Virginia Farm Bureau Federation submits these comments in support of proposed amendments to 2VAC5-390 establishing a minimum germination rate for cotton seed. VFBF is Virginia’s largest grassroots agricultural advocacy organization, representing over 33,000 producer members, including a significant number of cotton farmers.

Our members have reported issues of low germination rates for their cotton seed, which has resulted in decreased yields. For farmers operating on tight margins, this is a serious concern. We support the establishment of a 60% minimum germination of seed cotton for sale as regulated by the Virginia Seed Law. We also believe that seed cotton that tests below the germination tolerance, as established by the standards of the Association of Official Seed Certifying Analysts, but above the minimum germination rate, may be relabeled and sold.

These positions have been thoroughly discussed and agreed upon by our full membership,
including the VFBF Cotton Advisory Committee. This regulatory change will provide economic benefits to Virginia’s cotton farmers. Thank you for acting on this matter, as well as the opportunity to comment.