential of the project, with cursory reference to 

any studies that are not directly supportive of the 

project. A recent issue of Current Opinion in 

Environmental Sustainability (March 2011, 

Volume 3, Issues 1-2; Elsevier Publisher) is 

devoted to risks and benefits of growing biofuel 

crops. That literature needs to be considered to 

have a more-complete picture of the current 

state of knowledge. 

Biomass 

Feedstock NA AR 72703 Individual None

The BCAP establishment and annual payments are 

provided to the establishment and production of 

bioenergy crops. This environmental assessment is 

for one particular project area proposal being 

provided by the Project Sponsors. FSA for BCAP 

must either approve the project areas proposal 

after the appropriate processes are complete per 

statute and regulatory guidance or decline to accept 

the project area proposal. The process of approving 

the project area does not need to include specific 

producer acreage, at this point. FSA, after the 

project area has been approved, would solicit 

contract acreage from producers within the project 

areas. The BCAP is a voluntary program that 

producers enter based on their willingness and 

economic viability for production of the project 

areas species. Each producer entering acreage 

under these project areas would be required to 

follow all requirements of the Mitigation and 

Monitoring Plan, in addition to all other BCAP 

requirements within the site-specific Conservation 

Plan.

43 11

In conclusion, I believe the information provided 

in the EA is inadequate, treats several key issues 

superficially and treats the lack of any data as a 

clear sign to move forward, rather than seek 

information to address the issues. General Against AR 72703 Individual None No response required. 

44 1

Numerous oversimplifications, generalizations 

and mischaracterizations call to question the 

overall capacity of the sponsors to complete the 

project, and more importantly, to conduct it in a 

manner that ensures environmental safety. General Against AR 72701 Individual None

The Project Sponsors have committed to mitigation 

and monitoring of contract acres over the effective 

life of all intentionally contracted plantings of giant 

miscanthus. The final mitigation and monitoring 

plan will be included with the Final EA. Additionally, 

site-specific Conservation Plans for each producer 

would identify any additional BMPs required to 

minimize any potential effects below significance 

thresholds. 

44 2

The potential of giant miscanthus to harbor pests 

(insects and diseases) is largely ignored. Indeed, 

throughout the document the word "insect" only 

appears 3 times (twice in tables), "disease" is 

mentioned twice, "pest" twice and "arthropod" is 

mentioned. This indicates an inadequate 

Environmental Assessment. 

Pests & 

Diseases NA AR 72701 Individual None

A review of the literature associated with plant pest 

and diseases was performed and provided in the EA. 

There was little indication from European literature 

of susceptibility to major pests and diseases. The 

Mitigation and Monitoring Plan directly addresses 

the potential for the occurrence of pests and 

diseases and the roles of the producer and Project 

Sponsor for treatment, if necessary.
Page 66 of 128

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44 3

The suggestion that because recent research 

suggests that giant miscanthus is susceptible to 

some plant pests, "MMP monitoring and buffer 

efforts would be essential to ensure that any 

occurrence is identified and treated early to avoid 

transmission to local croplands" is naive and 

ignores well-established pest dynamics and pest 

management principles. The MMP (section 6) 

makes no mention of these treatments or buffers, 

or any efforts to mitigate plant pest effects on 

surrounding agricultural systems.

Pests & 

Diseases, 

Mitigation 

Measures NA AR 72701 Individual None

The Project Sponsors or the producer would notify 

adjoining properties if any pests or diseases are 

located and need to be treated. 

44 4

The lack of large-scale production in the US and 

the resulting data limitations of only large-scale 

trials in Europe are clearly noted in some areas of 

the EA (pg. ES-5, line 8ff). However, the 

experience of Europe is later cited as justification 

for low expectations on pest dynamics in 

surrounding agricultural systems.

Pests & 

Diseases NA AR 72701 Individual None

A review of the literature associated with plant pest 

and diseases was performed and provided in the EA. 

There was little indication from European literature 

of susceptibility to major pests and diseases. The 

Mitigation and Monitoring Plan directly addresses 

the potential for the occurrence of pests and 

diseases and the roles of the producer and Project 

Sponsor for treatment, if necessary.

44 5

Plant pest studies are rare and have focused 

more on the pests of giant miscanthus, not the 

potential of the crop to harbor pests of other 

crops. The mention of the crop's ability to harbor 

western corn root worm, several aphid species 

and rust pathogens is cause for concern and point 

to the need for data to be obtained before 

launching an experiment of this scale using an 

exotic species.

Pests & 

Diseases NA AR 72701 Individual None

Published literature was cited in the Draft EA 

concerning the potential for western corn rootworm 

to occur in giant miscanthus. Further detail has 

been included in the MMP, which has been drafted 

and revised from consultation with NRCS and ARS. 

Monitoring for pests and diseases is included as part 

of the MMP and would be adjusted accordingly 

based on the site-specific Conservation Plan.

44 6

The research documenting that miscanthus 

harbors large populations of the yellow sugar 

cane aphids (a species with no known parasitoids) 

(4-13) is most alarming for the Arkansas 

production area. The aphid is extremely 

damaging pest to grain sorghum (Sorghum 

bicolor) when it occurs, as evidenced by the 

threshold of a single aphid being found per plant. 

Inclusion of IPM programs or buffers away from 

existing corn crops (4-13) in the MMP would do 

nothing to mitigate real environmental impact of 

pests and diseases on all the crops and 

environments in target areas.

Pests & 

Diseases NA AR 72701 Individual None

These plant pests can be treated with conventional 

agricultural chemicals, if necessary. The Project 

Sponsors or the producer would notify adjoining 

properties if any pests or diseases are located and 

need to be treated. The agricultural chemicals to be 

used would be the same as for the treatment of the 

same plant pests, diseases, and weeds (only during 

establishment) that would be used on adjacent 

crops. Chemical use would be project area and sitespecific. All applicable guidance and regulations 

would be followed with documentation to be 

provided with each annual report. All chemical use 

would be described as part of the Conservation Plan 

for each producer's acreage.
Page 67 of 128

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44 7

The suggestion that the recommendations of 

planting giant miscanthus "away from corn" and 

treating the crop to "avoid transmission" 

somehow addresses the data gap of potential 

plant pests (4-2) trivializes the importance of the 

impact of the crop on extant pest and beneficial 

organisms (including pollinators).

Pests & 

Diseases NA AR 72701 Individual None

Comment noted. The Draft EA provided an 

overview of the best available information at the 

time of publication, including any shortcomings in 

the literature. The Project Sponsors, in consultation 

with the NRCS and ARS, developed the Mitigation 

and Monitoring Plan to address the issues of 

concern developed through this NEPA process. 

Since this NEPA process is only for the acceptance of 

BCAP project areas, more site-specific information is 

not available at this time. Individual producers 

would not contract acreage until the BCAP project 

area has been approved by FSA. Each individual 

producer would be required to develop a 

Conservation Plan, which addresses all resource 

areas specific to the local area and the region.

44 8

The statement that "Potential plant pests newly 

associated with giant miscanthus could require 

more pesticide use or greater IPM than 

potentially anticipated based on existing 

literature from Europe, but should be less than 

traditional row crops." is entirely without 

foundation. Pest dynamics in of an exotic plant in 

a novel habitat are essentially impossible to 

predict. Further, several existing "traditional row 

crops" have no or very little pest management or 

pesticide use, and any management in giant 

miscanthus would exceed that of several 

traditional row crops.

Pests & 

Diseases NA AR 72701 Individual None

A review of the literature associated with plant pest 

and diseases was performed and provided in the EA. 

There was little indication from European literature 

of susceptibility to major pests and diseases. The 

Mitigation and Monitoring Plan directly addresses 

the potential for the occurrence of pests and 

diseases and the roles of the producer and Project 

Sponsor for treatment, if necessary.

44 9

Biodiversity studies have only been conducted on 

young-aged giant miscanthus stands (ES-6), and 

have not focused on organisms smaller than 

mammals. The lack of arthropod studies in this 

crop indicates the complete lack of any 

environmental assessment of arthropods in this 

document. Biodiversity NA AR 72701 Individual None

Further literature review was conducted on 

invertebrates. 

44 10

The suggestion that "During the short-term, 

species using pastureland could relocate to 

marginal areas or wildlife corridors" (5-3) has no 

meaning for arthropod pest and beneficial 

(including pollinators) organisms. Additionally, 

the "marginal or idle" lands to be used in all 

states by for giant miscanthus typically are 

already the existing "marginal or wildlife 

corridors"! Biodiversity NA AR 72701 Individual None

Comment noted. Field buffers will be created or will 

be left at field edges to provide multiple 

environmental benefits. The size of the buffer will 

depend on the site-specific conditions prescribed 

through the Conservation Plan. 
Page 68 of 128

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44 11

The authors note that invasive plant species can 

have significant negative impacts on the 

environment by changing ecological processes 

and impacts on native species (including 

pollinators) (3-21). The authors state then state 

that giant miscanthus is not listed as a weed at 

any location and this species is not invasive. The

authors finally conclude that because it is not 

invasive, it will not likely have adverse 

environmental impacts. This is faulty logic. An 

exotic species planted in great acreages in 

monocultures would be expected to impact 

ecological processes. Whether the species is 

invasive to an environment through its own 

biological means or through purposeful planting 

as huge monocultures is irrelevant for the 

potential of the exotic species to alter ecological 

processes. This area is completely ignored in this 

Environmental Assessment. Biodiversity NA AR 72701 Individual None

Biodiversity information reviewed from European 

literature does suggest that miscanthus can provide 

wildlife and insect habitats when compared to 

traditional crops and some pasture lands. The

Mitigation and Monitoring developed in 

consultation with NRCS and ARS, provides 

appropriate minimum buffer width for each project 

area, combined with site-specific increases in buffer 

width for adjacency to sensitive areas, to be 

included in the individual Conservation Plan. 

Additional safeguards have been established for 

active producer monitoring and reporting to the 

Project Sponsor for the initiation of appropriate 

control technologies. 

44 12

It seems unlikely that the local "nurseries" to be 

established at each location will be unable to 

meet the demand to result in the target acreage 

within the projected time-frame. Thus the 

temptation may be to pursue chromosome 

doubling as demonstrated by Yu et al . (2009) as a 

means to more efficiently reach target planting 

areas through seed production. This technique 

must be specifically banned for this project. Seed Sterility NA AR 72701 Individual None

The Project Sponsors would only be using the Illinois 

clone vegetatively propagated through rhizomes to 

establish all acres within the project areas. No 

other clone or species of Miscanthus would be used 

as part of this project area. 

44 13

Water usage for production of this crop (i.e., 

consideration of MPG of water need) is excessive. 

The authors discount this fact with a misleading 

and inaccurate statement (ES-4, line 17ff) that 

"giant miscanthus would be anticipated to 

require more water than annual crops, such as 

corn, however giant miscanthus has much higher 

water use efficiency, generating higher amount of 

biomass per volume of water consumed." Corn is 

one of the least-efficient crops in terms of water 

usage, and to select that species for comparison 

is misleading. Specifically, their source 

(Jorgensen 2011) state giant miscanthus water 

use is high due to its high biomass productivity 

but is actually "exceeded by whole crop maize in 

some cases". Water Use NA AR 72701 Individual None

Water use has been furthered clarified and new 

literature is provided. This also includes a 

comparison with corn for silage, which is a crop that 

has enough data to be released in Pennsylvania. 
Page 69 of 128

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Group Response

44 14

The shortcomings of this assessment regarding 

the potential impact on pest and beneficial 

organisms (including pollinators) arise from the 

preparers' lack of background in agricultural pests 

and diseases necessary to address these key 

issues. Failure to include such expertise is a 

significant shortcoming to this Environmental 

Assessment and could result in a highly 

significant, detrimental environmental impact of 

this large scale experiment across several states. 

Pests & 

Diseases Against AR 72701 Individual None

Comment noted. The Draft EA provided an 

overview of the best available information at the 

time of publication, including any shortcomings in 

the literature. The Project Sponsors, in consultation 

with the NRCS and ARS, developed the Mitigation 

and Monitoring Plan to address the issues of 

concern developed through this NEPA process. 

Since this NEPA process is only for the acceptance of 

BCAP project areas, more site-specific information is 

not available at this time. Individual producers 

would not contract acreage until the BCAP project 

area has been approved by FSA. Each individual 

producer would be required to develop a 

Conservation Plan, which addresses all resource 

areas specific to the local area and the region.

45 1

This note is on response to a request to review 

and comment on the BCAP Environmental 

Assessment of the 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. 

Please note that I had been approached by MFA 

Oil Biomass and had discussed this project with 

them before their submission. General NA MO 65211 University

University 

of Missouri No response required. 

45 2

I have reviewed the proposal and believe this is 

an important approach to helping deal with our 

renewable energy portfolio in the U.S. Biomass is 

one of the few approaches that could be 

implementable within a short period of time 

compared to solar and wind, and that also has 

the opportunity for rural economic development. 

I also believe that the no action alternative would 

actually do more harm than the proposal 

indicates. The no action alternative assumes that 

current economic conditions stay constant, yet 

that is not the case. If anything, the economic 

conditions and development would more than 

likely continue to deteriorate over the proposed 

time period. Hence anything that can possibly 

increase rural economic development is a plus. 

Therefore, I strongly support this program and 

BCAP as a whole. My concerns with what is 

proposed are outlined below. General Support MO 65211 University

University 

of Missouri

Comment noted on the support of the proposed 

action. 
Page 70 of 128

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Group Response

45 3

1. I am not convinced that Giant Miscanthus is 

noninvasive. It appears to be from the studies, 

but this is critical in getting farmers to truly buy 

in. It would be nice to have more data, but it does 

not exist. This would be a way to help determine 

the invasiveness of the species. Invasive NA MO 65211 University

University 

of Missouri

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.

45 4

2. I would like to have seen a range on the 

potential production numbers. It is not clear if 

the estimated biomass produced is an optimistic 

prediction or a pessimistic prediction. It would be 

better if a worst-case scenario, average-case 

scenario and a best-case scenario was given. This 

would obviously also impact the economic 

assessment and payback period.

Socioecono

mics NA MO 65211 University

University 

of Missouri

BCAP is a voluntary program that producers join if 

there is enough economic incentive for the 

individual producer to justify the production of a 

bioenergy crop. As such, producers bear the burden 

of determining individual economic viability on their 

contract acres. The Project Sponsors are providing 

technical assistance to the contract producers for 

establishment, production, and harvesting. The 

economic analysis provided in the Draft EA, was 

determined from publicly available data most 

similar to the confidential economic information 

developed by the Project Sponsors as part of the 

application.
Page 71 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

45 5

3. The areas chosen for production were based 

on rainfall and little consideration appears to 

have been given to the soil conditions. The soil 

assessment was cursory and it is not clear to me 

that Giant Miscanthus would grow well in all the 

soil types in the different regions. This of course 

would also impact productivity of the stands.

Soil 

Resources NA MO 65211 University

University 

of Missouri

Site-specific analysis will be conducted on each 

proposed contract. This process will include an 

initial environmental screening to identify any 

potential environmental issue with the acreage. If 

necessary, consultation with the appropriate 

resources agency would be undertaken to develop 

mitigation measures, to reduce effects below the 

significance thresholds. If the effects cannot be 

reduced, that acreage would not be accepted into 

the BCAP. After the environmental screening, each 

producer would have to develop a Conservation 

Plan with the assistance of a TSP to identify 

appropriate buffer areas and BMPs in addition to 

the guidance provided in the Mitigation and 

Monitoring Plan.

45 6

Overall I believe that the proposal addresses the 

major environmental concerns and that there 

would be little to no negative impact for the 

proposed lands on which this would be planted.

