Page 1 of 41

FINDING OF NO SIGNIFICANT IMPACT

Organic Market Development Grant Program

January 17, 2024

On behalf of the United States Department of Agriculture (USDA), Agricultural Marketing Service 

(AMS) and Environmental Activities Division of the Farm Production and Conservation (FPAC) 

Business Center, and in compliance with the National Environmental Policy Act (NEPA), a 

Programmatic Environmental Assessment (PEA) was prepared to evaluate the environmental 

consequences anticipated to result from implementing the Organic Market Development Grant 

(OMDG) Program. The OMDG Program is authorized by Section 5(e) of the Commodity Credit 

Corporation (CCC) Charter Act, which funds the development of new and expanded organic markets 

by providing additional resources for operations transitioning to organic or establishing new organic 

production and processing capacity. 

The USDA AMS has proposed to fund projects that increase domestic organic supply chain 

capacities, facilitate market development for domestically produced organic food products, expand 

volume for processing and distribution of products to create more or better markets, and 

demonstrate clear benefits to organic communities and regions or historically underserved entities. 

Since the OMDG Program is a national program, the geographic scope of this PEA covers the entire

United States. Given the broad nature of the program, the Environmental Assessment (EA) is 

programmatic (PEA) and is intended to provide full NEPA coverage for activities clearly within the 

scope of the PEA. This PEA also serves as the basis for tiered, site-specific NEPA analysis, when 

additional documentation is required, that will occur prior to implementation of activities with 

possible resource impacts. The PEA was available for public review and comment from November 

20th, 2023 through December 20th, 2023, and was announced through a Notice of Availability 

published in The Federal Register (Vol 88 No 222). No comments were received during the 

designated timeframe, and as such, no substantial changes were made to the document. 

The Notice of Availability of the final PEA and signed FONSI will be published in the Federal Register 

and will be available for public viewing following the announcement at: 

https://www.ams.usda.gov/services/grants/omdg for a period of 30 calendar days.

Proposed Action

The Proposed Action Alternative will implement the OMDG Program as outlined in the RFA issued 

on May 10, 2023. AMS will grant approximately $75 million to eligible applicants seeking support 

for market development and promotion activities, processing capacity expansion projects, and 

simplified equipment only projects. Eligible applicants for Organic Market Development grants include 

business entities (regardless of legal structure) who produce or handle organic foods. Producer and 
Page 2 of 41

handler applicants must either be certified to the USDA organic standards or in transition to organic 

certification. Eligible applicants also include non-profit or government entities. Eligible government 

entities include but are not limited to tribal, state, territory, and local government entities such as 

economic development authorities and regional conservation districts. Eligible non-profit entities may 

include trade associations. All applicants must be domestic entities owned, operated, and located within 

the 50 United States, the District of Columbia, the Commonwealth of Puerto Rico, the United States 

Virgin Islands, Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands, or 

Tribal Governments.

Reasons for Finding of No Significant Impact

Programmatic environmental documents analyze impacts on a broad scale, in this case the 

introduction of a new program that will result in subsequent specific actions. Because of the large 

geographic scope and the innovative nature of the OMDG Program, it is not possible to 

meaningfully predict the location of the site-specific access and improvement activities, nor the 

environmental conditions that exist on those lands. Thus, before implementing projects with 

possible protected resource impacts, a site-specific environmental review will be completed to 

demonstrate that actions are within the scope of the PEA and do not have impacts not already 

analyzed.

In consideration of the analysis documented in the PEA and the reasons outlined in this FONSI, the 

Proposed Action would not constitute a major Federal action that would significantly affect the 

human environment; therefore, an Environmental Impact Statement (EIS) will not be prepared. The 

determination is based on the following:

1. All potential beneficial and adverse impacts of implementing the Proposed Action have 

been fully considered within the PEA; no significant adverse direct, indirect, or cumulative 

effects were identified based on this analysis.

2. All projects with potential resource impacts will undergo site-specific environmental 

reviews. The analysis will assess these impacts based on the conditions of each site, 

including the following factors: Cultural Resources, Threatened and Endangered Species, 

Coastal Barriers, Coastal Zone Management Act Areas, Wilderness Areas, Wild and Scenic 

Rivers and Nationwide Rivers Inventory, National Natural Landmarks, Sole Source Aquifers, 

Wetlands, Floodplains, Important Land Resources, and Environmental Justice.

3. As detailed in the analysis presented in the PEA, the Proposed Action would not significantly 

affect water quality, soils, wetlands, vegetation or wildlife, air quality, climate change, 

socioeconomics, and environmental justice, or other important resources.

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

that are likely to be highly controversial.

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

effects and does not represent a decision in principle about a future consideration.

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

with other actions that also individually have insignificant impacts.
Page 3 of 41

7. The Proposed Action does not threaten a violation of Federal, state, or local law or 

requirements imposed for the protection of the environment.

8. No comments were received on the Draft PEA and no controversies were identified.

Determination 

In accordance with the NEPA, which implements the regulations of the Council on Environmental Quality 

found at 40 CFR parts 1500-1508, I find the Proposed Action is not a major Federal action significantly 

affecting the quality of the human environment; therefore, no Environmental Impact Statement will be

prepared.

Melissa Bailey

Agricultural Marketing Service

Associate Administrator
Page 4 of 41

U.S. DEPARTMENT OF AGRICULTURE

Agricultural Marketing Service

FINAL PROGRAMMATIC ENVIRONMENTAL ASSESSMENT

Organic Market Development Grant

Prepared by the USDA Business Center Environmental Activities Division and 

USDA Farm Service Agency on behalf of the USDA Agricultural Marketing Service

January 17, 2024

USDA is an equal opportunity provider, employer, and lender.
Page 5 of 41

COVER SHEET

Proposed Action: The U.S. Department of Agriculture (USDA), Agricultural Marketing Service (AMS), is 

evaluating applications for a new, one-time funding opportunity. Applications from certified organic and 

transitioning producers and handlers, as well as non-profit entities, Tribes, certified benefit corporations, 

and state and local governments will be evaluated to receive federal financial assistance from the 

Organic Market Development Grant (OMDG) Program. Available funding will create new and enhanced 

markets for domestically produced organic products through investments in expanded certified organic 

processing capacity. Organic product improvements will benefit producers via newly created services 

that currently lack markets. These investments are predicted to increase the availability and 

consumption of domestic organic agricultural commodities by supporting expansion of current markets

into innovative supplementary markets, marketing facilities, and uses.

Type of Document: Final Programmatic Environmental Assessment (PEA)

Lead Agency: United States Department of Agriculture (USDA) Agricultural Marketing Service (AMS)

Cooperating Agencies: United States Department of Agriculture (USDA) Farm Service Agency (FSA) and 

United States Department of Agriculture (USDA) Farm Production and Conservation Business Center 

(FPAC BC)

Further Information: Lara Shockey, Natural Resource Specialist

(304) 373-5875

lara.s.shockey@usda.gov 

https://www.ams.usda.gov/services/grants/omdg 

Comments: This PEA was prepared in accordance with National Environmental Policy Act (NEPA) 

implementing procedures found in 40 CFR Part 1500 - 1508, as well as the NEPA of 1970, Public Law 91-

140, 42 US Code 4321-4347, as amended.

AMS accepted public comments for the Draft Programmatic Environmental Assessment from November 

20, 2023, to December 20, 2023. Comments were accepted via email to OMDG@usda.gov. The Notice of 

Availability (NOA) was posted to the Federal Register. 

No comments were received during the public commenting timeframe. 
Page 6 of 41

Contents

1. Purpose of and Need for Action..................................................................................................... 10

1.1 Introduction .................................................................................................................................. 10

1.1.1 Background........................................................................................................................ 10

1.1.2 Program Administration..................................................................................................... 11

1.1.3 Program Activities.............................................................................................................. 11

1.2 NEPA Compliance.......................................................................................................................... 13

1.2.1 Purpose of Using a Programmatic Environmental Assessment.........................................14

1.3 Purpose and Need for the Proposed Action ................................................................................. 15

1.3.1 Purpose of the Action........................................................................................................ 15

1.3.2 The Need............................................................................................................................ 15

1.4 Decision To Be Made..................................................................................................................... 16

1.5 Regulatory Compliance................................................................................................................. 16

1.6 Public Involvement and Consultation ........................................................................................... 17

2. Description of Proposed Action and Alternatives........................................................................... 17

2.1 Alternative A - No Action Alternative ........................................................................................... 17

2.2 Alternative B – Proposed Action Alternative (Preferred).............................................................. 18

3. Affected Environment and Environmental Impacts........................................................................ 18

3.1 Resources Eliminated from Detailed Analysis............................................................................... 19

3.2 Resources Considered with Detailed Analysis .............................................................................. 21

3.2.1 Cultural Resources............................................................................................................. 21

3.2.2 Climate Change.................................................................................................................. 23

4. Cumulative Impacts....................................................................................................................... 25

4.1 Definition ...................................................................................................................................... 25

4.2 Past, Present, and Reasonably Foreseeable Actions..................................................................... 25

4.3 Cumulative Impacts of the Proposed Action ................................................................................ 25

