B.1. "Removing or securely sealing any empty bee equipment in an apiary...."empty" means without bees but containing comb or other materials attractive to bees."  For years I have kept a bait hive in or near my apiary containing an old comb and a pheromone lure to attract swarms.  I have never experienced a complaint about this practice but it appears to be contrary to the Best Management Practices and a potential liability problem.  I think that having a swarm move into a bait hive is preferable to having it fly off to some unknown location.

B.3. "Repairing or replacing old, worn or defective hive boxes, frames and other bee equipment."  This is too subjective.

B.4. "Replacing frames containing old comb with new comb or cleaned frames containing foundation...."  I sometimes use frames without foundation as part of a varroa mite control procedure.  It would appear that use of frames without foundation or top-bar hives are contrary to Best Management Practices and a potential liability problem.

E. Distance from property lines.  I keep bees in Arlington County on a typical 50 foot by 118 foot lot.  My apiary is located on a roof and less than ten feet from the property line.  The bees fly well over the heads of people on the ground and I have never had any complaints from neighbors or passers-by.  Roof-top apiaries are not taken into consideration in the Best Management Practices and could be a potential liability problem if close to the property line.

G. "An apiary operator shall not maintain an apiary withing 50 feet of any animal that is tethered, kenneled or otherwise prevented from escaping a possible stinging incident."  My neighbor has many cats which she allows access to an outdoor cage in her wooded backyard.  The caged cats are less than 50 feet from my apiary and there has never been a complaint from my neighbor or any sign that a cat has been stung.  This appears to be contrary to Best Management Practices and a liability problem.  Is the problem the way I keep bees or the way my neighbor keeps cats?  There is no way for me to move my apiary 50 feet from her cat cage and conform to Best Management Practices regarding distance an apiary must be from property lines.

H. "An apiary operator shall avoid opening or disturbing a colony when another person is participating in outside non-beekeeping activities or using machinery within 150 feet of the apiary."  This is impossible in an urban area like Arlington County.  Nobody has complained about my beekeeping activities in the sixteen years I have managed bees on my property but I can't even see all the people that might be within 150 feet of my apiary for all the houses and vegetation in the way.