This appears to be well worth consideration. General Support MO 65211 University

University 

of Missouri No response required. 

46 1

The Division of Agriculture, University of 

Arkansas, would like to offer comment regarding 

the Environmental Assessment for the "Proposed 

BCAP Miscanthus x giganteus Establishment and 

Production in Arkansas, Missouri, Ohio, and 

Pennsylvania" project. The Division of Agriculture 

provides research and extension to the State of 

Arkansas, and we received comments from 

several of our scientists. Our comments are 

specific to Arkansas, and are not intended to 

apply to the other states, although the issues we 

raise are common to all states in the proposed 

project. General NA AR 72207 University

University 

of Arkansas, 

Division of 

Agriculture No response required. 
Page 72 of 128

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Group Response

46 2

We believe that there is insufficient information 

in the Environmental Assessment to be able to 

make the claims made by the sponsors. The 

large-scale deployment of this crop (50,000 acres 

in Arkansas by the year 2014) is of sufficient 

magnitude that we believe that greater detail and 

consultation with agricultural scientists is needed. 

The majority of contacts made have been with 

political or economic development (e.g., Chamber 

of Commerce) officials. The document stated 

that, in Arkansas, contacts with state agencies 

were made by Dr. Terry Griffin, an Extension

Agricultural Economist, and Mr. Randy Young, 

Director of the Arkansas Natural Resources 

Commission. Dr. Griffin indicated the extent of 

his contact was from a grower that may plant 

Miscanthus, which was not what was conveyed in 

the document. Given the claims regarding the 

agronomic yields and inputs required, the 

potential invasiveness of Miscanthus, as well as 

the proposed soil and water benefits, we believe 

that contact should have been made with UA 

Division of Agriculture scientists that could have 

provided appropriate scrutiny of the data and 

proposal - economists, agronomists, 

entomologists, soil scientists and invasion 

biologists. The lack of appropriate input from 

specialists in those fields renders the conclusions 

questionable at best. As written, we do not 

believe there is adequate information provided or 

assessment made of the factors that will 

determine the economic viability of the 

Miscanthus production. Therefore we do not 

support the Environmental Assessment, as 

written, but believe a more-detailed study of 

potential impacts needs to be made to ensure 

environmental safety and economic viability of 

the project. General Against AR 72207 University

University 

of Arkansas, 

Division of 

Agriculture

The Project Sponsors worked with many specialists 

and consultants as they developed their project 

area proposal for FSA. They have developed further 

literature of this species, as well as committed to an 

overall Mitigation and Monitoring Plan for the 

project areas to minimize risks associated with the 

establishment and production of this species. Also, 

as part of BCAP, producer are required to develop 

Conservation Plans to address site-specific resource 

needs, best management practices, and exclusion 

areas based on the parcel, State and local 

regulations, and the contractual obligations 

included within the overall Mitigation and 

Monitoring Plan. 
Page 73 of 128

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Group Response

47 1

Concern Nos. 1, 2, and 3: Giant Miscanthus 

(Miscanthus x giganteus) and Biodiversity: The 

DEA (page ES-6) discloses that there is little 

experience in planting and growing giant 

miscanthus in the U.S. No commercial-scale trials 

have been conducted in the U.S. and there is little 

peer-reviewed literature concerning the effects of 

giant miscanthus plantings on biological diversity. 

The DEA (pages 2-9) identifies giant miscanthus 

as a sterile hybrid which does not produce viable 

seed and is therefore propagated vegetatively by 

rhizome division. It appears that giant 

miscanthus is a hardy plant that can reach heights 

over 10 feet and once established can produce a 

thick monoculture in a few years. The DEA states 

that the rhizome spread is slow, 10 centimeters 

(cm) per year (page 4-12). The DEA identifies that 

Glyphosate and traditional tillage have been 

found to be effect eradication methods for giant 

miscanthus, though it may require more than one 

growing season for complete eradication (page 2-

10). If giant miscanthus rhizomes spread 

undiscovered offsite and are uncontrolled, there 

seems to be the potential for giant miscanthus to 

replace native plants with a plant that has limited 

ecological benefit for wildlife, insects or birds. Biodiversity NA IL 60604

Federal 

Agency

EPA-Region 

5

Literature indicates a low probability of invasiveness 

of giant miscanthus; however, the Project Sponsors 

and FSA understand that no commercial sized 

production has occurred in the United States. As 

such, a Draft Mitigation and Monitoring Plan was 

provided as part of the Draft Environmental 

Assessment. This was done to determine through 

further consultation with USDA staff concerns and 

mechanisms to avoid or minimize those concerns. 

The Project Sponsors and FSA also wanted to 

include concerns and suggestions for mitigation 

from public comments. A broad Mitigation and 

Monitoring Plan will be included with the Final EA, 

indicating the responsibilities of FSA, the Project 

Sponsors, and producers for ensuring that only 

minimal effects occur from the establishment and 

production of this species. The Mitigation and 

Monitoring Plan outline the minimum conservation 

efforts or exclusion areas for all project areas. More 

stringent site-specific measures could be 

incorporated into each producer Conservation Plan 

based on site-specific conditions, including adjacent 

properties, and State and local regulations. 

47 2

Recommendation: Please discuss the potential 

for the species to spread and establish offsite by 

animal digging up rhizomes and/or rhizomes 

inadvertently being brought to the surface during 

harvest that are carried and dropped off-site by 

mammals (e.g., dogs, squirrels, raccoons, rats) 

and/or birds to locations well away from a 

miscanthus production field/site. Biodiversity NA IL 60604

Federal 

Agency

EPA-Region 

5

Literature suggests that giant miscanthus rhizomes 

desiccate rapidly, thereby decreasing viability within 

a matter of hours from any predation. Literature 

also points out that rhizomes that remain on the soil 

surface, but are not covered, remain unsprouted 

and desiccate rapidly. 
Page 74 of 128

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Group Response

47 3

In all four project areas, habitats for endangered 

plant, mammal, bird, and aquatic species have 

been identified. The DEA lacks specificity on how 

site-specific reviews would be conducted, what 

criteria would be utilized to determine whether 

and what best management practices (BMPs) 

would be adequate or whether certain acres 

should be screened out, especially for dealing 

with endangered species impacts. Biodiversity NA IL 60604

Federal 

Agency

EPA-Region 

5

Overall, this environmental assessment analyzed a 

project area proposal for BCAP project areas. Only 

when FSA approves a BCAP project area can 

producers begin to enroll acres with FSA and the 

Project Sponsors for inclusion in the project area. 

At this stage, the individual parcels to be included 

within the project areas are not known. However, 

the environmental assessment process provide full 

detail on the general lack of data for certain 

resource areas, such as biodiversity. To ameliorate 

the potential for effects, the Project Sponsors in 

consultation with USDA staff developed an 

overarching Mitigation and Monitoring Plan to 

provide broad categories and actions to be 

conducted by each producer or by the Project 

Sponsors. At the local level, BCAP requires the 

development of a Conservation Plan as part of the 

environmental screening process. The 

Environmental Screening process, will be similar to 

other USDA programs to ensure minimal effects. 

The Environmental Screening process would allow 

FSA to decline acreage that would result in more 

than minimal effects to resources analyzed in this 

environmental assessment even with mitigation 

efforts. This screening process in combination with 

a site-specific Conservation Plan would provide 

reasonable activities that would be conducted 

based on the resources within and adjacent to the 

contract acres. Each Conservation Plan would be 

subject to all State and local regulations, which may 

be more stringent than Federal regulations 

concerning those resources areas. 
Page 75 of 128

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Group Response

47 4

Given the lack of experience, data and specificity, 

the report's conclusions of minor adverse impacts 

on vegetation and wildlife and zero impacts on 

protected species are not supported and 

therefore are not very convincing. Biodiversity NA IL 60604

Federal 

Agency

EPA-Region 

5

Since contract acreage has not been established 

within each proposed project area, site-specific 

analysis cannot be performed through the 

environmental assessment. The Conservation Plan 

for contract acreage will provide a site specific 

analysis of the potential effects at that localized 

level. The Project Sponsors are currently targeting 

lands that have failed as croplands, only produce 

marginal returns with traditional crops, or are 

currently abandoned or managed pastureland. 

Lands with significant or sensitive features would be 

avoided or not accepted into the project area as the 

discretion of the Project Sponsors of FSA before or 

during the site specific environmental review. 

47 5

Recommendation: A case study, where a sitespecific review is conducted on a 30-100 acre plot 

in one of four areas, would be extremely helpful 

to demonstrate how the environmental 

worksheet and screening process and proposed 

BMPs would actually address the sensitive 

resources and/or protected species identified in 

that plot. Biodiversity NA IL 60604

Federal 

Agency

EPA-Region 

5

The BCAP statute does not allow for field trials, test 

plots, or other small-scale demonstration projects. 

The BCAP does allow for reporting of activities 

associated with the establishment and production 

of vegetation on BCAP contracted acreage. The 

Project Sponsors are providing annual reporting to 

the FSA and other USDA agencies are multiple 

aspects associated with establishment and 

production, spread of giant miscanthus outside of 

intentionally planted areas, chemical usage, harvest 

metrics, and other items. 

47 6

Recommendation: We recommend the Final EA 

(FEA) disclose whether or not the Project 

Sponsors considered the feasibility of using a 

mixture of low input/high diversity native grasses 

and forbs for the biomass crop. If so, the FEA 

should please explain the reason for choosing 

giant miscanthus over the native species mixture. Biodiversity NA IL 60604

Federal 

Agency

EPA-Region 

5

The Project Sponsors are proposing a specific 

project for inclusion within the BCAP. The 

reasonable alternatives under consideration are (1) 

the Proposed Action, which implements the Project 

Sponsors plan or (2) the No Action Alternative, 

which would not implement the Project Sponsors 

plan. The Project Sponsors are not required to 

propose alternative species or project locations 

under NEPA.
Page 76 of 128

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Group Response

47 7

Concern No. 4: Mitigation: The DEA for these 

four project areas appears to be compromised by 

a lack of data and specificity. While the four 

project areas are identified, 30-100 acres 

commitments with individual growers within 

these project areas do not appear to have been 

realized, so specific environmental impacts have 

not been identified. Specific examples of how 

mitigation would adequately address these 

impacts are not provided. Rather, the DEA 

provides a generic process whereby site-specific 

reviews would be conducted by Technical Service 

Providers (TSPs) using an environmental 

worksheet to determine whether 

environmentally sensitive resources or protected 

species are present and could be potentially 

affected. If so, FSA proposes an adaptive 

mitigation and monitoring plan (MMP) which 

would include best management practices (BMPs) 

to be used in the establishment and production 

of giant miscanthus to ensure minimization of 

potentially adverse effects. FSA (page 6-2) is 

expected to have primary responsibility for 

implementation and tracking of the mitigation 

and monitoring program. The DEA identifies that 

FSA is currently developing a Memorandum of 

Understanding (MOU) with the Natural Resources 

Conservation Service (NRCS) to have NRCS 

provide technical support as TSPs on an individual 

contract basis to ensure each producer complies 

with existing requirements of BCAP including 

completion of the Environmental Screening 

worksheet, completion of a Conservation Plan, 

and compliance with all existing rules and 

regulations following BMPs outlined in NRCS 

Conservation Practice Standards. However, the 

DEA does not include a draft of the proposed 

Mitigation and Monitoring Plan or a draft of the 

FSA/NRCS MOU. Consequently, based on 

information in the DEA, we cannot determine if 

adequate mitigation and monitoring will likely be 

identified and successfully implemented in order 

to adequately protect the environment.

Mitigation 

Measures NA IL 60604

Federal 

Agency

EPA-Region 

5

The Mitigation and Monitoring Plan was provided in 

a draft form in the Draft EA to allow for public input 

and comment on the features to be included. 

Overall, comments from the public and agencies 

have provided a great deal of additional information 

to include in the Mitigation and Monitoring Plan as 

best management practices or exclusions of 

acreage.
Page 77 of 128

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Group Response

47 8

Recommendation: We recommend the FEA 

include a draft MMP specific for each project 

area, if feasible, and include the signed MOU 

between the USDA-FSA and NRCS regarding NRCS 

TSPs for this proposal. The project-area-specific 

MMPs should be in place prior to any plantings of 

giant miscanthus rhizomes and the plan/s should 

be reviewed by independent crop and invasive 

species experts to assure that there are adequate 

measures to prevent the release of giant 

miscanthus into the natural environment. As part 

of the MMPs, there should be a buffer around 

each of these sites where the spread of giant 

miscanthus can be identified before it spreads 

offsite. Existing vegetation should be identified 

and quantified for areas where paste/rangeland, 

will be converted. Rangeland vegetation, which 

may contain a diversity of native and/or nonnative perennial grasses, provides greater 

biodiversity, decreases the potential for erosion, 

does not require pesticides, herbicides, or 

fertilizers (PH&F) input, and increases water 

filtration. The consequences, positive and 

negative, of converting paste/rangeland should 

be described in the FEA.

Mitigation 

Measures NA IL 60604

Federal 

Agency

EPA-Region 

5

A final Mitigation and Monitoring Plan will be 

included with the Final EA, detailing the aspects 

considered within this comment.

47 9

Recommendation: EPA recommends areas 

currently in pasture/rangeland that have good 

biodiversity be avoided as potential sites for 

biomass production. We further recommend that 

brownfields, reclaimed mines, former landfills 

and other such unused land be aggressively 

pursued by FSA and the Project Sponsors for 

evaluation for possible biomass cultivation.

Mitigation 

Measures NA IL 60604

Federal 

Agency

EPA-Region 

5

Comment noted, suggestion will be taken into 

consideration by the Project Sponsors and the FSA 

on a site-specific basis as part of the environmental 

screening process and producer Conservation Plan. 

47 10

Concern No. 5: Water Quality: Although inputs 

of PH&F for giant miscanthus may be lower in 

areas where traditional row crops dominate, 

inputs will be higher where fallow, idle, or 

pasture/rangelands dominate. Stormwater 

runoff containing PH&F could lead to increased 

non-point source pollution in area waterways.

Water 

Quality NA IL 60604

Federal 

Agency

EPA-Region 

5

The Mitigation and Monitoring Plan and each 

producers' Conservation Plan will address 

agricultural chemical usage BMPs and guidance. 

The combination ensures that even with the 

conversion of pasture, that stormwater runoff even 

during the establishment period, would result in 

only minor effects to water quality. 
Page 78 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

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Group Response

47 11

Recommendation: The EA would benefit by 

including a list of potential pesticides, herbicides, 

and fertilizers that could be used in giant 

miscanthus production along with a discussion of 

their possible effects on water quality, including 

effects to Clean Water Act Section 303 (d) 

impaired waters. Please include amount of PH&F 

per acre typically used for biomass production of 

giant miscanthus or a similar biomass crop.

Water 

Quality NA IL 60604

Federal 

Agency

EPA-Region 

5

Average amount of fertilizer per acre were 

developed and included within the Final EA. All 

pesticides and herbicides would be applied at the 

appropriate label rate following all Federal, State, 

and local regulations. All agricultural chemical 

applications would be applied, handled, and stored, 

per best management practices and any applicable 

regulations. Special care would be taken with the 

use of agricultural chemical near sensitive areas and 

would be included as part of the individual 

producer's site-specific Conservation Plan.

47 12

Recommendation: For clarity, please include 

large scale maps in the EA that depict potential 

landowner locations overlaid on impaired waters 

and threatened and endangered species.

Water 

Quality NA IL 60604

Federal 

Agency

EPA-Region 

5

Overall, this environmental assessment analyzed a 

project area proposal for BCAP project areas. Only 

when FSA approves a BCAP project area can 

producers begin to enroll acres with FSA and the 

Project Sponsors for inclusion in the project area. 

