VAPG 2018 Burden Package Supporting Statement - Final

VAPG 2018 Burden Package Supporting Statement - Final.doc

Value Added Producer Grant Program

OMB: 0570-0064

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2018 - SUPPORTING STATEMENT

Value-Added Producer Grants

Part 7 CFR 4284, subpart J

0570-0064

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The Cooperative Programs unit within the Rural Business-Cooperative Service administers the Value-Added Producer Grant (VAPG) program with significant support from State Rural Development Offices. The primary objective of this program is to encourage producers of agricultural commodities to further refine or otherwise add value to these commodities to increase their value to end-users of the product. These grants encourage greater participation in markets for value-added agricultural products and facilitate opening new markets for value-added agricultural products. Grants are awarded either for planning purposes such as conducting a feasibility study or developing a business plan or for working capital expenses such as inventory, utilities, and salaries.

The VAPG program is currently approved under 0570-0064 and is authorized under section 231 of the Agriculture Risk Protection Act of 2000 (P. L. 106-224), as amended by section 6203 of the Agricultural Act of 2014 (P. L. 113-179) (see 7 U.S.C. 1632a). Funds are appropriated annually. In addition, the 2014 Farm Bill provided $60 million in mandatory funds. The Agency requests grant applications using a Notice once a year in the Federal Register.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the Agency has made of the information received from the current collection.

Information is collected by Rural Development State and Area office staff, as delegated, from applicants and grantees. The application information is used to confirm that the applicant and use of funds meet the eligibility requirements for the program as well as to assess the quality of the proposed project. The grantees are required to submit financial status and performance reports to confirm funds are being expended as approved and requests for advance or reimbursement to request payment.

PAPERWORK REQUIREMENTS – FORMS

Form AD-1047, “Certification Regarding Debarment, Suspension, and Other Responsibility Matters – Primary Covered Transactions,” to be completed once at the time of grant award. This form is submitted by the grantee and is used by the Agency to confirm that the applicant organization and its principles are not debarred, suspended, or otherwise excluded from receiving Federal assistance.

Form AD-1048, “Certification Regarding Debarment, Suspension, and Other Responsibility Matters – Lower Tier Covered Transactions,” to be completed each time the grantee will be entering into financial transactions with third-parties using grant or matching funds. This form is completed by any sub-grantees or sub-contractors and is used by the Agency to confirm that these organizations are not debarred, suspended, or otherwise excluded from receiving Federal assistance.

Form AD-1049, “Certification Regarding Drug-Free Workplace Requirements (Grants),” to be completed once at the time of grant award. This form is submitted by the grantee and is used by the Agency to confirm that the grantee will provide a drug-free workplace in accordance with 7 C.F.R. §3017.600.

Form DD-214 “Report of Separation from the U.S. Military,” to be completed once at time of application. This form is submitted by Veteran Farmer or Rancher applicants seeking priority points, in accordance with 7 CFR4284.924.

Form RD 400-4, “Assurance Agreement” (OMB No. 0575-0018). This form is executed by recipients of Rural Development’s Federal financial assistance as an assurance that the recipient will comply with the requirements of Title VI of the Civil Rights Act of 1964.

Form RD 1940-1, “Request for Obligation of Funds” (OMB No. 0570-0062), to be completed once at the time of award. This form is submitted by the grantee and used by the Agency to obligate funds.

Form RD 1942-46, “Letter of Intent to Meet Conditions” (OMB No. 0570-0062). The applicant must complete, sign and return to the Agency.

Form RD 4280-2, “Rural Business-Cooperative Service Financial Assistance Agreement” (OMB No. 0570-0067). This form must be signed by the Agency and the recipient before the award is considered approved.

PAPERWORK REQUIREMENTS – NO FORMS

Project Proposal – Working Capital Grants. Applicants must submit a project proposal to apply for a working capital grant. This grant is used to provide funds to operate a value-added project, specifically to pay the eligible project expenses related to the processing and/or marketing of the

Value-Added Agricultural Product that are eligible uses of grant funds.

Project Proposal – Simplified Applications. Applicants requesting less than $50,000 for a working capital grant will be allowed to submit a simplified application.

Project Proposal – Planning Grant Applications. Applicants must submit a project proposal to apply for a planning grant. This grant is used to facilitate the development of a defined program of economic planning activities to determine the viability of a potential value-added Venture, and specifically for the purpose of paying for conducting and developing a Feasibility Study, Business Plan, and/or Marketing Plan associated with the processing and/or marketing of a Value-Added Agricultural Product.

Priority Point Requirement for Best Contributes. Applicants for planning grants must suggest at least one criterion by which their performance under a grant could be evaluated. Applicants for working capital grants must identify the projected increase in customer base, revenue accruing to independent producers, and number of jobs attributed to the project.