4.4 Irreversible and Irretrievable Commitment of Resources ............................................................ 25

5. Compliance with Environmental Laws and Regulations.................................................................. 26

5.1 Clean Water Act ............................................................................................................................ 26

5.2 Coastal Zone Management Act (CZMA)........................................................................................ 27

5.3 Coastal Barrier Resources Act (CBRA)........................................................................................... 27

5.4 Endangered Species Act (ESA) ...................................................................................................... 28
Page 7 of 41

5.5 Farmland Protection Policy Act (FPPA).......................................................................................... 28

5.6 Migratory Bird Treaty Act (MBTA)................................................................................................. 28

5.7 National Historic Preservation Act (NHPA) ................................................................................... 29

5.8 Wild and Scenic Rivers Act (WSRA)............................................................................................... 29

5.9 Wilderness Act.............................................................................................................................. 29

5.10 Executive Order 11990: Protection of Wetlands ........................................................................ 30

5.11 Executive Order 11998: Floodplain Management...................................................................... 30

5.12 Executive Order 12898: Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations..................................................................................... 30

6. Implementation ............................................................................................................................ 31

6.1 Process for Screening Site-Specific Projects ................................................................................. 31

6.1.1 NEPA Screening Flowchart................................................................................................. 33

7. List of Preparers and Reviewers and Agencies Contacted............................................................... 34

References......................................................................................................................................... 35

Appendix ........................................................................................................................................... 37
Page 8 of 41

ACRONYMS AND ABBREVIATIONS

ACHP Advisory Council on Historic Preservation

AMS Agricultural Marketing Service 

BABA Build America, Buy America Act

BMPs Best Management Practices

CAFO Concentrated Animal Feeding Operation

CBRA Coastal Barrier Resource Act

CBRS Coastal Barrier Resource System

CCC Commodity Credit Corporation

CE Categorical Exclusion

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

CWA Clean Water Act

CZMA Coastal Zone Management Act

EA Environmental Assessment

EIS Environmental Impact Statement

EO Executive Order

EPA Environmental Protection Agency

ESA Endangered Species Act

FONSI Finding of No Significant Impact

FPPA Farmland Protection Policy Act

FWS United States Fish and Wildlife Service

GHG Green House Gases

MBTA Migratory Bird Treaty Act

NEPA National Environmental Policy Act

NHPA National Historic Preservation Act

NMFS National Marine Fisheries Service 

NOAA National Oceanic and Atmospheric Administration

NPDES National Pollutant Discharge Elimination System

NRCS Natural Resources Conservation Service

OMDG Organic Market Development Grant 
Page 9 of 41

PEA Programmatic Environmental Assessment

RFA Request for Applications

ROD Record of Decision

SHPO State Historic Preservation Officer

THPO Tribal Historical Preservation Officer

USDA United States Department of Agriculture

USACE United States Army Corps of Engineers

WOTUS Waters of the United States

WSRA Wild and Scenic Rivers Act
Page 10 of 41

1. Purpose of and Need for Action

1.1 Introduction 

The Agricultural Marketing Service (AMS) is an agency within the U.S. Department of Agriculture (USDA). 

AMS’ mission is to administer programs that create domestic and international marketing opportunities 

for U.S. producers of food, fiber, and specialty crops. AMS also provides the agriculture industry with 

valuable services to ensure the quality and availability of wholesome food for consumers across the 

country and around the world. The AMS Transportation and Marketing Program currently oversees 20 

grant and agreement programs, providing Federal financial assistance to support rural America and the 

Nation’s agricultural sector. 

This document is a programmatic environmental assessment (PEA) for the Organic Market Development 

Grant (OMDG) Program, a new program administered by AMS. Requested grant funding will be allocated 

to applications from certified organic and transitioning producers and handlers, non-profit entities, tribal 

entities, certified benefit corporations, in addition to state, tribal, and local governments. 

This PEA was prepared to streamline the overall OMDG NEPA review process. AMS anticipates using this 

PEA to guide decision-making for site-specific project actions, which may occur from the time grants are 

awarded in fiscal year (FY) 2023 to the completion of grant activities in FY 2026. Each proposed grant 

agreement, and any associated site-specific actions, will be further evaluated to determine if its potential 

environmental impacts have been addressed in this PEA. Site specific evaluations will be conducted by 

AMS staff as outlined in Chapter 6 under the Description of the Proposed Action. 

1.1.1 Background

The Organic Market Development Grant (OMDG) program is authorized by Section 5(e) of the 

Commodity Credit Corporation (CCC) Charter Act, (15 U.S.C. 714(e)). 

Section 5(e), as amended, authorizes USDA (through the CCC) to “increase the domestic consumption of 

agricultural commodities (other than tobacco) by expanding or aiding in the expansion of domestic 

markets or by developing or aiding in the development of new and additional markets, marketing 

facilities, and uses for such commodities.” Through the funds provided by Section 5(e), as amended, 

USDA will support the development of new and expanded organic markets by providing additional 

resources for businesses transitioning to organic or initiating new organic production and processing 

capacity. 

These grants will create new and improved markets for domestically produced organic products through 

investments in expanded certified organic processing capacity; activities that develop, maintain, or 

expand commercial organic markets; and organic product developments which create new uses for 

producers that currently lack markets, such as rotational grains. These investments are anticipated to 

increase the consumption of domestic organic agricultural commodities by expanding or aiding in the 

expansion of markets or by developing or aiding in the development of new and additional markets, 

marketing facilities, and uses for such commodities.
Page 11 of 41

Organic production and markets are critical to expanding and diversifying food systems. Consumer 

demand for organically produced goods surpassed $63 billion in 2021, and multi-year trends of strong 

growth in the sector provide market incentives for U.S. farmers across a broad range of products. 

Organic sales account for over four percent of total U.S. food sales and organic products are now 

available in about 20,000 natural food stores and nearly three out of four conventional grocery stores.

Selected applicants for the OMDG program may invest in certified organic infrastructure and expand 

processing capacities, in addition to adding manufacturing, storing, transporting, wholesaling, or 

distribution infrastructure. Funded activities will include developing new markets to increase demand for 

domestically produced organic agricultural products and providing additional market networks. 

1.1.2 Program Administration

OMDG will be administered by the U.S. Department of Agriculture (USDA) Agricultural Marking Service

(AMS). AMS published a Request for Applications (RFA) for project proposals accepted from May 10, 

2023, through August 8, 2023. Project proposals were invited under three project types: 

• Market Development and Promotion: Supports the development or expansion of new or 

existing organic markets to create access between organic producers, handlers, and consumers. 

• Processing Capacity Expansion: Supports the infrastructure to improve organic agriculture 

production, processing capacity, and to explore emerging technologies to help keep up with the 

demand for organic products. 

• Simplified Equipment-Only Projects: Funds equipment purchases only for projects up to

$100,000. These projects are designed to assist with immediate improvements to equipment 

applications for the operation. These funds will not be used for facility upgrades, additional staff, 

or other non-equipment costs. 

This program focuses on investments to aid the expansion of new and additional markets for U.S. organic 

commodities, opening markets for producers, and addressing inadequate capacity in certified organic 

processing, storage, handling, and shipping. Capacity in the middle of the organic supply chain has not 

kept pace with the growth in organic farming nor the demand for organic products, thus limiting market 

access to transform domestic organic crops into organic feed grains or consumer products. Expanded 

processing capacity will increase consumption of domestic organic commodities. AMS will review and 

evaluate each application that meets qualification standards and will rank proposals using competitive 

scores based on the criteria outlined in the Request for Applications. 

1.1.3 Program Activities

Market Development and Promotion 

Market development is a business growth strategy that focuses on introducing an existing product into 

newly available markets and developing new opportunities to sell their products in an unexplored sector. 

Market development and promotion is a business strategy that can result in revenue increase and 

expansion into more customer areas. OMDG supports operations through grants that will create new 

and improved markets for domestically produced organic products through investments in expanded 
Page 12 of 41

certified organic processing capacity; activities that develop, maintain, or expand commercial organic 

markets; and organic product developments that create new uses for producers currently lacking in 

certain markets, such as rotational grains. These investments are anticipated to increase the 

consumption of domestic organic agricultural commodities by expanding or aiding in the expansion of 

markets or by developing or aiding in the development of new and additional markets, marketing 

facilities, and uses for such commodities. In addition, activities occurring under the Market 

Development and Promotion category will be supported by OMDG by improving access among organic 

producers, handlers, and consumers. 

For example, an organic grain cooperative may seek funds to convene conferences that connect growers 

to processors and buyers, as well as paying for travel and booth space at trade shows to open new 

markets.

Activities funded under this category include, but are not limited to:

• Product development activities that create uses for organic commodities currently lacking

markets, such as rotational row crops.

• Producer and consumer education that creates or increases demand for new or existing organic 

product categories domestically or abroad.

• Creating or strengthening farm-to-institution market channels, farm to local retail, or other 

markets that build local and regional food system opportunities in organic agriculture.

• Exploring and promoting domestic and international opportunities for organically grown and 

processed agricultural commodities.

• Developing marketing strategies for organic producers to help strengthen new or emerging 

markets.

