# B I O M A S S 

# C R O P 

# A S S I S T A N C E 

# P R O G R A M

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

Unite d States Department of Agriculture Farm Service Agency

**MAY 2011** 



# FINAL

### MITIGATIED FINDING O **F NO SIGNIFICANT IMP ACT** 

**FINAL**

**- Environmental Assessment Giant Miscanthus Est**  **ablishment and Production I**  

# MITIGATED FINDING OF NO SIGNIFICANT IMPAC T



# ENVIRONMENTAL ASSESSMENT

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

Farm S ervice 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 b ioenergy 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 o f 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 Conver sion 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 est ablishment 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 Pennsylvani a 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 O **F NO SIGNIFICANT IMP ACT** 

**FINAL**

**- Environmental Assessment Giant Miscanthus Est**  **ablishment 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 l ate 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 on

farm 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 simila r 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 MITIGATE **D FINDING OF NO SIGN IFICANT 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 envi ronmental 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 ar eas 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 spe cies 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 O **F NO SIGNIFICANT IMP ACT** 

**FINAL**

**- Environmental Assessment Giant Miscanthus Est**  **ablishment and Production III**  3. The Proposed Action would require site specific environmen tal 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 effo rts 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 decis ion 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 Acti on 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 MITI **GATION AND MONITORI NG 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 a nd 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 effec tive establishment and management of the giant miscanthus fields. In addition to the educational components,

### MITIGATIED FINDING O **F NO SIGNIFICANT IMP ACT** 

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**- Environmental Assessment Giant Miscanthus Est**  **ablishment 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 underst anding 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 mitig ation 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 manage ment 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;

Setback s /buffer s 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 Cons ervation 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 spre ad 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 warm

season forage or turf grass; may be kept in existing vegetation; or kept clear by disking, rotovating, or treating with a non

- selecti ve burn down herbicide at

### MITIGATIED FINDING O **F NO SIGNIFICANT IMP ACT** 

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**- Environmental Assessment Giant Miscanthus Est**  **ablishment 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 propos ed 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 sterilit y 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 approxi mately 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 ce rtain 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

so on 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, vegeta tive barriers, etc.; fertilizer usage and application methods; and cost data.

### MITIGATIED FINDING O **F NO SIGNIFICANT IMP ACT** 

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**- Environmental Assessment Giant Miscanthus Est**  **ablishment 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 regula tions 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 enviro nmental impact statement will be prepared.

_____________________________, Acting Executive Vice President,

Commodity Credit Corporation, and

Acting Administrator,

Farm Service Agency

### EXECUTIVE SUMMARY

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**- Environmental Assessment Giant Miscanthus Establishment and Production**  **ES**

**- 1** 

**-** 

# EXECUTIVE SUMMARY

**INTRODUCTION AND BAC KGROUND** 

The U.S. Department of Ag riculture (USDA) Commodity Credit Corporation (CCC) implement s 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 t he 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 are a 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 significan ce.

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 o f 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 sup port 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

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**- Environmental Assessment Giant Miscanthus Establishment and Production**  **ES**

**- 2** 

**-** Action is to provide renewabl e biomass feedstock to a Biomass Conversion Facility ( BCF ) for use in energy production with in and potentially outside the immediate region(s)

.



## ALTERNATIVES

As part of the BCAP Project Area Selection Process, the Project Sponsors develop a proposal applica tion 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 Proj ect 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 th e 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

establ ish BCAP project areas that support the establish ment and produc tion 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 propos ed 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 pro ject

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 s hipped 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 are a with center

- pivot irrigation due to the timing of planting.

### EXECUTIVE SUMMARY

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**- 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 season s would follow the on

- farm model with

the initial e stablishment 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 industr ies. 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 pl antation acres (2012

- 2014)


## ENVIRONMENTAL CONSEQ **UENCES**

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 effe cts 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 Monitor ing Plan is included in section 6.0 of this document.

The Proposed Action would result in additional diversified income for a participating producer s , as well as technical assistance from the Project Sponsors in the production and harvesting of giant mis canthus. 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 pri marily 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

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**- 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 in to giant miscanthus croplands. The Mitigation and Monitoring Plan would be essential to provide mechanisms such as

reason able 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

mo nitoring 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

h ave positive effects on soil retention, soil organic matter, and soil carbon sequestration

. W ater quality should improve relative to other crops typically grown in the project areas due to improved nutrient uptake, low fertilizer requirements, and reduce d sediment transport. Also, due to its growth patterns, giant miscanthus would be anticipated to require more

water than corn grown f or g r ain , but less water than grass hay and improved pasture. The majority of the acres that enroll in the program are ex pected 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, gene rating 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 t he proposed project areas as described in this BCAP Project Proposal. However, the No Action Alternative would not

### EXECUTIVE SUMMARY

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**- 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 UN ITED STATES ESTABLIS**  **HMENT 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 in troduced 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, Mi chigan 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 miscan thus have not been cultivated in the United States; al though commercial production of giant miscanthus for bioenergy production in co

- fired system s have been established within the last few years in the United Kingdom. Given

, that giant miscanthus

has onl y 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, whi ch include s best management practices (BMP s ) 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 Mitigat ion 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 land scape based on observation and measurement. This

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

be updated over time as new data bec o me available. Likewise, other metrics or observable

measurements will be adapt ed over time based on past observations, new research finding s , and new regulations.

The following information related to the growth and production of giant miscanthus in the
United States has been found to be lack ing complete detail

. .
Potential effec ts 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

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**- 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 m odel 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 commer cial

- 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 opera tions in United States’ environments.

Literature discussing potential plant pest s 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 i s little p eer

- 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 som e 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 applica tion in 2011 due to late planting) during establishment has been

discussed based on the available literature.

### TABLE OF CONTENTS

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**- Environmental Assessment Giant Miscant**  **hus Establishment and Production i**  

# TABLE OF CONTENTS

MITIGATED FINDING OF NO SIGNIFICANT IMPAC T

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

**................................ ................................**  **................................ ................................**  **....... I** 
**REASONS FOR MITIGATE D FINDING OF NO SIGN**  **IFICANT IMPACT**

**................................ ................................**  **.. II** 
**OVERVIEW OF THE MITI GATION AND MONITORIN**  **G PLAN**

**................................ ................................**  **.............. III** 
**DETERMINATION**

**................................ ................................**  **................................ ................................**  **......... VI** 
EXECUTIVE SUMMARY

................................ ................................ ................................ ....................... ES

- 1

- **INTRODUCTION AND BAC KGROUND** 

**................................ ................................**  **................................ .....**  **ES**

**- 1** 

**- PURPOSE AND NEED** 

**................................ ................................**  **................................ ...........................**  **ES**

**- 1** 

**- ALTERNATIVES** 

**................................ ................................**  **................................ ................................**  **..... ES** 

**- 2** 

**- PROPOSED ACTION** 

**................................ ................................**  **................................ ..............................**  **ES**

**- 2** 

**- ENVIRONMENTAL CONSEQ**  **UENCES**

**................................ ................................**  **................................ ......**  **ES**

**- 3** 

**- DATA GAPS IN CURRENT**  **UNITED STATES ESTABL ISHMENT AND PRODUCTI**  **ON**

**................................ ......**  **E S** 

**- 5** 

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

................................ ................................ . 1

- 1

**1.1 INTRODUCTION AND BAC**  **KGROUND**

**................................ ................................**  **............................ 1** 

**- 1** 

**1.2 USDA NEPA GUIDANCE/A**  **UTHORITY**

**................................ ................................**  **............................. 1** 

**- 2** 

**1.3 PURPOSE AND NEED FOR**  **THE PROPOSED ACTION**

**................................ ................................**  **....... 1** 

**- 3** 

**1.4 ORGANIZATION OF THE**  **DOCUMEN T** 

**................................ ................................**  **............................. 1** 

**- 3** 

2 ALTERNATIVES INCLUDI NG THE PROPOSED ACTI ON

................................ ............................... 2

- 1

**2.1 ALTERNATIVES DEVELOP**  **MENT**

**................................ ................................**  **................................ .....**  **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 A**  **NALYZED**

**................................ ................................**  **................................ ..**  **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 A**  **LT**

**ERNATIVES**

**................................ ................................**  **...................... 2** 

**- 20** 

### TABLE OF CONTENTS

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**- Environmental Assessment Giant Miscant**  **hus 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 Condit**  **ions**

**................................ ................................**  **................................ .......**  **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 Projec**  **t 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 QU**  **ANTITY**

**................................ ................................**  **................................ .**  **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** 

### TABLE OF CONTENTS

**FINAL**

**- Environmental Assessment Giant Miscant**  **hus Establishment and Production iii**  **3.5.2.2 Existing Conditions** 

**................................ ................................**  **................................ .......**  **3**

**- 37** 

4 ENVIRONMENTAL CONSEQ UENCES

................................ ................................ ............................. 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 Protec**  **ted 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 QU**  **ANTITY**

**................................ ................................**  **................................ ..**  **4**

**- 20** 

**4.6.1 Water Quality** 

**................................ ................................**  **................................ ....................**  **4**

**- 20** 

**4.6.1.1 Significance Threshold** 

**................................ ................................**  **................................ ..**  **4**

**- 20** 

### TABLE OF CONTENTS

**FINAL**

**- Environmental Assessment Giant Miscant**  **hus Establishment and Production iv**  **4.6.1.2 Proposed Acti**  **on**

**................................ ................................**  **................................ ...........**  **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 COMPARI**  **SON**

**................................ ................................**  **................................ ....**  **4**

**- 26** 

**4.7.1 Proposed Action** 

**................................ ................................**  **................................ ...............**  **4**

**- 26** 

**4.7.2 No Action** 

**................................ ................................**  **................................ ..........................**  **4**

**- 27** 

5 CUMULATIVE IMPACTS A SSESSMENT

................................ ................................ ......................... 5

- 1

**5.1 DEFINITION** 

**................................ ................................**  **................................ ................................**  **.. 5** 

**- 1** 

**5.2 CUMULATIVE IMPACTS A**  **NALYSIS BY RESOURCE AREA** 

**................................ ................................**  **. 5** 

**- 1** 

**5.2.1 Socioeconomics** 

**................................ ................................**  **................................ ..................**  **5**

**- 1** 

**5.2.2 Land Use** 

**................................ ................................**  **................................ .............................**  **5**

**- 2** 

**5.2.3 Biological Resourc**  **es**

**................................ ................................**  **................................ ...........**  **5**

**- 3** 

**5.2.4 Soil Resources** 

**................................ ................................**  **................................ .....................**  **5**

**- 4** 

**5.2.5 Water Quality and Quantity** 

**................................ ................................**  **................................ ...**  **5**

**- 4** 

6 MI TIGATION AND MONITOR ING

................................ ................................ ................................ .... 6

- 1

**6.1 INTRODUCTION** 

**................................ ................................**  **................................ ............................**  **6**

**- 1** 

**6.2 ROLES AND RESPONSIBI**  **LITIES**

**................................ ................................**  **................................ ....**  **6**

**- 1** 

**6.3 MITIGATION AND MONIT**  **ORING RECOMMENDATION S** 

**................................ ................................**  **... 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** 

### TABLE OF CONTENTS

**FINAL**

**- Environmental Assessment Giant Miscant**  **hus Establishment and Production v**  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** 

### TABLE OF CONTENTS

**FINAL**

**- Environmental Assessment Giant Miscant**  **hus Establishment and Production vi**  This Page Intentionally Left Blank

### TABLE OF CONTENTS

**FINAL**

**- Environmental Assessment Giant Miscant**  **hus Establishment and Production vii**  LIST OF TABLES

Table ES

- 1. Proposed Giant Miscanthus Acres Added by Gro wing Season 2011

- 2014

.... ES

- 3

- Table ES

- 2. Comparison of the Alternatives

................................ ................................ .............. ES

- 4

- Table 2

- 1. Proposed Establishment and Production Meth ods for Giant Miscanthus

.......... 2

- 10
Table 2

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

- 2014

........ 2

- 12
Table 2

- 3. Estimated B iomass 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 Typ ology, 2007

................................ ............................... 3

- 2
Table 3

- 2. Planted Acres, Harvested Acres, and Production of Select Field Crops in the Project Counties (2010).

