DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT: Resilient Food Systems Infrastructure Program Cooperative Agreements

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U.S. DEPARTMENT OF AGRICULTURE

Agricultural Marketing Service

DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT

Resilient Food Systems Infrastructure Program Cooperative Agreements

Prepared by the USDA Farm Production and Conservation Business Center 

Environmental Activities Division and the USDA Agricultural Marketing Service

January 22, 2024

USDA is an equal opportunity provider, employer, and lender.
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COVER SHEET 

Proposed Action: The United States Department of Agriculture (USDA) Agricultural Marketing Service (AMS) has 

proposed to fund grants and agreements to maintain and improve food and agricultural supply chain resiliency.

USDA AMS will cooperate with states (50 States, the District of Columbia, the Commonwealth of Puerto Rico, 

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

Island) to fund and coordinate initiatives for non-meat and poultry food products in the middle-of-the-supplychain. Funds will support expanded capacity for the aggregation, processing, manufacturing, storing, 

transporting, wholesaling, and distribution of locally and regionally produced food products, including specialty 

crops, dairy, grains for human consumption, aquaculture, and other food products, excluding meat and poultry. 

States would make subawards to support local and regional food and farm businesses and other entities. States 

would also provide supply chain and market development services.

Type of Document: Draft Programmatic Environmental Assessment (PEA)

Lead Agency: USDA Agricultural Marketing Service (AMS)

Cooperating Agencies: None

Further Information: Lara Shockey, Natural Resource Specialist

U.S. Department of Agriculture, Agricultural Marketing Service

Transportation and Marketing Program, Grants Division

304-373-5875

lara.s.shockey@usda.gov

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

Comments: This Draft PEA was prepared in accordance with National Environmental Policy Act (NEPA) of 1970, 

Public Law 91-140, 42 US Code 4321-4347, as amended.
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Contents 

1. Purpose of and Need for Action.......................................................................................................6

1.1 Introduction.............................................................................................................................. 6

1.1.1 Background................................................................................................................... 6

1.1.2 Program Administration ............................................................................................... 7

1.1.3 Program Activities......................................................................................................... 7

1.2 NEPA Compliance...................................................................................................................... 8

1.2.1 Purpose of Using a Programmatic Environmental Assessment.................................... 8

1.3 Purpose and Need for the Proposed Action............................................................................. 9

1.3.1 Purpose of the Action................................................................................................... 9

1.3.2 The Need..................................................................................................................... 10

1.4 Decision To Be Made .............................................................................................................. 10

1.5 Regulatory Compliance........................................................................................................... 10

1.6 Public Involvement and Consultation..................................................................................... 11

1.7 Organization of PEA ................................................................................................................ 11

2. Description of Proposed Action and Alternatives........................................................................... 12

2.1 Alternative A - No Action Alternative ..................................................................................... 12

2.2 Alternative B – Proposed Action Alternative (Preferred) ....................................................... 12

3. Affected Environment and Environmental Impacts ........................................................................ 14

3.1 Resources Eliminated from Detailed Analysis ........................................................................ 15

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

3.2.1 Water Quality.............................................................................................................. 21

3.2.2 Socioeconomics and Environmental Justice ............................................................... 22

3.2.3 Climate Change........................................................................................................... 25

4. Cumulative Impacts....................................................................................................................... 27

4.1 Definition ................................................................................................................................ 27

4.2 Past, Present, and Reasonably Foreseeable Actions .............................................................. 27

4.3 Cumulative Impacts of the Proposed Action.......................................................................... 28

4.4 Irreversible and Irretrievable Commitment of Resources...................................................... 28

5. Compliance with Environmental Laws and Regulations.................................................................. 28

5.1 Clean Water Act...................................................................................................................... 28

5.2 Coastal Zone Management Act (CZMA).................................................................................. 29
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5.3 Coastal Barrier Resources Act (CBRA)..................................................................................... 29

5.4 Endangered Species Act (ESA) ................................................................................................ 30

5.5 Farmland Protection Policy Act (FPPA) ................................................................................... 30

5.6 Migratory Bird Treaty Act (MBTA)........................................................................................... 31

5.7 National Historic Preservation Act (NHPA) ............................................................................. 31

5.8 Wild and Scenic Rivers Act (WSRA) ........................................................................................ 31

5.9 Wilderness Act........................................................................................................................ 31

5.10 Executive Order 11990: Protection of Wetlands.................................................................... 32

5.11 Executive Order 11998: Floodplain Management.................................................................. 32

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

and Low-Income Populations........................................................................................................ 32

5.13 Executive Order 14008: Tackling the Climate Crisis at Home and Abroad ............................ 33

5.14 Executive Order 14017: Executive Order on America’s Supply Chains................................... 33

6. Implementation ............................................................................................................................ 33

6.1 Process for Screening Site-Specific Projects........................................................................... 34

7. List of Preparers and Reviewers and Agencies Contacted ............................................................... 36

References......................................................................................................................................... 37

Appendix ...........................................................................................................................................39

Appendix A - AMS ENV-A – Environmental Prescreening Worksheet................................................ 39

Appendix B - AMS ENV-B – Environmental Screening Worksheet...................................................... 40
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ACRONYMS AND ABBREVIATIONS 

AMS Agricultural Marketing Service

BABA Build America, Buy America Act

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

IPaC Information Planning and Conservation

LAMP Local Agriculture Market Program

RFSP Regional Food System Partnership Program

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

OO Office of Outreach

PEA Programmatic Environmental Assessment

RFSI Resilient Food Systems Infrastructure 

ROD Record of Decision

SHPO State Historic Preservation Officer

THPO Tribal Historic Preservation Officer

USDA United States Department of Agriculture

USACE United States Army Corps of Engineers

WOTUS Waters of the United States
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1.0 Purpose of and Need for Action 

1.1 Introduction

The Resilient Food Systems Infrastructure (RFSI) Program is a significant step toward building resilience in the 

middle of the food supply chain. The purpose of this program is to enhance the resilience of food systems, 

particularly in the face of challenges such as climate change, market volatility, and supply chain disruptions. This 

document is a draft programmatic environmental assessment (PEA) for the RFSI Program. This draft PEA 

describes the planned actions of the RFSI Program and potential environmental impacts resulting from those 

actions.

This PEA has been prepared to streamline the overall RFSI grant review process, and AMS anticipates using this 

PEA to review projects for site-specific actions over the next four years. Each proposed subaward would be 

evaluated to determine if its potential environmental impacts have been addressed in the PEA. Any activities not 

clearly within the scope of this review, have extraordinary circumstances, or involve new or expanded structures 

would be further evaluated using the site-specific environmental review process and form AMS-ENV-B found in 

Chapter 6. The site-specific review, if necessary, would be conducted by USDA Agricultural Marketing Service 

(AMS) and State agencies.

1.1.1 Background

The RFSI Program is funded under Section 1001 (b) (4) of the American Rescue Plan (ARP) of 2021 (Pub. L. 117-

2), as amended authorizes the USDA, to make grants and agreements to maintain to improve food and 

agricultural supply chain resiliency. RFSI provides up to $420 million of American Rescue Plan (ARP) funding. The 

purpose of the RFSI is to assist U.S. states and territories (States) to build resilience in the middle-of-the-supplychain and strengthen local and regional food systems by creating new revenue streams for their state’s 

producers.

The primary goal of the RFSI Program is to:

• Support food system crops and products meant for human consumption (excluding meat and poultry 

products, which are funded through other USDA programs).

The program also aims to:

• Support development of value-added products available to consumers;

• Support proposals that provide fair prices, fair wages, and new and safe job opportunities that keep 

profits in rural and underserved communities; and 

• Increase diversity in processing options in terms of business model approaches, geography, and 

availability to underserved communities.

The program is also aligned with efforts 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 and support the policies of Executive Order 14017 (Executive Order on 

America’s Supply Chains). 
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• Promote competition in the food system and support the policies of Executive Order 14036 (Executive 

Order on Promoting Competition in the American Economy).

• Implement the Build America, Buy America (BABA) Act.

1.1.2 Program Administration

The USDA, Agricultural Marketing Service (AMS), has entered into cooperative agreements with each U.S. State,

as well as its commonwealths and territories, for the RFSI Program. Once they have executed their agreements, 

states submit State Plans to AMS describing how they will develop and administer coordinated initiatives to build 

resilience across the middle-of-the-food-supply-chain in their state. Funds will support expanded capacity for the 

aggregation, processing, manufacturing, storing, transporting, wholesaling, and distribution of locally and 

regionally produced human food products, including specialty crops, dairy, grains, aquaculture, and other food 

products, excluding meat and poultry. States may use a limited portion of funds to develop and/or strengthen 

the State’s supply chain coordination and targeted market development services for locally and regionally 

produced products. USDA will review, inform, and approve this State Plan before approving expenditures by the 

State under the cooperative agreement. AMS would prioritize underserved producers and businesses and the 

support program goals stated in this PEA. An AMS review board may respond to the State with questions and 

recommendations to adjust award recommendations. 

