The following are my comments on the suggested Virginia Best Practices. I think overall that these represent great progress!

I suggest that B. 5  read - maintain 20 lbs of honey or feed.

B.7, first sentence, is unenforceable as no two people agree on what is a treatment threshold; also, not all beekeepers treat. I suggest deleting the second part of the first sentence ("to ensure treatment thresholds are not exceeded") but retaining the testing and monitoring requirements along with the general management requirement.

C. is excessively onerous and does not reference or appear to permit top-bar hives.   It should be left to the judgment of the beekeeper when, how,  how much and what kind of feed should be left on a colony given local forage and weather conditions and individual colony conditions.  Beekeepers who do not feed their colonies will probably lose them over winter; and beekeepers should provide sufficient feed in a dearth to minimize the possibility of robbing (but some bees will rob anyway and it is not reasonable to hold a beekeeper accountable for all robbing behavior).

H.  Is vague as to "operating machinery" and "participating in outside activities." This should be clarified, e.g., "excluding transitory passage of persons or vehicles through the area."

I. The queen replacement procedures are onerous.  Limiting queen sources may further reduce genetic diversity and local queens are not available at all times.  Requiring queen replacement of queens in captured swarms regardless of source or temperament and requiring requeening according to a strict timetable is irrational and should not be required: only colonies exhibiting heightened defensiveness should be requeened. Swarming behavior can be managed. Clipping queens is not considered a good practice in my understanding as it induces supersedure.

Finally, there are no restrictions on harvesting practices such as honey removal or replacement of supers, or on open feeding.  These should be done so that honey, feed and wet supers are enclosed and  not left exposed to attract robbing, other insects and pests.

Thanks for considering these comments.