At this stage, the individual parcels to be included 

within the project areas are not known. However, 

the environmental assessment process provide full 

detail on the general lack of data for certain 

resource areas, such as biodiversity. To ameliorate 

the potential for effects, the Project Sponsors in 

consultation with USDA staff developed an 

overarching Mitigation and Monitoring Plan to 

provide broad categories and actions to be 

conducted by each producer or by the Project 

Sponsors. At the local level, BCAP requires the 

development of a Conservation Plan as part of the 

environmental screening process. The 

Environmental Screening process, will be similar to 

other USDA programs to ensure minimal effects. 

The Environmental Screening process would allow 

FSA to decline acreage that would result in more 

than minimal effects to resources analyzed in this 

environmental assessment even with mitigation 

efforts. This screening process in combination with 

a site-specific Conservation Plan would provide 

reasonable activities that would be conducted 

based on the resources within and adjacent to the 

contract acres. Each Conservation Plan would be 

subject to all State and local regulations, which may 

be more stringent than Federal regulations 

concerning those resources areas. 
Page 79 of 128

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No. 

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No. Comment Category Position State

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Agency/

Group Response

47 13

Recommendation: EPA recommends the FEA 

correct the following: In the document (page 2-

9), there are several references to Harness 

herbicide containing "Acteochlor" as an active 

ingredient. However, the active ingredient in 

Harness is "Acetochlor."

Water 

Quality NA IL 60604

Federal 

Agency

EPA-Region 

5 Text correction has been included in the Final EA

47 14

Concern No. 6: Connected Actions/Biomass 

Conversion Facilities (BCFs): Each of the four 

project areas require that the miscanthus crop be 

taken to a Biomass Conversion Facility (BCF) for 

processing. However, the DEA provides minimal 

information regarding the BCFs for this proposal. 

The DEA is unclear whether some or all of the 

BCFs currently exist or will need to be 

constructed. The DEA does not identify the size 

of the area needed nor the components that 

make up a typical miscanthus BCF nor does the 

DEA explain how a miscanthus BCF operates. 

Consequently, potential direct, indirect and 

cumulative impacts associated with the siting, 

construction, and/or operations of the BCFs are 

not identified nor potential mitigation measures 

proposed.

Biomass 

Conversion 

Facility NA IL 60604

Federal 

Agency

EPA-Region 

5

The BCAP establishment and annual payments are 

provided to the establishment and production of 

bioenergy crops. FSA has no control over the 

materials once it leaves the field for conversion into 

another product. As such the project definition is 

limited to establishment and production of giant 

miscanthus only, not any related downstream issues 

that FSA cannot control or regulate. 

47 15

Recommendation: Since the BCFs for the 

proposed project areas are integral to the 

successful implementation of the Biomass Crop 

Assistance Program and this particular proposal, 

we recommend the BCFs be considered 

connected actions under NEPA and their impacts 

and proposed mitigation for those impacts be 

disclosed in the FEA. Any permits that may be 

needed to construct and/or operate should also 

be disclosed.

Biomass 

Conversion 

Facility NA IL 60604

Federal 

Agency

EPA-Region 

5

The BCAP establishment and annual payments are 

provided to the establishment and production of 

bioenergy crops. FSA has no control over the 

materials once it leaves the field for conversion into 

another product. As such the project definition is 

limited to establishment and production of giant 

miscanthus only, not any related downstream issues 

that FSA cannot control or regulate. 
Page 80 of 128

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No. Comment Category Position State

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Group Response

47 16

Concern No. 7: Renewable Fuel 

Standard/Greenhouse Gas Emission 

(GHGs)/Criteria Pollutants: There is no 

evaluation of greenhouse gas (GHG) emission 

impacts associated with establishment of giant 

miscanthus under BCAP. EPA has determined 

under the Renewable Fuel Standard (RFS) that 

several biofuel pathways that use miscanthus as a 

feedstock qualify as a "Cellulosic Biofuel" under 

RFS definitions, indicating that EPA has assessed 

that these pathways meet the 60% lifecycle 

greenhouse gas reduction threshold as compared 

to a 2005 fossil fuel baseline required for 

Cellulosic Biofuels under RFS (see 40 CFR Part 80 

for further details).

GHG 

Emissions NA IL 60604

Federal 

Agency

EPA-Region 

5

The BCAP establishment and annual payments are 

provided to the establishment and production of 

bioenergy crops. FSA has no control over the 

materials once it leaves the field for conversion into 

another product. As such the project definition is 

limited to establishment and production of giant 

miscanthus only, not any related downstream issues 

that FSA cannot control or regulate. 

47 17

EPA's July 26, 2010 Comments on BCAP 

Programmatic EIS with regards to impacts on 

GHG emissions. Since EPA's July 26, 2010 

comments on the BCAP Programmatic EIS 

regarding concerns with the overall assessment 

of the program's impact on GHG emissions were 

not adequately addressed, we take this 

opportunity to reiterate our PEIS comments and 

recommend the FEA incorporates these changes, 

as follows: 

GHG 

Emissions NA IL 60604

Federal 

Agency

EPA-Region 

5

These comments are specific to the BCAP PEIS and 

not to this environmental assessment. FSA has 

provided responses to these comments during the 

BCAP PEIS process. 
Page 81 of 128

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47 18

Section 4.4.3 - 4.4.4 Direct & Indirect impacts 

definitions and reference: U.S. legislation (Energy 

Independence and Security Act of 2007, or 

"EISA") and regulation (Renewable Fuels 

Standard, or "RFS") have laid down precedent in 

use of the terms "direct effects" and "indirect 

effects" with regard to lifecycle analysis of 

greenhouse gas emissions for biofuels. EPA is 

concerning that the use of the two terms in the 

EIS is inconsistent with precedent in U.S. 

legislation and regulation with typical usage of 

the terms in the field of lifecycle analysis. Section

4.4.3 - 04.4.4 refers to the "the concept of 

indirect" as "offsite activities" that contribute to 

biofuel production or electricity generation for 

irrigation). In RFS and in the science of lifecycle 

analysis, such "offsite activities" are typically 

considered "direct impacts" (or "indirect effects") 

as they directly contribute to the production of 

the biofuel - i.e., in this analysis, the "system 

boundaries" includes its direct impacts such 

offsite activities. "Indirect Impacts" are typically 

considered those secondary impacts mediated by 

the impact of the biofuel production/use on 

existing markets (e.g., land use change impacts). 

Section 4.4.3.2 and 4.4.4.2 titled "Indirect 

Impacts" discusses impacts on quality (i.e., nonGHG pollutants). These should be refereed to as 

"direct impacts" on air quality. The section would 

more appropriately be titled "Non-GHG Air 

Quality Impacts." EPA expresses its concern that 

these terms should be used in the BCAP EIS in a 

manner consistent with other U.S. reports and

studies in order to clearly communicate the types 

of effects the EIS has analyzed. 

GHG 

Emissions NA IL 60604

Federal 

Agency

EPA-Region 

5

These comments are specific to the BCAP PEIS and 

not to this environmental assessment. FSA has 

provided responses to these comments during the 

BCAP PEIS process. 
Page 82 of 128

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47 19

Section 4.4.3.2 and 4.4.42 - Non-GHG pollution : 

EPA expresses concern that the EIS does not fully 

analyze potential impacts of the BCAP program 

on air quality due to non-GHG emissions. The EIS 

reports that because the same machinery is used 

for feedstock production for biofuels as is used 

for other farming practices, implementation of 

BCAP program would result in no change to nonGHG related air quality. This assumption does 

not examine the possibility that increased crop 

production due to the BCAP program could lead 

to use of such machinery (and other related 

sources of air pollutant emissions) and increased 

total emissions compared to a No Action 

baseline.

GHG 

Emissions NA IL 60604

Federal 

Agency

EPA-Region 

5

These comments are specific to the BCAP PEIS and 

not to this environmental assessment. FSA has 

provided responses to these comments during the 

BCAP PEIS process. 

47 20

Section 4.4.2 - Methodology (for GHG Analysis): 

EPA expresses concern that the methodology 

description for the EIS analysis of potential GHG 

emissions impacts of BCAP does not provide 

sufficient information on analysis approach, 

modeling framework and tools, assumption, and 

emissions for readers to understand the reported 

results. In order for readers to adequately 

understand the EIS GHG analysis results, the 

methodology description should provide the 

following information: Modeling system and/or 

tools used to construct Net Ecosystem Carbon 

Budgets (NECB). Assumptions applied in 

constructing NECBs (for both the baseline and 

alternative use scenarios) and in comparing 

NECBs. (e.g., crop yields, fertilizer inputs) 

Description of the system boundaries for the 

analysis. The description should include 

clarification that downstream emissions (e.g., fuel 

processing and combustion ) are not included. 

The time for the analysis (i.e., near term, longer 

term?) Indicate whether emission impacts 

reported are annual or cumulative over time.

GHG 

Emissions NA IL 60604

Federal 

Agency

EPA-Region 

5

These comments are specific to the BCAP PEIS and 

not to this environmental assessment. FSA has 

provided responses to these comments during the 

BCAP PEIS process. 
Page 83 of 128

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Group Response

47 21

Criteria Pollutants: The DEA identifies all project 

areas are in attainment for all criteria pollutants, 

except for the Ohio/Pennsylvania project area. 

The project area in Ohio contains Lake County 

designated as non-attainment for PM2.5 and 

Ashtabula County designated as partial nonattainment for PM2.5 Lake County and Ashtabula 

County are part of the Cleveland-Akron-Lorain Air 

Quality Control Region (AQCR) 174.

GHG 

Emissions NA IL 60604

Federal 

Agency

EPA-Region 

5

These comments are specific to the BCAP PEIS and 

not to this environmental assessment. FSA has 

provided responses to these comments during the 

BCAP PEIS process. 

47 22

Recommendation: The EA should disclose the 

sources and amounts of PM2.5 that may be 

emitted in Lake and Ashtabula Counties due to 

project implementation and operation, including 

the construction and/or operation of the 

Ashtabula BCF. The FEA should identify measures 

that will be undertaken to prevent any increases 

in PM2.5 in these areas due to the proposal. The 

FEA should also identify any air permits that may 

be needed for construction and/or operation of 

all BCFs.

GHG 

Emissions NA IL 60604

Federal 

Agency

EPA-Region 

5

These comments are specific to the BCAP PEIS and 

not to this environmental assessment. FSA has 

provided responses to these comments during the 

BCAP PEIS process. 
Page 84 of 128

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47 23

Concern No. 8: Environmental Justice: It is not 

clear that a detailed environmental justice (EJ) 

analysis should be eliminated from this EA. EPA's 

comments on the draft Programmatic EIS, asked 

FSA to discuss how its Civil Rights Impact Analysis 

(CRIA) meets the letter and intent of Executive 

Order (E.O.) 129898. The July 2010 final 

Programmatic EIS, from which this EA was tiered, 

did not demonstrate this nor determine that 

disproportionate effects to minority, low-income 

and indigenous populations would not occur in 

the project areas. This precluded delineation of 

communities with possible EJ concerns.

Environment

al Justice NA v 60604

Federal 

Agency

EPA-Region 

5

A brief display of the minority and low-income 

communities within each county of each proposed 

project area will be included in the Final EA.

47 24

Recommendations: EPA recommends the FEA 

leverage publicly available demographic 

information resources by utilizing tools such as 

Landview or other GIS-type data visualization 

applications to support the identification, 

mapping, and analysis of potential populations 

with EJ concerns. At the core of any EJ analysis is 

the identification of populations that may be 

considered communities with EJ concerns. Once 

the population is identified, the affected area(s) 

can be delineated and the project's impacts and 

alternatives can be analyzed. EPA also 

recommends the FEA provide documentation 

that will substantiate a determination of nonapplicability for an EJ analysis and support the 

argument that a reasonable threshold 

determination could be made regarding this. The 

DEA did not identify the human environment 

within the 50-mile radius of the project area, any 

sources of exposure that population(s) may 

experience or mitigation measures to address any 

adverse impacts. The DEA analyzed the 

establishment of four proposed BCAP project 

areas, two in Missouri, one in Arkansas, and one 

in Ohio and Pennsylvania. The EA states in part 

..."Each proposed project area was developed as 

an approximate 50-mile radius from the 

approximate location of each BCF ... the BCF 

location must include access to rail, highway, and 

be within reasonable distance of ports for water 

connection. These factors suggest the probability 

of human habitation and activity. 

Environment

al Justice NA IL 60604

Federal 

Agency

EPA-Region 

5

A brief display of the minority and low-income 

communities within each county of each proposed 

project area will be included in the Final EA.
Page 85 of 128

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47 25

Recommendation: EPA recommends that the 

FEA identify the human environment within the 

50-mile radius of the project area/s, sources of 

exposure that the population(s) may experience 

and the mitigation measures to address any 

adverse impacts. The Council on Environmental 

Quality (CEQ) EJ NEPA Guidance discusses general 

principles for considering EJ under NEPA. It states 

in part: "In preparing an EIS or an EA, agencies 

must consider both impacts on the natural and 

physical environment and related social, cultural 

and economic impacts. EJ concerns may arise 

from impacts on the natural and physical 

environment, such as human health or ecological 

impacts on minority populations, low-income 

populations and Indian tribes, or from social or 

economic impacts."

Environment

al Justice NA IL 60604

Federal 

Agency

EPA-Region 

5

A brief display of the minority and low-income 

communities within each county of each proposed 

project area will be included in the Final EA.

47 26

Concern No. 9: Cumulative Effects: A cumulative 

effects analysis should take into consideration the 

effects of other past, present, and reasonably 

foreseeable future actions in the project area/s. 

The cumulative impacts assessment section of 

the DEA does not identify or discuss any other 

actions that could have an impact to the 

resources listed in the DEA. Only the potential 

cumulative effects by the proposed action are 

identified and discussed. This is not the intent of 

40 CFR Part 1508.7.

Cumulative 

Effects NA IL 60604

Federal 

Agency

EPA-Region 

5

The cumulative effects analysis was based on the 

past and existing agricultural activities within these 

project areas and the potential for additional BCAP 

project areas within the reasonably foreseeable 

future. 

47 27

Recommendation: EPA recommends the FEA 

provide a cumulative impacts analysis that 

identifies and takes into account the cumulative 

effects associated with other past, present and 

reasonably foreseeable actions in the project 

area/s. 

Cumulative 

Effects NA IL 60604

Federal 

Agency

EPA-Region 

5

The cumulative effects analysis was based on the 

past and existing agricultural activities within these 

project areas and the potential for additional BCAP 

project areas within the reasonably foreseeable 

future. 
Page 86 of 128

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48 1

On behalf of the Natural Resources Defense 

Council, I submitted these comments on the 

Environment Assessment (EA) for the proposed 

establishment and production of giant 

miscanthus (Miscanthus X giganteus) in Arkansas, 

Missouri, Ohio, and Pennsylvania as a project 

under the Biomass Crop Assistance Program 

(BCAP). We thank the Farm Services Agency (FSA) 

for considering these comments. We are pleased 

that FSA required Aloterra Energy and MFA Oil 

Biomass Company to prepare this environmental 

assessment, especially in light of the failure of the 

earlier BCAP programmatic environmental impact 

statement to consider specific potential impacts 

and mitigation of miscanthus or other biomass 

crops. We see the following concerns in the 

miscanthus Environmental Assessment: General NA CA 94104 NGO NRDC No response required. 

48 2

1) The EA relies on monitoring and adaptive 

response for invasiveness and other impacts, but 

there is not commitment to requiring or funding 

the work. Furthermore, potentially invasive 

species must be monitored during the full life of 

establishment and harvest of the crop, including 

transportation routes, because it can take many 

years for a species to demonstrate that it is 

indeed invasive.

