Virginia Regulatory Town Hall
Agency
Department of Agriculture and Consumer Services
 
Board
Department of Agriculture and Consumer Services
 
chapter
Best Management Practices for the Operation of Apiaries in Order to Limit Operator Liability [2 VAC 5 ‑ 319]
Chapter is Exempt from Article 2 of the Administrative Process Act
Action Promulgate best management practices for the operation of apiaries to limit operator liability
Stage Proposed
Comment Period Ended on 7/13/2016
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7/9/16  3:35 pm
Commenter: Richard D. Haynes, Beekeeping association of Northern virginia

Proposed bee hive management best practices 2VAC5 319.30
 

I have been keeping bees, first in Seattle and for the past six years in Northern Virginia.  I looked at the proposed bee hive management best practices for Virignia.  I find them to lean far too heavily on manipulation of bees, queens and hives for no reason that links to either public safety or good management of hives.  They seem to be urging manipulation for the sake of manipulation with no clear causal connection to docile bees or healthy bee hives.  For instance, the requirement to replace queens within 30 days for captured or trapped swarms has no relationship to anything without inspection of hives to determine the hive health and general behavior.  If the hive shows characterics of an unsatisfactory queen then yes, one would wish to replace her.  But, if the queen were laying successfully and if her brood seemed health and not aggressive, then there is no reason at all to roll the dice by introducing a new queen with unknown fertilization history.  Similarly, the requirement to replace queens every two years to minimize swarming behaviour has no relationship to swarming, which is much more closely tied to overcrowding than to the age of a queen.  Indeed, since it is the resident queen which goes with the swarm, replacing a queen merely means that queen would leave with a swarm, not that the hive would not swarm.  Hive swarming is best addressed through providing adequate hive space for a growing population within the hive or by splitting a hive into two, so that the hive perceives that it has swarmed already.  A hive that is not growing rapidly would be unlikely to swarm, and indeed, might need to be combined with another hive.  But, once again, one would judge and act on the situation on be basis of what one observes in a hive.  One of the other proposed regulations calls for combining hives in a state of "decline."  Hives have a natural calendar and naturally decline in population during Fall through winter.  A hive with sufficient stores in relationship to the number of bees would not need to be combined, even though declining in population, so long as there was honey enough to last the winter and/or the hive was fed, a common, normal practice.  In connection with that, the regulation that a hive should have 60 lbs of honey stores is meaningless.  Smaller hives (nucleus hives) are a common way of dealing with winters and the smaller hives do not need 60 lbs of honey.  And, once again, the common practice of feeding hives means that what is required is an observant bee keeper who feeds as necessary, not an automatic weight per hive of honey.  I strongly urge that Virginia scrap the current draft of these overly mechanical regulations and adopt something much like those regulations that West Virginia has adopted.  They are simpler, and more geared to responses based on observation and management of a hive rather than following a schedule which has no foundation in practices aimed at public safety and healthy bees. 

CommentID: 50563