In all programs and initiatives, USDA promotes climate-resilient landscapes and rural economic systems, 

including tools to support agriculture, forests, grazing lands, and rural communities. AMS encourages applicants 

to consider including goals and activities related to mitigating and adapting to climate change in their project’s 

design and implementation.

1.1.3 Program Activities 

RFSI serves as an important component of USDA’s framework to transform the food system to benefit 

consumers, producers, and rural communities by providing more options, increasing access, and creating new, 

more, and better markets for small and mid-size producers. The pandemic and recent supply chain disruptions 

have revealed the perils of a national food system that depends on capacity concentrated in a few geographic 

areas and requires many steps to get from farm to fork. To be more resilient, the food system of the future needs 

to be more diversified, distributed, and local.

Infrastructure Projects

States must offer most of their RFSI funding to Infrastructure Grants through a competitive subawards process. 

Infrastructure Grants will fund projects that expand capacity and infrastructure for the aggregation, processing, 

manufacturing, storing, transporting, wholesaling, or distribution of targeted agricultural products. 

• The minimum award amount is $100,000 and maximum award amount is $3,000,000. Infrastructure 

grant recipients are required to contribute 50% of the total proposed project cost as a match to federal 

funding. This applies to all applicants except those who qualify for the reduced match.
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• Simplified Equipment-Only Projects: Lead State Agencies may issue Simplified Equipment-Only Projects. 

These projects offer a simplified application to fund smaller grants between $10,000 and $100,000 for 

equipment purchases. The Simplified Equipment-Only option is a Fixed Price Grant, meaning it will fund 

only equipment purchases (and not associated facility upgrades, staffing, or other costs), and the 

amount awarded will be equal to the cost of the equipment up to $100,000. No match is required for 

Simplified Equipment Only Projects.

Supply Chain Coordination

States may allocate up to 20% of a their RFSI funding, or up to $1 million (whichever is less), to 

Supply Chain Coordination activities, led by the Lead State Agency or one or more partner state agencies, aligned 

with the purposes of the program, and designed to serve the producers and supply chains targeted by this RFSI 

program, including but not limited to Infrastructure Grant subaward recipients. States are encouraged to conduct 

these activities themselves to build state-level capacity but may contract or enter sub-agreements for some of 

the activities. Coordination with the USDA Regional Food Business Centers is strongly encouraged. Activities 

include nonmonetary assistance to businesses through either targeted technical assistance or training and other 

relevant resources. Through these efforts, the RFSI program aims to enhance market access for small and midsize producers and food businesses, contributing to a more resilient and sustainable food system.

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 the 

natural and social sciences in planning, evaluation, and decision-making. Federal agencies are obligated to 

comply with NEPA regulations coordinated by the White House Council on Environmental Quality (CEQ) (40 C.F.R. 

Parts 1500-1508). These regulations outline Federal agency requirements 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 by:

1) Applying 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 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 performed the necessary analysis to determine if the effects may be 

significant. If there is potential for significant impacts, then an EIS is prepared. If the impacts are not expected to 

be significant, a Finding of No Significant Impact (FONSI) is prepared.
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A PEA is necessary because AMS does not have a NEPA regulation with categorical exclusions and it therefore 

operates at a higher, national programmatic level of NEPA compliance. PEAs are broad in scope and may address 

several related actions or projects, an entire program, a broad action, or Federal Financial Assistance 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 analysis

of a hard look at major Federal actions and potential impacts associated with alternatives to the action. 

A PEA allows AMS to reduce paperwork and streamline NEPA reviews to the extent an assessment of potential 

impacts have already been addressed in the PEA. Programmatic environmental impact statements and 

environmental assessments and tiering from other analyses 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).

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

additional site-specific NEPA review. Depending upon the degree of the project’s potential impacts, this review 

could involve the preparation of a site-specific environmental review documenting consistency with the PEAs 

FONSI or additional support for a categorical exclusion, a supplemental EA tiered from this PEA, a new EA, or an 

EIS. This PEA addresses NEPA compliance at the program level. Evaluation of site-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 the FONSI, EA, or EIS is the appropriate level of analysis. 

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 the RFSI Program is to assist U.S. states and territories (States) in building resilience in the 

middle-of-the-supply chain and strengthening local and regional food systems by creating new revenue streams 

for their state’s producers. Grants made to middle-of-the-supply chain businesses would create more diverse 

local and regional market options and create more economic opportunities for communities, allowing them to 

retain more of the value chain dollar. RFSI investments aim to create a food systems infrastructure to support 

competitive and profitable market access for domestic farm products.

In addition, the RFSI program focuses on reducing greenhouse gas emissions, promoting efficient use of 

resources, and improving air and water quality. Through these efforts, the RFSI Program aims to build a more 

resilient and equitable food system. The environmental assessment of the program is a critical component of this 

effort, ensuring that the program’s activities align with environmental best practices and contribute to the 
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broader goal of combating climate change. The program is expected to enhance the resilience, diversity, and 

sustainability of the U.S. food system.

1.3.2 The Need

The RFSI Program is designed to strengthen the food supply chain and enhance the resilience of food systems. 

The program aims to provide more and better markets to small farms and food businesses, support the 

development of value-added products for consumers, ensure fair prices and wages, and create new and safe job 

opportunities.

The need for the RFSI Program arises from the challenges faced by small farms and food businesses in accessing 

markets and developing value-added products. Additionally, the program addresses the need for fair prices for 

consumers and fair wages for workers in the food supply chain. By building resilience in the middle of the food 

supply chain, the program will help to ensure the stability of food systems, creating more diverse local and 

regional market options and create more economic opportunities for communities, allowing them to retain more 

of the value chain dollar.

The proposed action is consistent with the goals and objectives of the USDA Strategic Plan 2023-2027, which 

include:

• Increasing agricultural opportunities by expanding markets and supporting a competitive agricultural 

system that creates greater access for producers.

• Fostering rural prosperity by investing in rural infrastructure, businesses, services, and housing.

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. Projects entered under the RFSI Program would be analyzed individually to 

determine the need for site-specific environmental reviews. 

1.5 Regulatory Compliance

This PEA was prepared to satisfy the requirements of the National Environmental Policy Act (NEPA) (Public Law 

91-190, 42 United States Code 4321 et seq.); the Executive Office of the President’s 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); and the RFSI Program, (AMS, 2023). The intent of NEPA is 

to protect, restore, and enhance the human environment through well-informed Federal decisions. The following 

non-exclusive list of laws and Executive Orders (EOs 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)

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

(54 USC 306108, 2014)
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• 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)

• EO 13985 Executive Order on Further Advancing Racial Equity and Support for Underserved 

Communities Through the Federal Government

• Implement the Build America, Buy America (BABA) Act

• EO 14008 Tackling the Climate Crisis at Home and Abroad (86 FR 19, 2021)

• EO 14017 (Executive Order on America’s Supply Chains)

1.6 Public Involvement and Consultation

Scoping is a process that seeks opinions and consultation from the interested public, affected parties, and any 

agency with interests or legal jurisdiction. Scoping occurs early and is an open process to allow for input on 

issues to be addressed in the environmental review document. Among other tasks, scoping eliminates nonsignificant issues and focuses on the significant issues for analysis. 

1.7 Organization of PEA

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 RFSI Program

• Chapter 6 outlines how the RFSI Program 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.
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2.0 Description of Proposed Action and Alternatives 

This PEA considers two options: The No Action Option and the Preferred Option (Proposed Action). No significant 

effects on important resources were found during the scoping process. The AMS review board will examine if 

individual subaward projects are viable, meet the Resilient Food Systems Infrastructure (RFSI) Program goals, and 

address environmental compliance needs. More NEPA documentation would be prepared for specific projects if 

they are found to be beyond the scope of this programmatic review. These documents would be completed 

when the projects are ready for evaluation.

2.1 Alternative A - No Action Alternative

Under the No Action Alternative, AMS will not fund projects to support the development, coordination, and 

expansion of direct producer-to-consumer marketing, local, and regional food markets and enterprises, and 

value-added agricultural products. This alternative would result in the continuation of the current conditions 

and would not invest in rural economic opportunities or state agency supply chain coordination. 