Expanding organic marketing opportunities through OMDG can increase business opportunities for 

organic operations while encouraging climate smart production practices. OMDG supports developing 

markets to increase sales, customer retention, and product awareness and reaches the target consumer 

audience. Activities occurring under Market Development and Promotion are not likely to have a direct 

impact on the human environment as they will largely be for promotional, educational, or research

purposes. 

Processing Capacity Expansion

The Processing Capacity Expansion funding will support infrastructure to improve organic agriculture 

production and processing capacity and explore emerging technologies to keep up with the demand for 

organic products. For example, a small pizza crust manufacturer may propose to purchase new 

equipment dedicated to organic products, thus increasing its processing capacity. These projects may

include costs associated with moving an interior wall to accommodate the machinery as well as related 

electrical upgrades to power the new equipment.
Page 13 of 41

Activities funded under this category include, but are not limited to: 

• Purchasing and installing equipment needed to support: 

o On-farm or cooperatively owned processing facilities that help agricultural producers 

add value to their products by generating new or enhanced products.

o New or expanded aggregation, processing, storage, marketing, and distribution 

mechanisms to create a path to markets for producers.

• Expanding processing capacities in existing facilities that increase organic production volume, 

process additional commodities, create parallel production needed to segregate organic 

production lines, and add new value-added products. 

• Supporting on-farm or cooperatively owned processing so multiple agricultural producers can 

add value to their products at the farm level to generate new products and increase producer 

income, including the purchase and installation of equipment. 

OMDG investments in organic infrastructure (e.g., expanding capacity for processing,manufacturing, 

storing, transporting, and wholesaling) will enhance the development of new markets. Grants will allow 

producers to increase production and improve existing facilities to meet the current and future demand 

for domestically produced organic agricultural products. Domestic organic producers and handlers have 

expressed through public comments and listening sessions that there is a critical need to develop new 

and expanded organic infrastructure to increase profitability. 

Activities occurring with Processing Capacity Expansion funding will assist existing processing facilities to 

increase capacity and process multiple commodities that are critical for the long-term success of organic 

markets at large. Activities funded under this category may result in interior renovations of existing 

structures and therefore will be analyzed on a case-by-case basis for potential environmental impacts. 

Simplified Equipment-Only Projects

Simplified Equipment-Only Projects will fund equipment-only grants up to $100,000. These grants only 

fund equipment purchases and not associated facility upgrades, staffing, or other costs. 

For example, a cooperative of alfalfa growers propose to purchase and install pellet mills that will make

their product more transportable, open new markets, and increase demand for organic alfalfa. There will 

not be alteration or renovation costs. 

These actions are expected to have negligible, if any, environmental impacts. The proposed equipment 

will be analyzed on a case-by-case basis to evaluate potential for water, air, or other environmental 

factors. 

1.2 NEPA Compliance

The National Environmental Policy Act (NEPA), as amended (42 U.S.C. §§ 4321, et seq.), was enacted in 

1970 to establish a national policy for the protection of the environment. It applies to Federal agency 

actions that have the potential to affect the quality of the human environment. It requires Federal 

agencies to conduct a review considering potential environmental impacts through a systematic and 

interdisciplinary approach, including consideration of the natural and social sciences in planning, 

evaluation, and decision-making. Federal agencies are obligated to comply with NEPA regulations 
Page 14 of 41

coordinated by the White House Council on Environmental Quality (CEQ) (40 C.F.R. Parts 1500-1508). 

These regulations outline the responsibilities of Federal agencies under NEPA and provide specific 

procedures for preparing environmental documentation to comply with NEPA. 

If the action is subject to NEPA review, then the environmental impacts must be documented at one of 

three levels of NEPA analysis:

1) Preparing a site-specific environmental review form to document that the activity qualifies for a 

categorical exclusion (CE); (AMS does not have a NEPA implementing regulation with CEs)

2) Preparing an environmental assessment (EA), and, if appropriate, a Finding of No Significant 

Impact (FONSI); or

3) Preparing an environmental impact statement (EIS) and Record of Decision (ROD).

1.2.1 Purpose of Using a Programmatic Environmental Assessment

Generally, Federal agencies prepare an environmental assessment (EA) to determine whether an action 

would have a significant effect on the quality of the human environment (40 C.F.R. 1508.27). One of the 

overall goals is to provide decision-makers and the public with information about the potential for 

impacts due to AMS’s proposed action before a final decision is made. Once this process is final, AMS has 

completed the necessary analysis to determine any effects may be significant. If there is potential for 

significant impacts, then an Environmental Impact Statement (EIS) is prepared. If the impacts are not 

expected to be significant, a Finding of No Significant Impact (FONSI) is prepared.

A programmatic environmental assessment (PEA) is necessary because AMS does not have a NEPA 

regulation with categorical exclusions, and the PEA would cover a higher, national programmatic level of 

NEPA compliance. PEAs are broad in scope and should address related actions or projects, an entire 

program, a broad action, or Federal financial assistance supported activities. A PEA is intended to 

accomplish NEPA compliance by: 

1. summarizing the current environmental situation;

2. describing the purpose and need for the activities;

3. identifying alternative actions; and

4. assessing the potential environmental impacts of all alternatives.

Before a federal agency implements policies, programs, plans, and projects, NEPA requires documented, 

formal consideration of major Federal actions and analyses of potential impacts associated with 

alternatives to the action. A PEA allows AMS to reduce paperwork and to streamline site-specific or 

project level NEPA reviews to the extent an assessment of potential impacts have already been 

addressed in the PEA. Programmatic environmental assessments and the use of tiering can reduce or 

eliminate redundant and duplicative efforts and effectively address cumulative effects. In this case, a PEA 

may be used to address the impacts of actions, or project types that are similar in nature or broad in 

scope, including cases where cumulative impacts are of concern. For consideration of potential impacts 

from specific actions and/or individual projects, tiering allows an agency to rely largely on the analysis of 

the programmatic NEPA document to address the impacts (Canter, 1996). 
Page 15 of 41

If the project type or impacts are not adequately covered in this PEA, the proposed project would 

require additional NEPA review. Depending on the degree of the project’s potential impacts, this review 

could involve the preparation of a site-specific review documenting the applicability of this PEA, a 

supplemental EA tiered from this PEA, a new EA, or an EIS. This PEA addresses NEPA compliance at the 

program level. Evaluation of project-specific impacts would be addressed during the planning and 

selection process for each project to ensure that any significant environmental issues are identified; that 

consultation among agencies, other area programs, and the public occurs; and that a decision may be 

made on whether further analysis and documentation is necessary. This process is further documented 

in the Implementation chapter below (see Chapter 6). 

1.3 Purpose and Need for the Proposed Action

1.3.1 Purpose of the Action

The purpose of OMDG is to support the development of new and expanded organic markets by 

providing additional resources for businesses transitioning to organic or initiating new organic 

production and processing capacity. These investments are anticipated to increase demand for 

domestically produced organic agricultural products and provide additional market paths. 

1.3.2 The Need

Stakeholders have conveyed through past public comments and listening sessions that producers may be 

less willing to commit to the three-year transition required for organic certification because of risks 

related to inadequate organic processing, storage, handling capacity, cost barriers due to limited markets 

for rotational crops, a lack of certainty about market access, and insufficient supply of certain organic 

ingredients. The organic livestock and processed product markets depend heavily on imported 

agricultural products for feed grains and key ingredients. These longstanding market issues facing organic 

livestock feedstocks, rotational crops, dairy, fiber, and ingredients were brought into sharp focus since

the impacts of COVID and international conflicts in critical overseas organic supply areas, resulting in 

limitations on certain organic products in the face of rising demand. 

Further, existing organic producers lack market access because of bottlenecks in certified organic

processing, storage, specialized equipment, and handling/shipping that have not kept up with the

growth in organic crops or the demand for organic products. Producers of organic commodities often

lack the resources or capacity to build processing infrastructure, which is also outside the business

model for end-use consumer food manufacturers or animal feed buyers. Certain regions also lack

certified organic processing capacity, so the local and regional organic producers must either pay

increased shipping costs or sacrifice organic price premiums by processing their commodities at 

nonorganic facilities, which removes the ability to sell the product as “organic” to the consumer. These

middle-of-the-supply-chain bottlenecks limit markets for raw organic commodities and cause some

producers to sell organic commodities at conventional prices, missing premium prices for organic animal

feed and processed consumer products.

Based on this input, USDA identified an opportunity to provide financial assistance to eligible applicants 

who propose projects that will enhance the competitiveness of domestic organic products in domestic 

and international markets. This program will also support the development of infrastructure and supply 
Page 16 of 41

chains that are necessary for increasing the availability and quality of organic products. By doing so, 

implementation of the Proposed Action is intended to align with numerous policy goals and objectives 

across government, including, but not limited to:

• Ensure equitable access to USDA programs and benefits from USDA-funded projects and support

the policies of Executive Order 13985 (Executive Order on Advancing Racial Equity and Support

for Underserved Communities Through the Federal Government).

• Contribute to the resilience of the food and agricultural supply chains through support for

diversified, value-added agriculture such as organic production and support the policies of

Executive Order 14017 (Executive Order on America’s Supply Chains).

