Comment on FR Doc # 2010-12731

• Keep business and enterprise planning of VAPG projects farmer-centered. The proposed rule includes conflicting provisions on this matter. Helpfully, it says farmers may count their time spent on development of business and marketing plans as an in-kind contribution for purposes of matching funds. Yet the rule also includes conflict of interest rules and several program definitions that seem to prohibit active participation by the producer in project development and planning. This undermines the fundamental principle of the VAPG program: That farmers and ranchers should be empowered through these grants to explore creative new businesses that will increase farm income and create rural wealth. USDA should ensure that the final rule is totally consistent on this point - farmers and ranchers should directly participate in the development of VAPG projects and be allowed to count their time as a contribution toward the program's matching requirements. • Ensure that the legislative priority for projects that targeted to small and mid-sized family farms and ranches and socially disadvantaged farmers and ranchers set by the 2008 Farm Bill are clearly expressed in the final rule and in the scoring/evaluation process. Congress has spoken - these are mandated VAPG priorities. Yet, the proposed rule from USDA would award only 15 ranking points out of a potential 110 ranking points for projects targeted to this group. USDA should ensure the final rule awards 25 total points for the priority group, and should also add clear language to the effect that proposals which target small, mid-sized and socially disadvantaged farmers and ranchers should take priority over projects that are not targeted in that fashion if proposals are otherwise equally ranked. • Allow producer groups or entities made up of more than 25% beginning farmers and ranchers to apply for the funds reserved by the farm bill specifically for projects benefitting beginning farmers and ranchers.