USDA Gave Away $2 Million of a $6 Million Catfish Pool. Round Two Cuts the Match From 50 Percent to 20 and Doubles the Ceiling.

September 8, 2026 · 10 min read

Granted Research Team · Editorial policy

USDA Rural Development posted RD-RBS-26-03-MPPEP on September 8, 2026 — the Meat and Poultry Processing Expansion Program, Phase 3, Round 2, restricted entirely to processors of invasive, wild-caught catfish. Assistance Listing 10.381. Applications close December 7, 2026 at 11:59 PM Eastern.

Six million dollars. Six anticipated awards. The maximum grant is the lesser of $2 million or 80 percent of total project costs; the minimum is $50,000; the required cost share is at least 20 percent; the maximum period of performance is 48 months.

Read those terms against Round 1 and the story of this NOFO becomes obvious.

Round 1 left $4 million on the table

Round 1 ran as RD-RBS-25-03-MPPEP with applications due October 6, 2025. It offered the same $6 million pool, but capped awards at the lesser of $1 million or 50 percent of total project costs and held projects to a 24-month implementation window.

In April 2026, USDA announced the results: two awards, $1 million each.

Two awards out of a $6 million pool. Whatever the mix of causes — a thin applicant field, applications that failed eligibility screening, or projects that could not clear the 50 percent match — the agency did not find six fundable projects, and it responded by moving nearly every term in the applicant's direction:

TermRound 1Round 2
Award ceiling$1,000,000 or 50% of project cost$2,000,000 or 80% of project cost
Award floor$50,000
Required cost share50%20%
Period of performance24 months48 months
Anticipated awards6

A 50 percent match on a $2 million processing line is $1 million of owner equity or debt. A 20 percent match on the same project is $400,000. For a regional seafood processor, that is the difference between a board conversation and a bank conversation. Doubling the period of performance to 48 months does the same work on the construction side — it makes a facility build, rather than an equipment retrofit, financeable within the award.

If you evaluated Round 1 and walked away because of the match, the arithmetic you ran no longer applies.

The policy context: blue catfish in the Chesapeake

The program sits inside a broader federal push. In August 2025, Secretary Rollins announced an $8 million set of initiatives targeting invasive catfish in the Chesapeake Bay, of which MPPEP Phase 3 is the processing-capacity component. A parallel piece is a one-year pilot with the Maryland Department of Agriculture to purchase up to $2 million of Chesapeake blue catfish through Section 32, routing the fish to food banks and other distributors.

That pairing matters strategically. A processor's two hardest problems in this market are supply reliability upstream and offtake downstream. Section 32 purchasing addresses the second on a pilot basis. The scoring rubric for this NOFO, as we will see, asks you to address both directly.

The statutory authority is Section 1001(b)(4) of the American Rescue Plan Act, which funds "loans and grants and provide other assistance to maintain and improve food and agricultural supply chain resiliency." The $6 million is made available under the Consolidated Appropriations Act, 2024 (P.L. 118-42), the Full-Year Continuing Appropriations and Extensions Act, 2025 (P.L. 119-4), and the Continuing Appropriations, Agriculture, Legislative Branch, Military Construction and Veterans Affairs, and Extensions Act, 2026 (P.L. 119-37).

Four eligibility tests, and the fourth is the one that ends applications

Eligible applicants are broad on paper: for-profit and nonprofit entities, producer-owned cooperatives and corporations, certified benefit corporations, Tribes and Tribal Entities, state or local government entities, "and other business types (regardless of legal structure)." Private entities must be Independently Owned and Operated — not subject to the control of a parent corporation or affiliate — and all entities must be Domestically Owned, meaning organized under state or Tribal law with a majority of ownership held by U.S. citizens. Facilities must be physically located and operating in the U.S. or its territories.

There is no rural area requirement. This is a Rural Business-Cooperative Service program that does not require you to be rural, which is unusual and worth knowing if you assumed otherwise.

Then come the four applicant tests, all of which must be satisfied:

  1. Currently process seafood or wild-caught catfish for commercial markets and have been in business for more than a year. This is not a startup program.
  2. Operate or plan to operate under an FSIS grant of inspection to process invasive, wild-caught catfish subject to the Federal Meat Inspection Act. Siluriformes are USDA-inspected, not FDA-inspected — a jurisdictional quirk that catches seafood processors who have never held an FSIS grant of inspection and do not understand that a HACCP plan written for FDA seafood rules will not transfer.
  3. Plan to increase processing capacity for invasive, wild-caught catfish at their existing facility.
  4. Have a State Aquatic Nuisance Species, or Invasive Species, management plan that specifically identifies catfish as an Invasive or Aquatic Nuisance Species in the state where the facility operates.

Test four is the gate. It is not something the applicant controls, produces, or can create in nine weeks. Either your state's ANS management plan names catfish, or your facility is ineligible regardless of how good the project is. Maryland and Virginia are the obvious yes cases given the Chesapeake blue catfish designation; the Mississippi and Ohio River basin states are where the answer requires actually reading the plan. Verify this in week one. Pull your state's ANS management plan, find the species list, and confirm catfish appear by name. If they do not, the correct decision is to stop, and to spend the time lobbying your state ANS coordinator ahead of a future round instead.

Note also a tension between test three ("at their existing Facility") and the allowable uses, which include "construction of a new Facility, purchase of an inoperable Facility, including the purchase of the real estate for a Facility." If your project is greenfield rather than an expansion at a facility you already operate, ask the program office in writing before you build the budget. The contact is mppep@usda.gov.