2.2 Alternative B – Proposed Action Alternative (Preferred) 

Under the Proposed Action Alternative, AMS will implement the Resilient Food Systems Infrastructure Program

as described in the Program Scope and Requirements and award up to $420 million over four years among each 

State based on the share of commodity by sales, small farm sales, and rural populations living in distressed 

communities. AMS has entered into cooperative agreements with each State and territorial Department of 

Agriculture. Cooperative agreements are a form of Federal financial assistance provided to state agencies or nongovernmental organizations (NGO) that anticipate substantial involvement by the awarding Federal agency. After 

executing a cooperative agreement, states submit a State Plan which describes the outreach activities, 

monitoring and evaluation strategies associated with the proposed activities, and how the applicant will manage 

the project. This plan also includes the specific needs and priorities for the targeted agricultural products in the 

State, as informed by local stakeholder feedback.

There are two sections within the RFSI Program: 

1. Infrastructure Grants

2. State-Led Complementary Supply Chain Coordination Activities

After AMS accepts a State Plan, states may open their subaward competitions for Infrastructure Award Grants. 

States will recommend to USDA funding awards (i.e., subawards) for projects in their states to expand capacity 

and infrastructure for the aggregation, processing, manufacturing, storing, transporting, wholesaling, or 

distribution of targeted local and regional agricultural products such as:

• Expanding processing capacities, including adding product types, increasing production volumes, and 

supporting new wholesale/retail product lines; 

• Modernizing equipment or facilities through upgrades, repairs, or retooling; (e.g., adapting product 

lines for institutional procurement or adding parallel processing capacity); 

• Purchase and installation of specialized equipment, such as processing components, sorting 

equipment, packing, and labeling equipment, or delivery vehicles;

• Modernizing manufacturing, tracking, storage, and information technology systems;
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• Enhancing worker safety through adoption of new technologies or investment in equipment or 

facility improvements;

• Construction of a new facility;

• Increasing packaging and labeling capacities that meet compliance requirements under applicable 

laws (e.g., sealing, bagging, boxing, labeling, conveying, and product moving equipment); 

• Increasing storage space, including cold storage; 

• Develop, customize, or install climate-smart equipment that reduces greenhouse gas emissions, 

increases efficiency in water use, improves air and/or water quality, and/or meets one or more of 

USDA’s climate action goals; 

• Modernize equipment or facilities to ensure food safety, including associated Hazard, Analysis, and 

Critical Control Points (HACCP) consultation, plan development and employee training; and 

• Training on the use of all equipment purchased under the grant and associated new processes.

These infrastructure grants will be available to: 

• Agricultural producers or processors, or groups of agricultural producers and processors;

• Nonprofit organizations operating middle-of-the-supply-chain activities such as processing, 

aggregation, distribution of targeted agricultural products;

• For-profit entities operating middle-of-the-supply-chain activities such as processing, aggregation, or 

distribution of targeted agricultural products, whose activities are primarily focused for the benefit 

of local and regional producers, and that meet the eligibility requirements of the SBA small business 

size standards are eligible; 

o For-profit entities must meet the eligibility requirements of the SBA small business size 

standards matched to industries described in the North American Industry Classification 

System (NAICS). 

• Local government entities operating middle-of-the-supply-chain activities such as processing, 

aggregation, distribution of targeted agricultural products;

• Tribal governments operating middle-of-the-supply-chain activities such as processing, aggregation, 

distribution of targeted agricultural products; and

• Institutions such as schools, universities, or hospitals bringing producers together to establish 

cooperative or shared infrastructure or invest in equipment that will benefit multiple producers 

middle-of-the-supply-chain activities such as processing, aggregation, distribution of targeted 

agricultural product.

Up to 20% of a State’s RFSI funding, or up to $1 million, may be allocated to Supply Chain Coordination activities. 

Such activities are to be led by the Lead State Agency or partner State agency, aligned with the purposes of the 

program, and designed to serve the producers and supply chains targeted by this RFSI Program, including but not 

limited to Infrastructure Grant recipients. 
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Specific forms of assistance may include: 

• Assessing supply chain needs and opportunities in the state to benefit agricultural producers, expand 

product offerings for consumers, expand processing options and capacity, facilitate cooperative 

solutions to bottlenecks, and plan for best use to meet needs and build opportunities through 

Infrastructure Grants;

• Providing innovative, yet practical, planning for the aggregation, processing, manufacturing, storage, 

transportation, wholesaling, or distribution of food; 

• Developing or facilitating general informational websites, webinars, conferences, trainings, plant 

tours, and field days; and 

• Business assistance, including business plan development for processed products, strategic planning 

assistance, and distribution and supply chain innovation.

3.0 Affected Environment and Environmental Impacts 

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

implementation of the RFSI Program, as well as the potential environmental consequences. 

As a draft PEA, this document evaluates the effects of implementing changes to a nationwide voluntary program. 

As such, the geographic scope of the program is extensive and not fully defined at this stage of program 

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

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

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

activities, such as activities involving new or expanded structures. This PEA and any supplemental site-specific 

environmental reviews will provide the full NEPA coverage for activities under RSFI. 

Applicants from all states, territories, and freely associated states of the United States can apply for the RFSI 

Program. However, the specific locations of the proposed projects are not yet determined, as AMS has yet to 

approve the state plans and begin reviewing proposals. Therefore, this PEA only gives a general description of 

the environmental setting based on the kinds of projects that qualify for funding under the program.

The environmental analysis for projects that may be funded include the following resources or features:

• Vegetation and Wildlife

• Cultural resources

• Coastal Barrier Resource and Coastal Zones 

• Wild and Scenic Rivers and Nationwide Rivers Inventory

• Wilderness Areas and National Natural Landmarks

• Floodplains and Wetlands

• Soils and Other Important Land Resources

• Water Quality

• Air Quality

• Noise 

• Socioeconomic conditions and Environmental justice

The baseline conditions and potential impacts of these resources or features are discussed in Chapter 3 of this 

PEA.
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3.1 Resources Eliminated from Detailed Analysis

CEQ regulations (40 CFR 1501.7(a)(3)) indicate that the lead agency should identify and eliminate from detailed 

study the issues that are not important or that have been covered by prior environmental review, narrowing the 

discussion of these issues in the document to a brief presentation of why they will not have a significant effect 

on the human or natural environment. 

Vegetation and Wildlife. Most of the activities under RFSI will take place indoors or in areas that are already 

disturbed by existing structures, where wildlife and vegetation are unlikely to be present or affected. Therefore, 

the program will have negligible impacts on wildlife, vegetation, and migratory birds. The program will not affect 

any Federally listed threatened or endangered species or critical habitats or introduce or spread any invasive 

species or pests. The program will comply with all relevant Federal, state, and local laws and regulations for 

wildlife and vegetation protection.

However, some activities under RFSI may involve new structures, the expansion of existing structures, 

wastewater structures, or possible resource impacts not considered under this PEA, which may have direct and 

indirect impacts on wildlife and vegetation resources. The type, magnitude, and duration of the impacts may 

depend on the location, scale, and design of the projects, and the sensitivity and adaptability of the affected 

wildlife and vegetation species and communities. For example: some projects may require the clearing of land, 

the removal of trees, the alteration of landscapes, the installation of fences, or the short-term generation of 

noise which could affect listed species or destroy habitat. 

To ensure consistency with the FONSI, any activities under RFSI that may affect wildlife and vegetation resources 

will require a site-specific environmental review and consultations, if applicable, prior to implementation, 

following the procedures outlined in Chapter 6 of this PEA. The site-specific review will identify the potential 

impacts and mitigation measures for each project and evaluate the significance of the impacts.

The AMS RFSI Program will not have any cumulative impacts on wildlife and vegetation beyond those already 

occurring from existing food system operations in the project areas. The program will not result in any 

irreversible or irretrievable commitments of resources related to wildlife and vegetation. The program will not 

conflict with any plans, policies, or programs for the conservation of wildlife and vegetation. The site-specific 

review process for RFSI Program activities will be followed according to Chapter 6 of this PEA.

Cultural Resources. Most of the activities under RFSI will take place indoors or in areas that are already disturbed 

by existing structures, where cultural resources are unlikely to be present or affected. Therefore, the program 

will have negligible impacts on cultural resources. This program is not expected to cause any significant adverse 

effects on archaeological resources, historic buildings or structures, historic landscapes, or other cultural 

features. The program will comply with all relevant Federal, state, and local laws and regulations for cultural 

resource protection.