• Promote competition in the organic sector and support the policies of Executive Order 14036

(Promoting Competition in the American Economy). 

• Implement the Build America, Buy America (BABA) Act. Guidance on BABA requirements for 

USDA award recipients is available at USDA’s Implementation of BABA Act. 

1.4 Decision To Be Made

AMS must decide if the proposed action affects the quality of the human environment. If AMS

determines it would not significantly affect the quality of the human environment, then a Finding of No 

Significant Impact (FONSI) will be prepared and signed. Grants entered under OMDG will be analyzed 

individually to determine the need for subsequent environmental reviews. 

1.5 Regulatory Compliance

This PEA has been prepared to satisfy the requirements of the National Environmental Policy Act (NEPA) 

(Public Law 91-190, 42 United States Code 4321 et seq.) and Whitehouse Council on Environmental 

Quality (CEQ) Regulations for Implementing the Procedural Provisions of the National Environmental 

Policy Act (40 Code of Federal Regulations [CFR] §§ 1500–1508). 

The intent of NEPA is to protect, restore, and enhance the human environment through well-informed 

Federal decisions. The following non-exclusive list of higher-tier Executive Orders (EOs), acts, and 

relevant decision and guidance documents apply to actions undertaken by Federal agencies and form 

the basis of the analysis presented in this PEA:

• Clean Air Act (42 USC 85 parts 7401 et seq., 1999)

• Clean Water Act (33 USC 26 parts 1251 et seq., 2000)

• Endangered Species Act [ESA] of 1973, as amended (16 USC 35 parts 1531 et seq., 1988)

• EO 11514, Protection and Enhancement of Environmental Quality (35 Federal Register [FR] 4247, 

1977)

• EO 12898, Federal Actions to Address Environmental Justice in Minority Populations and LowIncome Populations (59 FR 32, 1995)

• National Historic Preservation Act (54 USC 300101 et seq., 2014) and associated Section 106 

process (54 USC 306108, 2014)
Page 17 of 41

1.6 Public Involvement and Consultation

Scoping is an early and open process to involve agencies, organizations, and the public to determine the 

issues to be addressed in the environmental document. Among other tasks, scoping determines 

important issues and eliminates issues determined not to be important; identifies other permits, surveys 

and consultations required with other agencies; and creates a schedule that allows adequate time to 

prepare and distribute the environmental document for public review and comment before a final 

decision is made. Scoping is a process that seeks opinions and consultation from the interested public, 

affected parties, and any agency with interests or legal jurisdiction.

This document was made available for public review and comment on November 20, 2023, on the 

https://www.ams.usda.gov/services/grants/omdg webpage. An additional notification of availability to 

comment was published in the Federal Register on November 20, 2023 (88 FR 80687). 

This PEA assesses the potential impacts of the Proposed Action and the No Action Alternative on 

potentially affected environmental and economic resources.

• Chapter 1 provides background information, defines the Purpose and Need for the Proposed 

Action, and identifies the scoping process for this PEA.

• Chapter 2 defines the two alternatives, the No Action, and the Proposed Action, as well as those 

alternatives considered but not fully evaluated.

• Chapter 3 includes the Affected Environment (i.e., existing conditions) and defines the 

Environmental Consequences (i.e., direct, indirect, and cumulative impacts) anticipated to result 

from the implementation of each alternative.

• Chapter 4 describes the cumulative impacts of the action. 

• Chapter 5 describes federal environmental laws and regulations that are likely to apply to 

proposed projects, as well as a description of compliance by the OMDG. 

• Chapter 6 outlines how the OMDG would use this PEA for site-specific actions.

• Chapter 7 provides the list of individuals and agencies who collaborated to complete the PEA.

• Chapter 8 includes the references utilized in this PEA’s preparation.

2. Description of Proposed Action and Alternatives

Two alternatives are evaluated in this PEA: The No Action Alternative (not preferred), and the Proposed 

Action Alternative (preferred). No potentially significant impacts to important resources were identified 

during scoping. Decisions about whether individual projects are technically and economically feasible, 

meet the OMDG objectives, and resolve producer needs are being considered as a part of the panel 

review. Further site-specific NEPA documentation will be developed as site-specific projects are 

considered for grant awards. 

2.1 Alternative A - No Action Alternative

Under the No Action Alternative, AMS will not undertake or fund grants for the purpose of expanding 

organic market opportunities or processing capacities. Barriers to market, inadequate organic processing 

capacity, and a lack of certainty about market access would continue. This alternative would result in the 

continuation of the longstanding issues facing organic livestock feedstocks, rotational crops, dairy, fiber, 
Page 18 of 41

and ingredients, where stakeholders have conveyed that producers may be less willing to commit to the 

three-year transition to organic certification because of these risks. 

The No Action Alternative will not meet the purpose and need of the proposed action, which is to 

support the development of new and expanded organic markets. Therefore, this alternative is not 

preferred by AMS and will only be used as a baseline for comparison with the Preferred Alternative.

2.2 Alternative B – Proposed Action Alternative (Preferred) 

AMS’ Preferred Alternative is to undertake activities by awarding funds on a competitive basis to 

applicants to address one or more of the following categories described in more detail in Chapter 1.1:

1. Market Development and Promotion,

2. Processing Capacity Expansion, and

3. Simplified Equipment-Only Projects.

Under this alternative, several activities can be implemented under one project proposal. For example, a 

project to improve market accessibility issues in a region may include the remodel of an existing facility 

to accommodate additional processing equipment, thus increasing production volume. The three

categories are complementary by nature, and the Preferred Action Alternative will allow different 

operations to carry out its business endeavors under each category. By supporting multiple operations

from versatile sectors of organic products, the Preferred Alternative promotes the creation of new and 

better markets by funding activities that are currently not eligible for federal financial assistance through 

USDA. 

3. Affected Environment and Environmental Impacts

This chapter describes the existing environmental conditions for resources potentially affected by the 

implementation of OMDG, as well as the environmental consequences of implementation. 

As a programmatic EA, it evaluates the effects of implementing changes to a nationwide voluntary 

program. Therefore, the utility and availability of modeling and quantitative analysis is limited. The 

potential impacts of implementing the program changes are discussed on a national or regional level, as 

appropriate. Site-specific environmental reviews will occur prior to the implementation of on-the-ground 

activities, such as renovations needed for processing capacity expansion activities. This PEA and the sitespecific environmental reviews provide the full NEPA coverage for activities under OMDG. 

In compliance with NEPA, CEQ regulations, and USDA procedures for implementing NEPA, the 

description of the affected environment focuses on only those resources potentially subject to impacts 

and the level of analysis is commensurate with the anticipated level of impact. Based on the NEPA 

implementing regulations (40 CFR Part 1500), the discussion of the affected environment and associated 

environmental impact analysis presented here focuses on Cultural Resources, Climate, Socioeconomics 

and Environmental Justice, and Water Quality.
Page 19 of 41

3.1 Resources Eliminated from Detailed Analysis

NEPA regulations (40 CFR 1501.7(a)(3)) state that the lead agency should identify and eliminate from 

detailed study the issues that do not have the potential to affect the human environment or that have 

been covered by prior environmental review, thus narrowing the discussion of these issues to a brief 

discussion of why they would not have a significant effect on the human or natural environment. 

The environmental evaluation process for OMDG will involve the completion of a site-specific review for 

activities that will have direct on-the-ground impacts to legally protected resources, as further discussed 

in Chapter 6. This evaluation process includes collecting and documenting the data, consultation and 

permitting needed for AMS to ensure compliance with NEPA and other related laws, regulations, and 

EOs. 

A site-specific environmental review requires that AMS supported activities are evaluated for the 

potential presence of or proximity to threatened and endangered species, wetlands, floodplains, coastal 

zones, wilderness areas, etc. that can only be evaluated once project locations are known. Because

proposals received in response to OMDG did not include specific project locations, exact location for 

processing capacity expansion activities will be available for further site-specific analysis following an 

assessment of submitted applications. 

All processing capacity expansion activities undertaken by OMDG will require a site-specific 

environmental review that will be conducted prior to approval of any site-specific modifications or 

renovation activities. Once selected applicants have identified those specific locations that have been 

determined to meet eligibility requirements of OMDG specifications, necessary site-specific 

environmental reviews will occur. 

As such, the following resource areas have been eliminated from detailed analysis in this PEA: Vegetation

and Wildlife, Coastal Barriers, Coastal Zone Management Areas, Wild and Scenic Rivers and Nationwide 

Rivers Inventory, Wilderness Areas, National Natural Landmarks, Floodplains and Wetlands, and Soils and 

Other Important Resources.

Water Quality. This PEA does not address specific locations where activities under OMDG will occur; 

therefore, impacts to water quality as a result of processing capacity expansion activities are not 

analyzed here. Market development and promotion and simplified equipment-only project activities 

under OMDG are not anticipated to result in any impacts to water quality, as all activities under these 

categories will be performed without permanent alterations to the watershed and will not result in any 

indirect stormwater runoff as these activities will not involve construction. The site-specific review 

process for OMDG activities that may impact Waters of the U.S., or may result in stormwater pollution, is 

discussed in further detail in Section 5.1.