................................ ................................ .............................. 3

- 4

T

able 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 Us e 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 Biom ass 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 Re ported 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 P roposed Project Area with Planted Acres in Crops

.......................... 5

- 3
Table 6

- 1. Roles and Responsibilities for the Mitigation and Monitoring Plan

....................... 6

- 3

### TABLE OF CONTENTS

**FINAL**

**- Environmental Assessment Giant Miscant**  **hus 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 C ounty 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 t he 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 Fig ure 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

### TABLE OF CONTENTS

**FINAL**

**- Environmental Assessment Giant Miscant**  **hus Establishment and Production ix**  ACRONYMS AND ABBREVIATIONS

AOSCA Association of Seed Certifying Age ncies

A P HIS 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 Clea n 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 Enhancemen t 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 f inding of no significant impact

FR Federal Register
FS USDA Forest Service
FSA USDA Farm Service Agency

g gram

### TABLE OF CONTENTS

**FINAL**

**- Environmental Assessment Giant Miscant**  **hus Establishment and Production x**  GHG greenhouse gases

HEL highly erodible lands

HILD high

- input low div ersity
HUC hydrologic unit
IPCC Intergovernmental Panel on Climate Change

IPM integrated pest management
ISO International Standards Organization kg kilograms

kP A kilo Pascal

LIHD low

- input high diversity

LMM Lower Missouri

- Moreau

μ g/m 3 

### micrograms per cubic meter

m meter

m 2 

### 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
NO 2 

### nitrogen dioxide
NRCS USDA Natural Resource s Conservation Service

NZERMA New Zealand Environmental Risk Management Authority
OEPA Ohio Environmental Protection Agency
ODNR Ohio Department of Natural Resources
OSIA Ohio S eed Improvement Association

Pb lead
PEIS Programmatic Environmental Impact Statement

PDD Project Design Documentation

PL Public Law

PM 2.5 

### particulate matter of less than 2.5 microns

PM 10 

### particulate matter of less than 10 microns

PPA Plant Protecti on Act
QAP Quality Assurance Program
RES Renewable Energy Standard

### TABLE OF CONTENTS

**FINAL**

**- Environmental Assessment Giant Miscant**  **hus Establishment and Production xi**  ROD Record of Decision
ROI Region of Influence
SHPO State Historical Preservation Offices
SIP State Implementation Plan
SO 2 

### 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

U SGS U.S. Geological Survey

WRA Weed Risk Assessment

WRI World Resources Institute

WRP Wetland Reserve Program

### TABLE OF CONTENTS

**FINAL**

**- Environmental Assessment Giant Miscant**  **hus Establishment and Production xii**  This Page Intentionally Left Blank

### 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 BAC**  **KGROUND**

The U.S. Department o f Agriculture (USDA) Commodity Credit Corporation (CCC) implement s 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, 201 2

. 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
BCA P 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 Fi nal 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 pro ject 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 de veloped through the completion of

Forms BCAP

- 19, BCAP

- 20, BCAP

- 21, and BCAP

- 22 and supporting information. A fter this
initial evaluation FSA can conclude that no additional environmental analyses are applicable due to no potential for the proposed BCAP ac tivity 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 an alyzes 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 m arketing, 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. Durin g 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 Energ y’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, ha rvesting 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 cooperat ive 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 prepar ed 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 r esources 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 **OR GANIZATION OF THE DO**  **CUMENT**

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 Ac tion, 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 Propose d 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

reso urce 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**  This Page Intentionally Left Blank

### ALTERNATIVE INCLUDIN **G THE PROPOSED A CTION** 

**FINAL**

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

**- 1**  

# 2 ALTERNATIVES INCLUDI NG THE PROPOSED ACTI ON

**2.1 ALTERNATIVES DEVELOP**  **MENT**

As part of the BCAP Project Area Selection Process, the Project Sponsors develop ed a proposal applicat ion 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

miscanth us 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 w ere eliminated as unfeasible

alternatives.

**2.1.1 Proposed**  **Crop Alternative s** 

**– 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 th e perennial grass giant reed ( Arundo

donax ) that is a native of Europe, several varieties of the perennial native switchgrass ( Panicum virga tum varieties), and the perennial hybrid grass native to

Asia

, giant miscanthus. The results of the three

- year stud y 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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**- 2**  (2) Potentia l 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 hybri d 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 cer tification 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 a ir 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

mois ture 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.

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**- 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) R egional L ocation

- 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) A vailability of A dequate R ainfall to S upport P lanting P ropagation A cres

– 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 g rowth 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) P roximity of I nfrastructure for M arket T ransportation

- 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 economical ly 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. T he proposed Ashtabula project area was selected due to the

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

### ALTERNATIVE INCLUDIN **G THE PROPOSED A CTION** 

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

The other pr oposed 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) E conomic F easibility

- The Project Sponsors used economi c 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 Pro ject 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 coul d 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 prod ucers.

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) A ccess to L ocal M ar kets

– 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 o f 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

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**- 5**  transporting of pellets to both the Canadian and European markets i s 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

Universit y 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 thei r 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 locat ions 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 regula ted 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 imp aired 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 A NALYZED** 

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 poten tial effects to the human and natural environment and the potential significance of those effects, both positive and negative

.

**2.2.1 No**  **A ction**  **A lternative** 

Under the No Action Alternative, th e FSA would not establish the proposed project areas supporting the es tablishment 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

traditio nal 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 INCLUDIN **G THE PROPOSED A CTION** 

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**- 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 P**  **roposed A**  **ction**
Aloterra Energy LLC and MFA Oil Biomass LLC (Project Sponsors) are proposing that FSA establish four separa te 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

marg inal crop lands 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 l and 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 Re serve 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 o f 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; Colum bia 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 proj ect 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 loca tions of acreage to be included

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**- 7**  Figure 2

- 1

. Proposed Project Area Locations

.

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**- 8**  within the first growing season, but those acres are not committed; therefore, the level of analysis for this EA is based at th e 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 bio energy 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 5 0

- 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 fr om 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 withou t 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 stewards hip 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 CPA

052 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 Fin al 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 languag e 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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**- 9**  **2.2.2.1 Methods for Establishment and Production of Giant Miscanthus** 

The esta blishment 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

seaso n (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 propos ed project area would only occur this planting season; all other planting s eason s would follow the on

- farm model with the initial establishment of propagation acres, followed by plantation acres the following growing season , both without subsequent irrigat ion beyond 2011

. No irrigation will be required following the 2011 season.

Giant m iscanthus is a triploid hybrid perennial warm

season grass developed through the crossing of

Miscanthus sinensis (diploid species) with M.

sacch ar iflorus (tetraploid speci es)

, 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 develop ed 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 div ision (J ø rgensen 2011, Gordon et al 2011) . Planting equipment for B ermudagrass ( Cynodon spp) or specialty vegetable crops has been used to successfully establish g i ant
miscanthus in Midwestern United States . Harvesting is done in a manner similar to

trad itional hay crops, but the equipment must be able to handle high

- yield crops. Table 2

- 1 summarizes best practices for the e stablishment and management of g iant m iscanthus. Figure 2

- 2

. Giant Miscanthus.

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**- 10**  Table 2

- 1

. Proposed Establishment a nd 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 non

sel ective 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, prio r 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 wi nter/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 X TRA© 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 Follo wing 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 th e 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 encoura ged, 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, g iant 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 occ ur until after first frost when nutrients have been translocated from the stem to

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**- 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 planta tion acres, there would not be any long distance transport of live plant materials off farms.

Glyphosate and traditional tillage have been found to be effect ive eradication methods for giant miscanthus though it may require more than one growing season f or 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 cen timeters 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 inten ded 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 an d 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 conve yor 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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**- 12**  Table 2

- 2

. Proposed Giant Miscanthus Acres Added by Gr owing 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 13,5 00 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: Confid ential 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**  **Pr**

**oject 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 th e 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 fa rmers 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 commitme nts from farmers to plant between 100 to 300 propagation acres of giant m iscanthus, 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 6 00,000 tons of biomass each year. The Project

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**- 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 conv eyor 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,

flexibl e 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 to nnage 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 area s or limitations on effects by program guidelines. Those resources areas being

excluded from this analysis include :

W etlands

– were eliminated from detai led 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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**- 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

likeli hood 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 ;

R egulated C oas tal Z ones

– were eliminated from detailed analysis in this EA ; the

P roject S ponsors have agreed not to plant within regulated coasted zones.

P rime and U nique F armla nd

– were eliminated from detailed analysis in this EA, since they are exempt from coordinat ion 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 underta ken 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 low

income populations at the county level within each propo sed 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 t he 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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**- 15**  Figure 2

- 3

. Percent Minority by County for Each Proposed Project Area.

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**- 16** 

Figure 2

- 4

. Percent of the Population Below the Poverty Threshold by County for Each Proposed Project Area.

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**- 17**  Air Quality

– was eliminated from d etailed 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

- r ural 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 qual ity 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 cri teria pollutants: carbon monoxide ( CO )

, particulate matter ( PM 10 

### , PM 2.5 

### , ) 1

- hour ozone, 8

- hour ozone, and sulfur dioxide (SO 2 

### ). All counties in the proposed project area are designated as in

attainment for all criteria pollutants.

Missouri has designati ons for the following criteria pollutants: lead ( Pb ) , 8

- hour

ozone, SO 2 

### , and PM 2.5. 

### All counties in the proposed project area s are designated as
in attainment for all criteria pollutants.

Arkansas has designations for the following criteria pollutants: Pb, SO 2 

### , nitrogen

dioxide (N O 2 

### ) , CO, PM 10 

### , and PM 2.5

. 

