Thank you for the opportunity to comment. I have a number of concerns with the proposed regulations which seem to be onerous to hobby beekeepers (a group who has helped fortify the honeybee population in the face of Colony Collapse Disorder). Specifically I am concerned with:

1. 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 -- When is this measured? Summer? Spring? The "growing season" on the border of North Carolina may be different than the growing season in Northern Loudoun County. Honey and pollen stores in a hive vary throughout the seasons and feeding, splitting hives, and natural factors such as weather will also influence the stores. 

2. Monitoring disease and pest levels to ensure that treatment thresholds are not exceeded. An apiary operator shall manage the colony to address any disease or pest infestation or remove all disease or pest-infested hives that may be detrimental to the health of other colonies in the vicinity of the apiary.  -- I don't think even seasoned or commercial beekeepers can agree on what the "treatment thresholds" are. Which diseases/pests are they specifically referring to? There are a lot of them. What if I am breeding pest-resistant stock and do not wish to apply chemicals which could potentially weaken the bees in the long term? 

3. Not obtain queens or bees from suppliers within 100 miles from known Africanized honey bee populations -- Much of the bee stock of Northern VA comes from counties in Georgia which have been known to have Africanized bees for several years now. Are we no longer allowed to buy bee stock from the major bee suppliers in Georgia?

4. Replace queens in all captured or trapped swarms within 30 days of capturing or trapping swarms -- By replacing queens from swarms you are potentially destroying the genetic variation that allowed a feral colony to survive in the first place. These genes are crucial for maintaining healthy bee populations in the face of honeybee diseases and poor pesticide application practices which are threatening the honeybee.

5. An apiary operator shall avoid opening or disturbing a colony when another person is participating in outside nonbeekeeping activities or using machinery within 150 feet of the apiary -- If I am managing my hive in my backyard and someone walks by on the street 150 feet away and gets stung, I am liable? How on earth do you prove it was my bee versus someone else's bee (or an un-owned bee) that did the stinging? Bees travel MILES for forage and mating. 

6. An apiary operator shall place all colonies that are less than 40 feet from a property line behind a barrier that is no less than six feet in height and is located between the colony and the property line.-- So even if my bee landing boards and hive entrances face away from the adjacent property, I have to install a barrier because they are less than 40 feet from the property line? This does not make sense due to the nature of bee flight paths. Additionally this is an enormous cost to be shouldered by the beekeeper for little to no increase yield in safety.

We should be supporting backyard beekeepers and encouraging more people to enter beekeeping with reasonable, achievable, guildelines instead of hindering their efforts with vague, overly restrictive covenants.

Sincerely,

Nicole Reid