On behalf of the 38,000 Producer Members of the Virginia Farm Bureau Federation I offer the following comments regarding the Open Burning NOIRA.

Burning remains a critical tool for production agriculture.  Crops such as warm season grasses, used for livestock forage and energy production, require burning in order to reach their full potiential.  Many vegetable crops and cotton utilize burning to remove residue for subsquent crops.  Every farm in the Commonwealh has significant storm damage several times a year.  Each of these scenarios and more produce high volumes of organic material that generally requires burning.  The volume makes transportation impractical and other practices such as pit burning with fans expensive.

The use of onsite burning is a must for agriculture producers.  Such burns are generally single occurances over a short period of time.  However timing is critical due to safety concerns.  When crops are green and growing they are less susceptible to spreading fire to unintended fields and crops.  This offen conflicts with non attainment periods.  However since such burns are single shorts events variances should be allowance to address normal production practices and weather related damage.

If these regulations move forward, farmer and farm organization representation, from organizations like Farm Bureau, is critical to achieving balance and reduced harm economically.