However, some activities under RFSI may involve new structures, the expansion of existing structures, 

wastewater structures, or possible resource impacts not considered under the PEA, which may have direct and 

indirect impacts on cultural resources. The type and magnitude of the impacts may depend on the location, 

scale, and design of the projects, and the sensitivity and historical use of the area. For example: projects may 

result in the disturbance or destruction of cultural resources, the alteration or loss of historic character or 

integrity, or the reduced access or visibility of the resources to the public or stakeholders.
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To ensure the consistency with the FONSI, any activities under RFSI that may affect cultural resources will require 

a site-specific environmental review and consultation prior to implementation, following the procedures outlined 

in Chapter 6 of this PEA. The site-specific review will identify the potential impacts and mitigation measures for 

each project and evaluate the significance of the impacts.

The AMS RFSI Program will not have any cumulative impacts on cultural resources beyond those already 

occurring from existing food system operations in the project areas. The program will not result in any 

irreversible or irretrievable commitments of resources related to cultural resources. The program will not conflict 

with any plans, policies, or programs for the preservation of cultural resources.

Based on the analysis above, the AMS RFSI program will have no significant impact on cultural resources. No 

mitigation measures are required or recommended for this resource area. However, should any inadvertent 

discoveries of cultural resources be encountered during the implementation of the program activities, a sitespecific review process will be followed according to Chapter 6 of this PEA.

Coastal Barriers and Coastal Zones. Most activities under RFSI will occur either indoors or in previously 

disturbed areas adjacent to existing structures where there is little chance of impact to coastal barriers or coastal 

zones. Therefore, the potential impacts on coastal barriers or coastal zones from the proposed activities are 

expected to be negligible. No significant adverse effects on coastal ecosystems, habitats, species, or processes 

are anticipated. The proposed activities will comply with all applicable Federal, state, local laws, and regulations 

regarding coastal barriers or coastal zones protection.

However, some activities under RFSI may involve new structures, the expansion of existing structures, 

wastewater structures, or possible resource impacts not considered under this PEA, which may have direct and 

indirect impacts on coastal barriers or coastal zones. The type, magnitude, and duration of the impacts may 

depend on the location, scale, and design of the projects, and the sensitivity and adaptability of the affected 

coastal barriers or coastal zones. For example: some projects may require the clearing of land, the removal of 

trees, the alteration of landscapes, the installation of fences, or the short-term generation of noise which could 

affect the water quality and hydrology of coastal barriers or coastal zones.

To ensure the consistency with the Finding of No Significant Impact (FONSI), any activities under RFSI that may 

affect coastal barriers or coastal zones will require a site-specific environmental review and consultation or 

consistency review completion prior to implementation, following the procedures outlined in Chapter 6 of this 

Programmatic Environmental Assessment (PEA). The site-specific review will identify the potential impacts and 

mitigation measures for each project and evaluate the significance of the potential impacts.

The AMS RFSI Program will not have any cumulative impacts on coastal barriers or coastal zones beyond those 

already occurring from existing food system operations in the project areas. The program will not result in any 

irreversible or irretrievable commitments of resources related to coastal barriers or coastal zones. The program 

will not conflict with any plans, policies, or programs for the conservation of coastal barriers or coastal zones. A 

site-specific review process for RFSI Program activities that may impact coastal barriers or coastal zones will be 

followed according to Chapter 6 of this PEA.

Wild and Scenic Rivers and Nationwide Rivers Inventory. Most proposed activities under the AMS RFSI Program

will occur either indoors or in previously disturbed areas adjacent to existing structures where there is little 

chance of impact to Wild and Scenic Rivers or Nationwide Rivers Inventory. Therefore, the potential impacts on 

Wild and Scenic Rivers or Nationwide Rivers Inventory from the proposed activities are expected to be negligible. 
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No significant effects on river-related values, such as scenery, recreation, fish, and wildlife, historic, cultural, or 

other similar values are anticipated. The proposed activities will comply with all applicable Federal, state, local 

laws, and regulations regarding Wild and Scenic Rivers or Nationwide Rivers Inventory protection.

However, some activities under RFSI may involve new structures, the expansion of existing structures, 

wastewater structures, or possible resource impacts not considered under this PEA, which may have direct and 

indirect impacts on Wild and Scenic Rivers or Nationwide Rivers Inventory. The type, magnitude, and duration of 

the impacts may depend on the location, scale, and design of the projects, and the sensitivity and adaptability of 

the affected Wild and Scenic Rivers or Nationwide Rivers Inventory. For example: some projects may require the 

clearing of land, the removal of trees, the alteration of landscapes, or the short-term generation of noise which 

could affect the view shed, water quality, and hydrology of Wild and Scenic Rivers or Nationwide Rivers 

Inventory.

To ensure consistency with the Finding of No Significant Impact (FONSI), any activities under RFSI that may affect 

Wild and Scenic Rivers or Nationwide Rivers Inventory will require a site-specific environmental review and 

consultation or consistency review completion, as necessary, prior to implementation, following the procedures 

outlined in Chapter 6 of this Programmatic Environmental Assessment (PEA). The site-specific review will identify 

the potential impacts and mitigation measures for each project and evaluate the significance of the impacts.

The AMS RFSI Program will not have any cumulative impacts on areas listed as Wild and Scenic River systems or 

listed on the Nationwide Rivers Inventory beyond those already occurring from existing food system operations 

in the project areas. The program will not result in any irreversible or irretrievable commitments of resources 

related to areas listed as Wild and Scenic River systems or listed on the Nationwide Rivers Inventory. The 

program will not conflict with any plans, policies, or programs for the conservation or management of areas 

listed as Wild and Scenic River systems or listed on the Nationwide Rivers Inventory. 

Based on the analysis above, the AMS RFSI Program will have no significant impact on areas listed as Wild and 

Scenic River systems or listed on the Nationwide Rivers Inventory. No mitigation measures are required or 

recommended for this resource area. The program will not conflict with any plans, policies, or programs for the 

conservation of Wild and Scenic Rivers or Nationwide Rivers Inventory. A site-specific review process for RFSI 

Program activities that may impact Wild and Scenic Rivers or Nationwide Rivers Inventory will be followed 

according to Chapter 6 of this PEA.

Wilderness Areas and National Natural Landmarks. Most activities under the AMS RFSI Program will occur 

either indoors or in previously disturbed areas adjacent to existing structures where there is little chance of 

impact to Wilderness Areas or National Natural Landmarks. Therefore, the potential impacts on Wilderness 

Areas or National Natural Landmarks from the proposed activities are expected to be negligible. No significant 

effects on wilderness character traits or on biological and geological resources (such as scenery, habitats, 

species, or processes) are anticipated. The proposed activities will comply with all applicable Federal and state 

local laws and regulations regarding Wilderness Area and National Natural Landmark protection.

However, some activities under RFSI may involve new structures, the expansion of existing structures, 

wastewater structures, or possible resource impacts not considered under this PEA, which may have direct and 

indirect impacts on Wilderness Areas or National Natural Landmarks. The type, magnitude, and duration of the 

impacts may depend on the location, scale, and design of the projects, and the sensitivity and adaptability of the 

affected Wilderness Areas or National Natural Landmarks. For example: some projects may require the clearing 
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of land, the removal of trees, the alteration of landscapes, or projects in proximity that could affect the 

viewshed, Wilderness Areas or National Natural Landmarks.

To ensure the consistency with the Finding of No Significant Impact (FONSI), any activities under RFSI that may 

affect Wilderness Areas or National Natural Landmarks will require a site-specific environmental review and 

consultation or consistency review completion prior to implementation, following the procedures outlined in 

Chapter 6 of this PEA. The site-specific review will identify the potential impacts and mitigation measures for 

each project and evaluate the significance of the impacts.

The AMS RFSI Program will not have any cumulative impacts on Wilderness Areas and National Natural 

Landmarks beyond those already occurring from existing food system operations in the project areas. The 

program will not result in any irreversible or irretrievable commitments of resources related to areas listed as 

Wilderness Areas and National Natural Landmarks. The program will not conflict with any plans, policies, or 

programs for the conservation or management of areas listed as Wilderness Areas and National Natural 

Landmarks.

Based on the analysis above, the AMS RFSI Program will have no significant impact on Wilderness areas and 

National Natural Landmarks. No mitigation measures are required or recommended for this resource area. 

However, if any impacts on Wilderness Areas and National Natural Landmarks are encountered during the 

implementation of the program activities, a site-specific review process will be followed according to Chapter 6 

of this PEA. 

Floodplains and Wetlands. Most activities under the AMS RFSI Program will occur either indoors or in previously 

disturbed areas adjacent to existing structures where there is little chance of impacts to floodplains and 

wetlands. Therefore, the potential impacts on floodplains and wetlands from the proposed activities are 

expected to be negligible. No significant adverse effects on hydrology, soils, vegetation, wildlife, or other 

resources associated with floodplains and wetlands are anticipated. The proposed activities will comply with all 

applicable Federal, state, local laws, and regulations regarding floodplain and wetland protection.