Mitigation 

Measures NA CA 94104 NGO NRDC

The Project Sponsors, as part of the MMP, will 

outline a long-term monitoring plan for potential 

escape and control of giant miscanthus. As part of 

the Quality Assurance Program with the OSIA, the 

Project Sponsors have agreed to thoroughly clean 

equipment used for planting, harvesting, and 

transporting giant miscanthus rhizome materials. 

The MMP will detail, the steps to occur if viable 

seed are found through the seed sampling program. 

These steps could include (1) halting any harvest of 

the identified field with no off-site movement of any 

material harvested from that field, (2) immediate 

removal of existing inflorescences in the field that 

was found to contain viable seeds, (3) resampling of 

those inflorescences at a greater rate to determine 

an approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range. The Project Sponsors will 

continue the MMP through the life of the contract 

between the producer and the Project Sponsor, 

which can be renewed in perpetuity.
Page 87 of 128

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48 3

2) Mitigation plans are touted but still under 

development, and not discussed in even general 

terms. Once miscanthus has escaped, what 

would be done to eliminate the escaped and the 

original perennial crops? Who would bear the 

expense and do the work, and how would private 

landowners be compensated? Which methods 

are effective? We all know many examples of the 

near impossibility of getting rid of invasive plants, 

so what evidence is there that a miscanthus 

mitigation plan work? 

Mitigation 

Measures NA CA 94104 NGO NRDC

The Mitigation and Monitoring Plan was provided in 

a draft form in the Draft EA to allow for public input 

and comment on the features to be included. 

Overall, comments from the public and agencies 

have provided a great deal of additional information 

to include in the Mitigation and Monitoring Plan as 

best management practices or exclusions of 

acreage.

48 4

3) The EA assumes no displacement of 

productive activity to other lands. However, 

since 80 percent of the projected contracts will 

be on pasturelands, those impacts would have a 

lot to do with the elasticity of demand for beef 

and dairy. Cattle on pasture can be a beneficial 

land use, but if those cattle are displaced into 

feedlots by biomass production, there could be 

an indirect effect on more cropland needed to 

grow feed, thereby leading to plowing up 

marginal lands for cropland. All proposed project 

areas have CRP acreage, but there is no 

assessment of the project's impact on 

conservation enrollment. Some areas include 

woodlands, which received no meaningful effects 

analysis at all. Land Use NA CA 94104 NGO NRDC

An analysis of the livestock activities currently ongoing within these project areas was further 

identified in the Final EA. Producers are unlikely to 

convert high quality pastureland that provides 

livestock grazing, if that enterprise provides a higher 

return on investment that production of giant 

miscanthus. BCAP is a voluntary program that 

producer will only enter if they determine on any 

individual basis that the return would be superior to 

the existing operations on the contract acreage.

48 5

4) Species that are considered candidates for 

being listed as threatened or endangered are 

mentioned as sensitive, but no analysis whatever 

is offered of their occurrence or vulnerability in 

the project areas.

Species of 

Concern NA CA 94104 NGO NRDC

The Final EA will include information on State-listed 

protected species and species of concern. However, 

all protected and species of concern would be 

considered on a site-specific basis through the 

environmental screening process and each 

producer's Conservation Plan. Any acreage that 

would have adverse effects to protected species 

would enter through the appropriate consultation 

process to determine mitigation measures that 

would reduce those effects, or if mitigation would 

not reduce the effects, the contract acreage would 

not be accepted into the project area.
Page 88 of 128

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48 6

5) Added chemical input from conversion of 

pasture or fallow lands is glossed over, which is 

particularly troubling given the number of 

impaired waterbody segments in the project 

areas.

Chemical 

Inputs NA CA 94104 NGO NRDC

Chemical inputs during establishment would be 

similar to other products used to control the growth 

of unwanted vegetation during the early stages of 

growth in giant miscanthus. All agricultural 

chemical applications would follow all Federal, 

State, and local regulations concerning use, 

handling, and disposal. The Conservation Plan for 

each producer contract acreage would include an 

overview of agricultural chemicals to be used and 

the appropriate rates. Fertilization of giant 

miscanthus would not occur until year three or 

later, after the giant miscanthus crop has 

established. Soil testing would occur prior to the 

first application and then at a frequency appropriate 

for the site-specific conditions at random locations 

throughout the fields. The soil testing will help to 

pinpoint the necessary amount of fertilization 

required for continued production of biomass. 

Pesticide use would follow the same protocols as 

herbicide use. 

48 7

6) No transportation related impacts are 

analyzed, notwithstanding that the end product is 

a highly fungible pellet with far-flung markets, 

including foreign countries. We hope that the 

project is held to its plan that harvested biomass 

should not be shipped more than 50 miles to its 

biomass conversion facility. However, 

transportation costs after pelletizing should also 

be analyzed.

Transportati

on Effects NA CA 94104 NGO NRDC

Emissions outside of the establishment and 

production of giant miscanthus are not considered 

part of the project definition, as such they have not 

been analyzed. Mobile source emissions from 

agricultural equipment would be minor and occur 

infrequently throughout the year in the nonattainment areas.

48 8

7) There is zero analysis of impact on atmospheric 

CO2, either directly, from displacement, or 

through processing/transportation. While 

cellulosic biomass for energy can be much better 

at reducing greenhouse gas emissions than fossil 

fuels, there is absolutely no guarantee that this 

will be the case.

Atmospheric 

CO2 NA CA 94104 NGO NRDC

Emissions outside of the establishment and 

production of giant miscanthus are not considered 

part of the project definition, as such they have not 

been analyzed. Mobile source emissions from 

agricultural equipment would be minor and occur 

infrequently throughout the year in the nonattainment areas.

48 9

8) Despite the high price tag for miscanthus crop 

establishment (more than $5,000/acre for the 

proposed 200,000 acres = $100 million) from a 

now quite limited BCAP funding pool, there is no 

comparative analysis of how else BCAP money 

might be spent. Perhaps other perennial crops 

that can be safely established by seed might be a 

better investment of the taxpayer dollar.

Other 

Species NA CA 94104 NGO NRDC

The Project Sponsors are proposing a specific 

project for inclusion within the BCAP. The 

reasonable alternatives under consideration are (1) 

the Proposed Action, which implements the Project 

Sponsors plan or (2) the No Action Alternative, 

which would not implement the Project Sponsors 

plan. The Project Sponsors are not required to 

propose alternative species or project locations 

under NEPA.
Page 89 of 128

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Group Response

48 10

9) The EA recognized the features of giant 

miscanthus that make it an extreme threat as an 

invasive species, but it failed to consider the 

potential for it to reproduce, as have so many 

other supposedly sterile species such as Bradford 

pear. Ornamental plantings of related 

miscanthus species should be studied for their 

potential cross with giant miscanthus. It is 

particularly alarming to hear about companies 

like Ceres, Inc. which are developing varieties of 

miscanthus that can be grown by seed. Invasive NA CA 94104 NGO NRDC

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.
Page 90 of 128

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49 1

We submit these comments on behalf of a 

national network of grassroots groups working to 

ensure that our country’s energy programs are 

implemented in a manner that is adequately 

protective of the environment and public health 

and that is consistent with the urgent need to 

address climate change. We are concerned about 

the actions described under the proposed 

Environmental Assessment (EA) because of their 

ecosystem, climate and health impacts. The EA 

fails to comply with NEPA because its 

consideration of alternatives is inadequate and it 

fails to adequately describe and mitigate 

ecosystem impacts. The EA is also inadequate for 

purposes of complying with the October 27, 2010 

Record of Decision (ROD) for the BCAP Final 

Programmatic Environmental Impact Statement 

(PEIS). We submitted comments on the draft 

PEIS for the BCAP program on September 24, 

2009 (Comments of EcoLaw) and on the FPEIS on 

August 16, 2010 with the Natural Resources 

Defense Council and the National Sustainable 

Agriculture Coalition. General Against MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning No response required. 

49 2

1. The EA relies on monitoring and adaptive 

response, but there no commitment to requiring 

or funding the work needed to actually 

implement and monitor the mitigation activities 

throughout the life of the project. Without such a 

commitment, the monitoring and adaptive 

response are not credible control or mitigation 

measures.

Financial 

Responsibilit

y NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

The Mitigation and Monitoring Plan clearly identifies 

the responsibilities of the FSA, the Project Sponsors, 

and the producers. 

49 3

2) The EA refers to mitigation plans as the means 

to address various issues, but these plans are still 

development, and not discussed in even the most 

general terms. The EA should be revised to 

describe in detail the mitigation plans, and they 

must be site specific, based on current data about 

the condition of ecosystems that will be 

impacted.

Mitigation 

Measures NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

The Mitigation and Monitoring Plan was provided in 

a draft form in the Draft EA to allow for public input 

and comment on the features to be included. 

Overall, comments from the public and agencies 

have provided a great deal of additional information 

to include in the Mitigation and Monitoring Plan as 

best management practices or exclusions of 

acreage.
Page 91 of 128

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49 4

3) The EA assumes the planting and production 

will not result in displacement of productive 

activity to other lands or locations. Since most of 

the projected BCAP contracts will be on 

pasturelands, those impacts would impact the 

elasticity of demand for beef and dairy. All 

proposed project areas have Conservation 

Reserve Program (CRP) acreage, but there is no 

assessment of the project on conservation 

enrollments. Some proposed project areas 

include woodlands which receive no meaningful 

effects analysis at all under the draft EA. 2. world 

food prices and prices for U.S. farmland are 

skyrocketing, EA fails to accurately account for 

these socioeconomic impacts.

Indirect Land 

Use Effects NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

Based on the amount of available "other cropland" 

and pastureland within the project areas, there is 

sufficient acreage to avoid the conversion of higher 

quality habitats (e.g., forestlands or woodlands) or 

lands currently included within a Federal or State 

conservation program. BCAP, by statute, provides a 

mechanism to help producers establish and produce 

bioenergy crops. With this program, the Project 

Sponsors are estimating a positive balance for 

producers by Year 6 of production, rather than at 

Year 10 or later without BCAP.

49 5

4) The EA mentions candidate species are 

mentioned “sensitive” but no analysis whatever is 

offered of their occurrence or vulnerability in the 

project areas.

Sensitive 

Species NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

Further clarification would be provided to ensure 

that site-specific conditions do not create adverse 

effects to State-listed species. Species of concern, 

but not protected under State law/regulation, 

Federal laws/regulations, or tribal regulation would 

be considered to the extent of management by the 

appropriate entity. Site specific Conservation 

Planning would address wildlife best management 

practices that meet the needs of locally occurring 

protected species. No taking of a protected species 

would be allowed without appropriate consultation 

with the U.S. Fish and Wildlife Service and the 

appropriate State agency. 
Page 92 of 128

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Group Response

49 6

5) The EA provides inadequate data and analysis 

on the added chemical inputs from conversion of 

pasture or fallow lands, and wholly fails to 

address the impacts of these chemical inputs.

Chemical 

Inputs NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

Chemical inputs during establishment would be 

similar to other products used to control the growth 

of unwanted vegetation during the early stages of 

growth in giant miscanthus. All agricultural 

chemical applications would follow all Federal, 

State, and local regulations concerning use, 

handling, and disposal. The Conservation Plan for 

each producer contract acreage would include an 

overview of agricultural chemicals to be used and 

the appropriate rates. Fertilization of giant 

miscanthus would not occur until year three or 

later, after the giant miscanthus crop has 

established. Soil testing would occur prior to the 

first application and then at a frequency appropriate 

for the site-specific conditions at random locations 

throughout the fields. The soil testing will help to 

pinpoint the necessary amount of fertilization 

required for continued production of biomass. 

Pesticide use would follow the same protocols as 

herbicide use. 

49 7

6) The EA fails completely to analyze 

transportation related impacts. This is 

particularly notable since the EA describes one of 

the possible end uses of the crops as an export 

product, including as a highly fungible pellet with 

far-flung markets, including foreign countries.

Transportati

on Effects NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

Emissions outside of the establishment and 

production of giant miscanthus are not considered 

part of the project definition, as such they have not 

been analyzed. Mobile source emissions from 

agricultural equipment would be minor and occur 

infrequently throughout the year in the nonattainment areas.

49 8

7) The EA fails to analysis of impact on 

atmospheric carbon dioxide, CO2, either directly, 

from displacement, or through 

processing/transportation, or from combustion of 

the crops for energy production (electricity or 

thermal).

Atmospheric 

CO2 NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

Emissions outside of the establishment and 

production of giant miscanthus are not considered 

part of the project definition, as such they have not 

been analyzed. Mobile source emissions from 

agricultural equipment would be minor and occur 

infrequently throughout the year in the nonattainment areas.

49 9

8) Despite the high price cost of implementing 

the project (>$5k/acre for 200,000 acres = $100 

million) from a now quite limited funding pool on 

the federal level, the EA contains no comparative 

analysis of how else the money might be spent.

Other 

Species NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

The Project Sponsors are proposing a specific 

project for inclusion within the BCAP. The 

reasonable alternatives under consideration are (1) 

the Proposed Action, which implements the Project 

Sponsors plan or (2) the No Action Alternative, 

which would not implement the Project Sponsors 

plan. The Project Sponsors are not required to 

propose alternative species or project locations 

under NEPA.
Page 93 of 128

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49 10

9) The alternatives analysis is faulty because it 

fails identify alternatives to bioenergy crops that 

will also meet the myriad goals of the Farm Bill of 

2008. Alternatives that should be considered 

include use of farmland for alternative energy 

other than biomass combustion and conversion 

to liquid biofuels. This would include using the 

land for wind turbines or other energy facilities.

Alternatives 

Analyzed NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

The Project Sponsors are proposing a specific 

project for inclusion within the BCAP. The 

reasonable alternatives under consideration are (1) 

the Proposed Action, which implements the Project

Sponsors plan or (2) the No Action Alternative, 

which would not implement the Project Sponsors 

plan. The Project Sponsors are not required to 

propose alternative species or project locations 

under NEPA.

49 11

The EA does not comply with CCEQ NEPA 

regulations for a EA or with USDA NEPA 

regulations at 7 CFR 799. General NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

Comment noted, the NEPA process requires an 

appropriate level of environmental review based on 

the Agency's assessment of the potential for 

significant effects. In this instance, the EA was an 

appropriate NEPA-level evaluation to determine if 

effects would be significant and require the 

preparation of an EIS

49 12

Cumulative Effects: The NEPA regulations require 

a cumulative effects analysis that considers the 

potential environmental impacts resulting from 

“the incremental impacts of the action when 

added to other past, present and reasonably 

foreseeable actions regardless of what agency or 

person undertakes such other actions.” The EA 

fails to consider the potential environmental 

impacts of the actions proposed under the EA. 

The summary provided in Table ES-2 is not 

substantiated by the facts outlined in regards to 

water use, invasiveness/uncontrolled spread of 

the species. The economic data do not provide 

evidence that the project is financially feasible, so 

though rated as “minor” these factors are not.

