USDA R.D. Listening Session tomorrow: VAPG & Food Safety Financial Assistance

  • USDA R.D. Listening Session tomorrow: VAPG & Food Safety Financial Assistance

  • Elizabeth Atwell

    Member
    October 5, 2021 at 9:55 AM

    Hey friends – see below a message from NSAC on an upcoming opportunity for you to weigh in on a Farm Bill funded effort that would allow Value Added Producer Grants to provide financial assistance for food safety implementation and equipment costs. For context, I have included the whole message from NSAC below, but the questions related to food safety are in bold. It would be great to have someone(s) from the Food Safety and Quality Community of Practice weigh in on this program! As a reminder we have our CoP meeting tomorrow from 1-2:30pm EST. If anyone wants to duck to early to attend this listening session, let us know.

    Talk soon!

    Elizabeth

    _

    It’s finally happened! USDA Rural Development has begun to move forward with implementing the food safety financial assistance component of the program we helped to secure during the 2018 Farm Bill (yes it took them long enough).

    Last week a notice in the federal register was published announcing a listening session and a request for information about the subject of food safety and VAPG and a couple other questions.

    The listening session will be held on: October 6, 2021 at 2:00 PM – 4:00 PM ET

    Register for the listening session here.

    Both the MFSRD and FSI committees are going to be putting together and submitting a comment, thankfully they have provided 60 days to respond and the questions are a lot more straightforward than some of the other comment opportunities USDA has opened up this year.

    The request for information and listening session revolves around 4 questions (see below) and we are looking for input from members on the questions. We have already developed a lot of the materials and information relevant to the questions during previous work around implementation of the 2018 Farm Bill that we will be using to inform the development of our comment. However, we wanted to still revisit the questions and solicit input from members as there are some questions we had not previously contemplated.

    We are hoping in addition to NSAC comment, a handful of members will also submit comments and attend the listening session to provide feedback. With everything else going on (reconciliation, priority setting, Farm bill 2023 prep work) we most likely will not be able to develop a template or model for others to use for commenting, however attached you will find the original one-pager about the changes we helped secure in the farm bill that also lays out the overall approach we developed. Also, attached is a chart we developed with member input to detail proposed eligible food safety costs that should be supported.

    Brief Background:

    During the 2018 Farm Bill we were originally pushing for a separate food safety financial assistance program to provide small grants to farmers for food safety related upgrades and food safety audits. Instead of creating a new separate program Congress folded it into VAPG and we have been pushing USDA for years to implement it via creating a 3rd option to VAPG. 1. planning/feasibility, 2. working capital, 3. food safety only (while also allowing food safety to be part of 1 and 2).

    Federal Register Questions:

    1. The Agricultural Improvement Act of 2018 (2018 Farm Bill) added food safety and food safety equipment as eligible use of program funds. RBCS is seeking feedback on applicant eligibility requirements as it relates to food safety and food safety equipment.

    a. The 2018 Farm Bill requires food safety to be an eligible activity in 7 CFR Part 4284 Subpart J. In defining food safety, what can be included in the definition to further assist the applicants with understanding what qualifies as food safety?

    b. The 2018 Farm Bill requires food safety equipment to be an eligible expense in 7 CFR Part 4284 Subpart J. What can be included in the definition of food safety equipment to further assist the applicants with understanding what qualifies as food safety equipment?

    c. The 2018 Farm Bill allows expenses relating to costs incurred in obtaining food safety certifications. Given that eligible cost must be related to post-harvest value added activities for the VAPG program, what type of food safety certifications should be included as eligible expenses?

    d. The 2018 Farm Bill allows for recipients to make changes and upgrades to food safety practices. Given that eligible costs for the VAPG program must be related to post-harvest value-added food safety practices, what would you like to see as eligible uses of funds?

    e. The 2018 Farm Bill further states that a recipient may use not more than $6,500 of the amount of a grant to purchase or upgrade equipment to improve food safety. Given that eligible cost for the VAPG program must be related to post-harvest value-added activities, what would you like to see included as eligible uses of funds as it relates to food safety equipment?

    f. The 2018 Farm Bill requires that a reserve be established for food safety assistance of not more than 25 percent of the available funds. However, other statutory reserved fund categories (set-aside) such as Beginning Farmer or Rancher, Socially Disadvantaged Farmer or Rancher, and Mid-Tier Value Chain projects are each currently capped at 10 percent of program funds. Are there any compelling reasons to establish a food safety set-aside higher than 10 percent?

    2. RBCS is seeking feedback on the submission of a Business Plan related to a VAPG project. Currently, the VAPG program requires the Business Plan be completed by a Qualified Consultant and specifically for the proposed value-added project. However, RBCS has considered changing this requirement to allow applicants to prepare their own Business Plan associated with the value-added project without the assistance of a Qualified Consultant.

    Should an applicant be allowed to prepare their own Business Plan without the assistance of a Qualified Consultant?

    Are there any unforeseen issues with allowing the applicant to prepare their own Business Plan?

    Would not requiring business plans from qualified consultants set up projects for failure?

    3. RBCS is seeking feedback for evaluating and measuring the economic impact of the program on new and existing market outcomes related to the post-harvest value-added activities. Currently our program measures the production of value-added products, job creation, and increases in revenue return and customer base to the producer as a result of the value-added project. Are there other outcomes related to the value added project that RBCS should be measuring?

    4. RBCS seeks feedback on when the application deadline for the program should be. It is our intention to have a consistent deadline from year to year, rather than released at variable times through a Federal Register Notice. In keeping with traditional agricultural production cycles, we are trying to avoid an application deadline during production season. What would be an appropriate application deadline date for the VAPG program?

  • Lindsay Gilmour

    Member
    October 5, 2021 at 12:14 PM

    Hey Liz

    do you have the attachments that came with this NSAC email? I usually get these emails. Not sure Why I missed it.

    Linds

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