### 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, NO 2 

### , PM 10 

### and

PM 2.5 

### , 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, PM 10 

### , Pb, NO 2 

### , and CO. Geauga and Trumbull c ount ies are designated as in attainment for PM 2.5 

### . Lake County is designate d as in full non

- attainment for PM 2.5 

### and Ashtabula County as partial non

- attainment for PM 2.5 

### . Lake County and Ashtabula County are part of the Cleveland

- Akron

- Lorain Air Quality Control Region (AQCR) 174. PM 2.5 

### pollutants are considered f ine 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.

Environmenta l Protection Agency [EPA] 2011). The 2005 Emissions Inventory for
Ohio (EPA 2006 ) indicates that Lake County had 3,310 tons per year (tpy) of PM 2.5

### ALTERNATIVE INCLUDIN **G THE PROPOSED A CTION** 

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**- 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 PM 2.5 

### nonattainment status for counties in Ohio (OEPA 2010). The OEP A provided monitoring data from the Lake County air quality monitor ing station that indicated that the three

- year average was 11.9 micrograms per cubic meter of air ( μ g/m 3 

### ), which is below the 15 μ g/m 3 

### primary NAAQS standard. There are no monitoring stati ons 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 PM 2.5 

### particulate load within these tw o 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 PM 2.5 

### 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 e ach 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 Asht abula 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

### ALTERNATIVE INCLUDIN **G THE PROPOSED A CTION** 

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

**- 19**  that the 2009 estimated mobile source emissions were 779.15 tpy. When compared,

the a gricultural emissions would contribute 0.4 percent to this total. In the long term,

PM 2.5 

### 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 fr om 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 perc ent). 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 l argest 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 o f $483. Of the types of land, nine percent of hunters used public land only, 67 percent used private la nd 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

### ALTERNATIVE INCLUDIN **G THE PROPOSED A CTION** 

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**- 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 p ercentage 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 o ver $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 publi c and private land.



## 2.4 **COMPARIS ONS OF THE ALTERNATI**  **VES**

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 n eed 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 Propo sed 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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**- 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, i ncome, 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 f rom 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 Agricul tural 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

a mount 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 als o 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 o f farms in the proposed project area s fall within the small family farm

– residential or lifestyle farm ( Table 3

- 1 ).

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**- 2**  Table 3

- 1

. Number of Farms by Farm Typology, 2007

Location Item Total Small Family Farms

Large family Very large family Non

family 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

Calla way 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

Monite a u 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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**- 3**  Location Item Total Small Family Farms

Large family Very large family Non

family 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 Num ber 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 productio n 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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**- 4**  Table 3

- 2

. Planted Acres, Harvested Acres, and Pr oduction of Select Field Crops in the Project Counties (2010)

.

Area Crop Type Planted Acres Harvested Acres Production
Arkansas

Arkansas State Totals Corn ( G rain) 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) 28,5 00 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 6,22 9,800 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, Uplan d (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 Al l (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 So

rghum ( 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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**- 5**  Area Crop Type Planted Acres Harvested Acres Production

Callaway Corn ( Grain ) 30,600 29,800 4,052,000 Hay All (Dry) (20 08) 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 3,1 77,000 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) (2 008) 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 Whea t 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 (2 008) 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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**- 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

Tru mbull 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 Al l (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) 2,8 00 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 20 11



### 3.1.2.3 **Primary Livestock I ndustries** 
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.

### AFFECTED ENVIRONMENT

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**- 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 Cat tle 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) 30,5 00 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

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**- 8**  five percent or less for their state totals. The Ashtabula proposed projec t 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

a pproximately 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 wa s 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 estim ated to increase to $24.1 billion ( Ibid )

.
At the household level, the average family farm household income for 20 10 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 pe rcent 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 t he 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 c ontrolled 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 saf ety 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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**- 9**  **3.2.2 Existing Conditions** 
The 2007 Agricultural Census estimates the amount of land in agricultural land uses in the
United States

. Table s 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 perce nt) 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 th e 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 with in 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 declin e 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 perce nt. 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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**- 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 (A cres 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, building s, 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 pas ture 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 p astured 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

Perman ent 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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**- 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 33,8 79 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

Othe r 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 CR EP 1,691,694 978 855 5,902 12,551 7,968 3,955

- Source: Adapted from USDA NASS 2009

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**- 12**  Table 3

- 6

. Farmland Land Use Categories and Sub

- Categories for the Columbia Proposed Project Area (2007)

Land Use Type M issouri 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

, 929 180,84 0 302,429 276,590 242,946 288,293 221,647 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 10,48 5 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 1 5,445 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 18,20 1 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 P ermanent 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 200 9

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**- 13**  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 R andolph (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 84 9 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 23,49 4 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 1 0,727 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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**- 14** 

Figure 3

- 1

. Percent of Farmland Acres by County in the Proposed Project Areas

.

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**- 15**  Figure 3

- 2

. Comparison of the Percentage of Harvested Cropland and Total Pas tureland in the Proposed Project Areas.

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**- 16**  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: Conf idential Application for Proposed BCAP Project Areas, 2011

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**- 17**  Figure 3

- 3

. Percent of Total Acres Enrolled in Conservation Programs, 2007

.

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**- 18**  

## 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 I II 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

cover ed 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 stri p 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 loca ted within the Ozark Highlands E coregion. Topography varies from steep slopes near the large streams to moderate relief hills on the broad plateaus or inter

- stream areas. The m ajority 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 E coregions, Central Irregular Plains, Interior River Valleys and Hills

, and Ozark Highlands. The Cent ral 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 croplan d and pastureland. The

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**- 19**  Figure 3

- 4

. Level III Ecoregions within and adjacent to the Proposed Project Areas

.

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**- 20**  Interior River Valleys and Hills E coregion is made up of many wide, flat

- bottomed, terraced

vall eys, 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 a re 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 Valle y 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 agricul tural 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 inv asive 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 addit ion, 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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**- 21**  any species, with respect to a particular ecosystem, including its seeds, eggs, spores, or other biological material capabl e 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 we ed 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

Fe deral 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 significa nt 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 depe nd 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, s uppress 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 wildfi re 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 ar duous 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 spe cies. 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 do rmant, 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 miscan thus 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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**- 22**  USDA PLANTS database , this may be partially due to the fact that this species has not had

w idespread 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. sin ensis ) , 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 i n 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 lev el 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 i n 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 lemm ing ( 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 rubr ipes ), Canada goose ( Branta c anadensis ), 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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**- 23**  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, east ern 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 ( L epus 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 ( Ph asianus colchicus ) , and bobwhite quail ( Colinus virginianus ) . Fish of importance, including common game fish, across the a rea 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 rab bit, 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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**- 24**  **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 d efined 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 protec tion; and (2) specific areas outside the geographical area occupied by the species if the agency determines that the area itsel f is essential for conservation (USFWS 2008a).

**3.3.3.2 Existing Conditions** 

Table 3

- 9 lists the Federally

- listed t hreatened and /or e ndange red 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 occ ur 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 Fede rally

- 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 kirtland ii

) 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 Py matunig 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 p lovers 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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**- 25**  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 c avefish ( 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 ( Geo carpon 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 (pe arly 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 Cu rtis 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, Er ie, 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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**- 26**  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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**- 27**  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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**- 28**  Figure 3

- 7

. Potential Ranges of Federally

- listed Th reatened and/or Endangered Plants within and adjacent to the Proposed Project Areas.

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**- 29**  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 d esignated 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 threaten ed species and 89 State

- listed endangered species. Of those species, 8 are State

- list ed endangered birds, 2 are State

- listed threatened birds, 7 are
State

- listed threaten ed fish, 8 are State

- liste d endangered fish, 36 are State

- listed threatened plants, 71 are State

- listed endangered plants, 1 is a State

- list ed threatened reptile, and 2 are State

- list ed endangered reptiles within the Pennsylvania counties in the Ashtabula proposed project area. Th e search also indicates that there are 16 species listed as rare ( p lant species which are uncommon within the Commonwealth), 10 species listed as extirpated ( p lant species believed to be extinct within the Commonwealth), and 7 species listed as PC ( a nimals 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 revie w of Ohio Biodiversity Database State

- listed Species indicates that there 60 S tate

listed threaten ed species and 71 State

- listed endangered species. Of those species, 2 are
State

- listed threatened birds, 3 are S tate

- listed threatened fish, 2 are State

- lis ted endangered fish, 8 are State

- listed threatened insect s, 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, 5 6 are State

listed endangered plants, 1 is a State

- list ed threatened reptile, and 1 is a State

- list ed endangered reptile within the Ohio counties within the Ashtabula proposed project area.

The search also indicated that 56 species are potentially threate ned, 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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**- 30**  **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 ( Geocarp on 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 wa ter 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 i ndicates that there are 4 bird species, 3 mammal species, 3 fish species, 1 reptile species, and 5 plant species listed as a S tate 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 p lant 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

In diana bat and the g ray 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 revi ew 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 S tate 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 fiv e State

- listed threatened plants within the counties within the Paragould proposed project area. The search also indicates that 129

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**- 31**  species are Inventory Elements ( The Arkansas Natural Heritage Commission is currently conducting active inventory work on t hese 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 ma tter, 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 char acteristics 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 t o 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

propose d 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 th e 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 with in

the proposed project area s ( 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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**- 32**  Figure 3

- 8

. Percent of Total Land Classified as Highly Erodible by County w ithin the Proposed Project Areas.

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**- 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 posit ion. 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 counti es 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**  **P**

**roject 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 percen t 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 fro m 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 Prop osed BCAP Project Areas, 2011 )

. There was approximately 710,118 acres of HEL within the counties of the Paragould proposed p roject a rea, with an average of 25 percent of the land being HEL ( Confidential Application for Proposed BCAP Project Areas, 2011 ). W ithin 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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**- 34**  

## 3.5 **WATER QUALITY AND QU ANTITY** 

**3.5.1 Water Quality** 

**3.5.1.1 Definition of the Resource** 

Freshwater is nec essary 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

Wa ter 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, de legates the authority to issue and enforce permits to qualified S tates. For this analysis, water resources include
surface water quality (including lakes, rivers and associated tributaries, and estuaries), groundwater quality, and water use/quantity of bo th surface and groundwater.

Surface water , as defined by the EPA, are waters of the United States, such as rivers,
streams, creeks, lakes, and reservoirs

, support ing everyday life through uses such as drinking water and other public uses, irrigation, and i ndustrial uses. S urface 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 rainfal l 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. Th e 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 f or 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 illustrate s the impaired streams and water bodies within each state containing the proposed project areas.

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**- 35**  Figure 3

- 9

. Waters Listed on the State 303(d) Lists for Impaired Waters

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**- 36**  Groundwater is the water that flo ws 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 a nd 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 al so 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 impair ed 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

squa re 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 Rive r are more likely to use ground water s ources. Uses of ground water include domestic, indust ry, 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 fr om 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, effluen t disposal and power generation ( Food and Agricultural Organization [ FAO ] 2005)

.