Cumulative 

Effects NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

The cumulative effects analysis was based on the 

past and existing agricultural activities within these 

project areas and the potential for additional BCAP 

project areas within the reasonably foreseeable 

future. 
Page 94 of 128

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Group Response

49 13

Land use selection The EA is in accurate because 

the land to be used is not accurately determined 

or described. Impacts of near-term water usage, 

the use of pesticides to clear land, the soil 

disturbance with planting, and the economic 

viability questions raised by using 38-100 acre 

farm plots is not adequately addressed. On Page 

ES-2 the report says ‘Prior to this submittal, the 

Project Sponsors have likely determined the 

economic feasibility of their proposal, including 

developing alternatives for location and crop 

species.” This is speculative. Without knowing 

what land will actually be involved, the 

determination of feasibility and alternatives 

cannot be done. This has the impact of 

invalidating the entire EA analysis. For example, 

the following portion of the EA does not explain 

why arundo donax was not further considered 

nor is the data revealed in sufficient detail: The 

report itself acknowledges that more accurate 

site selection could be part of the review process 

by allowing the Project Sponsors to decline a 

proposed planting site. That “map could be 

drawn for the EA. Page 2-8: “The Project 

Sponsors reserve the right to decline any acres 

within the eligible project area that the Project 

Sponsors, the FSA, or the FSA technical partners’ 

determine cannot produce giant miscanthus 

effectively without substantial environmental 

effects.” This shows that the actual land that will 

be planted is as yet actually unidentified. It is 

impossible to adequately describe the 

environmental impacts on a parcel if it is as yet 

unidentified. Land Use NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

Overall, this environmental assessment analyzed a 

project area proposal for BCAP project areas. Only 

when FSA approves a BCAP project area can 

producers begin to enroll acres with FSA and the 

Project Sponsors for inclusion in the project area. 

At this stage, the individual parcels to be included 

within the project areas are not known. However, 

the environmental assessment process provide full 

detail on the general lack of data for certain 

resource areas, such as biodiversity. To ameliorate 

the potential for effects, the Project Sponsors in 

consultation with USDA staff developed an 

overarching Mitigation and Monitoring Plan to 

provide broad categories and actions to be 

conducted by each producer or by the Project

Sponsors. At the local level, BCAP requires the 

development of a Conservation Plan as part of the 

environmental screening process. The 

Environmental Screening process, will be similar to 

other USDA programs to ensure minimal effects. 

The Environmental Screening process would allow 

FSA to decline acreage that would result in more 

than minimal effects to resources analyzed in this 

environmental assessment even with mitigation 

efforts. This screening process in combination with 

a site-specific Conservation Plan would provide 

reasonable activities that would be conducted 

based on the resources within and adjacent to the 

contract acres. Each Conservation Plan would be 

subject to all State and local regulations, which may 

be more stringent than Federal regulations 

concerning those resources areas. 
Page 95 of 128

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49 14

Evaluation of alternatives: Given the size of the 

project, the evaluation of alternatives must be 

done with clear reference to the particular sites 

being considered. Moreover, to merit the 

expenditure of this sum of federal funds, the 

effects should clearly be unequivocally positive. 

Controlling the impact from a 50,000-acre site is 

different than controlling the impact or assessing 

the alternatives for 500-700 38-100 acre sites, but 

the report does not account for this simply 

stating, without adequate data, “As part of the 

alternatives development process the Project 

Sponsors analyzed both alternative crops and 

alternative locations for the proposed project 

areas; however, each of these was determined 

not to be feasible.” 

Alternatives 

Analyzed NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

The Project Sponsors are proposing a specific 

project for inclusion within the BCAP. The 

reasonable alternatives under consideration are (1) 

the Proposed Action, which implements the Project 

Sponsors plan or (2) the No Action Alternative, 

which would not implement the Project Sponsors 

plan. The Project Sponsors are not required to 

propose alternative species or project locations 

under NEPA.
Page 96 of 128

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Group Response

49 15

Socioeconomic effects : The EA emphasizes the 

economic benefits developers that will benefit 

from use of the crops, but does not adequately 

explain the ongoing risk or non-viability for the 

individual farmer with a 38-100 acre plot given 

the expense of planting [covered for the 

developer by the BCAP grant] and the uncertainty 

as to availability and cost of the proper harvesting 

equipment for the individual farmer. If the 

individual economics of the “on-farm model” are 

not positive then the socioeconomic effects 

cannot be portrayed as positive as in Table ES-2. 

An example of the risk to individual farmers is 

illustrated by this statement “Equipment to be 

used to establish giant miscanthus would be 

modified equipment from existing perennial grass 

industries. Equipment used to harvest and bale 

giant miscanthus would be similar to existing 

types of agricultural machinery used for hay 

crops; however, they would need to be more 

heavy-duty due to the increased biomass 

amounts being harvested and baled” Page ES-3. 

A recent article based on a study at the University 

of Illinois looked at the necessary price level 

required to sustain agricultural supply to maintain 

large scale biomass combustion and came to the 

conclusion that the market price would need to 

be $140/metric ton in 2007 dollars. This is clearly 

not a sustainable price in the current energy 

market, even if further BCAP subsidies were 

available to the individual farmer. Other studies 

have also indicated that significant subsidies are 

necessary to make growing miscanthus a viable 

economic enterprise.

Socioecono

mics NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

BCAP is a voluntary program that producers join if 

there is enough economic incentive for the 

individual producer to justify the production of a 

bioenergy crop. As such, producers bear the burden 

of determining individual economic viability on their 

contract acres. The Project Sponsors are providing 

technical assistance to the contract producers for 

establishment, production, and harvesting. The 

economic analysis provided in the Draft EA, was 

determined from publicly available data most 

similar to the confidential economic information 

developed by the Project Sponsors as part of the 

application. As a point of clarification, the 

commenter cites a study that the market needs to 

support $140/ton biomass to be sustainable. The 

project sponsors confirmed with the author of that 

cited article that, more accurately, a price of $50-70 

per metric ton of biomass is likely to be 

economically viable over the 2015-2035 period in 

2007 prices. This is consistent with the findings of 

the project sponsor and an achievable price for the 

producer. 
Page 97 of 128

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49 16

Socioeconomic effects/economic viability: The 

degree of economic uncertainty for the farmer is 

very high, in terms of cost of planting, use and 

maintenance of machinery, invasiveness, and 

selling price. EA, Page 2-2: “Aloterra Energy’s 

owners are now leveraging four decades of 

commodities and energy experience to form a 

vertically integrated energy supply chain, focused 

on giant miscanthus. Aloterra Energy’s proposed 

project area will provide farmers an energy crop 

rhizome source, harvesting and planting 

equipment for the crop’s rhizomes, specialty 

harvesting for the mature cane, processing 

technology, and marketing services for the 

cooperative’s biomass fuel.” “MFA’s proposed 

project area will provide farmers an energy crop 

source, harvesting and planting equipment for 

the crop’s rhizomes, specialty harvesting for the 

mature cane, processing technology, and 

marketing services for the cooperative’s biomass 

fuel” The EA is faulty because it does not state 

what “provide” actually means. It could mean 

rent or lease, or that the terms are set by 

negotiating individually with a farmer. It does not 

set a price per facility. The EA should look at the 

question of whether, given the harvesting 

requirements and short window of time for 

harvest, how this will be accomplished 

economically for the farmer?

Socioecono

mics NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

BCAP is a voluntary program that producers join if 

there is enough economic incentive for the 

individual producer to justify the production of a 

bioenergy crop. As such, producers bear the burden 

of determining individual economic viability on their 

contract acres. The Project Sponsors are providing 

technical assistance to the contract producers for 

establishment, production, and harvesting. The 

economic analysis provided in the Draft EA, was 

determined from publicly available data most 

similar to the confidential economic information 

developed by the Project Sponsors as part of the 

application.
Page 98 of 128

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49 17

The report continually emphasizes using the farm 

model, based on statements like the following for 

which no substantiating data is provided: EA, 

Page 2-4: “Additionally, based on existing 

research and internal economic analyses the 

Project Sponsors determined that giant 

miscanthus could economically produce on 

smaller acreages, potentially benefitting a larger 

group of producers. “ This seems to be in direct 

conflict with the study cited in the EA that shows 

net negative results, thereby necessitating the 

BCAP payments one assumes, but further 

underlining the lack of economic viability of the 

proposal: EA, Page 4-3: “Under MSU’s analysis 

with “market rhizomes” after 10 years the 

producer is still cash flow negative over $6,000 on 

each acre planted. If the rhizome costs were 

reduced to only 25 percent of MSU’s estimate, 

the producer would still need 10 years to break 

even.” EA, Page 4-5: “Importantly, producer 

commitments are contingent upon BCAP funding, 

which indicates that the short term incentives 

provided by BCAP create a viable energy crop 

market. MSU’s research supports the Project 

Sponsors’ experience with actual producers in 

proposed project areas that without BCAP 

incentives in an approved project area, producer 

interest under current market conditions declines 

dramatically.” Thus the later statement, requires 

what is currently an unsupportable statement 

about market price if the crop is to be used to 

provide affordable electricity: EA Page 4-5: The 

EIA estimated the annual value to the producers 

in each proposed project area to be 

approximately $33 million for the approximately 

600,000 tons anticipated to be produced annually 

at full production (2017). In conclusion, given the 

data in the report, and considering the price point 

data from outside reference sources, and given 

the farm model requires >500 plots of farm land 

to reach target acreage, the scale and dollars 

proposed under the EA are not economical nor 

socially desirable. 

Socioecono

mics NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

BCAP is a voluntary program that producers join if 

there is enough economic incentive for the 

individual producer to justify the production of a 

bioenergy crop. As such, producers bear the burden 

of determining individual economic viability on their 

contract acres. The Project Sponsors are providing 

technical assistance to the contract producers for

establishment, production, and harvesting. The 

economic analysis provided in the Draft EA, was 

determined from publicly available data most 

similar to the confidential economic information 

developed by the Project Sponsors as part of the 

application.
Page 99 of 128

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Group Response

49 18

Effectiveness of Mitigation and Monitoring Plan 

[MMP] : The overall effect of the project is very 

dependent on the content of the “Mitigation and 

Monitoring Plan [MMP]” but the actual content is 

unknown. Page ES-2: “FSA has a framework for 

defining the components of the MMP that will be 

required for this project, but has not yet finalized 

the plan to consider all public input on the draft 

EA prior to making a final plan recommendation. 

“ Assuming the EA is at least adequate, then the 

MMP should also be available for public 

comment, because changes to the MMP are in 

fact likely to require major changes or reevaluation in the EA. As an example, there have 

been multiple studies showing that miscanthus is 

a vector for the spread of corn borer. Especially 

using an “on farm model” of plots to 38-100 

acres, this will mean juxtaposition to corn fields 

given the planting acreage for corn on EA Page 3-

4 to 3-6. The farmer would want assurance of 

protection of their major crop, yet the document 

provides assurances without adequate detail 

making this very risky for the farmer and raising 

the issue of the adequacy of the evaluation of 

minimal impact in the EA. 

Mitigation 

Measures NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

The Mitigation and Monitoring Plan was provided in 

a draft form in the Draft EA to allow for public input 

and comment on the features to be included. 

Overall, comments from the public and agencies 

have provided a great deal of additional information 

to include in the Mitigation and Monitoring Plan as 

best management practices or exclusions of 

acreage.
Page 100 of 128

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Group Response

49 19

Page ES-4: “The MMP would be used to ensure 

that adverse effects from this new crop are 

minimized or avoided. Similarly, minor negative 

effects would be anticipated for biological 

diversity as pastureland is converted into giant 

miscanthus croplands. The MMP would be 

essential to provide mechanisms such as 

reasonable and economically feasible buffers and 

field edges to provide for continued wildlife and 

vegetative diversity in these areas. Recent 

research has indicated that giant miscanthus is 

susceptible to some plant pests; the MMP 

monitoring and buffer efforts would be essential 

to ensure that any occurrence is identified and 

treated early to avoid transmission to local 

croplands, such as corn.” How this treatment 

would be done, at what dollar cost and what 

environmental cost is unclear, but exactly the 

type of information the EA should provide. As 

noted above the complexity, cost, and 

effectiveness of such efforts would be 

complicated and increased if it was necessary to 

deal with hundreds of plots as is assumed in this 

EA.

Mitigation 

Measures NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

The Mitigation and Monitoring Plan was provided in 

a draft form in the Draft EA to allow for public input 

and comment on the features to be included. 

Overall, comments from the public and agencies 

have provided a great deal of additional information 

to include in the Mitigation and Monitoring Plan as 

best management practices or exclusions of 

acreage.
Page 101 of 128

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49 20

This is compounded in other areas of the report 

where research is dismissed and the lack of 

research is used as a reason to leave the MMP 

indefinite. For example, page 4-12: “Additionally, 

Spenser and Raghu (2009) found that in 

greenhouse and field studies there was significant 

emergence of western corn rootworm from giant 

miscanthus placed near corn fields. Bradshaw et 

al. (2010) found two species of aphids (yellow 

sugarcane aphid and corn leaf aphid) in samples 

taken from giant miscanthus fields in four states 

with stands ranging from one year to 21-years 

old. The yellow sugarcane aphid was located in 

seven samples across the four states and the corn 

lead aphid was located in four samples in four 

states. According to Bradshaw et al. (2010) the 

presence of aphids in giant miscanthus is of 

concern since aphids can transmit plant viruses. 

The research in this area is somewhat lacking as 

these are new reports and steps should be taken 

to monitor for any plant diseases or pests within 

established stands of giant miscanthus. Future 

directions to be included in the MMP may include 

integrated pest management (IPM) programs 

associated with dedicated energy crops or buffers 

away from existing corn crops.” 

Mitigation 

Measures NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

The Mitigation and Monitoring Plan was provided in 

a draft form in the Draft EA to allow for public input 

and comment on the features to be included. 

Overall, comments from the public and agencies 

have provided a great deal of additional information 

to include in the Mitigation and Monitoring Plan as 

best management practices or exclusions of 

acreage.
Page 102 of 128

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Group Response

49 21

Water Usage: The EA repeatedly obfuscates the 

true water impacts by repeatedly citing the 

assertion that miscanthus has a purported higher 

efficiency of using water, without clarifying that 

total water usage, at least in the first 3-5 years if 

establishing the crop, will increase. For example, 

Page 4-19: “Giant miscanthus does have higher 

ET losses when compared to corn or corn mixes 

and switchgrass (McIsaac et al. 2010; VanLoocke 

et al. 2010; Heaton et al. 2010)” Page 4-20: “The 

annual water use of giant miscanthus may be 

higher than corn or sorghum due to the rainfall 

interception and transpiration rates.” Page 4-21: 

“Also, due to its growth patterns, giant 

miscanthus would be anticipated to require more 

water than annual crops, such as corn” Page 5-4: 

“Giant miscanthus would be anticipated to use 

more water than fallowed or idle lands with 

permanent pasture, rangeland, or annual species. 

Taken in combination with traditional crops in the 

proposed project areas, there could be greater 

use of groundwater supplies or effects on 

groundwater recharge.” Page 6-8: Adaptive 

monitoring is expected to be used to determine 

whether any surface or groundwater supplies are 

being affected and if so, implement corrective 

measures. If the crops are used to fuel a biomass 

combustion power plant, which is typically 

“baseload,” how will mitigation occur for water 

supplies if the biomass plant is dependent on the 

supply of fuel, which is dependent on the water? 

Does irrigation of water from another area 

constitute mitigation for depletion of water 

supplies? Water Use NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

Water use is furthered clarified through literature 

citing European experience with overall water use. 

It has been indicated that energy grasses require 

between 500 to 600 mm annually for production (20 

to 24 inches) with an interception loss of 

approximately 20 percent indicating a need for 

approximately 28 inches of precipitation per year. 

Corn requires between 22 to 23 inches annually 

with an average water use of 3,000 gallons per acre. 