Certification Regarding Lobbying. Recipients must certify that they have not expended nor will expend any Federal funds to pay any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with any of the following covered actions: the awarding of any Federal contract, the making of any Federal grant, the making of any Federal loan, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment, or modification of any Federal contract, grant, loan, or cooperative agreement. The certification must include the language prescribed by 2 CFR Part 418, Appendix A.

Semi-Annual Performance Reports. Recipients will be required to submit written project performance reports on a semi-annual basis. The agency will use these reports to gauge whether the recipient is making appropriate progress on the project.

Final Performance Report. Recipients will be required to submit a written performance report at the end of the period of performance. The agency will use this report to measure the achievements and the overall effectiveness of the funded projects.

FORM BURDEN APPROVED UNDER OTHER OMB NUMBERS

Form SF-424, “Application for Federal Assistance – Common Form” (OMB No. 4040-0004). This form is used by applicants as a required face sheet for applications for federal funding.

Form SF-424A, “Budget Information - Non-Construction Programs” (OMB No. 4040-0006). This form must be completed by applicants to show the project's anticipated budget breakdown in terms of expense categories and division of Federal and non-Federal sources of funds. Identifying the project’s requested funding by expense category is necessary to assure that the expense is necessary for successful conduct of the project, is allowable under applicable Federal cost principles, and is not prohibited under any applicable Federal statute or regulation.

Form SF-424B, “Assurances - Non-Construction Programs” (OMB No. 4040-0007). This form must be completed by the applicant to provide the Federal government certain assurances of the applicant's legal authority to apply for Federal assistance and financial capability to pay the non-Federal share of project costs. The applicant also assures compliance with various legal and regulatory requirements as described in the form.

Form SF-425, “Federal Financial Report” (OMB No. 4040-0014). This form is used to confirm that funds are being spent in conformity with the budget and work plan.

Form SF-LLL, “Disclosure of Lobbying Activities” (OMB No. 4040-0013). This form is to be completed once at the time of award. This form is submitted by the recipient and is used by the Agency to obtain disclosure of lobbying activities on the part of the recipient.

Form SF-270, “Request for Advance or Reimbursement” (OMB No. 4040-0012). This form is used by the recipient to request payment of funds under the award. Funds will not be disbursed on more than a monthly basis.

RECORDKEEPING REQUIREMENTS

USDA Administrative Requirements require that financial records, supporting documents, statistical records and all other records pertinent to the award will be retained for a period of at least three years after the period of performance has ended. Records must be retained beyond three years if audit findings have not been resolved.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

Grant applications may be submitted electronically through Grants.gov. Historically, approximately 8-10 percent of applications have been submitted electronically. Recipients are encouraged to submit reports electronically via e-mail to their grant monitors. It should be noted that many of the applicants and recipients for this program do not have access to up-to-date technology, including high-speed internet, so the use of technology or electronic submissions is not always a time-saving method. Thus, we continue to allow the submission of applications, reports, and other required documents via non-electronic methods.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

The Agency has completed an analysis to determine what percentage of its VAPG recipients are also funded through other Agency programs and has determined that less than six percent of VAPG recipients also receive funding through another Agency program. The Agency has also compared the VAPG program requirements to other Agency program requirements and determined that the VAPG program has unique program information requirements. Thus, the Agency has made an effort to identify duplication and has found that similar information is not available for its applicants and recipients.

5. If the collection of information impacts small businesses or other small entities (item 5 of OMB Form 83-I), describe any methods used to minimize burden.

No significant economic impact is expected for small businesses or other small entities. The Agency estimates that approximately 75 percent of the agricultural producers (operators of

Family Farms and beginning and Socially-Disadvantaged applicants) that utilize the program are considered small entities.

6. Describe the consequences to Federal program or policy activities if the collection is not conducted or conducted less frequently, as well as any technical or legal obstacles to reducing burden.

The information collection for grant applications is conducted annually by the Agency, but only once for the applicant. It cannot be conducted less frequently because program funds are appropriated annually and must be awarded annually according to statutory and regulatory requirements. Reporting is conducted at the minimum level (semi-annually) allowed by Federal regulations.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

Requiring respondents to report information more than quarterly.

Grant recipients would only be required to submit reports more frequently than quarterly if they have demonstrated poor performance under past awards and/or have demonstrated poor financial management capabilities.

Requiring written responses in less than 30 days.

If a grant recipient requests an extension to the grant period and the Agency needs additional information to process the request, the recipient would be given less than 30 days to provide the additional information needed.

Requiring more than an original and two copies.