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**- 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 (EP A 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 le vels 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 propo sed 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 wi thdrawn 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 th e 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 riv ers 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 with in 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 mil lion 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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**- 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

Total (acres) Ground

water Surface 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 1 5,462 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 2010 b

.

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**- 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 M oreau 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 wi thin 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 193,0 14 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 withdr awn per day in the proposed project area , with a n 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 Lowe r 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 sev en watersheds, inclusive. However, these watersheds represent a much smaller portion of the proposed project area

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**- 40**  ( Confidential Application for Proposed BCAP Project Areas 2011 )

. There were approximately 14,000 miles of streams and rivers within this prop osed project area. There were approximately 20,600 acres of ponds, lakes and reservoirs within this proposed project area (USGS 2010a).

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**- 1**  

# 4 ENVIRONMENTAL CONSEQ UENCES

**4.1 DATA GAPS** 

Giant miscanthus is a new agronomic crop species in the United States, and also s till 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 Gr asses 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 produ ction 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

des igned 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 m ethods 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 t o 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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**- 2**  BCAP combined with the model undertaken by the Project Sponsors and technical assistance to be provided to producers addresses most of these conce rns.
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 gen us 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 extensiv ely 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 evide nce 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 Unit ed 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 informa tion 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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**- 3**  

## 4.2 **SOCIOECONOMI CS** 

**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 A ction 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 lo cal, 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

be ginning 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 chemica ls. 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. Over all, 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 assis tance 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 payment s 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 st ill need 10 years to break even. Under MSU’s analysis, producers

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**- 4**  Table 4

- 1

. Cost Comparison for Participating Versus Non

- Participating Producers for the Establishment and Production of Giant Miscanthus

It em 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 BC AP 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 A nnual 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 o f 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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**- 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 Spons ors 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 continge nt 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, su ch 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 ea ch proposed project area. For each proposed project area region, the 20 year project time

- frame from the giant miscanthus acres

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**- 6**  produced under BCAP, the anticipated economic impact to the region would total more than $750 million (US$2011). The EIA estim ated the annual value to the producer s 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 P roject 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 al l 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 pr oject 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 Pa**  **ragould 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 $5 0.0 million into the region annually. Economic modeling was performed to analysis the contribution of the Proposed Action for

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**- 7**  each proposed project area as part of the Project Sponsors’ confidential project area application.

**4.2.3 No Action Alternative** 

The se lection 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 ener gy 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 i n 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 l and use types that could trigger development of agricultural lands into other non

- agricultural land use types

n or would it create a substantial loss of arable cropland within the proposed project areas. Under the Proposed Action, the Project Sponsors prop ose 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 are as 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 o f 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 percenta ges could change over time depending upon the individual parcels that become enrolled.

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**- 8**  The conversion of pastureland could negatively affect livestock production within the proposed project areas, if sufficient grazing acreage was converted. The Ashtabu la 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 a pproximately 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 Pasturel and

– 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 2,0 8 7,971 52,986 10,0 00 18.9 261,540 40,000 15.3 Sour ce: 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 higher

value harvested croplands and past urelands . T he 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 c ropland and pas tureland land use types , when compared to the other proposed project areas. The Paragould proposed project area would be antici pated 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 pro ject 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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**- 9**  **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 condition s 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** 

Fo r 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 establishe d.

**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 co ver 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 minimi ze 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 m ost 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 a nd perennial vegetation, in permanent impro ved 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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**- 10**  Figure 4

- 1 provides the approximate locations of the anticipated current producers, which are spread throughout the proposed project areas. T he Project Sponsors have estimated

that individ ual 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

fie lds 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

.
J ø rgensen (2011 ) indicates a pot ential 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 produce r’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 s tanding dead plant

mater ial ), 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 inc lude 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, t his 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

miscan thus 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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**- 11**  Figure 4

- 1

. Approximate Locations of Anticipated Producers within the Proposed Project Areas

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**- 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 Biomas s 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 Pe sticide 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 poten tial for this species to be invasive it

has the ability to resprout from belowground, rapid growth, and efficient photosynthetic pathways. J ø rgensen (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. T here 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 rh izomes in intentionally planted areas spread beyond the planted fields, J ø rgensen (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, J ø rgensen (2011) indicates that M iscanthus 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
pote ntial 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 Au stralia 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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**- 13**  with approxima tely 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

t h ey 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 g um, 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 chan ges 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 fi eld 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

. J ø rgensen (2011) indicates tha t 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. A dditionally, 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 a phid 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 t he four states and the corn

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**- 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 include s integrated pest management (IPM) programs associated with dedicated energy crops that will provide protection equa l 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 wo uld 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 mis canthus 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

- ter m 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 polyculture s, 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 hig h 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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**- 15**  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 great er 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 contribu tion 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 misca nthus plants matured and the crop structure developed.

Similarly, Semere and Slater (2007 a ) 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 (2007 a ) indicate that perennial biomass grasses could provide improved wildlife habi tat 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 gr asslands. 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 dou ble for species of concern than for general ist species. Fargione (2010) indicates a lack of specific data availability for crops such as giant miscanthus, which has a different

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**- 16**  structure than native prairie grass species in the United States, indicating a need for more

research on these species. J ø rgensen (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 Illi nois 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 lackin g 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 potent ial 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

switc hgrass 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 regiona l 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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**- 17**  **4.4.3 Protected Species** 

**4.4.3.1 Significance Threshold** 

For prot ected 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 th e 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 buffer s 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 produ ce 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 implemen tation 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

. G iant 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, whil e nearly half of the

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**- 18**  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 (Blanc o

- 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 [m 2 

### ]) when compared to switchgrass, native prairie, (344 to 705 g C/m 2 

### ) and corn (405 to 717 g
C/m 2 

### ). 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) indicate d 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 establish ment could result in the s oil

disturbance similar to traditional tillage of commodity crops

. The preparation process could cause erosion following rainfall events until the giant miscanthus becomes establish ed (Donnelly et al 2010). S oil 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). First

year harvesting of rhizomes would have simila r 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 th e 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

establish ed, 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 la nd, 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 ye ar 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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**- 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, resu lted 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 con servation 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, tradition al 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.) indicate d 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 acreag e 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

P roposed A ction. 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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**- 20**  

## 4.6 **WATER QUALITY AND QU ANTITY** 

**4.6.1 Water Quality** 

**4.6.1.1 Significance Threshold** 
An accounting of increases or reductions in input use such as fertiliz er, 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 proje ct 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 m iscanthus 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 earli er, 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 phosphor us 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 include d 180 pounds of nitrogen, 115 pounds of phosphorus, a nd 260 pounds of potassium for corn grown for forage ( Roth and Heinrichs 2001). No fertilizer treatment s are recommended during the establishment or propagation phase for giant miscanthus, thereby reducing the potential for nutrient losses through stormwa ter flows on exposed or on partially covered acreage.

Research also suggests that

, once established

, giant miscanthus can lead to lo w levels of nitrate leaching and as a result improv e groundwater quality relative to other crops ( Christian and Riche 1998 ). Further, Love and Nejadhashemi (2011)

, through modeling with

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**- 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 q uality 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 bea ns, 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 reduc ed 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 m isca n thus 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 wa tersheds

. 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

establishm ent 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

p erennial 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 incorpor ated 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 approximat ely 5.4 percent between 2008 and 2017; however, all other primary field crop planted acreage is anticipated to decline. Overa ll, the change in land use through

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**- 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 ne gative 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 Acti**  **on**
Miscanthus has a high er efficiency of water use per biomass yield than corn or sorghum crops. Typically, giant miscanthus require s between 100 to 300 l iters 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 wate r 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 annua lly. 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 typi cally 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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**- 23**  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)

C oastal 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 a nd 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. (198 8) 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 3 36 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 Sto ne 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 H erwaarden (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 m aximum vapor pressure deficit, were within the range of C 4 

### 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 pas ture land species use

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**- 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 som ewhat 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 Fi n ch 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

– non

irrigated 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 Bar raclough (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 Englan d, 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/ P ublication 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 m m/day 3/ Grasslands in England have a longer growing season than Miscanthus

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**- 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 25 0 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) c hanges 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 expe cted. 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 m iscanthus 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 allow ing 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 req uire 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 t he proposed project areas. T here fore, 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 g rowth 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

g oal 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 area s have less t han 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 percent age 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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**- 26**  depleted. Some of the more marginal ac res 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 ar ea

. Some unknown proportion of these areas will be irrigated lands. The c onversion 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 t his 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 wi th 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

c omparison 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 c ould 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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**- 27**  a proposed BCF in each of the proposed project areas ensuring that producers will h ave 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 w ith 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.

M inor neg ative 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 bu ffer 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 effect s 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.
G iant 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 in to the conversion of bioenergy.

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### CUMULATIVE IMPACTS A **SSESSMENT**

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**- 1**  

# 5 CUMULATIVE IMPACTS A SSESSMENT

**5.1 DEFINITION** 

The CEQ regulations stipulate that cumulative effects analysis consider the potential environmental impacts resulting from “the i ncremental 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 ac tion 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 sepa rated. 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 produc tion of giant miscanthus as a dedicated energy c rops 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, project ed 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 A NALYSIS 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 inc ome; however, the percentage difference has been declining from a high of 31.1 percent higher to 13.5 percent higher (USDA ERS 2011 b ). Farming activities have contributed approximately 11.3 percent to household income, with the projected average being 12. 5 percent in 2010 ( Ib i d

). 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 th e driver for alternative fuels and energy sources from

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**- 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 int o 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 throug h 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 regi on 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 d egrees 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. Pr ojections 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, approxim ately 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 Unit ed 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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**- 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 Soy

beans Corn Sorghum Oats Soy

beans

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 1,2 2 6,524 131,336 799,682 323,700 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 p reviously 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 tradition al 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 N o 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 product ion 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.

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**- 4**  **5.2.4 Soi**  **l 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 lan d 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 en ough 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 us e 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 spec ies. 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 t he 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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**- 1**  

# 6 MITIGATION AND MONIT ORING

**6.1 INTRODUCTION** 

The CEQ issued revised guidance for mitigation and monitoring to be included in NEPA decision documents that include three gener al 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 purpo se 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 action s 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 F ederal agency meet their stated goals

.



## 6.2 **ROLES AND RESPONSIBI LITIES** 
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; responsi bility 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 a ssisting the lead agency through financial or other

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**- 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 de scribed 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 CP S, 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 impl ementing 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 an y 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.

Base d 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,

pu blication 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 th e responsible party for different mitigation and monitoring activities per this plan.