The estimated production for giant miscanthus has 

been anticipated to require between 288,000 to 

864,000 gallons per acre, while an acre of corn with 

an average yield would require approximately 

444,000 gallons. If corn is grown for silage or 

biomass production, at an average production rate 

of 20 tons per acre, corn would require more than 

1.4 million gallons. When compared to native 

perennial grasses (natural communities) giant 

miscanthus would be estimated to require a greater 

amount of water; however, it has been indicated 

that the historic water balance has been greatly 

altered by annual cropping systems. If annual 

cropping system were converted to perennial 

grasses, it was estimated in the literature that 

stream flow would decline between 24 to 28 

percent. The percentage for giant miscanthus 

would be approximately 32 percent reduction in 

stream flow when compared to annual cropping 

systems. 
Page 103 of 128

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Group Response

49 22

Water Quality: During the establishment of the 

crop there will be a decrement in water quality 

that is acknowledged in the EA, but then 

minimized without substantiating data. The effect 

will likely be increased as the number of smaller 

plots increases in number. EA Page 6-7:

“Potential impacts on water quality include shortterm and temporary increases in nutrient and 

fertilizer runoff during establishment and 

monitoring. Compared to land currently in 

traditional row crops, conversion to giant 

miscanthus is expected to result in less nutrient 

and fertilizer runoff. Compared to land currently 

idle or in pasture or hay, conversion to giant 

miscanthus may result in slight but short-term 

and temporary increases in nutrient and fertilizer 

runoff. However, long-term declines in nutrient 

loss (i.e., phosphorus and nitrogen) during the 

maintenance period (years 3 to 15) are likely to 

off-set temporary and short-term increases in 

nutrient leaching or runoff. The anticipated 

fertilizer application rate is also expected to be 

substantially lower compared to traditional row 

crops, but may be higher than idle or pasture or

hay land. 

Water 

Quality NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

Soil erosion is anticipated to be slightly higher in 

converted pasturelands than the existing 

vegetation; however, that is highly dependent on 

the site-specific groundcover being converted into 

giant miscanthus. The Mitigation and Monitoring 

Plan and each producers' Conservation Plan will 

address agricultural chemical usage BMPs and 

guidance. The combination ensures that even with 

the conversion of pasture, that stormwater runoff 

even during the establishment period, would result 

in only minor effects to water quality. 

49 23

Land Use-- Repeatedly throughout the EA there is 

an emphasis on the use of marginal and nonproductive land. That is contradicted by this 

statement indicating only a small quantity of such 

land is available: EA Page 4-5: “The Project 

Sponsors estimate that approximately 20 percent 

of the total acreage in the proposed project areas 

for Aurora, Columbia, and Paragould would be 

marginal cropland with the remainder being noncropland, such as pastureland.” (emphasis 

supplied) Land Use NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

Based on the amount of available "other cropland" 

and pastureland within the project areas, there is 

sufficient acreage to avoid the conversion of higher 

quality habitats (e.g., forestlands or woodlands) or 

lands currently included within a Federal or State 

conservation program. BCAP, by statute, provides a 

mechanism to help producers establish and produce 

bioenergy crops. With this program, the Project 

Sponsors are estimating a positive balance for 

producers by Year 6 of production, rather than at 

Year 10 or later without BCAP.
Page 104 of 128

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49 24

Invasiveness -- The report emphasizes that the 

plant is not invasive since there is high likelihood 

that the seed will be sterile. Even if that assertion 

is true 99% of the time, given the planting of 

200,000 acres that is still significant risk since 

eradication can be achieved only with herbicides. 

What is more significant is the report repeatedly 

cites that all propagation is done by rhizomes, not 

by seed. Since much of the proposed land to be 

planted is “highly erodible”, in the three to five 

years it takes to get the crop established, and 

likely thereafter at the margins of plantings, 

rhizomes will break off and move with the water, 

leading to widely disseminated spread. Then after 

saying the direct rhizome spread is not significant, 

one of the parents of the currently untested 

hybrid has a spread velocity of up to ten feet per 

year. Invasive NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.
Page 105 of 128

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Group Response

49 25

Similarly, it is unrealistic and dangerous to 

assume that a rhizome will not be transported off 

the land. This could easily occur on the wheels of 

a vehicle used to transport the crop. A rhizome 

could blow off the vehicle during transport to the 

processing facility or could be deposited at the 

facility itself. Page 4-11: “Giant miscanthus is a 

naturally occurring hybrid species that is 

vegetatively propagated and does not produce 

viable seeds with one of the parent species being 

Miscanthus sinensis, which is considered an 

invasive species in the United States; the other 

parent species (M. sacchariflorus) is not included 

on any Federal or State lists of noxious or invasive 

species. “Jrgensen (2011) indicates that rhizome 

spread of giant miscanthus occurs only at about 

10 centimeters (cm) per year. “Jrgensen (2011) 

indicates that M. sacchariflorus (i.e., a parent 

species of giant miscanthus) has creeping 

rhizomes that spread several meters (m) in a few 

years with high adaptability to riparian areas, 

which has a higher potential for translocation via 

erosion and water transport.” EA Page 6-6: 

Regardless of current land use, long-term benefits 

of soil retention with established rhizomes and 

carbon soil sequestration towards the middle of 

the 15-year maintenance period on enrolled 

fields are expected to off-set temporary and 

short-term increases in soil erosion and loss that 

may also be associated with reduced carbon 

sequestration. EA Page 6-7: “Potential impacts 

on water quality include short-term and 

temporary increases in nutrient and fertilizer 

runoff during establishment and monitoring. The 

fact that such erosion and the potential spread of 

rhizomes will occur is recognized in the report. Invasive NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.
Page 106 of 128

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Group Response

49 26

In addition the EA at one time says that plants 

that are not normally planted are not included on 

the “invasive species list” of a state or the federal 

list, and then later uses the non-inclusion of the 

grass on the list as a justification for considering 

the risk of invasion to be nonexistent. There is no 

resolution of the risk in the statement that one of 

the parent species of the hybrid is on the invasive 

list. That is seemingly ignored. At best smaller and 

more extensive field trials to prove the lack of 

invasiveness are called for. The EA uses circular 

logic in saying that the miscanthus is not listed as 

invasive – that is because it is not established yet 

in the proposed growing area. EA Page 3-21: 

Giant miscanthus is not listed on any of the 

proposed project areas State (Arkansas, Missouri, 

Ohio, or Pennsylvania) list of noxious weeds as of 

March 2011, this may be partially due to the fact 

that this species has not had widespread 

distribution in a localized or regional level; 

however, this is the most recent listing for these 

states. This species is also not listed on the 

Federal Noxious Weed List as of March 2011. 

Two species of Miscanthus (M. floridulus and M. 

sinensis), one of which is a parent species of the 

hybrid being proposed by the Project Sponsors, 

are listed on the Federal Invasive species list as of 

March 2011. Invasive NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.

49 27

Air quality The trucking and other emissions have 

an impact regardless of whether these are rural 

communities, certainly in counties such as Lake 

which are not in attainment. Moreover since the 

actual agricultural methods are currently 

undefined in the EA and there is no MMP, the 

additional emissions comment is hard to validate. 

EA Page 2-14: “All counties located within the 

proposed project areas are rural or semi-rural 

and the majority of the land use in these counties 

in agriculture. As such, the additional agricultural 

use anticipated to be produced should not 

introduce any additional significant emissions.” Air Quality NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

Emissions outside of the establishment and 

production of giant miscanthus are not considered 

part of the project definition, as such they have not 

been analyzed. Mobile source emissions from 

agricultural equipment would be minor and occur 

infrequently throughout the year in the nonattainment areas.
Page 107 of 128

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Group Response

49 28

In regards to PM 2.5, assessment is avoided, 

perhaps because there is no enough definition of 

the actual planting procedure and distribution as 

well as the necessary agricultural techniques and 

transportation even though the following is 

included: Page 2-14: “Lake County is designated 

as in full non-attainment for PM2.5 and Ashtabula 

County as partial non-attainment for PM2.5. Air Quality NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

An analysis of PM2.5 associated with traditional 

tillage activities has been included within the Final 

EA. 

49 29

Moreover the EA dismisses PM 2.5 almost as if it 

doesn’t matter. EA Page 2-14: ““These particles 

are so small they can be detected only with an 

electron microscope.” The comment in context 

makes it seems like the particles are too small to 

matter. They are very small, but the numbers 

amount to trillions, especially when looking at the 

smokestack emissions of the combustion of the 

miscanthus. Moreover, because they are so small 

that is why they are medically dangerous and why 

organizations like the American Heart Association 

and the American Lung Association have 

determined that there is no safe threshold for 

exposure to nano/UFP particulate matter and 

that medical risk is a linear dose response curve, 

representing significant risk to the population 

with every increment of PM nano/UFP exposure, 

regardless of the absolute level of particle count. 

[Please note that the footnote is only a very 

limited reference set. There are literally 

thousands of articles in the last few years 

detailing the heightened medical risk from 

exposure to these chemicals which are not 

accounted for in this EA.] Air Quality NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

An analysis of PM2.5 associated with traditional 

tillage activities has been included within the Final 

EA. 
Page 108 of 128

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Group Response

49 30

Air Quality and monitoring so as to adequately 

inform the MMP: There is almost no monitoring 

capability in close proximity to many of the 

proposed project areas. This makes it difficult to 

verify assertions/anticipations and to adequately 

prepare an MMP. EA Page 2-14: “There are no 

monitoring stations located in Ashtabula County. 

Overall, it would be anticipated that agricultural 

equipment necessary for the establishment, 

harvesting, and transportation of giant 

miscanthus would provide a minimum amount of 

the PM2.5 particulate load within these two 

counties based on the high level of electric 

generating units in Lake County and the proximity 

to the Cleveland, Ohio metropolitan area.” Air Quality NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

An analysis of PM2.5 associated with traditional 

tillage activities has been included within the Final 

EA. 

49 31

Projected markets: The ultimate use of this 

material and the actual location of the use, given 

the current export market to Europe is not clear. 

EA Page 2-11: “Pellet markets are diverse and are 

strong both inside and outside of the United 

States. To that point; the Project Sponsors have 

giant miscanthus contracts with a large biomass 

aggregator and a local residential pellet 

distributor.”

Projected 

Markets NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

The Project Sponsors are proposing a specific 

project for inclusion within the BCAP. The 

reasonable alternatives under consideration are (1) 

the Proposed Action, which implements the Project 

Sponsors plan or (2) the No Action Alternative, 

which would not implement the Project Sponsors 

plan. The Project Sponsors are not required to 

propose alternative species or project locations 

under NEPA.

49 32

Biodiversity: There is no adequate data 

presented to account for the effects of planting 

the total acreage or the acreage planted through 

the “farm model”. The claim is no impact but the 

data is not substantive, and the EA acknowledges 

that there is no long-term applicable data. Page 

ES-6: “These studies also looked at young-aged 

giant miscanthus stands, so there was little 

information available on biodiversity found in 

mature stands.” Biodiversity NA MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

Biodiversity information reviewed from European 

literature does suggest that miscanthus can provide 

wildlife and insect habitats when compared to 

traditional crops and some pasture lands. The 

Mitigation and Monitoring developed in 

consultation with NRCS and ARS, provides 

appropriate minimum buffer width for each project 

area, combined with site-specific increases in buffer 

width for adjacency to sensitive areas, to be 

included in the individual Conservation Plan. 

Additional safeguards have been established for 

active producer monitoring and reporting to the 

Project Sponsor for the initiation of appropriate 

control technologies. 
Page 109 of 128

Commenter 

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Comment 

No. Comment Category Position State

Zip 

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Agency/

Group Response

49 33

Conflict of interest: In assessing the invasiveness 

the Project Sponsors for a period became a 

member of the group assessing the invasive 

potential of the crop. If Project Sponsors are a 

member of the group assessing their own product 

and proposal, then they are not an independent 

third party, even though tier information was 

apparently accepted as such. This may have also 

influenced OSIA judgments on other issues and 

the assessment of other grass species. The group 

also never addresses in the EA the issue of 

propagation risk from rhizome spread as opposed 

to seed. EA Page 2-2: “The Project Sponsors 

subsequently became a member of the OSIA and 

worked with them as an independent, third party, 

to develop a voluntary Quality Assurance 

Program (QAP) that included site visits at their 

propagation locations, genetic tracing of their 

stock, and a records audit.” EA Page 2-2: “In their 

letter to the Project Sponsors dated March 4, 

2010 that was submitted as part of their BCAP 

application, OSIA concluded that the Project 

Sponsors proposed giant miscanthus was a sterile 

triploid hybrid producing no viable seed at the 

Conneaut, Ohio and Kansas propagation locations 

inspected.”

Quality 

Assurance 

Program NA MA 02238 NGO

Biomass

Accountability 

Project - No 

Biomass 

Burning

The OSIA has been designated by the Ohio 

Legislature as the Official Certifying Agency for the 

State of Ohio. The OSIA establishes and administers 

standards for certification and inspects the 

production of Certified seed under their standards. 

The OSIA provides cooperating producers an 

unbiased and rigid inspection service. 
Page 110 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

49 34

Inclusion of excluded data requiring the matching 

payment to be treated as a major action under 

the NEPA definition EA Page 2-8: “the collection, 

harvest, storage, and transportation of biomass 

from the proposed project areas to the BCF are 

included within the provisions of the BCAP 

Matching Payments Program; therefore, those 

activities are not being analyzed as part of the 

Proposed Action (BCAP Final PEIS Chapter 1.3.2, 

page 1-6). The Matching Payment Program was 

determined not to be a major Federal action per 

the NEPA definition since (1) there was no 

discretionary authority to implement the 

program terms; it was implemented per the 

direct language of the 2008 Farm Bill and (2) that 

the materials collected during the Matching 

Payment Program were currently being utilized in 

the marketplace for a similar, if not the same, 

purpose.” As has been established in defining 

invasiveness [see 12 above] this crop is not grown 

in the United States except at one or two test 

plots. Therefore item (2) is invalid: if the crop is 

not grown then there can be no existent market 

for a “similar, if not the same, purpose.” 

Therefore such a project as proposed to plant 

200,000 acres with an essentially unknown 

species of grass in four states does require a full 

NEPA environmental impact report to assess the 

true impacts not only on local ecosystems, but on 

air and water quality, to more accurately assess 

the true risk of invasiveness and the potential 

impact on human health from the cultivation and 

use of miscanthus as a biomass combustion fuel 

source.

Matching 

Payment Against MA 02238 NGO

Biomass 

Accountability 

Project - No 

Biomass 

Burning

The BCAP establishment and annual payments are 

provided to the establishment and production of 

bioenergy crops. As was fully described in the 

Record of Decision for the Final BCAP PEIS and the 

implementing regulations for BCAP, the Matching 

Payments program was determined to not be a 

major Federal action. The Matching Payment 

Program was determined not to be a major Federal 

action per the NEPA definition since (1) there was 

no discretionary authority to implement the 

program terms; it was implemented per the direct

language of the 2008 Farm Bill and (2) that the 

materials collected during the Matching Payment 

Program were currently being utilized in the 

marketplace for a similar, if not the same, purpose. 

50* 1

I support the approval of Aloterra Energy’s BCAP 

applications and I support the use of Miscanthus 

as an energy crop to meet America’s renewable 

energy needs. General Support Individual None

Comment noted on the support of the proposed 

action. 
Page 111 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

51* 1

The City of Aurora is very excited to support this 

project. It provides a very necessary influx of 

capital in several forms, financial, intellectual, and 

social. We all see the need for a diversified 

energy portfolio and this project promises to be 

one of the viable avenues for our future energy 

needs. This project is scalable and a logical 

stepping stone to future technology. This will 

bring a tremendous amount of financial capital to 

our small community. This area has already 

committed itself to the alternative energy sector 

with its alternative energy programs at Crowder 

College in Neosho and even our community high 

school has an award winning high mileage car 

program and an exciting alternative energy 

program for high school students. These will only 

get better with the development of this project. 