Vegetation and Wildlife. This PEA does not address specific locations where activities under OMDG will 

occur; therefore, impacts to vegetation and wildlife as a result of processing capacity expansion activities

are not analyzed here. Market development and promotion and simplified equipment-only project 

activities under OMDG are not anticipated to result in any impacts to vegetation and wildlife, as all 

activities under these categories will be performed without permanent alterations to the environment or 

potential habitat for at-risk species. The site-specific review process for OMDG activities that may impact 
Page 20 of 41

species, or their critical habitat (processing capacity expansion) listed under the Endangered Species Act,

or the Migratory Bird Treaty Act is discussed in further detail in Section 5.4 and 5.6, respectively.

Wild and Scenic Rivers and Nationwide Rivers Inventory. This PEA does not address specific locations 

where activities under OMDG will occur; therefore, impacts to designated Wild and Scenic Rivers or 

rivers listed in the Nationwide Rivers Inventory as a result of processing capacity expansion activities are 

not analyzed here. Market development and promotion and simplified equipment-only project activities 

under OMDG are not anticipated result in any impacts to Wild and Scenic Rivers or rivers listed in the

Nationwide Rivers Inventory, as all activities under these categories will not result in permanent 

structures or other development that would impact the integrity of these rivers. The site-specific review 

process for OMDG activities that may impact designated Wild and Scenic Rivers or rivers listed in the 

Nationwide Rivers Inventory (processing capacity expansion) listed under the Wild and Scenic Rivers Act 

is discussed in further detail in Section 5.8.

Wilderness Areas and National Natural Landmarks. This PEA does not address specific locations where 

under OMDG will occur; therefore, impacts to designated Wilderness Areas and National Natural 

Landmarks as a result of processing capacity expansion activities are not analyzed here. Market 

development and promotion and simplified equipment-only project activities under OMDG are not 

anticipated result in any impacts to National Natural Landmarks, Federal Wilderness, Wilderness Study 

Areas, National or State Parks, or Federal or State Wildlife Refuges. The site-specific review process for 

OMDG activities that may encroach on designated wilderness areas or national natural landmarks 

(processing capacity expansion) listed under the Wilderness Act is discussed in further detail in Section 

5.9.

Floodplains and Wetlands. This PEA does not address specific locations where activities under OMDG 

will occur; therefore, impacts to floodplains and wetlands as a result of processing capacity expansion 

activities are not analyzed here. Market development and promotion and simplified equipment-only 

project activities under OMDG are not anticipated result in any impacts to floodplains or wetlands, as all 

activities under these categories will not involve construction and therefore will not have the potential to 

adversely impact or otherwise degrade the floodplain or wetlands. The site-specific review process for 

OMDG activities that may impact floodplains (processing capacity expansion) protected under Executive 

Order 11998 or wetlands protected under Executive Order 11990 is discussed in further detail in Section 

5.11 and Section 5.10, respectively.

Soils and Other Important Resources. This PEA does not address specific locations where activities 

under OMDG will occur; therefore, impacts to soils and other important resources as a result of 

processing capacity expansion activities are not analyzed here. Market development and promotion and 

simplified equipment-only project activities under OMDG are not anticipated result in any impacts to 

soils or other important resources as all activities under these categories will not involve construction 

and therefore will not have the potential to adversely impact or otherwise degrade the landscapes’

current structure. The site-specific review process for OMDG activities that may impact soils and other 

important resources (processing capacity expansion) protected Farmland Protection Policy Act (FPPA) is

discussed in further detail in Section 5.12.
Page 21 of 41

Coastal Barriers and Coastal Zones. All processing capacity expansion activities undertaken by OMDG 

will not involve the construction of any new facilities or increase the footprint of existing facilities. 

Therefore, increased development within coastal areas will not occur. Market development and 

promotion and simplified equipment-only project activities under OMDG are not anticipated to result in 

any impacts in a coastal barrier or coastal zone system as each of these items will not result in new 

permanent structures or other development that obstructs the ecological services provided by coastal 

ecosystems. Therefore, potential adverse impacts to coastal barriers and coastal zones will not be 

considered further in this PEA.

Socioeconomics and Environmental Justice. All processing capacity expansion activities undertaken by 

OMDG will not involve the construction of any new facilities. Therefore, impacts of facility renovations or 

visual impacts will occur to any person, regardless of socioeconomic status, within the area. Market 

development and promotion and simplified equipment-only project activities under OMDG are not 

anticipated to result in any impacts to low income or minority populations, as all activities under these 

categories will not involve construction and therefore will not have the potential to disproportionately 

impact any specific population. As USDA will prioritize funding projects which benefit underserved 

communities, the proposed action should maintain or improve the quality of life for low income and/or 

minority communities. Therefore, potential adverse impacts to low income and/or minority populations 

will not be considered further in this PEA.

3.2 Resources Considered with Detailed Analysis

This section describes the environment that would be affected by implementing the changes described 

in Chapter 2. Aspects of the affected environment described in this section focus on the relevant major 

resources or issues. Under the No Action Alternative, the Proposed Action would not be implemented. 

The No Action Alternative would result in the continuation of the current land and resource uses in the 

project area.

3.2.1 Cultural Resources 

Definition of Resource

Cultural Resources are indications of past human activity, often in places greater than 50 years of age. 

These include but are not limited to archaeological sites, districts, cemeteries, structures, and places 

holding historical significance. Cultural resources are distinguished by their unique characteristics such as 

a buildings’ architecture, archaeology, engineering, and community associated values that are attached 

to the object or location. Further, some cultural resources deemed more significant than others are 

classified as historic properties under Section 106 of the National Historic Preservation Act (NHPA) that 

requires all federal agencies to account for possible impacts as a result of their actions. 

Regulations set for federal agencies by the Advisory Council on Historic Preservation (ACHP) requires 

compliance with Section 106 of the NHPA therefore necessitating consultations with State Historic 

Preservation Officers (SHPO) and Tribal Historic Preservation Officers (THPO); these agencies are 

responsible for protecting and make known of historic properties or places withing their respective state 

and areas of interest.
Page 22 of 41

Affected Environment

Historic preservation is defined as the implementation of measures to protect and sustain sites, 

structures, and landscapes via national policies governing historical places. Since 1906 to present day 

Congress has established and expanded its understanding and value of historic resources and supports 

the preservation of these resources for all people of the United States (McMurry 2016). The State 

Historic Preservation Office program and Tribal Historic Preservation Office program each make an 

evaluation on a proposed action to assess its potential eligibility for nomination or listing on the National 

Register of Historic Places (NHPA). Activities sponsored by each program include surveys, public 

education on safeguarding resources, architectural planning, and preservation related activities to keep 

cultural resources protected should the area be considered extraordinary by nature. 

For activities that consist of undertakings that could have the potential to affect historic or cultural 

resources, the Section 106 review process requires that descriptions of the activity and area of impact be 

described for SHPO’s and THPO’s appropriate to each state to review. Increased development pressure in 

recent decades has continued to impact agricultural lands; therefore, farm structures with historical 

significance are increasingly less common.

The opportunity for OMDG’s goals to assist applicants with processing expansion projects includes 

assistance for modifying existing buildings to accommodate new machinery or reconfiguring the existing 

footprint of the building to allow for upgrades. Some of these proposals may include the modification of 

the interior layout or necessary fixtures of a structure greater than 50 years of age. While it is possible 

that these modifications could be completed on a facility exceeding 50 years of age, it is expected that 

the majority of processing capacity expansion activities will not fall under these criteria. Buildings with 

extensive modern modifications or that have little remaining of their original construction will not be 

considered to have retained their historical integrity. 

Environmental Consequences

No Action Alternative

Without the implementation of the OMDG, AMS would not administer funds under the program 

guidelines for the opportunities for market development and promotion, processing capacity expansion, 

or supplement needs for additional equipment-only proposals for organic producers. Without assistance

specifically geared towards processing capacity expansion involving remodeling projects, producers and 

processors may have to keep existing structures or remove structures that have aged and are no longer 

practical to invest in. The no action alternative may result in impacts to cultural resources, as operations 

would make business decisions without cultural resources considerations, whereas such decisions 

resulting from federal grants would require cultural resources considerations. 

Proposed Action Alternative

Under the proposed action alternative, funds made available to applicants seeking assistance with 

prospects for market development and promotion, processing capacity expansion, or supplement needs 

for additional equipment-only proposals for organic producers are anticipated to see successful 

preservation in their facilities. Eligibility for OMDG is limited to the modification of an existing structure 

without resulting in the increase of square footage, changes in the buildings foundation, exterior or load 

bearing walls. These limitations will be beneficial overall when applicants indicate that that structure 
Page 23 of 41

that they intend to make these changes on is greater than 50 years of age or shows some distinguishing 

historical significance. 

The program anticipates no significant adverse effects and positive impacts are predicted to be slightly 

beneficial for cultural resources in the project areas. However, if any unforeseen impacts on cultural 

resources are detected during the implementation of the program activities, a site-specific 

environmental review process will be conducted according to Chapter 6 of the PEA.