However, some activities under RFSI may involve new structures, the expansion of existing structures, 

wastewater structures, or possible resource impacts not considered under this PEA, which may have direct and 

indirect impacts on floodplains and wetlands. The type, magnitude, and duration of the impacts may depend on 

the location, scale, and design of the projects, and the sensitivity and adaptability of the affected floodplains and 

wetlands. For example: some projects may involve the alteration or disturbance of floodplains and wetlands, 

such as filling, grading, new structures, or changes in water levels and drainage patterns that will require a sitespecific environmental review.

To ensure the consistency with the Finding of No Significant Impact (FONSI), any activities under RFSI that may 

affect floodplains and wetlands will require a site-specific environmental review and consultation review 

completion prior to implementation, following the procedures outlined in Chapter 6 of this PEA. The site-specific 

review will identify the potential impacts and mitigation measures for each project and evaluate the significance 

of the impacts.
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The AMS RFSI Program will not have any cumulative impacts on areas listed as floodplains or wetlands beyond 

those already occurring from existing food system operations in the project areas. The program will not result in 

any irreversible or irretrievable commitments of resources related to areas listed as floodplains or wetlands. The 

program will not conflict with any plans, policies, or programs for the conservation or management of areas 

listed as floodplains or wetlands.

Based on the analysis above, the AMS RFSI Program will have no significant impact on floodplains and wetlands. 

No mitigation measures are required or recommended for this resource area. However, if any inadvertent 

impacts on floodplains and wetlands are encountered during the implementation of the program activities, a 

site-specific review process will be followed including required permits according to Chapter 6 of this PEA.

Soils and Other Important Land Resources. Most activities under the AMS RFSI Program will occur either 

indoors or in previously disturbed areas adjacent to existing structures that are properly permitted where there 

is little chance of impact to soils and other important land resources. Therefore, the potential impacts on soils 

and other important land resources from the proposed activities are expected to be negligible. No significant 

adverse effects on soil quality, quantity, or productivity are anticipated. The proposed activities will comply with 

all applicable Federal and state local laws and regulations regarding soil and land resource protection.

However, some activities under RFSI may involve new structures, the expansion of existing structures, 

wastewater structures, or possible resource impacts not considered under this PEA, which may have direct and 

indirect impacts on soils and other important land resources. The type, magnitude, and duration of the impacts 

may depend on the location, scale, and design of the projects, and the sensitivity and adaptability of the affected 

soils and other important land resources. For example: some projects may involve the alteration or disturbance 

of soils and other important land resources, such as filling, grading, erosion, and sedimentation, or reduced 

biological productivity.

To ensure the consistency with the Finding of No Significant Impact (FONSI), any activities under RFSI that may 

affect soils and other important land resources will require a site-specific environmental review and consultation 

completion prior to implementation, following the procedures outlined in Chapter 6 of this PEA. The site-specific 

review will identify the potential impacts and mitigation measures for each project and evaluate the significance 

of the impacts.

The AMS RFSI Program will not have any cumulative impacts on soils and other important land resources beyond 

those already occurring from existing food system operations in the project areas. The program will not result in 

any irreversible or irretrievable commitments of resources related to areas related to soils and other important 

land resources. The program will not conflict with any plans, policies, or programs for the conservation or 

management of areas related to soils and other important land resources.

Based on the analysis above, the AMS RFSI Program will have no significant impact on soils and other important 

land resources. No mitigation measures are required or recommended for this resource area. However, if any 

inadvertent impacts on soils and other important land resources are encountered during the implementation of 

the program activities, a site-specific review process will be followed including required permits according to 

Chapter 6 of this PEA.
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Noise. Most activities under the AMS RFSI Program are designed to take place either indoors or in previously 

disturbed areas adjacent to existing, properly permitted structures; this minimizes the likelihood of increased 

noise levels. Noise can cause annoyance, disturbance, and complaints from the community. Noise can also 

disrupt the natural behavior and habitat of animals, especially those that rely on sound for communication, 

navigation, and survival. The potential impacts on noise from the proposed activities are anticipated to be 

negligible. The proposed activities will adhere to all relevant Federal and state local laws and regulations. 

However, some activities under RFSI may involve new structures, the expansion of existing structures, 

wastewater structures, or possible resource impacts not considered under this PEA, which may have direct and 

indirect impacts on noise. The type, magnitude, and duration of the impacts may depend on the location, scale, 

and design of the projects, and the sensitivity and adaptability of the affected environment. For example: an 

increase in traffic noise, construction and development noise may cause some species to temporarily avoid the 

area, humans may notice that ambient levels of noise increase during the construction phase, these impacts are 

expected to be short-lived and to return to normal levels upon completion of the construction.

To ensure the consistency with the Finding of No Significant Impact (FONSI), any activities under RFSI that may 

affect water will require a site-specific environmental review and consultation completion prior to 

implementation, if necessary, following the procedures outlined in Chapter 6 of this PEA. The site-specific review 

will identify the potential impacts and mitigation measures for each project and evaluate the significance of the 

impacts.

The AMS RFSI Program will not have any cumulative impacts on noise levels beyond those already occurring from 

existing food system operations in the project areas. The program will not result in any irreversible or 

irretrievable commitments of resources. The program will not conflict with any plans, policies, or programs.

Based on the analysis above, the AMS RFSI Program will have no significant impact on noise levels. No mitigation 

measures are required or recommended for this resource area. However, if impacts on noise levels are 

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

including required permits according to Chapter 6 of this PEA.

Air Quality. Most activities under the AMS RFSI Program are set to occur either indoors or in previously 

disturbed areas adjacent to existing, properly permitted structures. The potential impacts on air quality from the 

proposed activities are expected to be negligible. The proposed activities will comply with all relevant Federal, 

state, and local laws and regulations concerning the protection of air resources.

However, some activities under RFSI may involve new structures, the expansion of existing structures, 

wastewater structures, or possible resource impacts not considered under this PEA, which may have direct and 

indirect impacts on air quality. The type, magnitude, and duration of the impacts may depend on the location, 

scale, and design of the projects, and the sensitivity and adaptability of the affected environment. For example: 

Diesel exhaust from construction equipment; fugitive dust from earth moving and dirt roads; exhaust from 

onsite equipment and deliveries; release of particulate matter from initial installation of new equipment. As per 

the intent of the program, upon the completion of the initial installation, the expectation is that there will be a 

reduction in greenhouse gas emissions and improved air quality, as facility upgrades, and modern equipment 

purchases are expected to be more efficient.
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To ensure the consistency with the Finding of No Significant Impact (FONSI), any activities under RFSI that may 

affect air quality will require a site-specific environmental review and consultation completion prior to 

implementation, following the procedures outlined in Chapter 6 of this PEA. The site-specific review will identify 

the potential impacts and mitigation measures for each project and evaluate the significance of the impacts.

The AMS RFSI Program will not have any cumulative impacts on air quality beyond those already occurring from 

existing food system operations in the project areas. The program will not result in any irreversible or 

irretrievable commitments of resources related to air quality. The program will not conflict with any plans, 

policies, or programs for the conservation or management of air quality.

Based on the analysis above, the AMS RFSI Program will have no significant impact on air quality. No mitigation 

measures are required or recommended for this resource area. However, if any inadvertent impacts on air 

quality are encountered during the implementation of the program activities, a site-specific review process will 

be followed including required permits according to Chapter 6 of this PEA.

3.2 Resources Considered with Detailed Analysis

This section describes the environment that could be affected by implementing the alternatives 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 Water Quality

Definition of Resource

Water Quality is applicable to surface waters, as defined by The Environmental Protection Agency and the United 

States Army Corps of Engineers (USACE) as waters of the U.S., including streams, lakes, rivers, estuaries, coastal 

waters, and wetlands. The principal law governing pollution of the nation’s surface water resources is the Clean 

Water Act (CWA). The CWA aims to prevent, reduce, and eliminate pollution in the nation’s water to “restore 

and maintain the chemical, physical, and biological integrity of the Nation’s waters”, CWA Section 101 (a). 

The Clean Water Act was designed to eliminate the discharge of pollutants into U.S. waters and protect water 

quality. There is a permitting process in place to mitigate any negative impacts to water quality. 

Affected Environment

The RFSI Program does not increase any pesticide use in the environment, as it does not fund the use of 

pesticides on crops. However, some of the value-added products may require washing or rinsing before 

processing, which could introduce residual pesticides in rinse water. These pesticides are approved by the EPA 

for fruits and vegetables and typically degrade or wash off within 5-7 days after application. They also have EPA 

mandated harvest restrictions after application. Therefore, the water quality concern is minimal, and no permits 

are necessary.