The social aspect of this project cannot be over 

estimated. This area needs a dose of hope and 

optimism. We need to feel a part of the future 

and contribute to the energy portfolio for our 

nation. This technology is appropriate for this 

area and plays to our strengths. We are a farming 

community and this will allow us to have pride in 

that and work together to make a better future. 

We feel the environmental impact will be very 

positive for all the reasons sighted in the analysis. 

This area needs to have the pulsing action of 

growing grass and root die back to build the 

carbon bank back into the soils that have been 

depleted over the last century. This project needs 

to happen and it needs to happen in Aurora. General Support MO

Local 

Governmen

t

City of 

Aurora, 

Missouri

Comment noted on the support of the proposed 

action. 

52* 1

I support the approval of Aloterra Energy’s BCAP 

applications and I support the use of Miscanthus 

as an energy crop to meet America’s renewable 

energy needs. Please help reduce the corn-toethanol mistake that drives up costs in many 

other areas for all of us General Support TX 77027 Individual

Jackson 

Gilmour & 

Dobbs, PC

Comment noted on the support of the proposed 

action. 

53* 1

I wanted to drop you a quick note to let you know 

that I support the approval of Aloterra Energy’s 

BCAP applications. Additionally I believe that 

Miscanthus is a great energy crop and will do well 

to suit the needs of America’s renewable energy 

needs. General Support Individual

First Bell 

Capital

Comment noted on the support of the proposed 

action. 
Page 112 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

54* 1

The Fish and Wildlife Service (Service) has 

reviewed the Draft Environmental Assessment 

(DEA) for the Proposed Giant Miscanthus 

Establishment and Production in Arkansas, 

Missouri, Ohio, and Pennsylvania under the 

Biomass Crop Assistance Program (BCAP). The 

following general and page-specific comments 

are submitted in response to the Notice of 

Availability of the DEA, which was published in 

the Federal Register on April 8, 2011, (Vol. 76, No. 

68) by the U.S. Department of Agriculture Farm 

Service Agency (FSA) on behalf of the Commodity 

Credit Corporation and Farm Service Agency. General NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service No response required. 
Page 113 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

54* 2

Due to the long history of negative impacts of 

invasive species on the biodiversity in North 

America (see excellent review in Duke and 

Mooney 2004, pgs. 411-437), we have major 

concerns over the proposed introduction of giant 

miscanthus into the United States as a possible 

biofuel species. There are numerous records of 

the spread of noxious, invasive plants, especially 

perennial Eurasian grasses such as giant reed 

(Arundo donax) into non-targeted areas. Such 

impacts are well summarized and three are 

important citations referenced in Ragh et al. 

(2006, pg. 1742). Conclusions in the DEA that 

implementing mitigation measures "under 

development" would result in minimal or 

temporary impacts to native species/natural 

communities is unsubstantiated and the Service 

has not had the opportunity to review and 

comment on such mitigation measures.

Invasive, 

Mitigation 

Measures NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range. The Mitigation and 

Monitoring Plan was provided in a draft form in the 

Draft EA to allow for public input and comment on 

the features to be included. Overall, comments 

from the public and agencies have provided a great 

deal of additional information to include in the 

Mitigation and Monitoring Plan as best 

management practices or exclusions of acreage
Page 114 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

54* 3

The Service has serious concerns with the 

potential impact of this action on multiple trust 

resources based on our authorities and 

responsibilities under the Endangered Species Act 

(ESA), the Fish and Wildlife Coordination Act, and 

the Migratory Bird Treaty Act. Conclusions that 

giant miscanthus has a low potential for 

invasiveness is based mostly on the claim that 

this hybrid is a sterile triploid and therefore 

produces no viable seed. However, as clearly 

pointed out by Raglu et al. (2006, pg. 1742) 

allopolyploidy does not guarantee sterility. Giant 

miscanthus is a triploid perennial warm-season 

grass created by combining Miscanthus sinensis 

with Miscanthus sacchiflorus, both native to 

Southeast Asia. It is not listed on the Federal list 

of noxious weeds or on any state noxious weed 

lists of the project area states. However, one of 

the parent species, M. sinensis is considered an 

invasive species in the United States and is on the 

Federal Noxious Weed List. Additionally, 

comments that the species is not likely to spread 

because it will not produce viable seed is also 

contrary to the fact that invasive perennial 

grasses are often spread by rhizomes that get 

displaced from introduction sites and distributed 

by floods, machinery, and other means.

Seed 

Sterility, 

Invasive NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.
Page 115 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

54* 4

The EA estimates that other than initial site 

preparation for establishment, there would be 

positive effects on soil quality and a reduction of 

soil erosion. This is intuitive for croplands 

converted to giant miscanthus. However, it 

should be noted that in situations where pasture 

is converted to giant miscanthus (the DEA 

estimates that over 82% of the 200,000 acres 

proposed for planting to giant miscanthus by 

2014 is pastureland), there is increased potential 

for soil erosion. Several species of federally listed 

mussels occur in the project area. Any increase in 

sediment into these streams could have an 

adverse effect and could constitute a "take" of 

threatened or endangered species. All 

appropriate steps should be taken to keep 

disturbed soil from moving off site during plant 

establishment and project sponsors or the 

responsible agency should consult the Service on 

project where there are potential effects on these 

species.

Soil 

Resources, 

Protected 

Species NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

Further clarification would be provided to ensure 

that site-specific conditions do not create adverse 

effects to State-listed species. Species of concern, 

but not protected under State law/regulation, 

Federal laws/regulations, or tribal regulation would 

be considered to the extent of management by the 

appropriate entity. Site specific Conservation 

Planning would address wildlife best management 

practices that meet the needs of locally occurring 

protected species. No taking of a protected species 

would be allowed without appropriate consultation 

with the U.S. Fish and Wildlife Service and the 

appropriate State agency. 

54* 5

The section on water quantity (4.6.2) seems to 

provide conflicting information about water 

needs and irrigation. The EA states that 

establishing miscanthus would reduce irrigation 

demand, while also stating that giant miscanthus 

requires more water than corn and that giant 

miscanthus has higher evapotranspiration losses 

compared to annual row crops. The Service 

believes this section needs to be clarified and 

water use of giant miscanthus better quantified. 

For example, although total rainfall in Arkansas 

exceeds the minimum requirements of giant 

miscanthus and corn, rainfall during most of the 

growing seasons is below what is required for 

optimal production and much of the corn grown 

in Arkansas is irrigated. Therefore, it is 

questionable as to whether it is going to be 

necessary to irrigate giant miscanthus to achieve 

production targets. The results of this 

clarification/evaluation will also need to be 

applied to determining the potential impacts on 

stream flow and/or other water bodies in the 

project area. Water Use NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

Further clarification to water use has been provided 

in reference to both comparisons of corn for grain 

and corn for silage. There would be no irrigation of 

giant miscanthus within these project areas after 

initial establishment this growing season. There was 

no indication based on available data that these 

project areas contain substantial amount of 

irrigated croplands. Average annual precipitation 

greater than 30 inches should be sufficient for the

production of giant miscanthus. 
Page 116 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

54* 6

The EA indicates that there is potential for giant 

miscanthus to provide refuge or reservoir for 

plant pests, especially corn rootworm and aphids. 

Since pesticide will most likely be used if this 

occurs, the EA needs to provide information and 

discussion on what pesticides will likely be used, 

their potential toxicity to fish and wildlife and the 

potential for these pesticides to get into surface 

or groundwater. This information would be used 

to determine is there may be negative effects on 

federally listed freshwater mussels that occur in 

project area streams.

Pests & 

Diseases NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

The agricultural chemicals to be used would be the 

same as for the treatment of the same plant pests, 

diseases, and weeds (only during establishment) 

that would be used on adjacent crops. Chemical use 

would be project area and site-specific. All 

applicable guidance and regulations would be 

followed with documentation to be provided with 

each annual report. All chemical use would be 

described as part of the Conservation Plan for each 

producer's acreage.

54* 7

The Service does not believe it is appropriate in 

the spirit of the National Environmental Policy Act 

(NEPA) for FSA to restrict this EA to the proposed 

action and the no action alternative based solely 

on the Project Sponsors determination that other 

alternatives are not feasible. The Service believes 

FSA should prepare a supplemental EA that 

adequately addresses a reasonable range of 

alternatives with respect to other feasible energy 

crops and their potential impacts on the human 

environment.

Alternatives 

Analyzed NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

The Project Sponsors are proposing a specific 

project for inclusion within the BCAP. The 

reasonable alternatives under consideration are (1) 

the Proposed Action, which implements the Project 

Sponsors plan or (2) the No Action Alternative, 

which would not implement the Project Sponsors 

plan. The Project Sponsors are not required to 

propose alternative species, methods, or project 

locations under NEPA.
Page 117 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

54* 8

Scattered throughout the document reference is 

made to FSA's Mitigation and Monitoring Plan 

(MMP) or FSA's framework for a MMP. On page 

6-1, the EA states the proposed mitigation is 

equivalent to the type identified in the new CEQ 

guidelines and referred to as "mitigation 

incorporated into project design." If this is the 

case, the Service believes the EA needs to provide 

more specific information about what mitigation 

actions are being considered for various 

situations and this MMP should be available for 

public comment.

Mitigation 

Measures NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

The Mitigation and Monitoring Plan was provided in 

a draft form in the Draft EA to allow for public input 

and comment on the features to be included. 

Overall, comments from the public and agencies 

have provided a great deal of additional information 

to include in the Mitigation and Monitoring Plan as 

best management practices or exclusions of 

acreage. The Project Sponsors have committed to a 

stringent Mitigation and Monitoring Plan with 

financial responsibility for control of any unwanted 

spread resting with both the producer and the 

Project Sponsors. As part of the Mitigation and 

Monitoring plan, a field buffer, of a minimum width, 

would be required for all giant miscanthus fields to 

minimize vegetative spread outside of intentionally 

planted areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.
Page 118 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

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Agency/

Group Response

54* 9

In accordance with the new CEQ guidelines on 

mitigation and monitoring, FSA should identify 

the legal authority it has to implement mitigation 

and monitoring and the funding source. As 

currently written, the EA (page 6-2) states, "The 

role of the Project Sponsors, are expected to 

include potential financial assistance with 

implementation of the monitoring program to 

assess the effectiveness of mitigation and 

financial assistance for any eradication efforts 

outside of the intentionally planted areas." The 

Service believes that a mechanism needs to be in 

place that clearly documents what will be done, 

who will do it and who is financially responsible 

with respect to controlling giant miscanthus if it 

becomes invasive. Merely stating that Project 

Sponsors may be a potential funding source for 

monitoring or eradication costs is not adequate.

Financial 

Responsibilit

y NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

The Mitigation and Monitoring Plan clearly identifies 

the responsibilities of the FSA, the Project Sponsors, 

and the producers. 

54* 10

Page 2-3. We disagree that floodplains need not 

be considered in the DEA. Although targeted 

areas for introductions are outside of floodplains, 

we are concerned that rhizomes displaced from 

introduction sites could be washed downstream 

and become established in riparian corridors. 

There are numerous records in the western 

United States where the invasive exotic grass 

giant reed has become established within 

floodplain habitats and has completely eliminated 

native vegetation.

Eliminated 

Resource 

Areas NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

Floodplains would be considered on the 

site=specific basis through the Conservation Plan of 

each individual producer. A minimum buffer 

distance is included within the Mitigation and 

Monitoring Plan; however, a wider buffer may be 

required for certain site-specific conditions. The 

amount of floodplain within each project area varies 

greatly depending upon the watersheds. 
Page 119 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

54* 11

Page 3-20. We agree that Executive Order 13112 

should be considered in the analysis but disagree 

with any assumption here and elsewhere in the 

document that the benefits gained by the 

experimental use of this grass for biofuel 

production clearly outweigh potential harm from 

the introduction or spread of a potentially 

invasive, non-native species. The Service believes 

that a specific clause in the legislation for the 

BCAP should form the principal criteria for 

evaluating this application. Section 9011(a)(4) of 

PL 110-246 defines eligible and non-eligible 

(excluded) crops for BCAP. The pertinent 

exclusion for this application is addressed in 

section 9001(a)(4)(B)(ii), which states: "any plant 

that is invasive or noxious or has the potential to 

become invasive or noxious, as determined by 

the Secretary, in consultation with other 

appropriate Federal and State departments and 

agencies." Based on current scientific 

information, the Service believes that giant 

miscanthus (Miscanthus x giganteus) has the 

"potential to become invasive or noxious".

Invasive, 

BCAP Statute NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

A review of literature from Europe and the United 

States has not indicated that this clone of giant 

miscanthus would result in an invasive spread. The 

Mitigation and Monitoring Plan activities would be 

used to ensure that acres intentionally planted as 

part of the proposed project areas would not create 

an unintentional spread of giant miscanthus. The 

field buffers, as well as, an eradication strategy 

would be implemented as part of the Conservation 

Plan.

54* 12

Pages 3-21 and 3-22. The fact that giant 

miscanthus is not listed as a noxious weed in any 

of the proposed project areas is a moot point as 

there has not been time for this species to be so 

identified. The fact that other members of the 

genus (Raghu et al. 2006,pg. 1742) are listed as 

invasive perennials should be an immediate 

concern, especially given that grasses have been 

demonstrated to be significantly overrepresented as natural area invaders compared 

to other plant families (Daehler 1998, pg. 171). 

Information on the USDA website pertaining to 

the two species of Miscanthus that are on the 

federal invasive species list clearly indicate these 

grasses are invasive and noxious. Invasive NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

As an initial screening metric, the Federal and State 

lists for invasive and noxious weeds were consulted 

for the occurrence of giant miscanthus or other 

miscanthus species. 
Page 120 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

54* 13

Page 3-24. Table 3-9: Information on federally 

listed species for Missouri should be updated and 

corrected. Virginia sneezeweed should not be 

listed for the Columbia area. The basis for this 

record in Boone Co. was a planting at a site on 

private property (outside the historic and known 

range of the species) that has since been 

eliminated. The species has, however, been 

recently documented in the Aurora area 

(Christian County). Topeka shiners no longer 

occur in Boone, Cole, or Randolph counties; 

Western prairie fringed orchid is not considered 

extant in Jasper or Lawrence counties; Ozark bigeared bat is not longer considered extant in Barry 

or Stone counties; and American burying beetle is 

no longer considered present in Newton County. 

Although we have no recent documented records 

of running buffalo clover in Boone, Cole, Cooper, 

or Moniteau counties, we recommend retention 

of this legume in the table because the species 

has a persistent seed bank and recent discoveries 

in Missouri suggest that it could be found in most 

floodplains and riparian corridors, especially 

those that have been exposed to some level of 

disturbance. See additional endangered species 

comments below.

Protected 

Species NA VA 22203

Federal

Agency

U.S. Fish 

and Wildlife 

Service Text correction has been included in the Final EA
Page 121 of 128

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No. Comment Category Position State

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Group Response

54* 14

Page 4-11. On page 4-11, Table 4-3 outlines 

several characteristics that make giant 

miscanthus "ideal" as a weed. Two are worth 

noting: the fact that such species are allelopathic 

(i.e., puts out harmful chemicals that impede or 

prevent the growth of other species) and that 

they are drought tolerant. Noxious and invasive 

allelopathics species such as garlic mustard 

(Alliatia petiolata), spotted knapweed (Centaurea 

maculosa), and sericea lespedeza (Lespedeza 

cuneata) produce various phytotoxins and/or 

harmful biochemicals that have enabled these 

species to replace or significantly impair multiple 

natural communities by eliminating native 

species. While drought tolerance may be a 

desirable characteristic for ideal biomass species. 

this trait may enable invasive species to become 

an even greater threat in the face of predicted 

impacts from climate change. Once again, the 

Service believes these characteristics are 

sufficient for invoking the exclusion in section 

9011(a)(4)(B)(ii) of BCAP about using giant 

miscanthus (Miscanthus X giganteus) because of 

its potential to become invasive or noxious. Invasive NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

Giant miscanthus (Miscanthus X giganteus) is not 

considered to be allelopathic. Qasem and Foy 

(2001) did find evidence in literature that 

Miscanthus floridulus produced phenolic acids 

(Chou and Chung 1974), while Miscanthus sinensis

was a targeted species affected by allelopathic 

plants of Erigeron spp. and Solidago altissima

(Kobayashi et al. 1980). The table referenced from 

the Draft EA is a generalized description of 

characteristics observed in energy crops and weeds, 

not specific to any one species. 