3.2.2 Climate Change

Definition of Resource

According to the EPA, “climate change refers to changes in global or regional climate patterns attributed 

largely to human-caused increased levels of atmospheric greenhouse gases. Greenhouse gases, such as 

carbon dioxide, methane, nitrous oxide, and certain synthetic chemicals, trap some of the Earth’s 

outgoing energy, thus retaining heat in the atmosphere.” (EPA, 2023) 

The changes of the earth’s climate can be seen in changing of temperature and precipitation patterns, 

increases in ocean temperatures, sea level and acidity, melting of glaciers and sea ice as well as changes 

in the frequency, intensity, and duration of extreme weather events. 

Climate change involves longer-term trends, such as shifts toward warmer, wetter, or drier conditions. 

These trends can be caused by natural variability in climate over time, as well as human activities that 

add greenhouse gases to the atmosphere like burning fossil fuels for energy” (EPA, 2022). 

Affected Environment

Climate change presents real threats to U.S. agricultural production, forest resources, and rural 

economies. These challenges are complex as agriculture generates 10% of GHG emissions in the U.S. 

(Figure 1) through sources such the operation of internal combustion engines, enteric fermentation by 

livestock, agricultural soil management, manure management, field burning, and other practices. 

Agricultural activities contribute directly to emissions of GHGs including carbon dioxide (CO2), methane 

(CH4), and nitrous oxide (N2O). 
Page 24 of 41

Figure 1. Sources of U.S. Greenhouse Gas Emissions in 2021. 

Agriculture

10%

Commercial & 

Residential

13%

Industry

23%

Transportation

28%

Electric Power

25%

Source: U.S. Environmental Protection Agency (2023).

Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2021

Environmental Consequences

No Action Alternative 

Under the No Action Alternative, USDA would not make funds available under the OMDG program for 

organic agricultural producers to expand their market base and improve production efficiencies. Without 

the AMS OMDG grant program funds, organic operations would have less incentive and capacity to 

adopt best management practices and technologies that can reduce their emissions of greenhouse 

gases, such as carbon dioxide, methane, and nitrous oxide. The continued use of aging equipment can 

result in less efficient operations and contribute to the continued emission of greenhouse gases. 

Ultimately, the No Action Alternative would also miss the opportunity to create positive impacts on 

climate change that could result from implementing the AMS OMDG grant program. 

Proposed Action Alternative

Under the Proposed Action Alternative, USDA will make funds available through the OMDG program and 

increase opportunities for organic operations to develop, customize or install climate-smart equipment 
Page 25 of 41

that reduces greenhouse gas emissions. It is expected that the successful implementation of OMDG 

projects will ultimately result in little to no impacts to overall climate trends but may result in decreased 

emissions from individual operations. Increasing opportunities for organic operations to better establish 

themselves in new markets close to home or increase the capacity existing facilities can improve

efficiency and reduce emissions generated through the transportation of organic products.

The program anticipates no significant adverse effects and positive impacts are predicted to be slightly 

beneficial for climate change beyond those that already occur from the existing organic processing 

operations in the project areas. However, if any unforeseen impacts on climate change are detected 

during the implementation of the program activities, a site-specific environmental review process will be 

conducted according to Chapter 6 of the PEA.

4. Cumulative Impacts

4.1 Definition 

CEQ regulations stipulate that a cumulative effects analysis be conducted to consider the potential 

environmental impacts resulting from “the incremental impacts of the action when added to other past, 

present, and reasonably foreseeable actions regardless of what agency or person undertakes such other 

actions.” Cumulative effects most likely arise when a relationship exists between a proposed action and 

other actions expected to occur in a similar location or during a similar period. An action which overlaps 

with or is in proximity to other proposed actions would be expected to have more potential for a 

cumulative effect on the same resources than actions that are more geographically separated. Similarly, 

actions that coincide, even partially, in time tend to have potential for cumulative effects.

4.2 Past, Present, and Reasonably Foreseeable Actions

The affected environment for this cumulative impact analysis includes renovation of existing structures 

with no additional ground disturbance. 

4.3 Cumulative Impacts of the Proposed Action

The cumulative total of environmental impacts associated with implementation of the OMDG program is

not anticipated to have any cumulative negative impact to the environment, as the activities will 

primarily involve renovations with no new development or construction planned. The OMDG Program is 

likely to have a cumulative positive impact on the environment because of the potential energy 

efficiency upgrades to existing facilities. This program has been given approximately $75 million to 

support a wide range of activities to purchase equipment and upgrade buildings and facilities. 

4.4 Irreversible and Irretrievable Commitment of Resources

NEPA requires that environmental analysis include identification of any irreversible and irretrievable 

commitments of resources which would be involved should an action be implemented. Irreversible and 

irretrievable resource commitments are related to the use of nonrenewable resources and the effects 

that the use of these resources has on future generations. Irreversible effects primarily result from the 

use or destruction of a specific resource that cannot be replaced within a reasonable time frame. 
Page 26 of 41

Irretrievable resource commitments involve the loss in value of an affected resource that cannot be 

restored because of the action. The implementation of OMDG will result in no irreversible or 

irretrievable resource commitments.

5. Compliance with Environmental Laws and Regulations

AMS is responsible for ensuring that projects comply with all relevant authorities. Compliance with these 

authorities will result in few, if any, negative environmental, social, and/or economic impacts. 

Consultation, permits, authorities, and actions relative to water quality, endangered, threatened, and 

protected species, historic and cultural resources, environmental justice, and wetland protections are 

described in Chapter 5 below, and would be required as applicable. 

5.1 Clean Water Act

The Clean Water Act (CWA) was established with the goal of restoring and maintaining the chemical, 

physical, and biological integrity of the Nation’s waters. Pursuant to this goal, the U.S. Army Corps of 

Engineers (USACE) regulates the discharge of dredged or fill material in waters of the United States 

(WOTUS) under Section 404 of the CWA, which includes adjacent wetlands. Work and structures located 

in, or that affect, WOTUS, including work below the ordinary high-water mark in non-tidal waters, also 

are regulated by USACE and require permits.

Section 402 of the CWA established the National Pollution Discharge Elimination System (NPDES) which 

sets forth conditions and permitting requirements for point source discharges into WOTUS, including 

wetlands. In most cases, EPA has delegated NPDES authority to states and Tribes. Point sources of 

pollution are primarily defined as direct discharges into surface waters from pipes, ditches, and channels, 

but also include CAFO’s and construction sites. Nonpoint sources of pollution, such as runoff from an 

agricultural field, are defined as an exclusion to the NPDES program under CWA and are not considered a 

point source of pollution.

There are several CWA provisions that address non-point source pollution that are administered by 

states and Tribes. Section 319 of the CWA requires states and Tribes to identify waters impaired by nonpoint source pollution and adopt a management program. States and Tribes are also required to 

establish water quality standards under Section 303(d) of the CWA and allowable Total Maximum Daily 

Loads (TMDLs) that meet water quality standards. Section 401 of the CWA requires states to certify that 

Federal permits, such as Section 404 CWA permits issued by USACE, are not in violation of any state 

water quality standards.
Page 27 of 41

Since OMDG processing capacity expansion activities will only occur in existing structures or facilities, 

permanent impacts to waters of the U.S. protected under the CWA are not expected. Where OMDG 

processing capacity expansion or replacement activities may involve restoring an existing structure 

within waters of the U.S. including wetlands, CWA permitting for temporary impacts may be required. 

CWA permitting requirements will be confirmed on a project-level basis during the site-specific 

environmental review consistent with Chapter 6 and any required coordination with USACE will be 

initiated during the project planning stage. Inadvertent stormwater runoff to adjacent regulated 

wetlands and waterways resulting from increased off-road traffic or ground disturbance would require 

onsite stormwater controls, including erosion and sediment control devices, to avoid and minimize 

impacts to downgradient water resources.

5.2 Coastal Zone Management Act (CZMA)

The Coastal Zone Management Act encourages coastal states, Great Lake states, and U.S. Territories and 

Commonwealths (collectively referred to as “coastal states” or “states”) to be proactive in managing 

natural resources for their benefit and the benefit of the Nation. The CZMA Federal consistency 

provision (16 U.S.C. § 1456 and 15 C.F.R. part 930) provides states with an important tool to manage 

coastal uses and resources and to facilitate cooperation and coordination with Federal agencies. Under 

the CZMA, Federal agency activities that have coastal effects must be consistent to the maximum extent 

practicable with federally approved enforceable policies of a state’s NOAA-approved coastal 

management program. In addition, the CZMA requires non-federal applicants for federal authorizations 

and funding to be consistent with enforceable policies of state coastal management programs.

Activities performed under the OMDG Program with extraordinary circumstances may require a federal 

consistency review for activities taking place within a state-designated coastal zone management area. 

Each project will be evaluated for consistency with the CZMA, and additional regulatory review will be 

performed on a case-by-case basis. 

5.3 Coastal Barrier Resources Act (CBRA)

The Coastal Barrier Resource Act (CBRA) provides landscape-level conservation benefits for fish, wildlife, 

and plant resources by reducing the intensity of development. CBRA does this by restricting federal 

funding and financial assistance within designated System Units. The Coastal Barrier Resources System 

(CBRS) includes 588 System Units, which comprise nearly 1.4 million acres of land and associated aquatic 

habitat. There are also 282 “Otherwise Protected Areas,” a category of coastal barriers that are mostly 

held for conservation and/or recreation purposes that include an additional 2.1 million acres of land and 

associated aquatic habitat. Section 6 of the CBRA permits certain federal expenditures and financial 

assistance within the CBRS, but only after consultation with the U.S. Fish and Wildlife Service. 

