Headwaters Soil & Water Conservation District covers Augusta County. We have cost share practices on many farms that produce and/or use poultry litter.

            The technical requirements proposed represent change for end users. We ask if these changes are the result of short falls in the existing system.  The Ag Stewardship Act is designed to address bad actors. Are these proposed changes backed by good science?

If end users were to feel that these requirements were burdensome, it could result in a backlog of litter left on farms. What affect on watersheds in TMDL areas would result?  Will these changes cause a switch in the use of organic nutrients that are now regulated to the use of inorganic nutrients that are not regulated?

We voice our concerns through these questions and hope DEQ has good answers to warrant technical requirement amendments.

            We acknowledge the process is complex.  If change is necessary, the technical revisions proposed are more acceptable to the end user and broker than the permit process.