States and Tribes are additionally 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.” Alternatively refer to regulatory considerations under Section 5.1.
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Major impacts on water quality are not anticipated, given the individual project funding levels and program 

limitations. Infrastructure improvements performed under the RFSI Program with extraordinary circumstances 

may require consultation with the USACE and a Section 404 permit or require a Section 402 NPDES permit from 

the state or Tribal authority and undergo an additional level of regulatory review.

The RFSI Program is designed to have a positive impact on maintaining existing food system resilience and 

establishing more opportunities for a sustainable food system. By supporting the middle segment of the food 

supply chain, the RFSI Program can expand capacity for processing, aggregation, and distribution of agricultural 

products. The program will encourage projects which reduce food waste, increase food access, enhance food 

quality and safety, and promote local and regional food systems. The RFSI Program can also foster innovation and 

collaboration among food system stakeholders, such as farmers, processors, distributors, retailers, consumers, 

and policymakers. 

Environmental Consequences

No Action Alternative

Under the No Action Alternative, the potential benefits of the RFSI Program are aimed to build resilience in the 

middle of the food supply chain, provide more and better markets to support the development of value-added 

products for consumers, and support fair prices and wages would not be realized.

Proposed Action Alternative 

Under the Proposed Action Alternative, AMS would make funds available through the RFSI Program. 

The RFSI program represents a significant step towards creating robust local food economies that offer more and 

better market opportunities creating new streams of revenue for small and mid-sized agricultural producers.

Through implementation of all pertinent Federal, State, and local regulatory requirements, good engineering 

practices, construction BMPs, as well as applicable stormwater pollution prevention controls during 

infrastructure improvements, the program anticipates no significant adverse effects to water quality. However, if 

any unforeseen impacts on water quality are detected during the implementation of the program activities, a 

site-specific environmental evaluation process will be conducted according to Chapter 6 of the PEA. 

3.2.2 Socioeconomics and Environmental Justice

Definition of Resource

Socioeconomics is a branch of economics that studies how social processes affect and are affected by economic 

activity. Socioeconomics considers factors such as income, education, occupation, place of residence, ethnicity, 

and religion, and how they influence the well-being, opportunities, and choices of individuals and groups. 

Socioeconomics also examines how economic policies and practices impact the distribution of wealth, power, 

and resources among different segments of society. A USDA Programmatic Environmental Assessment (PEA) 

should analyze the socioeconomic impacts of the proposed actions and alternatives on the affected 

communities, such as changes in employment, income, production, consumption, public services, and quality of 

life.
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Environmental justice is the fair treatment and meaningful involvement of all people, regardless of race, color, 

national origin, or income, with respect to the development, implementation, and enforcement of 

environmental laws, regulations, and policies. Environmental justice aims to ensure that no population bears a 

disproportionate share of negative environmental consequences resulting from industrial, municipal, and 

commercial operations or from the execution of federal, state, and local laws; regulations; and policies. 

Environmental justice also requires effective access to decision makers for all, and the ability in all communities 

to make informed decisions and take positive actions to produce environmental justice for themselves. A USDA 

Programmatic Environmental Assessment (PEA) should evaluate the environmental justice impacts of the 

proposed actions and alternatives on the affected communities, such as potential effects on health, safety, 

culture, subsistence, and human rights.

Affected Environment

The Resilient Food Systems Infrastructure (RFSI) Program is designed to build resilience in the middle of the food 

supply chain, provide more and better markets to small farms and food businesses, support the development of 

value-added products for consumers, ensure fair prices and wages, and create new and safe job opportunities. 

Food resilience ensures that the food system can withstand and recover from disruptions, guaranteeing a 

sufficient supply of acceptable and accessible food for all.

RFSI aims to provide opportunities to create more and better processing options for local and regional producers 

across the specialty crops, dairy, grain and other non-meat and poultry sectors. This will create more diverse 

local and regional market options and create more economic opportunities for communities, allowing them to 

retain more of the monetary value within that populace. The RFSI Program supports proposals that provide fair 

prices, fair wages, and new and safe job opportunities that keep profits in rural communities and will increase 

diversity in processing options in terms of business model approaches, geography, and availability of 

underserved communities. 

However, the specific impacts on socioeconomic development and environmental justice would depend on the 

implementation of the program and the specific projects undertaken. 

The statistics in figure 1 highlight the challenges faced by those living in the underserved communities within the 

United States and underscore the importance of programs and policies aimed at improving food resilience and 

security among these populations. In its funding distribution, AMS weighted the state’s percent share of rural 

populations living in distressed communities to direct more funds towards those areas, as defined by the 

Distressed Communities Index (DCI). The DCI is a tool for measuring the comparative well-being of U.S. 

communities and helps illuminate ground level disparities across the country. The seven components of the 

index are: no high school diploma, housing vacancy rate, adults not working, poverty rate, median income ratio, 

change in employment and change in establishments. 
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Figure 1 shows that 14.8% of the United States qualifies as a distressed community based upon the U.S. Census 

reports (Group 2023). 

Figure 1. Distressed Communities in the U.S. (Group 2023)

States will have the ability to distribute funds to areas with historically underserved producers and allow them 

the ability to retain a large portion of the profits by having access to markets. The RFSI Program is designed to 

have a positive impact on maintaining existing food system resilience and establishing more opportunities for 

local and regional food systems. 

Environmental Consequences

No Action Alternative 

The No Action Alternative would eliminate the potential for positive socioeconomic impacts and could mean that 

the existing conditions continue without the implementation of the AMS RFSI program.

Under the No Action Alternative, the potential benefits of the AMS RFSI program in terms of environmental 

justice and socioeconomic impacts may not be realized. These benefits include strengthening regional food 

economies, increasing access to local knowledge and networks, and potentially improving food access and 

economic conditions in local communities, especially those primarily considered to be underserved and at risk.

Proposed Action Alternative

Under the Proposed Action Alternative, AMS would make funds available through the AMS RFSI Program. 

The benefits of the AMS RFSI program on socioeconomic development are numerous. It supports the 

development of business plans, and strategies for local and regional marketing opportunities, and local and 

regional food systems infrastructure development. It also aids in regional food system development and 
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improved healthy food access through community collaboration and expansion of food hubs, mid-tier value 

chains, and other similar types of business ventures. Furthermore, it creates economic opportunities for 

producers and food businesses through possible job creation.

Overall, the AMS RFSI program represents a significant step towards creating robust local and regional food 

economies that are economically viable and socially equitable.

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

for Socioeconomic and Environmental Justice. However, if any unforeseen impacts on Socioeconomic and 

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

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

3.2.3 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 temperatures and precipitation patterns, increases in 

ocean temperatures, sea level and acidity, melting 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 2) through 

sources such as 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). 
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Figure 2. Sources of U.S. Greenhouse Gas Emissions in 2021.

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

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

Environmental Consequences

USDA promotes climate-resilient landscapes and rural economic systems, including tools to support agriculture, 

forests, grazing lands, and rural communities. AMS encouraged applicants to consider including goals and 

activities related to mitigating or adapting to climate change in their project’s design and implementation.

No Action Alternative 

Not implementing the Resilient Food Systems Infrastructure (RFSI) Program would miss the opportunity to create 

positive impacts on climate change. The middle of the supply chain improvements would be forgone, and the 

trajectory would remain unchanged. 

Proposed Action Alternative

The RFSI Program encourages applicants to consider goals and activities related to reducing and stabilizing the 

levels of heat-trapping greenhouse gases in the atmosphere or adapting to the already occurring climate change 

in their project’s design and implementation. 

The AMS RFSI Program can have several climate change benefits:

Agriculture

10%

Commercial & 

Residential

13%

Industry

23%

Transportation

28%

Electric Power

25%
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• Reducing Greenhouse Gas Emissions: The program encourages the development, customization, or 

installation of equipment that reduces greenhouse gas emissions. This could include energy-efficient 

machinery, renewable energy sources, or practices that sequester carbon in the soil.

• Increasing Efficiency in Water Use: The program supports initiatives that increase efficiency in water 

use. Efficient water use is crucial in the context of climate change, as it can help mitigate the impacts 

of droughts and water scarcity.

• Improving Air and Water Quality: The program also aims to improve air and water quality. This could 

involve supporting farming practices that reduce air and water pollution, which can also contribute 

to climate change mitigation.

• Supporting Climate-Smart Agriculture: The program supports the development of value-added 

products for consumers. This could include products that are produced using climate-smart 

agricultural practices, which increase productivity, build resilience, and reduce emissions.