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**- 3**  Table 6

- 1

. Roles and Responsibilities for the Mitigation and Monitoring Plan
Activity Responsible Party Comment

Biann ual 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 applicatio n, 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, a nd 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

e radication. 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 monitor ing 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 produc er’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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**- 4**  Activity Responsible Party Comment

Monitoring program developed to monitor wildlife use or changes in use. Environmental Evaluation CPA

- 52 may need to be r evised 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 fa cilitate 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 pa rty 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 pla nted 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, veg etative 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 Repo r t. 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 sterili ty 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 Mi scanthus 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 MONIT ORI**  **NG 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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**- 5**  avoidance for energy crop establishment to avoid establish ment 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 BCA P 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 resource s such as F ederally threatened or endanger ed species or wetlands are present and could be potentially affected. Where possible, implementation of appropriate BMPs and/or CPS identified during the c onservation p lan ning process would mitigate or reduce any potential environmental impacts on key res ources 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 conduct ing 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 P roject S ponsors 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 proje ct 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 indivi dual 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 , p otential impacts are also likely to vary by current land use . Im pacts 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

surroun ding 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 t o BCAP

cover a smaller area . Finally, impacts are likely to vary by phases of the growth cycle

. E stablishment in year one (propagation) and year two ( plantation planting) may have greater

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**- 6**  impacts than maintenance (years three to 15) related to soil erosi on 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 th e 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 h old 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 resource s 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. Add itionally, 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 basic s of establishment, maintenance, and production. T he 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, t his 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 a nd when that conve rsion does occur, focusing on the marginally productive lands currently in food crop production . The P roject S ponsors have

worked with FSA, the USDA Agricultural Research Service (ARS), and NRCS to develop

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**- 7**  appropriate metrics for trackin g 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

e nrolled 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 con verted, 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 m eeting 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 implem ented

. 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 ad ditional requirements are necessary to mitigate potential environmental impacts on land use.

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**- 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 spre ad 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 t hrough rhizomes and does not produce sterile seed (Linde

Laursen 1993, Lewandowski et al. 2000). The New Zealand Environmental Risk Management Authority (NZ E RMA) approved giant miscanthus for use as a biomass feedstock in 2007 after an extensive process o f literature review, risk assessment methodology, and contact with researchers (NZ E RMA 2007). The NZ E RMA concluded, through literature and contact with researchers, that giant miscanthus is a triploid hybrid that does not produce seed or viable pollen; ho wever, it will produce inflorescences in warmer climates (NZ E RMA 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 a djacent to the giant miscanthus selection ( Ibid ).

Exclusion of Acreage Near Other **Miscanthus** S pecies

- 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 cross

pollination resulting in viable seed. This distance is the ma ximum distance observed
in Quinn et al. 2011.

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**- 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 t o 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. I f viable seed are found through the seed sampling program th ese 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

infl orescences 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 re commend 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 an d illustrates a
compan y ' 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

sys tem of the items described below and r hizomes carrying the green "QA" tag ha ve
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 onl y on th e 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.

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**- 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 publ ished 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 pote ntial 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 State s is low (Barney and DiTomaso 2008, Gordon et al. 2011).

Published rese arch studies have shown a slow growth rate of intentionally planted giant

miscanthus rhizomes of approximately five cm per year (approximately two inches) in Europe (J ø rgensen 2011) , but those studies focused on rhizome growth from deliberately planted gia nt 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 w as successful in eliminat ing 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 train ings and resource sessions with local extension and TSPs to provide specific training on identification of western corn rootworm incidents.

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**- 11**  Equipment Sanitizing

– As part of the agreement with the OSIA for quality assurance the Project Sponsor s have agre ed that a ll 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 destine d 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. Th e 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 , t hese buffers will be monitored every other year, at a

minimum.

Minimum Setback/Buffer Distance

- Although published data on the maximum rate of giant miscan thus 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 g iant 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 misca nthus 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 herb icide at

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**- 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 t reatment 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 Report ing

– 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 plantin g , 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 monitorin g 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 Sponsor s, t he producer contracts woul d allow for either party, the producer or Project Sponsors, to eradicate giant miscanthus within the contracted acres at the termination of the

cont r act.

To address potential crop pest and disease outbreaks such as the western corn rootworm,

an IPM Plan wi ll 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 fo r effective treatment. The IPM Plan will

als o follow a tiered approach

, similar to that described above for detection of potential vegetative spread.

### MITIGATION AND MONIT **ORING**

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**- 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 pro ducer’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 respo nsibility 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 a lso 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 tr ack 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 b obwhites ( 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, pasture land, or hayland) may have proportion ally larger impacts on habitat fragmentation in project areas.

### MITIGATION AND MONIT **ORING**

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**- 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 o f 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, hu nting 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 t he 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 pro tected species, such as F ederally 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. Additiona lly, 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 i n 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 consultat ions, 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 inclu de buffers

### MITIGATION AND MONIT **ORING**

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**- 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

l abeled 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 cur rently 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 t owards 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 str ucture 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 w ill 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

ma nagement 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 NRC S 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 pla nting (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

### MITIGATION AND MONIT **ORING**

**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 t o 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 D esign Documentation (PDD) and third party validation/verification procedures, as set out by the World Resources Institute (WRI) GHG Accounting Protocol, International Standards Organization (I SO ) 14064, Intergovernmental Panel on Climate Change ( IPCC ) Guid elines 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 credit ing 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** 

Potenti al 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 onl y 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 n utrient 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 subs tantially lower compared to traditional row crops, but may be higher than idle or pasture or hay land.

### MITIGATION AND MONIT **ORING**

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**- 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 p roducer 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 quali ty
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 An nual 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 n ot 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). G iant 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 ass ociated with unsustainable farming practices by traditional row crops (e.g., rice, corn, and beans) by providing an economically viable alternative.

### MITIGATION AND MONIT **ORING**

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**- 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 existin g NRCS CPS utilized, and their average and total yield per field

enrolled.

### REFERENCES

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**- Environmental Assessment Giant Miscanthus Establishment and Production**  **7**

**- 1**  

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**- 18**  This Page Intentionally Left Blank

### PREPARERS

**FINAL**

**- Environmental Assessment Giant Miscanthus Establishment and Production**  **8**

**- 1**  

# 8 PREPARERS

Name Organization Experience Project Role Rae Lyn n 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 Env ironmental Solutions, LLC 2.5 years Affected Environment, Environmental Consequences B.S.

, Environmental Science, Stephen F. Austin State University, 2008

Ransley Welch Integrated Environmental Solutions, LLC 6 years GIS Analysis and Map Genera tion

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, Un iversity 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 Manageme nt, 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

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**- Environmental Assessment Giant Miscanthus Establishment and Production**  **8**

**- 3**  Name Organization Experience Project Role
Gene Garrett University of Missouri 30 yea rs 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

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**- 4**  This P age Intentionally Left Blank

### PERSONS AND AGENCIES **CONTACTED**

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**- 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
Coordin ation 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 Trib es
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

- go vernment
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

- to

government consul tations 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

th e 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 recogn ized 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 r elation to environmental

### PERSONS AND AGENCIES **CONTACTED**

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**- 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 individ ual 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 comp leted 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 Of fice (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 area s (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 area s (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 concern s 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 impl ementing for BCAP enrollees.

### PERSONS AND AGENCIES **CONTACTED**

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**- 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. Mart in 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 Ser vice 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 Administ rator 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 Barbou r, 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**

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**- 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 Natura l 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 Resourc es 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 D irector, 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 Pau la 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**

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**- Environmental Assessment Giant Miscanthus Establishment and Production**  **9**

**- 5**  Name Organization/Agency
Bob McDavid, Mayor, City of Columbia, MO Sue McGowan, Director, Para gould Regional Chamber of Commerce, Paragould, AR John Palo, Director, Conneaut Port Authority, OH Sean Ratican, Exec utive Director, Ashtabula County Port Authority , OH Jeff Roskam, Kansas Alliance for Biorefining and Bioenergy, KS Tony Stonecypher, City M anager, 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 Crawf ord Representative Steven C. LaTourette Senator Claire McCaskill Senator Mark Pryor

### PERSONS AND AGENCIES **CONTACTED**

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**- Environmental Assessment Giant Miscanthus Establishment and Production**  **9**

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### APPENDICES

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**- Environmental Assessment Giant Miscanthus Establishment and Production**  

# APPENDICES

### APPENDICES

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### APPENDICES

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**- Environmental Assessment Giant Miscanthus Establishment and Production**  

# APPENDIX A

– State

- listed Species that Could Potentially Occur within the Proposed Project Areas

### APPENDICES

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**- Environmental Assessment Giant Miscanthus Establishment and Production**  This Page Intentionally Left Blank

### 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

Mam mal 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 abr upta) SE Cole
Topeka Shiner (Notropis topeka) SE Boone, Calloway, Moniteau

Plant Running Buffalo Clover (Trifolium stoloniferum) SE Boone, Calloway

Aurora

Bird Ame rican 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 Cav efish (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, Ston e, 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 (C helone 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 Cla y 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, Lawre nce

Ashtabula

Bird American Bittern (Botaurus lentiginosus) SE Erie, Crawford, Mercer

Bald Eagle (Haliaeetus leucocephalus) ST Ashtabula, Lake, Geauga, Trumbull, Er ie, 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 S apsucker (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 (Cor egonus 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 fulves cens) 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 Ashta bula, 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, Me rcer 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 (No turus 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 ap hylla) 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 (Helo cordulia uhleri) SE Lake

Mammal Black Bear (Ursus americanus) SE Ashtabula
Bobcat (Felis rufus) SE Ashtabula, Lake

Mussel Black Sandshell (Ligumia recta) ST Ashtab ula, Lake, Trumbull
Clubshell (Pleurobema clava) SE Erie, Crawford, Mercer
Eastern Pondmussel (Ligumia nasuta) SE Ashtabula, Geauga
Fawnsfoot (Truncilla donacifor mis) 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 Ashtabul a, 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 (Cy pripedium parviflorum) SE Geauga
A Sedge (Carex tetanica) ST Crawford, Mercer
American Beach Grass (Ammophila breviligulata ) ST Ashtabula, Lake
American Beachgra ss (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 appalachie nsis) 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. c audata) SE Erie
Bearded Wheat Grass (Elymus trachycaulus ) ST Ashtabula, Geauga
Bebb's Sedge (Carex bebbii) SE Erie, Crawford

Beck's Water

- marigold (Megalodonta b eckii) 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 (Sali x 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 heterop hyllum) 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 dum osum) 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

- ru sh (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 par adoxa) 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 fascic ularis) 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 a ngustifolium) 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

- rus h (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

- pars ley (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

- leave d 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 S pike

- 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

- leav ed 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 cilino dis) 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) S E 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 Er ie
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 alpinoart iculatus 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

- sed ge (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 anse rina) 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

Slend er 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 polygo nifolia) 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 (S choenoplectus 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 Cr awford
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 oblongi folia) 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 (Compt onia 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 boreali s) 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
Varieg ated 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 W ater

- 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 verticillatu m) 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 ochrol eucus) 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