The unallowable list is where budgets die

The NOFO's prohibited-cost list is longer than most and several entries are structural:

And three that are really eligibility restatements: a period of performance longer than 48 months, a grant request above $2 million or above 80 percent of project cost, or a request below $50,000, each render the application unfundable.

The 115-point rubric and where the points actually are

Applications are scored to a maximum of 115 points. The Agency funds in rank order until the money is exhausted or a minimum score of 50 points is reached, and may offer partial funding if an application cannot be fully funded.

Alignment and Intent — 20 points. Identify specific constraints in processing invasive, wild-caught catfish; describe how the project increases capacity and volume; define the geographic focus area and regional market demand versus processing constraints; estimate the number of fishers who will benefit; and address marine impact — specifically how the project results in fewer invasive catfish in local marine ecosystems, plus pollution control strategies for water quality and solid waste.

Market Development and Industry Opportunities — 20 points. Split evenly. Ten points for fishing industry opportunities: a clear procurement plan showing more catfish bought from fishers, an increase in the number of fishers sourced from, and income diversification for those fishers. Ten points for market development: new sales channels and value-added products, and how expanded capacity meets fisher, buyer, and consumer needs.

Financial Viability — 20 points, in four equal 5-point pieces: commitments from fishers demonstrating supply reliability; commitments from buyers demonstrating demand; the plan and timeline for reaching optimal processing capacity; and overall financial viability supported by historical financials and three years of income and expense projections.

Technical Merit and Achievability — 20 points. Ten for a budget and workplan with every line item tied to project activities and staff. Ten for achievability: a realistic milestone schedule, key partnerships with aligned local and regional entities, a full risk inventory (product recall, past and current health and safety violations, labor risk, operating capital access, legal risk) with mitigation strategies, staff capable of sustaining operations after the period of performance, and identification of all necessary permits and inspections including construction permits.

Labor and Personnel — 10 points. Living wages, essential benefits, worker training, safe working conditions — and disclosure of the facility's current or past federal and state safety and labor violations and how they were resolved. The NOFO separately reserves the Agency's right not to fund an applicant whose health, safety, or labor law violations are "deemed unsatisfactory," regardless of score.

Community Impact and Support — 10 points. Letters from qualifying leaders — state and local officials, associations of agricultural producers, labor unions — each identifying the writer's connection to the project, describing sustained community impact, and addressing long-term community needs. No letters, no points. For projects on Tribal lands where the applicant is not a member of or owned by the Tribe, a Tribal Resolution of Consent or a Letter of Consent from the Tribal Council is mandatory; without it the application "will not be considered for funding."

Discretionary Points — up to 15, assigned by the RBCS Administrator during administrative review "to maximize diversity among awards on the basis of geography and species, including the prioritization of projects involving the Processing of Apex Predators."

The apex predator line is the most exploitable sentence in the notice

The NOFO defines Apex Predator as "a species, including invasive Wild-Caught Catfish, at the top of a food chain, without natural predators of their own," and the Administrator may award up to 15 discretionary points — 13 percent of the maximum score — partly on that basis.

Fifteen discretionary points is larger than any single narrative criterion except the four 20-point blocks. It is also larger than the labor criterion and the community criterion combined. The geographic diversity half of that discretion is a straightforward read: after Round 1 funded Maryland and Illinois, an application from an underrepresented basin — the Gulf Coast, the Carolinas, the Tennessee and Cumberland systems — carries an argument that a second Chesapeake application does not.

The species half is an invitation to be explicit. If your intake includes flathead catfish alongside blue catfish, or other apex invasive species within the Siluriformes order your state plan names, say so in the narrative and use the NOFO's own term. Discretionary points are assigned by an administrator reading for specific language, not inferred from a species table in an appendix.

The submission mechanics

The project narrative is limited to 20 pages, excluding the application template and supporting documents. Required forms include SF-424; SF-424B (assurances, non-construction) if the project does not involve construction; SF-424C (budget information, construction) and SF-424D (assurances, construction) if it does; environmental information via the checklist; and supporting documents per section 4.2. Form AD-2106, the civil rights compliance questionnaire, is optional.

Review runs in six steps: completeness and eligibility screening, panel review to a consensus score, RBCS administrative review of top rankings against scope and allowability, ranking on merit plus discretionary points, funding in rank order to the 50-point floor, and finally environmental and National Historic Preservation review.

An active SAM.gov registration with a UEI and TIN must be in place and maintained through the review period and, if awarded, the project period. Applicants without current SAM registration should start that this month, not in November.

The nine-week plan

  1. Week one. Read your state's Aquatic Nuisance Species management plan and confirm catfish are named. Nothing else matters until this is settled.
  2. Week one. Confirm your FSIS grant of inspection status for Siluriformes, or your path to one. FDA seafood HACCP does not substitute.
  3. Weeks two through four. Secure written commitments from fishers and from buyers. Twenty of the 115 points are financial viability, and half of those are supply and demand commitments in writing. These take longer than anything else in the package.
  4. Weeks three through five. Request letters of support from state and local officials, producer associations, or labor unions. Ten points are unavailable without them, and elected officials do not turn letters in three days.
  5. Weeks four through seven. Build a budget where every line increases primary processing capacity, carries no indirect cost, and fits inside 80 percent of a project cost your 20 percent match can actually cover.
  6. By December 1. Submit. The deadline is December 7, and Grants.gov does not extend.

The full NOFO, application checklist, and template are attached to the Grants.gov listing for RD-RBS-26-03-MPPEP; program materials are on the USDA Rural Development MPPEP Phase 3 page. Given how Round 1 closed, a well-built application entering this field has better odds than the $6 million headline suggests.

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