5. Maintaining a minimum of 20 pounds of honey in a hive with the equivalent of one frame of pollen stores for brood production during the growing season; This would be difficult to impossible in nucleus type hives used for overwintering or sale.  

I. An apiary operator shall only maintain a colony with EHB or EHB hybrid stock and shall:

1. Obtain queens, packaged bees, nucleus colonies, or established hives from suppliers providing EHB stock, or obtain a queen and bees from a local supplier; What if we raise our own local queens based on our selection criteria?

4. Replace queens in all captured or trapped swarms within 30 days of capturing or trapping swarms; Replacement Queens are not always avialable locally or on short notice from catalogs

5. Replace queens in all colonies every two years to minimize swarming behavior; This will be onerous to documement and most queens don't last more than 2 years before being superceded.