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### APPENDICES

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**- 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:Yourstatement belowiscorrect.Morespecifically,whatIhavedoneistomonitortheflowerunitofOSIA’sM.xgiganteusselectionforpollenandseedproductionbyobservationandmicroscopicexamination.Todateneitherpollenorseedhasbeenprodu ced.Theextrudedanthersoftheflowerunithavebeenshriveledinappearanceandsimilar towhatweseewithmalesterile seedcorninbredlines.Inaddition,Ihaveobservednovolunteerseedlingse merginginobservationpl otareasadjacenttotheM.xgiganteusselection.Furthermore,the followingtechnicalreferencesprovideadditionalcommentregardingtheinvasiveissue:1. CASTCommentary,QTA20071,November2007,“BiofuelFeedstocks:TheRiskofFutureInvasions”,p.5.2. Lewandowski,I.,J.C.CliftonBrown,J. M.O.Scurlock,andW.Huisman.2000.Miscanthus:Europeanexperiencewitha novelenergycrop.BiomassBioenergy19:209227.Bestregards.JohnArmstrong,Sec./Mgr.OhioSeedImprovementAssociation61650AveryRoadP.O.477Dublin,Ohio43017Ph.6148891136Fax:6148898979Email: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?They arebasingthatonyourobservationsinyour3yearstudy.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 mis canthus 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 app ropriate 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 Non

native, it grows like wildfire, and contributes not hing 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 o n 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 w ith 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 energ y 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 pro vides 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 tr ansitioning 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 c ommunities, 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 ap plication 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 a nd 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 ene rgy 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 eco nomic 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 supp ort 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

ne

w 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 L LC. 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

cu ltivation 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 Regional

NGO Regional Economic Develop

ment, Inc. Comment noted on the support of the proposed action.

8 1 One correc tion regarding invasiveness of giant miscanthus parents: Miscanthus sacchariflorus (Maxim.) Franch. is on the Massachusetts state

listed noxious weeds list, contrary to P4

- 11 L9 Text Correction NA IL Individual University of Illinois at Urbana

Champaign 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 R egional

NGO Florida Fish & Wildlife Conserva

tion 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 intere st 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 supp ly 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 cr op 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 com plimentary 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 industr y 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 Assessm ent 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 partici pated 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 o n 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 the se 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 As

htabula, 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 h igh 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 t hat 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 dev elopment 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 sup port 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 respo nsible 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 Conserva

tion 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 Conserva

tion The Project Spo nsors 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 Agricul tural 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 wou ld 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 conce rns 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 Conserva

tion A substantial amount of r esearch 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, a ny 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 p rogram. 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 p otential for land conversion and the unknown invasiveness nature of mass plantings of miscanthus. Impact Analysis NA MO 65102 State Agency Missouri Department of Conserva

tion The Project Sponsors and FSA have developed a Mitigation and Monitoring Plan tha t 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 re search is needed to determine potential impacts to wildlife and invasiveness of giant miscanthus before the federal government funds an extensive, long

term BCAP initiative. Additional Research NA MO 65102 State Agency Missouri Department of Conserva

tion 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 Proj ect 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, BCA P 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 inspe ctions 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 Conserva

tion The Mitigation and Monitoring Plan take many of these considerations into account and have included similar activities as necessa ry 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 requir e 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 hab itats 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 Conserva

tion 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, ma rginal 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 us ed 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, woodl ands, 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 thi s 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 Conserva

tion Since contract acreage has not been established within each propos ed 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 projec t 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 contro l 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 Conserva

tion 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 versio n 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 tri gger an immediate, new environmental assessment process and public comment period. Viable Seed NA MO 65102 State Agency Missouri Department of Conserva

tion The Project Sponsors are proposing to only use the Illinois clone of giant miscanthus, which is onl y 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 promo tion 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 Conserva

tion 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 uninten tional 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 an d 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 Conserva

tion General statement, no re sponse 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

ener gy 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 desperate ly, 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 t he 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 re newable 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 Alo terra 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 large st 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 cro p 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;

e fficient 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. Hig her 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 Ind ividual University of Washington Department of Micro

biology Comment noted on the support of the proposed action.

### Page 13 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 sup port 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 involv ing 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

- pro ducts and by

products 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 opportunit ies 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, Bi omass 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 M i s s o u r i Department of Agriculture Comment noted on the support of the proposed action.

26 1 The Pennsylvani a 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 Pennsyl

vania Game Com mission Bureau of Wildlife Habitat Manage

ment No response required.

### Page 14 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 ha ve 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 Steri lity Against PA 17110 State Agency Pennsyl

vania Game Commission Bureau of Wildlife Habitat Manage

ment The Project Sponsors have committed to a stringent Mitigation and Monitoring Plan with financial responsibility for control of any unwanted spread resti ng 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 d 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 Pro vider. 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 loo sestrife ( 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 Pennsyl

vania Game Commission Bureau of Wildlife Habitat Manage

ment 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 w ithin 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 th e 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 f unded, but if it is, the industry should contribute more to reducing that risk, as described below. Invasive, Non

- Native NA PA 17110 State Agency Pennsyl

vania Game Commission Bureau of Wildlife Habitat Manage

ment 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

con tracted 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 wit hin 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 durin g 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 b order 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 Pennsyl

vani a Game Commission Bureau of Wildlife Habitat Manage

ment 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 floodpla in. 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 cer tain 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 yie ld 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 con ditions. 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 hav e 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 prop osed 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 deta iled analysis be conducted pertaining to regulated coastal zones. Eliminated Resource Areas NA PA 17110 State Agency Pennsyl

vania Game Commission Bureau of Wildlife Habitat Manage

ment The Project Sponsors will exclude any acreage included within the ma naged coastal zones of Lake Erie to ensure compliance with the USACE regulations or Coastal Zone Management regulations.

### Page 16 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

26 7 Additionally, in section 2

- 15, line 26, the evaluation that Recreation will not be significantly impacted is not sufficiently add ressed. 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 sign ificant 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 N A PA 17110 State Agency Pennsyl

vania Game Commission Bureau of Wildlife Habitat Manage

ment 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 Coope rative 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 co ncern also further supports the three numbered mitigating recommendations listed above, especially number 2. Land Use NA PA 17110 State Agency Pennsyl

vania Game Commission Bureau of Wildlife Habitat Manage

ment 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 wit h 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 tha t 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 Pennsyl

vania Game Commission Bureau of Wildlife Habitat Manage

ment 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 Commenter 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 contr act or within one full year following a contract expiration. CREP acres NA PA 17110 State Agency Pennsyl

vania Game Commission Bureau of Wildlife Habitat Manage

ment This is a CREP contract issue and not a BCAP contract issue. FSA has no control over prod ucers 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 ov er 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 pl anted. 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 re

funded 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 Co uncil. 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 Pennsyl

vania Game Commission Bureau of Wildlife Habitat Manage

ment The 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 t hat 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 Pennsyl

vania Game Commission Bureau of Wildlife Habitat Man age

ment 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 site

specific co nditions 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 Fede ration 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 invas ive 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. 20 004 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 c ontract 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

sam pling 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 wi th 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 pe rcent 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 tha t 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 Bradfo rd 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 plant ings 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 tri als 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 miscanthu s 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 4 00 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. Addition ally, 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 gigan teus 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 rece ive 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 N A 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 clo nes 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 in vasive 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 a pproach 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 site

specific 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 rep orting 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 p roduction, 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 th e 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 pot ential 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 mi llion 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 b oth 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 maxi mum 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. I n 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 inflo rescences 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 re commend 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 propos ing 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 note d; 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 Distric t 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 inadeq uately 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 addi tional 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 versio n 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 with in 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, in adequately 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 res ponse 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 mini mum 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 adjac ent 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 imp acts. 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 N A 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, gia nt 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 ge ographies 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 l ocations 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 specie s of conservation need, including migratory birds, as well as state

managed 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

- spec ific 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 enti ty. 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 condit ions 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 s pecific 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 S ervice 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 esca pe 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 proxim ity 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 invasive s, 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 r hizome 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) samp ling 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 1 2 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 gi ant 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 l ands, 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

o f 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 site

specific 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 escap e 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 spre ad 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., ne ighboring 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 inclu ded 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 disc ussion 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 d ollars 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 gene ra 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 inad equately 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 e vidence 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 establis hed 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 a nd 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 s inensis 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 samplin g 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 co nservation 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. La nd 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 o f 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 con verted 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

w

ithin 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 great er 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 approv ed 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 c omplex 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 mi scanthus. 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 F ish & 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 P lans 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 o f 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 acr eage 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 proj ect 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 sto res 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 includ ed 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 combinat ion 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 i s 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 soli d 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 Miscanthu s 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 co rn 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 thei r 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 pro ven 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 Non e 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 ove rall 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 b irds, 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 B CAP 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 BCA P 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 i s 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 M iscanthus 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 Mis canthus (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 I N 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 biomas s 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 h ave 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. FS A 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 tha t FSA cannot contro l 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 bioe nergy 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 F SA 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 p ellets 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 possibl e 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 p roposed

– 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 Mitigat ion and Monitoring Plan, in addition to all other BCAP requirements within the site

- specific Conservation Plan.

### Page 33 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

33 6 Land impacts

– Pastureland is still productive agricultural land, providing animals useful for food, wool and leather, and for human act ivity, 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 Mar ch 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 assistan ce 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 viabl e 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 c ommitment 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

33 8 Miscanthus giganteus, although presently not known to propagate except by rhizome extension, has th e 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 gras s 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, Da te 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. Additiona lly, 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 on

going 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 exist ing 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/im pacts 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 mitigati ng 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 decad e 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 info rmation, 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 t o 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 f rom 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 carbo n 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 sequ estration. 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 t he 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 fertili zer 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 requir ed 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 var iability 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 t o 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 m iscanthus 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. T he 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 observ ed 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 rainf all 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 Furt her 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 wa s
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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

33 17 The water usa ge 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 liter ature 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, beginnin g 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 clari fication 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 ind ication 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 ab sence 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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

ec

onomic 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 t o 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, relia ble, base load energy supply that America desperately needs. General Support NV 89410 Individual Shellhamm

er Farm Comment 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 a nd I support the use of Miscanthus as an energy crop to meet America's renewable energy needs. General Support O H 43604 Local

- NGO Toledo

Lucas County Port Authority Comment noted on the support of the proposed action.

37 1 I support the approval of Alot erra 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 t he 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

39 1 The EA evalu ated 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 aspect s’ 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 b e 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 specie s 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

39 4 I think it’s safe to sa y 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, fo reign 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 Se curity 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 “un

American..” 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) th e 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 primari ly 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. Gener al NA GA 30605 Individual None No response required.

### Page 42 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 th e 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, orga nic 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 Indiv idual 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 g iant 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. Howeve r, 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 enroll ment 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 FS A 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

an d idle lands to avoid compromising harvestable acreage in traditional crops.