It is not anticipated that any available exceptions under Section 6 of CBRA would apply to OMDG

projects. Therefore, AMS will not provide funding under the OMDG to undertake processing capacity 

expansion activities within System Units designated under the CBRA. 
Page 28 of 41

5.4 Endangered Species Act (ESA)

Section 9 of the ESA, as amended, and federal regulations pursuant to section 4(d) of the ESA prohibit 

the take of endangered and threatened species, respectively, without special exemption such as by a 

permit.

Section 7 requires Federal agencies to use their authorities in furtherance of the purposes of the ESA by 

carrying out programs for the conservation of endangered and threatened species. Agencies are further 

required to ensure that any action authorized, funded, or carried out is not likely to jeopardize the 

continued existence of any threatened or endangered species or result in destruction or adverse 

modification of habitat for such species. If AMS proposes to fund or undertake an action that may affect 

ESA-listed species, it must initiate a Section 7 consultation with the Department of the Interior (US Fish 

and Wildlife Service – FWS) or Commerce (NOAA National Marine Fisheries Service - NMFS). Regulations 

specify the procedural requirements for these consultations (50 Part C.F.R. 402). Federal agencies must 

determine whether their proposed actions will have no effect on threatened and endangered species or 

whether informal or formal consultation is required with the FWS or NMFS. Informal consultation 

requires that the action agency prepare a Biological Assessment for concurrence by the FWS or NMFS.

AMS has made a no effects determination regarding ESA species. However, if extraordinary 

circumstances are identified, consultations would be initiated at the earliest planning stage for sitespecific environmental evaluation consistent with Chapter 6 below. 

5.5 Farmland Protection Policy Act (FPPA)

The FPPA, implemented by NRCS, aims to minimize the impacts Federal programs have on the 

irreversible conversion of farmland to nonagricultural uses. For FPPA, farmland includes prime farmland, 

unique farmland, and land of statewide or local importance. Farmland subject to FPPA requirements 

does not have to be currently used for cropland. It can be forest land, pastureland, cropland, or other 

land, but not water or urban built-up land.

Activities under OMDG are not expected to result in irreversible conversion of farmland to 

nonagricultural uses, as it defies the purpose of the program.

5.6 Migratory Bird Treaty Act (MBTA)

The MBTA protects over 1,000 species of migratory bird species from any attempt at hunting, pursuing, 

wounding, killing, possessing, or transporting any migratory bird, nest, egg, or part thereof, unless 

permitted by regulations (i.e., for hunting and subsistence activities). Additional protection is allotted 

under the Bald and Golden Eagle Protection Act for the identified species. Compliance with the MBTA 

does not usually require a permit or authorization; however, the FWS is currently working on proposed

rulemaking that may impact whether permits for certain Federal activities are required.

Generally, activities under OMDG are expected to have no adverse impacts on migratory bird species as 

there will be no new construction or development of previously undeveloped areas. 
Page 29 of 41

5.7 National Historic Preservation Act (NHPA)

The NHPA of 1966, amended in 1992, requires that responsible agencies taking action that may 

potentially affect any property with historic, architectural, archeological, or cultural value that is listed on 

or eligible for listing on the National Register of Historic Places (NRHP) comply with the procedures for 

consultation and comment issued by the Advisory Council on Historic Preservation. The responsible 

agency also must identify properties affected by the action that are listed on or potentially eligible for 

listing on the NRHP, usually through consultation with the State Historic Preservation Officer (SHPO) 

and/or Tribal Historic Preservation Officer (THPO).

OMDG, and all associated site-specific projects, must comply with the NHPA by coordinating with the 

SHPO, THPO, or relevant Tribes, when necessary. OMDG processing capacity expansion activities that are 

anticipated to occur within structures 50 years old or greater will require a site-specific environmental 

review, as described in Chapter 6. Therefore, consultations would be initiated at the earliest planning 

stage for site-specific actions when AMS determines the action may affect historic, architectural, 

archeological, or cultural resources. 

5.8 Wild and Scenic Rivers Act (WSRA)

The WSRA established the National Wild and Scenic Rivers System to preserve rivers deemed to have 

outstanding natural, cultural, and recreational values. The National Wild and Scenic River System consists 

of a river or river segments that are in free-flowing condition which have been categorized as wild, 

scenic, or recreational. The National Wild and Scenic River System is administered by various land 

management agencies. To ensure continued protection of these waterways, Federal agencies may not 

provide financial assistance for projects which would have a direct and adverse effect on the values for 

which a river was designated.

AMS has made a no effects determination regarding a river or river segments listed under the WSRA, 

AMS. However, if extraordinary circumstances are identified, consultations would be initiated at the 

earliest planning stage for site-specific environmental review consistent with Chapter 6 below. 

5.9 Wilderness Act

The Wilderness Act established the Wilderness Preservation System to protect and preserve the 

wilderness character of designated areas by prohibiting certain uses, such as timber harvest, new grazing 

and mining activity, or any other kind of development. The Wilderness Preservation System is 

administered by various land management agencies. To ensure the continued wilderness character of 

designated wilderness areas, Federal agencies must consider whether proposed actions will result in an 

adverse impact on wilderness areas within the action area. 

As areas designated as part of the Wilderness Preservation System are Federal lands, it is not anticipated 

that any available OMDG projects would occur within wilderness areas. Processing capacity expansion 

activities that occur adjacent to any wilderness areas will require consultation with the jurisdictional 

Federal agency to ensure consistency with the Wilderness Act. AMS will not provide funding under 

OMDG to undertake processing capacity expansion activities that are not consistent with allowable land 

uses as defined in the Wilderness Act. 
Page 30 of 41

5.10 Executive Order 11990: Protection of Wetlands

The purpose of Executive Order 11990 is to minimize the destruction, loss, or degradation of wetlands 

and to preserve and enhance the natural and beneficial values of wetlands. To meet these objectives, 

the order requires Federal agencies, in planning their actions, to consider alternatives to wetland sites 

and limit potential damage if an activity affecting a wetland cannot be avoided.

As OMDG processing capacity expansion activities are to occur solely in existing structures, direct 

impacts to wetlands are not expected. Where OMDG processing capacity expansion activities involve 

restoring a structure adjacent to a wetland, there may be indirect, short-term impacts to the wetland 

from increased traffic to the surrounding area. In these instances, the AMS staff will consider potential 

adverse impacts to wetlands on a project-level basis and ensure proper permitting is in place to ensure 

permanent damage is avoided. Considerations for potential adverse impacts to wetlands will be 

determined on a project-level basis and implement best practices to ensure permanent damage is 

avoided.

5.11 Executive Order 11998: Floodplain Management

The purpose of Executive Order 11998 is to avoid the long- and short-term adverse impacts associated 

with the occupancy and modification of floodplains and to avoid direct or indirect support of floodplain 

development wherever there is a practicable alternative. It requires that each Federal agency take action 

to reduce the risk of flood loss, to minimize the impact of floods on human safety, health, and welfare, 

and to restore and preserve the natural and beneficial values served by floodplains. Each agency should 

determine if any actions undertaken would occur in a floodplain and evaluate the potential effects of any 

actions. If an agency has determined to, or proposes to, conduct, support, or allow an action to be in a 

floodplain. The agency shall consider alternatives to avoid adverse effects and incompatible 

development in the floodplains.

As OMDG processing capacity expansion activities are to occur solely in existing structures, direct 

impacts to floodplains are not expected. Where OMDG processing capacity expansion activities involve 

restoring a structure within the floodplain, the property owner will be required to obtain a flood 

insurance policy or meet floodproofing requirements as required in the development permit for that 

federally supported structure. AMS staff will consider potential adverse impacts to floodplains on a 

project-level basis and ensure proper permitting is in place to ensure permanent damage is avoided.

5.12 Executive Order 12898: Federal Actions to Address Environmental Justice 

in Minority Populations and Low-Income Populations

The purpose of Executive Order (E.O.) 12898 is to focus Federal attention on the environmental and 

human health effects of Federal actions on minority and low-income populations with the goal of 

achieving environmental protection for all communities. It directs Federal agencies to identify and 

address the disproportionately high and adverse human health or environmental effects of their actions 

on minority and low-income populations, to the greatest extent practicable and permitted by law. If AMS 

determines that the proposed project may cause disproportionately high and adverse effects for lowincome or minority populations, a site-specific environmental review will be performed to determine 

whether measures to minimize, mitigate, or avoid those impacts would be required. 
Page 31 of 41

Activities under OMDG are not expected to result in disproportionate adverse impacts to minority and 

low-income populations, as all activities will not result in construction and will therefore impact all 

populations in similar manners. Further, AMS may also prioritize applications based on diversity in 

applicants funded in geographic regions and across size, scale, or product types. Therefore, it is expected 

that OMDG will have beneficial long-term and short-term impacts to communities with environmental 

justice concerns.