• Building Resilience: By building resilience in the middle of the food supply chain, the program can 

help ensure that the food system can withstand and recover from the impacts of climate change.

The AMS RFSI Program represents a significant step toward creating robust local and regional food economies.

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

for climate change. However, if any unforeseen impacts on climate change are detected during the 

implementation of the program activities, a site-specific environmental evaluation process will be conducted 

according to Chapter 6 of this PEA.

4.0 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 pandemic and recent supply chain disruptions have revealed the perils of a national food system that 

depends on capacity concentrated in a few geographic areas and requires many steps to get from farm to fork. 

Although the pandemic has subsided and the food supply chains have largely recovered to their pre-pandemic 

levels, the looming threat of climate change makes it imperative for the nation to enhance its resilience, 

especially regarding its food systems. The future food systems need to be more diversified, distributed, and local, 

so that they can adapt to the changing environmental conditions and reduce the risks of disruptions and 

shortages in national supply chains.
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Considering the ongoing climate crisis, the RFSI Program would urge applicants to incorporate goals and activities 

that aim to mitigate or adapt to the effects of climate change in their project’s design and implementation. This 

could include reducing and stabilizing the levels of greenhouse gases that trap heat in the atmosphere or 

adjusting to the already observed changes in the climate that impact the food systems.

4.3 Cumulative Impacts of the Proposed Action

The RFSI Program aims to enhance the sustainability and resilience of food systems by supporting the adoption 

of climate smart equipment that reduces greenhouse gas emissions and water consumption, as well as 

improving air quality and creating employment opportunities. The environmental impacts of implementing this 

program are expected to be negligible or slightly positive, as no significant adverse effects on the natural 

resources, ecosystems, or human health are anticipated. 

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. Irretrievable resource 

commitments involve the loss in value of an affected resource that cannot be restored because of the action. The 

implementation of the AMS RFSI Program would result in no irreversible or irretrievable resource commitments.

5.0 Compliance with Environmental Laws and Regulations 

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

authorities would 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.
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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 the 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 according to 

CWA.

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

and Tribes. Section 319 of the CWA requires states and Tribes to identify waters impaired by non-point 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. 

Major impacts on water quality are not anticipated, given the individual project funding levels and program 

limitations. Activities performed under the AMS Resilient Food Systems Infrastructure (RFSI) Program with 

extraordinary circumstances may require consultation with the USACE and a Section 404 permit or require a 

Section 402 NPDES permit from the state or Tribal authority and undergo an additional level of regulatory 

review. 

5.2 Coastal Zone Management Act (CZMA)

The Coastal Zone Management Act encourages coastal states, Great Lakes states, and US 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 National Oceanic and Atmospheric Administration (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 Resilient Food Systems Infrastructure (RFSI) 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 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 
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expenditures and financial assistance within the Coastal Barrier Resources System (CBRS), but only after 

consultation with the US Fish and Wildlife Service. 

Activities performed under the Resilient Food Systems Infrastructure Program with extraordinary circumstances 

may require a consultation with US Fish and Wildlife Service for activities taking place within a state-designated 

coastal barrier resource area. Each project will be evaluated in accordance with the CBRA, and additional 

regulatory review will be performed on a case-by-case basis.

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 consultations are required with the 

FWS or NMFS. Informal consultation requires that the action agency prepare a Biological Assessment for 

concurrence by the FWS or NMFS.

A formal Section 7 consultation results in a Biological Opinion (BO) prepared by the NMFS or FWS. If 

unintentional but not unexpected take of ESA-listed species may result from the action, and it is determined that 

the take would not jeopardize the continued existence of the species, the BO may include an incidental take 

statement. The incidental take statement specifies the amount or extent of anticipated take that is allowable due 

to the Federal action. It also outlines reasonable and prudent measures to minimize the take, and terms and 

conditions that must be observed when implementing those measures.

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 site-specific environmental 

evaluation consistent with Chapter 6 below. 

5.5 Farmland Protection Policy Act (FPPA)

The FPPA, implemented by the USDA Natural Resources Conservation Service, 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 the AMS RFSI Program are already converted and therefore not subject to the FPPA.
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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 the AMS RFSI Program are expected to have no adverse impacts on migratory bird 

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

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

5.7 National Historic Preservation Act (NHPA)

The NHPA of 1966, amended in 1992, requires that responsible agencies taking actions 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 (ACHP). 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 Office (SHPO) and/or Tribal Historic Preservation 

Officer (THPO).

The AMS RFSI Program, while unlikely to affect cultural resources, requires associated site-specific projects to 

comply with the NHPA by coordinating with the SHPO, THPOs, or relevant Tribes, when necessary, in accordance 

with Chapter 6 of this PEA.

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 evaluation 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 
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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 AMS RFSI Program projects would occur within wilderness areas. However, if extraordinary 

circumstances are identified, consultations would be initiated at the earliest planning stage for site-specific 

environmental evaluation consistent with Chapter 6 below.

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.

There should be no AMS RFSI Program activities that will impact a wetland. Should there be any existing facility 

upgrades that are within a wetland area, proper USACE permits will be required prior to project activities. 

5.11 Executive Order 11998: Floodplain Management

The purpose of Executive Order (EO) 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 each Federal agency take actions 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, then the agency shall consider 

alternatives to avoid adverse effects and incompatible development in the floodplains.

When an AMS RFSI Program project involves access or improvement activities impacting a floodplain, AMS will 

ensure a floodplain development permit is obtained. 

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

Minority Populations and Low-Income Populations

The purpose of Executive Order (EO) 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. AMS complies with EO 12898 by reviewing a proposed 

project to identify the presence of low-income and/or minority populations that could be affected by the project. 

AMS then analyzes if those populations/communities would bear any disproportionately high and adverse 

human health or environmental effects from the project’s implementation. If AMS determines that the proposed 

project could cause disproportionately high and adverse effects for low-income or minority populations, 

measures to minimize, mitigate, or avoid those impacts would be implemented. 
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Activities under the AMS RFSI Program are not expected to result in disproportionate adverse impacts to 

minority and low-income populations, as an adverse impact would defy the purpose of the program. Further, the 

RFA states AMS will prioritize applications from applicants that engage with underserved producers. AMS also 

encouraged applications that support smaller farms and ranches in the region, new and beginning farmers and 

ranchers, veteran producers, and/or underserved communities. Therefore, it is expected that the AMS RFSI 

Program will have beneficial long-term and short-term impacts to communities with environmental justice 

concerns. 

5.13 Executive Order 14008: Tackling the Climate Crisis at Home and Abroad

The purpose of (EO) 14008 builds on and reaffirms actions already taken to place the climate crisis at the 

forefront of this Nation’s foreign policy and national security planning, including submitting the United States 

instrument of acceptance to rejoin the Paris Agreement. In implementing — and building upon — the Paris 

Agreement’s three overarching objectives (a safe global temperature, increased climate resilience, and financial 

flows aligned with a pathway toward low greenhouse gas emissions and climate-resilient development), the 

United States will exercise its leadership to promote a significant increase in global climate ambition to meet the 

climate challenge.

The AMS RFSI Program is designed to encourage a wide range of activities to fund applications that support the 

development, coordination, and expansion of direct producer-to-consumer marketing, local and regional food 

markets and enterprises, and value-added agricultural products. 

5.14 Executive Order 14017: Executive Order on America’s Supply Chains

Executive Order (EO) 14017 was issued to strengthen the resilience of America’s supply chains for critical 

products and sectors, such as semiconductors, batteries, pharmaceuticals, and minerals. The order directed each 

department in the administration to assess potential supply-chain risks within their jurisdiction and come up 

with strategies to mitigate or overcome these. The order also sought to revitalize the U.S. manufacturing base, 

promote innovation and research, create well-paying jobs, and cooperate with allies and partners who share our 

values.

In response, USDA published a report outlining the risks and resilience of the US agri-food supply chains, as well 

as identifying potential solutions to address vulnerabilities. This report was informed by public comments 

solicited through the Federal Register. 

The AMS RFSI program responds to the recommendations of this report by supporting partnerships that connect 

public and private resources to plan and develop local or regional food systems. It focuses on strengthening the 

viability and resilience of regional food economies through collaboration and coordination. The program offers 

different types of projects, including planning and design, implementation and expansion, and farms to 

institutions. The goal is to strengthen the food supply chain at the local level.

6.0 Implementation 

Site-specific actions are projects undertaken or funded by AMS through the RFSI Program 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 applications received for the RFSI Program. For any 

future funding opportunities considered substantially similar, AMS would review the PEA, and relevant 
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environmental concerns, to determine whether the PEA’s scope and analysis remain applicable to the program. If 

the program’s mandate or focus shifts substantially during that time, a new PEA may be prepared, or this PEA 

may require additional environmental evaluation to allow evaluation under the existing FONSI.