### Page 43 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 en ough 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 b y 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, for est, early

successional 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 Nationa l 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 long

term 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 t hat this species does not become an invasive problem from the project areas.

### Page 44 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

39 10 C. Biological Resources: Potential invasiveness and adverse effects on wildlife and natural habitats are two primary concerns. With regards to invasiveness, it shou ld 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 C 4 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 306 05 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 Mo nitoring 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 mov ement 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 infloresc ences 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 o f viability is outside a safe range.

### Page 45 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 triplo id 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, clu mp

- 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 n on

- 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 respon sibility 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 vegetativ e 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 develop ed 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 fo und 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 fo und 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 46 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

39 12 Past performance of an introduced/potentially invasive species reflects past e nvironmental 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 poll en, 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 Moni toring 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 miscan thus 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 C

onservation 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 ste ps 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 inflor escences 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 deter mine 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 47 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 var iety 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 Mitigati on 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 g iant 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 Pl an. 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 deta il, 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 exis ting 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 regi on 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

39 14 The most widely used predictive to ol 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 miscan thus 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. Th e 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 Provid er. 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 49 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 occur red 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. Er adication measures also can have unintended consequences for non

target 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 c ontrol 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 outsi de 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

as

sistance 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 th e 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 50 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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. T he 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 early

successional habitat. Bi odiversity 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. Addi tional 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 th e 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 Mitiga tion and Monitoring Plan as best management practices or exclusions of acreage.

### Page 51 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 a bsence 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 gre atest 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. Biodiv ersity 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/regula tions, 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 tak ing 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

a ssociated 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 produce s 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 so il 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 306 05 Individual None No response required.

### Page 52 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 recyc ling 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., f uel, 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 ef fects to water quality.

### Page 53 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 ce ntralized 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 k g of water lost (normalized for maximum vapor pressure deficit) and is comparable to other C 4 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 C 3 and C 4 gram inoids and herbaceous species has a WUE of 0.2 to 2.2 g/kg (not normalized). Comparisons between normalized values for miscanthus and un

normalized values for native prairies (Burba 2005) are problematic. Water Use NA GA 30605 Individual None Further cl arification will be provided through normalized values where available in the literature.

### Page 54 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

39 22 However, the issue here is that the EA is attempting to justify the cultivation of a non

native, 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 s witchgrass. 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 mak es 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 cropla nds. Average annual precipitation greater than 30 inches should be sufficient for the production of giant miscanthus.

### Page 55 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

39 23 II. Mitigation and Monitoring Plan The MMP (referenced in earlier sections), is the plan that addresses the possible identifi cation 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 p erforming 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 asso ciation (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 w ith 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 h ave provided a great deal of additional information to include in the Mitigation and Monitoring Plan as best management practices or exclusions of acreage.

### Page 56 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 entrepreneu rs, 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 n atural 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 miscan thus 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 support ing 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 m ay 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

conser vation 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 Pr oject 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 implem ent the Project Sponsors plan. The Project Sponsors are not required to propose alternative species, methods, or project locations under NEPA.

### Page 57 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

39 26 With regards to the specific use of giant miscanthus as a biofuel crop, there seem to be ample reasons fo r 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 C 4 photosynthetic pathway, high water use efficiency, etc. Third, despite the fact that it is considered a sterile hybrid triploid, there are numerous ‘natural’ genetic mechani sms 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 fo r 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 speci es 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 Monit oring 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 sit

e 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 bee n 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.

### Page 58 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 o f 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 worki ng 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 fuel s 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 supp ort 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.

### Page 59 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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, Miss ouri, 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 f or 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 thi s 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 Environm ental 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 appropri ate specialists (agronomists, entomologists, wildlife specialists) renders the conclusions suspect. General Against AR 72703 Individual None No response required.

### Page 60 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 po ints 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 poten tial 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 obli gated 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 th e 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 bil led for those activities, if necessary.

### Page 61 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 i mpacts. 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 base d 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 obligate d 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 ne cessary 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 D raft 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

43 5 · There is no landscape

- level analysis of Miscanthus because there is no lar ge

- 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 a nd 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 potenti al 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, M iscanthus 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

curre nt 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 proje ct 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 sufficien t for the production of giant miscanthus.

### Page 63 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 fr om 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 pro duce 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 h igher 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 financia l 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

v egetative 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 see d 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 tha t 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 p otential 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 incre ases 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 th rough 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 site

specific.

### Page 6 4 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

43 9 · The statement was made that, because there is little peer

- reviewed literat ure 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 d ifference 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 dete rmine 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 f ields. 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 a gain 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 dat a 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 c an 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 sit e

- 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 o f appropriate control technologies.

### Page 65 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 recen t 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 cur rent 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 propos al 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 approvi ng 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 e nter 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 forwa rd, 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 co mplete 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 al l 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 minimiz e 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 prov ided 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 id entified 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 Europ ean 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 f or 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 adju sted 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 productio n 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 wo uld 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 necessa ry. 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 we eds (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.

### Page 67 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 o f 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 a vailable 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 thi s 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 Indi vidual 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 di rectly 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 hav e 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. Ad ditionally, 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 b e 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

44 11 The authors note that invasive plant species can have significant negat ive 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 En vironmental 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 individua l 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 establ ished 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 ta rget 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

es

tablish 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 amou nt 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 d ue 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 si lage, which is a crop that has enough data to be released in Pennsylvania.

### Page 69 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 a gricultural 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 P roject 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 reso urce 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 Ark ansas, 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 with in 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 assume s 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

a ction.

### Page 70 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 restin g 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 Prov ider. 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 step s 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 tho se 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 spons or 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 pu blicly 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 giv en 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, consult ation 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 environment al 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 pr oposal 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 Mi ssouri 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, Oh io, 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 othe r 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

46 2 We believe that there is insufficient information in the En vironmental 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 agricultura l 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 c laims 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 pr

ovided 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 writte n, 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 specialist s 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 regulatio ns, and the contractual obligations included within the overall Mitigation and Monitoring Plan.

### Page 73 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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) id entifies 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 p roduce 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 mis canthus, 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 unders tand 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 staf f 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, in dicating 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 ex clusion 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 m atter 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 shou ld 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 proce ss 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 p rovide 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 mitig ation 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 subj ect to all State and local regulations, which may be more stringent than Federal regulations concerning those resources areas.

### Page 75 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

47 4 Given the lack of experience, data and specificity, the report's conclusions of minor adverse impacts on vegetation and wi ldlife 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 anal ysis 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 Pro ject Sponsors of FSA before or during the site specific environmental review.

47 5 Recommendation: A case study, where a site

specific review is conducted on a 30

- 100 acre plot in one of four areas, would be extremely helpful to demonstrate how the en vironmental 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 tr ials, 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 mi scanthus 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 cond ucted 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 monito ring 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 im plementation 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 TS Ps 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 i f 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 dra ft 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 man agement practices or exclusions of acreage.

### Page 77 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 pr oject

- 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 mi scanthus 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 non

native 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 Monitor ing 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 : Althoug h 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 pollutio n 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

conv ersion 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 Code Entity Agency/ Group Response

47 11 Recommendation: The EA would benefit by including a list of potential pesticides, herbicides, and fertilizers tha t 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 prod uction 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 approp riate 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 provi de 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 b road 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 ef

forts. 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 a ll State and local regulations, which may be more stringent than Federal regulations concerning those resources areas.

### Page 79 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

47 13 Recommendation: EPA recommends the FEA correct the following: In the document (page 2

- 9), there are several references to Harne ss 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: Connect ed 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 pro posal. 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 miscan thus 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 606 04 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

suc cessful 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 t hat 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 deter mined 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 g as 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 prov ided 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 regardi ng 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 6060 4 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

47 18 Section 4.4.3

- 4.4.4 Direct & Indirect impacts defini tions 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 lifecyc le 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 consi dered "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., non

GHG 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 t o these comments during the BCAP PEIS process.

### Page 82 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 repo rts 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 non

GHG related air quality. This assumption does not examine the possib ility 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

r esults. 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 app lied 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 down stream 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 E PA

- 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

47 21 Criteria Pollutants: The DEA identifies all project areas are in attain ment 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 non

attainment for PM2.5 Lake County and Asht abula 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 respon ses 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

47 23 Concer n 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 t he 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 o ccur 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 pro

ject 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 i dentification, 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 non

applicability for an EJ analysis and support the argument that a reasonable th reshold 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 impac ts. 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

a pproximate 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

47 25 Recommendation: EPA recommends that the FEA identify the human enviro nment 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 prin ciples 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 d isplay 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 oth er 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 a gricultural 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 existi ng agricultural activities within these project areas and the potential for additional BCAP project areas within the reasonably foreseeable future.

### Page 86 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

48 1 On behalf of the Natural Resources Defense Council, I submitted these comments on the Environment As sessment (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) f or 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 con sider 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 ad aptive 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 transpor tation 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 cont rol 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 s teps 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 infl orescences 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 det ermine 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 throug h the life of the contract between the producer and the Project Sponsor, which can be renewed in perpetuity.

### Page 87 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 th e 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 assume s 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 benef icial 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 on

going 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 miscant hus. 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 p rotected 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 establi shment 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, afte r 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 th e 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 fu ngible 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 pellet izing 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 emis sions from agricultural equipment would be minor and occur infrequently throughout the year in the non

attainment 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 pr

oduction 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 non

attainment 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

reasona ble 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 alternativ e species or project locations under NEPA.

### Page 89 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 ste rile 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 b e 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 r ate 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 t hat field, if it is determined that the percentage of viability is outside a safe range.

### Page 90 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 th at 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 ecosyste m, 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 Octob er 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 th e Natural Resources Defense Council and the National Sustainable Agriculture Coalition. General Against MA 02238 NGO Biomass Accounta

bility Project

- No Biomass Burning No response required.

49 2 1. The EA relies on monitoring and adaptive response, b ut 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 mitig ation

measures. Financial Responsibilit y NA MA 02238 NGO Biomass Accounta

bility 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 specifi c, based on current data about the condition of ecosystems that will be impacted. Mitigation Measures NA MA 02238 NGO Biomass Accounta

bility Project

- No Biomass Burning The Mitigation and Monitoring Plan was provided in a draft form in the Draft EA to al low 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 exclusio ns of acreage.

### Page 91 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 elas ticity 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 meaning ful 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 Accounta

bility 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 with in 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, r ather 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 Acco unta

bility 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

49 6 5) The EA provides inadequate data and analysis on the added chemical inputs from conversi on of pasture or fallow lands, and wholly fails to address the impacts of these chemical inputs. Chemical Inputs NA MA 02238 NGO Biomass Accounta

bility Project

- No Biomass Burning Chemical inputs during establishment would be similar to other products us ed 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 Accounta

bility Project

- No Biomass Burning Emissions outside of the establi shment 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 non

atta inment 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). Atmosph eric CO2 NA MA 02238 NGO Biomass Accounta

bility 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 e missions from agricultural equipment would be minor and occur infrequently throughout the year in the non

attainment 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 limi ted 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 Accounta

bility Project

- No Biomass Burning The Project Sponsors are proposing a specific project fo r 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 Sponso rs are not required to propose alternative species or project locations under NEPA.

