Because the BMPs, once adopted by the VA Department of Agriculture, may become "the standard for compliance" for local governments, it is important to incorporate some additional flexibility.  To that end, I offer the following suggestions.

Section A(3); Eliminate the term old since it is undefined and in the eye of the beholder. the other descriptive terms are more than adequate.

Section C:  The minimum store recommendations are sensible, but because stores can vary and quickly, you might add a reference to feeding as a supplement to stores, and a mitigating factor for having stores below the recommended level.

Section E; The entrance of the hive should be 40 feet from the property line, with barriers to establish the bee flyway, but for urban beekeepers with small lots erecting barriers on the sides and back of their hives may be problematic and unnecessary.  Specifying that the entrance side shall be 40 feet, with a flyway barrier may remedy this.

Section H; Operator shall avoid opening or disturbing colony when another person is participating in outside non-beekeeping activites..... For urban beekeepers property lines may be less than 150 feet from the hive, and during an inspection beekeepers cannot control activities on neighboring properties.  The beekeeper should avoid those times when other activity is more likely, and never open a hive when the neighborhood barbecue is ongoing, but pedestrians, cyclists, and others may come well within 150 feet during an inspection. Mowing, on adjoining property for example, may begin after the hive is open.  A house may lie between the hives and the neighbor- yet the standard would not be met. Perhaps the standard should be modified to 50-100 feet and within line of sight.

Thank you for the opportunity to comment on these important standards.