As site-specific actions are being considered under the AMS RFSI Program, this PEA would 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 CFR. 1508.28, the 

tiered NEPA documents would 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 evaluation analysis would be prepared consistent with CEQ regulations at 40 CFR 

1500-1508 if:

• The AMS RFSI 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. 

The RFSI Program funding covers most projects which have minimal or no impact on any protected resources, 

and they can be evaluated under the Programmatic Environmental Assessment (PEA). However, some 

extraordinary circumstances, such as new or expanded structures, wastewater structures, or potential resource 

impacts, may have direct or indirect effects on protected resources and will need further review using the sitespecific environmental review below. The utilization of the NEPA Screening Flowchart (Figure 3) will assist in 

determining if the proposed action is consistent with the Finding of No Significant Impact (FONSI).

When it is found that the PEA may not cover the scope or impacts of the proposed action, these are called 

extraordinary circumstances. The Agency must do a site-specific analysis that fills in the gaps of this PEA. This 

way, the Finding of No Significant Impact (FONSI) can be valid for the specific site.

Some examples of extraordinary circumstances are:

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

as endangered species, remodeling, or demolition of structures older than 50 years of age, 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.
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The Agency should engage with relevant stakeholders, such as other agencies, Tribes, Fish and Wildlife Service, 

or the public, to ensure that the environmental impacts of the action are thoroughly addressed in the sitespecific environmental review. If an extraordinary circumstance is identified, and the agency cannot confirm that 

the FONSI is still applicable after further investigation, the agency should document the reasoning for why the 

PEA does not apply.

Figure 3. NEPA Screening Flowchart

RFSI

NEPA Screening 

Site Specific Environmental Review

Further investigation needed to demonstrate 

actions are within the scope of the PEA and do 

not have significant impacts not already 

analyzed. 

(Refer to contractor for

evaluation of protected resources and 

consultations)

Environmental Review Complete

A review indicated the proposed project is unlikely to have Impacts to 

Protected Resources.

Proceed with evaluation.

(If applicable site specific forms are saved to agency record)

Project Outside Scope of NEPA

The PEA and FONSI do not cover the 

project. AMS will determine the 

appropriate level of NEPA analysis and 

documentation for the project.

No

New or 

Expanded 

Structures, or

Possible Resource 

Impacts?

No

Yes

Yes

Potentially 

Significant 

Impacts?

Project 

determined 

consistent with 

RFSI

Yes

Resilient Food Systems Infrastructure Program 

NEPA Review 
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7.0 List of Preparers and Reviewers and Agencies Contacted 

List of Preparers

Name and Title Education and Experience

Jason E. McMillin, Natural 

Resource Specialist, FPAC BC, 

Environmental Activities Division

MS Certificate in Energy and Environmental Law, Texas A&M 

University School of Law, MS Agriculture Economics, Texas A & M 

University

BS Agriculture Business & Management, Texas State University

21 Years of experience in preparing NEPA documents for USDA

Adriana Alcorn, Agricultural 

Program Specialist, Iowa SEC

Compliance Specialist

BA in Criminal Justice, Loras College 

State Environmental Coordinator

7 years of experience in preparing environmental documents for 

USDA

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 26 years of 

Federal government experience. Ph.D. Entomology.

Betsy Rakola, Associate Deputy 

Administrator

USDA Agricultural Marketing Service, Transportation and 

Marketing Program

Master of Science in Agriculture, Food, and Environment; Tufts 

University 

Emily West, Grants 

Management Specialist

USDA Agricultural Marketing Service, Transportation and 

Marketing Program

Bachelor of Technology; Animal Science, State University of New 

York at Cobleskill

Lara Shockey, Natural Resource 

Specialist

USDA Agricultural Marketing Service, Transportation and 

Marketing Program

Bachelor of Science in Agricultural and Environmental Education, 

Master of Science in Agriculture; West Virginia University, 8 Years 

of experience in preparing NEPA documents for USDA
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8.0 References 

American Farmland Trust (AFT). (2018). Greener Fields: California Communities Combating Climate Change. 

American Farmland Trust, Washington, D.C. Available: https://s30428.pcdn.co/wpcontent/uploads/sites/2/2019/09/AFT_CA-GrFields-web3_0.pdf. 

Canter, Larry W. 1996. Environmental Impact Assessment. McGraw-Hill.

Congressional Research Service (CRS). (2021). Racial Equity in U.S. Farming: Background in Brief. Available at: 

https://crsreports.congress.gov/product/pdf/R/R46969. 

Council on Environmental Quality (CEQ). (1997). The National Environmental Policy Act: a study of its 

effectiveness after twenty-five years. Executive Office of the President, Washington, D.C. Available: 

http://www.blm.gov/or/regulations/files/nepa25fn.pdf. 

Economic Research Service (ERS). (2019). Characteristics of principal farm operator households, by limitedresource farm status, 2016. Available: 

https://www.ers.usda.gov/webdocs/DataFiles/48870/table11.xls?v=6191.3. 

Environmental Protection Agency. (2022). Frequently Asked Questions About Climate Change [Website]. 

Available: https://www.epa.gov/climatechange-science/frequently-asked-questions-about-climatechange#climate-change.

Environmental Protection Agency. (2023). Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2021. EPA 

430-R-23-002. Available: https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-andsinks1990-2021. 

National Environmental Policy Act (NEPA) Task Force. (2003). The NEPA Task Force Report to the Council on 

Environmental Quality: Modernizing NEPA Implementation. Executive Office of the President, Washington, D.C. 

Available: http://ceq.hss.doe.gov/ntf/report/totaldoc.html. 

National Agricultural Statistics Service (NASS). (2017). 2017 Census of Agriculture. Available: 

www.nass.usda.gov/AgCensus. 

Plater, Z.J.B., R. Abrams, and W. Goldfarb. (1992). Environmental Law and Policy: A Coursebook on Nature, Law, 

and Society. West Publishing Company, St. Paul, Minnesota.

The White House. (2022). Biden-Harris Administration Launches Version 1.0 of Climate and Economic Justice 

Screening Tool, Key Step in Implementing President Biden’s Justice40 Initiative [Press release]. Available: 

https://www.whitehouse.gov/ceq/news-updates/2022/11/22/biden-harris-administration-launches-version-1-0-

of-climate-and-economic-justice-screening-tool-key-step-in-implementing-president-bidens-justice40-initiative/.

United States Department of Agriculture (USDA) Civil Rights Action Team. (1997). Civil rights at the United States 

department of agriculture. United States Department of Agriculture, Washington, DC.

Agency, Environmental Protection. 2023. Basics of Climate Change. https://www.epa.gov/climatechangescience/basics-climate-change .

—. 2023. Climate Adaptation and EPA's Role. https://www.epa.gov/climate-adaptation/climate-adaptation-andepas-role#:~:text=Definitions,levels%20of%20atmospheric%20greenhouse%20gases.
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—. 2023. Greenhouse Gases. https://www.epa.gov/report-environment/greenhousegases#:~:text=Greenhouse%20gases%2C%20such%20as%20carbon,retaining%20heat%20in%20the%20a

tmosphere.

—. 2023. Managing Air Quality- Ambient Air Monitoring. https://www.epa.gov/air-quality-managementprocess/managing-air-quality-ambient-air-monitoring.

Ahammad, Heal, Harry Clark, Hongmin Dong. 2014. "Agriculture, Forestry and." Cambridge University Press, 

Cambridge, United . https://www.ipcc.ch/site/assets/uploads/2018/02/ipcc_wg3_ar5_chapter11.pdf.

Briefing, White House. 2021. Execuitve Order on Promoting Competition in the American Economy.

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Room, The White House Briefing. 2021. Executive Order on Tackling the Climate Crisis at Home and Abroad.

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—. 2023. Fact Sheet: Presdient Biden Signs Executive Order to Stregthen Racial Equity and Support for 

Underserved Communities Across the Federal Government. https://www.whitehouse.gov/briefingroom/statements-releases/2023/02/16/fact-sheet-president-biden-signs-executive-order-to-strengthenracial-equity-and-support-for-underserved-communities-across-the-federalgovernment/#:~:text=The%20Executive%20Order%20d.

Service, USDA Economic Research. 2023. Food Security in the U.S. Key Statistics and Graphics. June 20. Accessed 

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Appendix 

Appendix A - AMS ENV-A – Environmental Prescreening Worksheet
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Appendix B - AMS ENV-B – Environmental Screening Worksheet
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