### Page 93 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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. Alt ernatives 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 M A 02238 NGO Biomass Accounta

bility 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 regula tions for a EA or with USDA NEPA regulations at 7 CFR 799. General NA MA 02238 NGO Biomass Accounta

bility Project

- No Biomass Burning Comment noted, the NEPA process requires an appropriate level of environmental review based on the Agency's assessment o f 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 cumula tive 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 ac tions.” 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 speci es. 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 Accounta

bility Project

- No Biomass Burning The cumulative effects analysi s 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 address ed. 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 wha t 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 f or 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 Ac

counta

bility 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 Conservatio n 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 regul ations concerning those resources areas.

### Page 95 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 t his 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 ac count 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 Accounta

bility 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 P roposed 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 pla nting [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 eff ects 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/m etric 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 gro wing miscanthus a viable economic enterprise. Socioecono mics NA MA 02238 NGO Biomass Accounta

bility Project

- No Biomass Burning BCAP is a voluntary program that producers join if there is enough economic incentive for the individual producer to justify t he 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, a nd 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, th e 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 economic ally 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

49 16 Socioeconomic effects/economic viability: The degree of economic uncertainty for the farm er 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 te chnology, 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 no t 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 Accounta

bility 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 individu al 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 a vailable data most similar to the confidential economic information developed by the Project Sponsors as part of the application.

### Page 98 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

49 17 The report continually emphasizes using the farm model, based on statements like the following for which no substantiat ing 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 pr oducers. “ 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: “Und er 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 p roduced 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 Accounta

bility Project

- No Biomass Burning BCAP is a voluntary program that producers join if there is enough economic incentive for the ind ividual 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 th e 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 b e available for public comment, because changes to the MMP are in fact likely to require major changes or re

evaluation 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 assurance s 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 Accounta

bility Project

- No Biomass Burning The Mitigation an d 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 Miti gation and Monitoring Plan as best management practices or exclusions of acreage.

### Page 100 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 d iversity 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 t o 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 effor ts 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 Accounta

bility 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 st

ates. 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 an y 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.” M itigation Measures NA MA 02238 NGO Biomass Accounta

bility 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

49 21 Water Usage: The EA repeatedly obfuscates the true water imp acts 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 mi scanthus 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 ra infall 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 th an 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

: A daptive 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 Accounta

bility 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 esti mated 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

49 22 Water Quality: During the establishment of the crop there will be a decrement in water quality that is ackno wledged 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 short

term and temporary increases in nutri ent 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 1 5) 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 Accounta

bility 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, tha t 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 non

productive land. That is contradicted by thi s 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 crop land with the remainder being non

cropland, such as pastureland.” (emphasis supplied) Land Use NA MA 02238 NGO Biomass Accounta

bility 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

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 u p to ten feet per year. Invasive NA MA 02238 NGO Biomass Accounta

bility 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. T he 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 Provi der. 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 thos e 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 sponso r to recommend eradication of that field, if it is determined that the percentage of viability is outside a safe range.

### Page 105 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 occu r 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 th at 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 Fede ral 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 mi scanthus) 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 potentia l spread of rhizomes will occur is recognized in the report. Invasive NA MA 02238 NGO Biomass Accounta

bility Project

- No Biomass Burning The Project Sponsors have committed to a stringent Mitigation and Monitoring Plan with financial responsibility for c ontrol 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 outsi de 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

as

sistance 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 th e 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

49 26 In addition the EA at one time says that plants that are not normally planted are not includ ed 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 o f 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 W eed 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 Accounta

bility 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 determ ine 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 Con servation 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 d etermine 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 fiel d, 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 attai nment. 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

- rura l 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 Accounta

bility Projec t

- 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 non

attainment areas.

### Page 107 of 128 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 t echniques 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 Accounta

bility Pro

ject

- 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 the y 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 com bustion 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 Bioma ss Accounta

bility 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ Group Response

49 30 Air Quality and monitoring so as to adequately inform the MMP : There is almost no monitorin g 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 Accounta

bility Project

- No Biomass Burning An analysis of PM2.5 associated with traditional tillage activities has been inclu ded 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 ou tside 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 Accounta

bility Project

- No Biomass Bur ning 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 acr eage 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 Accounta

bility 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 No. Comment No. Comment Category Position State Zip Code Entity 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 asses sing 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 gro up 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 Accounta

bility 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 Cer tified 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 Propose d 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 a s 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 ass ess 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 Accounta

bility Project

- No Biomass Burning The BCAP e stablishment 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 det ermined 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 app lications 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 pro

ject. 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 p roject 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 progra ms 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 socia l 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 streng ths. 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, Missou ri 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

- to

e thanol 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 sup port 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 o n the support of the proposed action.

### Page 112 of 12 8 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. De partment 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 imp acts 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. The re 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 revie w 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 o f 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 in tentionally 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 s ampling 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 com mitment 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 Treat y 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) allo polyploidy 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 weed s 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 no t 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 Ster ility, 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 woul d 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 buf fer 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 a ny 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 greate r 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 o f 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 threa tened 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 effect s 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 wate r 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 minimu m 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

ne cessary 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 V A 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 ne eds 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 t he 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 w ith 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 restri ct 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 r ange 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 Sponsor s 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 wha t 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 f orm 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 managem ent 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 produc er 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 fiel d 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 approximat e 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 Code Entity 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

curr ently 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 erad ication 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 miscanthu s 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 Mon itoring 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 floodpl ains, 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 e stablished 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 P lan 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 great ly 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 gr ass 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

ev

aluating 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 miscan thus ( 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 poin t 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 over

represented 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 indi cate 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 miscanth us 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 i n Boone, Cole, or Randolph counties; Western prairie fringed orchid is not considered extant in Jasper or Lawrence counties; Ozark big

eared 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 d iscoveries 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 Commenter No. Comment No. Comment Category Position State Zip Code Entity Agency/ 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 s pecies 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 (Cen taurea 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 drough t 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 a re 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 G iant 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 s pecies 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 fiel d 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 th at 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 an d 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 w ith 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 recti fy 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 intentio nally 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 samplin g 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 commitmen t 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 developm ent 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 bo th 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 maxim um 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 i nclude (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 inflor escences 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 rec ommend 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 ina bility 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, 20 04). 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 rhizome s 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 area s. 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 accorda nce 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 co ntrol 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 outsid e 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

ass istance 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 complia nce 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 r eference 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 f ully 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 scientifi c 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 preparin g 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 ca n 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 ca tegories 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 simila r 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 Stat e 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 a s 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 conflic t 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 potent ial 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 spr ead 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 yea rs 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 conduc ted 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 hav e 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 a nd 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 th e use of Miscanthus as an energy crop General Support WA 98406 Individual None Comment noted. Comment received after end of comment period.

N o

t e : * Comment received after end of comment period.

### Page 128 of 128 

### T h i s p a

g

e i n t e n t i o

n

a l l y l e f t b l a n k

### 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 BlankOSIA QUALITY ASSURANCE (QA) PLANTING MATERIALS PROGRAMFOR ALOTERRA ENERGY MISCANTHUS GIGANTEUS RHIZOMESCUSTOM TEN STEP PLANTPROPAGULE QA PROGRAMOSIA INSPECTOR QA STANDARDS AND REQUIREMENTS TO BEFOR MISCANTHUS GIGANTEUSACTION ITEMCHECK LISTINSPECTED OR AUDITEDCOMMENTRHIZOMES1. Miscanthus RhizomesApplicant to QA Planting Stock Rhizomes, YesNo Custom Program for Miscanthus Giganteus clones, Program to consist of field inspection, laband biomass production.in production fields, research plots anda perennial grass energy crop.test, auditing, traceability and optional QA Labeling.plantations.2. Planting StockApplicant to provide botanicalAuditing of source documents by designated QA Applicant to provide documentation prior to or withdescription, 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 plotApplicant to provide a field croppingA rhizome crop will not be eligible for QAif planted Applicant to provide prior crop field history withland historyhistory for all production fields, plantationson land that has grown a different Miscanthus Giganteus field application.and research sites.variety during the previous two years.4. Field Isolation AssignmentMinimum distance from other MiscanthusFields shall be clearly separated fromAudit field maps and annually verify isolation atfields of the same species.other Miscanthus species, or same speciesthe time of September or October field inspection.that is not entered in the QA program, orfromGMO clones, in such a manner as to preventmechanical mixture.5. Field InspectionsThird party QA Agency inspection ofAssess general agronomic field conditionsOSIA field inspects and gathers ten head samples perproduction fields, research plots, plantationsand breeders description for genetic purityclone and submits same to OSIA seed laboratory foror greenhouses.at the flowering stage in September ormicroscopic examination for seed set (non-invasiveOctober annually. Other varieties permitted, 1:1000. species tendency). Viability tests will be used if needed.Ten head samples per 10 acres to be collected forseed set (non-invasive monitoring).6. Equipment InspectionView transplanting, lifting, handlingAudit applicant's procedures for cleaningandAnnual audits required. Applicant must submit a planequipment and storage site facilities.inspection of field, harvesting, handling, andor checklist for cleaning harvesting, handling andstorage equipment. Inspection agency reservesstorage areas. QA rhizomes to be identified and storedright for unannounced spot check inspections.separately from non-field inspected rhizomes.7. Non-Invasive Species Validation Head sample collection.Field inspector to collect ten heads perand seed lab examinations.clone for seed lab microscopic analysis forAnnual lab examination of head samples at post floweringpresence of any seed set.stage.8. Applicant's file records.Applicants are required to maintain records NotifiedInspection agency shall have the optional right to Applicant must show due diligence in maintainingof all planting, harvesting, labeling and salesrequire applicant to provide such recordsfor auditing traceability for all QA records.for all QA rhizome production.purposes.9. Program Standard Compliance A. No process deficiencies.Program standards metField(s)/site passed.(check only one)B. Minor process inadequacies reported.Re-inspection of sites following applicant'sPending re-inspection.remedy of situation.C. Field Rejection.QA standard(s) not met (specify).Reject production field or portion of field area. ReportQA logo and labels prohibited from use on rejected problem on field inspection report or affidavit.production.Results:10. QA label use approved forOSIA Quality Assurance (QA)Quality Assurance standards for thisOptional use or QA label for plant material lot and batchestags, certificates or literature.custom program compliance achieved.Miscanthus Giganteus propagule production was passing program standards. Third party inspectionproduced in compliance with OSIA QAagency completes one program cycle by performingprogram minimum guidelines for geneticsystem validation, by providing QA services, bypurity, field history, isolation, customdetermining product conformity and by communicatinginspection criteria and product traceability.product availability.Signature:_________________________________Date: _____________F:\EA\FINAL EA Docs\Copy of QAPROGRAM-edits