6. Implementation

Site-specific actions are projects undertaken or funded by AMS through OMDG that are consistent with 

the categories identified in Section 1.1.3 and the Proposed Action Alternative. AMS anticipates using this 

PEA to guide decision-making for site-specific actions for the funding of Organic Market Development 

Grants in response to the Request for Applications, and future funding opportunities that are 

substantially similar. For any future funding opportunities considered substantially similar, AMS would 

review the PEA, and relevant environmental concerns, to determine whether the PEA’s scope and 

analysis remains applicable to the program. If the program mandate or focus shifts substantially during 

that time a new PEA may be prepared or this PEA may be supplemented.

As site-specific actions are being considered under OMDG, this PEA will be reviewed to determine 

whether they are within the scope of its analysis. If additional NEPA analysis is warranted for a specific 

decision, it may be tiered from this PEA as appropriate. Consistent with CEQ regulations at 40 C.F.R. 

1508.28, the tiered NEPA documents will incorporate by reference the applicable general discussions in 

this PEA and concentrate solely on the issues specific to the analysis being prepared. 

Site specific environmental analysis would be prepared consistent with CEQ regulations at 40 C.F.R. 

1502(c) if:

• The OMDG program is considering an action that is substantially different from the proposed 

action and the changes are relevant to environmental concerns; or

• There are significant new circumstances or information relevant to environmental concerns and 

bearing on the proposed action or its impacts. 

6.1 Process for Screening Site-Specific Projects

A PEA cannot be used to avoid or defer the consideration of extraordinary circumstances that may arise 

from individual actions within the program. 

Most projects eligible for the OMDG program are unlikely to affect any protected resources, and they 

can be assessed under the Programmatic Environmental Assessment. However, some extraordinary

cases may need additional site-specific review.

When it is found that the PEA does not fully address the scope or impacts of the proposed action, these 

are called extraordinary circumstances. The agency must do a site-specific environmental review that fills 

in the gaps of this PEA. This way, the Finding of No Significant Impact (FONSI) can be valid for the specific 

site.
Page 32 of 41

Some examples of extraordinary circumstances are:

• Actions that have significant impacts on a resource or issue that were not analyzed in the PEA, 

such as endangered species, residing in structures targeted for remodeling, cultural resources 

discovered in previously disturbed areas, or human health concerns not considered.

• Actions that involve new technologies, methods, or locations that were not considered in the 

PEA.

• Actions that have cumulative effects that were not accounted for in the PEA, such as multiple 

projects in the same area or region over time.

• Actions that have changed substantially since the PEA was completed, such as new information, 

regulations, or public input.

If an extraordinary circumstance is identified, the agency should document the rationale for why the PEA 

does not apply and what level of NEPA analysis is required for the action. The Agency should also consult 

with relevant stakeholders, such as other agencies, Tribes, U.S. Fish and Wildlife Service, or the public, to 

ensure that the environmental impacts of the action are adequately addressed in the site-specific 

environmental review in accordance with Chapter 6.1.1 of this PEA.
Page 33 of 41

6.1.1 NEPA Screening Flowchart
Page 34 of 41

7. List of Preparers and Reviewers and Agencies Contacted

List of Preparers

Name and Title Education and Experience

Erin Kelly, Agricultural Program 

Specialist, Wisconsin State 

Environmental Coordinator

State Environmental Coordinator with 4 years of experience 

completing environmental reviews with the Farm Service Agency. 

B.S. Environmental Science, University of Wisconsin-Oshkosh. 

Rose Vath, FPAC BC, Eastern 

Regional Environmental 

Coordinator

Natural Resource Specialist with 7 years of environmental 

compliance experience with State of Florida and the Federal 

government. M.S. Oceanography, Florida State University. B.S. 

Environmental Science, Florida State University. 

List of Reviewers

Name and Title Education and Experience

Robyn Rose, FPAC BC, Deputy 

Director

Deputy Director for USDA Farm Production and Conservation 

Business Center Environmental Activities Division with 27 years of 

Federal government experience. Ph.D. Entomology.

Betsy Rakola, AMS 

Transportation and Marketing 

Program, Associate Deputy 

Administrator

Associate Deputy Administrator for AMS Transportation and 

Marketing and former Director in the AMS National Organic 

Program with 13 years of Federal government experience. M.S. in 

Agriculture, Food and Environment from Tufts University. 
Page 35 of 41

References

Alfoeldi, Thomas, et al. "Organic agriculture and the environment." Organic agriculture, environment,

and food security 4 (2002).

Bellows, Barbara C., et al. "Bringing local food to local institutions: a resource guide for farm to 

institution programs." National Center for Appropriate Technology. Retrieved from: https://attra. ncat. 

org/attra-pub/summaries/summary. php (2013).

Callahan, Scott, and Daniel Hellerstein. "Access to Farmland by Beginning and Socially Disadvantaged 

Farmers: Issues and Opportunities." (2022).

Campbell, Catherine G., Alia N. DeLong, and John M. Diaz. "Commercial urban agriculture in Florida: a 

qualitative needs assessment." Renewable Agriculture and Food Systems 38 (2023): e4.

Canter, L. (1996). Environmental Impact Assessment, 2nd edition. McGraw-Hill, New York.

Clark, Sean. "Organic farming and climate change: The need for innovation." Sustainability 12.17 (2020): 

7012.

Conner, David S., et al. "The diverse values and motivations of Vermont farm to institution supply chain 

actors." Journal of Agricultural and Environmental Ethics 27 (2014): 695-713.

Dar, Aamir Hussain, et al. "Fresh-cut products: Processing operations and equipment." Fresh-Cut Fruits 

and Vegetables. Academic Press, 2020. 77-97.

Delate, Kathleen, Ben Heller, and Jessica Shade. "Organic cotton production may alleviate the 

environmental impacts of intensive conventional cotton production." Renewable Agriculture and Food 

Systems 36.4 (2021): 405-412.

DeSantis, Mark K. "The federal role in historic preservation: An overview." Congressional Research 

Service (2020).

Dimitri, Carolyn, and Richard Nehring. "Thirty years of organic dairy in the United States: the influences 

of farms, the market and the organic regulation." Renewable Agriculture and Food Systems 37.6 (2022): 

588-602.

Durant, Jennie L., et al. "Farm resilience during the COVID-19 pandemic: The case of California direct 

market farmers." Agricultural Systems 204 (2023): 103532.

EPA. Protecting Water Quality from Agricultural Runoff. Mar. 2005.

Farm to Institution Initiatives - USDA, www.usda.gov/sites/default/files/documents/6

Farmtoinstitution.pdf. Accessed 27 Sept. 2023. 
Page 36 of 41

Global Eco Fiber Market Size, Share & Growth Report, 2030.” Global Eco Fiber Market Size, Share & 

Growth Report, 2030, www.grandviewresearch.com/industry-analysis/eco-fiber-market. Accessed 27 

Sept. 2023. 

Highlights - National Agricultural Statistics Service, 

www.nass.usda.gov/Publications/Highlights/2014/Beginning_Farmers/Highlights_Beginning_Farmers.pd

f. Accessed 27 Sept. 2023. 

Hoidal, Authors: Natalie. “Small-Scale Hydroponics.” UMN Extension, University of Minnesota Extension, 

2022, extension.umn.edu/how/small-scale-hydroponics. 

Holka, Małgorzata, Jolanta Kowalska, and Magdalena Jakubowska. "Reducing Carbon Footprint of 

Agriculture—Can Organic Farming Help to Mitigate Climate Change?" Agriculture 12.9 (2022): 1383.

Kaur, Gurinder, and Ronald Kander. "The Sustainability of Industrial Hemp: A Literature Review of Its 

Economic, Environmental, and Social Sustainability." Sustainability 15.8 (2023): 6457.

Khan, Nawab, et al. "Current progress and future prospects of agriculture technology: Gateway to 

sustainable agriculture." Sustainability 13.9 (2021): 4883.

McMurry, Sally. "Preserving agricultural history through Land and buildings." Agricultural History 90.1 

(2016): 4-21.

Nations, Tribal. "Section 106 Tribal Agreements: Strengthening Government-to-Government Partnerships 

and Accelerating Project Delivery." (2019).

Paudel, Jayash, and Christine L. Crago. "Environmental externalities from agriculture: evidence from 

water quality in the United States." American Journal of Agricultural Economics 103.1 (2021): 185-210.

Pesch, Ryan, and Rani Bhattacharyya. "Assessing the potential northwest Minnesota farm-to-institution 

market: An analysis of the market potential of purchase of locally raised foods by educational and 

healthcare institutions in 16 Northwest Minnesota counties." (2014).

Sanders, Catherine, et al. "Exploring the needs of urban producers in a rural state: A qualitative needs 

assessment." Journal of Agriculture, Food Systems, and Community Development 11.1 (2021): 99-113.
Page 37 of 41

Appendix

Appendix A- AMS-ENV-A –Environmental Pre-screening Worksheet
Page 38 of 41

Appendix B- AMS-ENV-B—Environmental Screening Worksheet
Page 39 of 41
Page 40 of 41

Appendix C- AMS Request for Applications 
Page 41 of 41

Appendix D- OMDG Federal Register Notice of Availability