54* 15

Pages 4-14 and 4-15. The EA states that minor 

negative effects on wildlife diversity are 

anticipated. Research cited from studies in the 

United Kingdom indicated a greater abundance 

and diversity of birds in miscanthus field (field 

size - three hectare) than in winter wheat fields, 

and the number of birds was neutral when 

compared to grasslands. However, research cited 

from the United States found potential for a loss 

of bird diversity in bioenergy crops vs. native 

prairie and that impacts to species of concern 

was more than double generalist species; 

however, specific data for miscanthus was 

lacking. If the Proposed Action is implemented, 

project sponsors should avoid planting in native 

warm-season grasslands and efforts should focus 

on using existing pastures consisting of 

introduced forages (e.g., tall fescue, dallisgrass, 

etc.) Biodiversity NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

The report from the United States, is a review of 

literature and is not fully supported by field trials or 

observations. Biodiversity information reviewed 

from European literature does suggest that 

miscanthus can provide wildlife and insect habitats 

when compared to traditional crops and some 

pasture lands. 
Page 122 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

54* 16

Page 5-3. Claims in the DEA that the cumulative 

effects to biological resources associated with the 

proposed action would be minor are 

unsubstantiated. Limiting acreage proposed for 

energy crop production does not negate our 

concerns that rhizomes from miscanthus could be 

displaced and eventually transported to areas 

that could impact non-targeted natural 

communities and sensitive species.

Biodiversity, 

Cumulative 

Effects NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

The Mitigation and Monitoring developed in 

consultation with NRCS and ARS, provides 

appropriate minimum buffer width for each project 

area, combined with site-specific increases in buffer 

width for adjacency to sensitive areas, to be 

included in the individual Conservation Plan. 

Additional safeguards have been established for 

active producer monitoring and reporting to the 

Project Sponsor for the initiation of appropriate 

control technologies. 

54* 17

Page 6-1. The Service does not concur that 

environmental impacts will be minimal due to the 

implementation of various mitigation measures 

currently in development. Although we have not 

had the opportunity to review such measures, 

they apparently will include compensation for 

impacts if they happen. We disagree that 

corrective measures can be counted on to rectify 

the situation if mitigation measures fail to 

address such unforeseen impacts. Based on the 

history of impacts of invasive exotic species on 

North America's biodiversity, corrective measures 

are usually not possible once such species have 

been released or escaped from captivity.

Mitigation 

Measures, 

Cumulative 

Effects NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.
Page 123 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

54* 18

Page 6-2 and 6-3. The Service and key State 

natural resource agencies should be involved in 

the development of any mitigation measures, 

BMPs and accompanying monitoring plans as well 

as implementation and tracking of such actions. 

There is no evidence to support the claim in the 

DEA that any potential impacts on the 

environment are "likely to be temporary" or 

"localized."

Mitigation 

Measures NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.

54* 19

Page 6-4. As noted in our general comments 

above, we are not in agreement that this grass is 

unlikely to spread due to its reported inability to 

produce viable seed as rhizomes can be 

distributed by multiple methods. An example of 

an aggressive, rhizomatous, perennial grass that 

has developed into an invasive exotic species, is 

Cogongrass (Imperata cylindrical (L.) Beauv.) 

(MacDonald, 2004). Invasive NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

Literature suggests that giant miscanthus rhizomes 

desiccate rapidly, thereby decreasing viability within 

a matter of hours from any predation. Literature 

also points out that rhizomes that remain on the soil 

surface, but are not covered, remain unsprouted 

and desiccate rapidly. 
Page 124 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

54* 20

Page 6-5. A study apparently underway and cited 

(Anderson 2011) is used to outline control 

measures in the event miscanthus escapes from 

target areas. Because this manuscript is "in 

preparation," it is inappropriate to cite it as a 

published document in a peer-reviewed journal. 

It would be prudent for the Service to assist in 

identifying methods to avoid impacts to nesting 

grassland birds in accordance with our authority 

under the Migratory Bird Treaty Act.

Mitigation 

Measures NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

The Project Sponsors have committed to a stringent 

Mitigation and Monitoring Plan with financial 

responsibility for control of any unwanted spread 

resting with both the producer and the Project 

Sponsors. As part of the Mitigation and Monitoring 

plan, a field buffer, of a minimum width, would be 

required for all giant miscanthus fields to minimize 

vegetative spread outside of intentionally planted 

areas. The maximum buffer width would be 

determine within each producer contract per local 

site conditions and regulations, as part of each 

producer held Conservation Plan. Each 

Conservation Plan would be developed with the 

assistance of a Technical Service Provider. In 

addition to the buffer and Conservation Plan, a seed 

sampling program has been developed to identify if 

viable seed is being produced. The MMP will detail, 

the steps to occur if viable seed are found through 

the seed sampling program. These steps could 

include (1) halting any harvest of the identified field 

with no off-site movement of any material 

harvested from that field, (2) immediate removal of 

existing inflorescences in the field that was found to 

contain viable seeds, (3) resampling of those 

inflorescences at a greater rate to determine an 

approximate percent of inflorescences that 

produced viable seeds, (4) sampling of fields in the 

immediate region to determine if additional viable 

seed is occurring, (5) a commitment by the project 

sponsor to recommend eradication of that field, if it 

is determined that the percentage of viability is 

outside a safe range.
Page 125 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

54* 21

Page 6-6, section 6.333 Protected Species. This 

section of the DEA briefly mentions compliance 

with the Endangered Species Act. Although the 

DEA provides general information on federally 

listed species within the proposed project areas, 

there is no mention of a completed analysis of 

impacts to federally listed species. Furthermore, 

we saw no reference in the DEA pertaining to 

consultation with the Service under section 

7(a)(2) of the Endangered Species Act (Act) nor 

any mention of a Biological Assessment in 

accordance with the Interagency Consultation 

regulation s(50 CFR, section 402.12). To fully 

comply with section 7(a)(2) of the Act, the federal 

action agencies (CCC and FSA) should prepare a 

Biological Assessment to determine if the 

proposed action is likely to adversely affect 

federally listed species. Based on the best 

available scientific and commercial information, 

the Service believes that establishing giant 

miscanthus as a biomass crop in some of the 

identified geographic areas could adversely affect 

specific listed plants. The Service can provide 

assistance to CCC and FSA in preparing the 

required Biological Assessment.

Protected 

Species NA VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

Overall, this environmental assessment analyzed a 

project area proposal for BCAP project areas. Only 

when FSA approves a BCAP project area can 

producers begin to enroll acres with FSA and the 

Project Sponsors for inclusion in the project area. 

At this stage, the individual parcels to be included 

within the project areas are not known. However, 

the environmental assessment process provide full

detail on the general lack of data for certain 

resource areas, such as biodiversity. To ameliorate 

the potential for effects, the Project Sponsors in 

consultation with USDA staff developed an 

overarching Mitigation and Monitoring Plan to 

provide broad categories and actions to be 

conducted by each producer or by the Project 

Sponsors. At the local level, BCAP requires the 

development of a Conservation Plan as part of the 

environmental screening process. The 

Environmental Screening process, will be similar to 

other USDA programs to ensure minimal effects. 

The Environmental Screening process would allow 

FSA to decline acreage that would result in more 

than minimal effects to resources analyzed in this 

environmental assessment even with mitigation 

efforts. This screening process in combination with 

a site-specific Conservation Plan would provide 

reasonable activities that would be conducted 

based on the resources within and adjacent to the 

contract acres. Each Conservation Plan would be 

subject to all State and local regulations, which may 

be more stringent than Federal regulations 

concerning those resources areas. 
Page 126 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

54* 22

Contrary to the analysis provided in the DEA, the 

Service believes that the proposed establishment 

and production of giant miscanthus as a 

dedicated energy crop in Arkansas, Missouri, 

Ohio, and Pennsylvania could have potentially 

significant environmental impacts. Because the 

full extent of this propose introduction has not 

been adequately analyzed, and for reasons 

outlined above, we are opposed to the use of this 

exotic grass as a biomass energy crop as 

described under the proposed action in the DEA. 

Because this plant clearly has the potential to 

become invasive or noxious, we believe that the 

proposed introduction is in direct conflict with 

section 9011(a)((4)(B)(ii) of Public Law 110-246 

and the Plant Protection Act of 2000. 

Furthermore, we see no statutory, regulatory, or 

scientific validity for reaching a conclusion that 

the benefits of the proposed introduction 

outweigh the potential harm to the environment. General Against VA 22203

Federal 

Agency

U.S. Fish 

and Wildlife 

Service

Comment noted. The Draft EA provided an 

overview of the best available information at the 

time of publication, including any shortcomings in 

the literature. The Project Sponsors, in consultation 

with the NRCS and ARS, developed the Mitigation 

and Monitoring Plan to ensure minimization of 

effects from the production activities. There is 

currently no published data indicating that the 

Illinois clone of giant miscanthus is invasive. When 

compared to giant reed and cogongrass, giant 

miscanthus does not show either rapid vegetative 

establishment from rhizomes or green stems or 

through high seed germination. Mechanisms have 

been provided to control unwanted spread of giant 

miscanthus and more stringent measures could be 

put in place through each individual producer's 

Conservation Plan.

55* 1

I have some serious concerns about farm scale 

plantings of Miscanthus. I have been working 

with the plant for about 5 years and believe that 

it has a strong potential to become invasive. The 

rhizomes of some types of Miscanthus travel a 

distance of 5 ft each year. Escape plants that are 

left unchecked for a few years could soon occupy 

large areas. As more research is conducted on 

this species, I’m confident that we’ll understand it 

better and develop good stewardship practices to 

keep Miscanthus from becoming an invasive 

problem. However, until then, it seems 

premature to allow it to be grown unmonitored. General Against PA 16802 Individual

Penn State 

University

Comment noted. Comment received after end of 

comment period.
Page 127 of 128

Commenter 

No. 

Comment 

No. Comment Category Position State

Zip 

Code Entity

Agency/

Group Response

56* 1

I would like to comment on the proposed 50,000 

acre planting of Giant Miscanthus (GM) in 

Ashtabula.

I have taken some time to read about GM, and 

have concluded Ohio and PA are not ready for 

this vast of a planting. My main concern is the 

invasiveness. There seems very little research on 

exactly how invasive GM is, and I believe there is 

real potential for it to be invasive. I would much 

prefer OH and PA concentrating on native species 

like switch grass instead. I live in NW PA, and see 

first hand most every day the effects of other 

invasive species like multi-flora rose have on our 

environment. I believe OH and PA are unique in 

the amount of water ways and wet areas that will 

harbor/transplant GM. Please re-consider - to 

NOT plant GM around Ashtabula General Against Individual None

Comment noted. Comment received after end of 

comment period.

57* 1

for Aloterra Energy's BCAPP application and the 

use of Miscanthus as an energy crop General Support WA 98406 Individual None

Comment noted. Comment received after end of 

comment period.

Note: * Comment received after end of comment period.
Page 128 of 128

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APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

APPENDIX D – Summary of Quality Assurance Plan
APPENDICES

FINAL - Environmental Assessment Giant Miscanthus Establishment and Production 

This Page Intentionally Left Blank
OSIA QUALITY ASSURANCE (QA) PLANTING MATERIALS PROGRAM

 FOR ALOTERRA ENERGY MISCANTHUS GIGANTEUS RHIZOMES

CUSTOM TEN STEP PLANT

PROPAGULE QA PROGRAM OSIA INSPECTOR QA STANDARDS AND REQUIREMENTS TO BE

FOR MISCANTHUS GIGANTEUS ACTION ITEM CHECK LIST INSPECTED OR AUDITED COMMENT

 RHIZOMES1. Miscanthus Rhizomes Applicant to QA Planting Stock Rhizomes, Yes No Custom Program for Miscanthus Giganteus clones, Program to consist of field inspectioand biomass production. in production fields, research plots and a perennial grass energy crop. test, auditing, traceability and optio

plantations.

2. Planting Stock Applicant to provide botanical Auditing of source documents by designated QA Applicant to provide documentation 

description, origin, producers declaration, agency to verify claims. field inspection application(s).

source tag or invoice to substantiatelicensing agreement, ownership ornon-GMO claims.

3. Production field or test plot Applicant to provide a field cropping A rhizome crop will not be eligible for QA if planted Applicant to provide prior crop field 

land history history for all production fields, plantations on land that has grown a different Miscanthus Giganteus field application. 

and research sites. variety during the previous two years.

4. Field Isolation Assignment Minimum distance from other Miscanthus Fields shall be clearly separated from Audit field maps and annually verify 

fields of the same species. other Miscanthus species, or same species the time of September or October f

that is not entered in the QA program, or from

GMO clones, in such a manner as to prevent mechanical mixture.

5. Field Inspections Third party QA Agency inspection of Assess general agronomic field conditions OSIA field inspects and gathers ten 

production fields, research plots, plantations and breeders description for genetic purity clone and submits same to OSIA seor greenhouses. at the flowering stage in September or microscopic examination for seed s

October annually. Other varieties permitted, 1:1000. species tendency). Viability tests wTen head samples per 10 acres to be collected for seed set (non-invasive monitoring).

6. Equipment Inspection View transplanting, lifting, handling Audit applicant's procedures for cleaning and Annual audits required. Applicant m

equipment and storage site facilities. inspection of field, harvesting, handling, and or checklist for cleaning harvesting

storage equipment. Inspection agency reserves storage areas. QA rhizomes to be iright for unannounced spot check inspections. separately from non-field inspected 

7. Non-Invasive Species Validation Head sample collection. Field inspector to collect ten heads per and seed lab examinations. clone for seed lab microscopic analysis for Annual lab examination of head sa

presence of any seed set. stage.

8. Applicant's file records. Applicants are required to maintain records Notified Inspection agency shall have the optional right to Applicant must show due diligence 

of all planting, harvesting, labeling and sales require applicant to provide such records for auditing traceability for all QA records.for all QA rhizome production. purposes. 

9. Program Standard Compliance A. No process deficiencies. Program standards met Field(s)/site passed.

(check only one) B. Minor process inadequacies reported. Re-inspection of sites following applicant's Pending re-inspection.

remedy of situation.

C. Field Rejection. QA standard(s) not met (specify). Reject production field or portion of 

QA logo and labels prohibited from use on rejected problem on field inspection report oproduction. Results:

10. QA label use approved for OSIA Quality Assurance (QA) Quality Assurance standards for this Optional use or QA label for plant mtags, certificates or literature. custom program compliance achieved. Miscanthus Giganteus propagule production was passing program standards. Third 

produced in compliance with OSIA QA agency completes one program cyc

program minimum guidelines for genetic system validation, by providing QA 

purity, field history, isolation, custom determining product conformity and 

inspection criteria and product traceability. product availability.

Signature:_________________________________Date: _____________

F:\EA\FINAL EA Docs\Copy of QAPROGRAM-edits