The Urban Committee of the Virginia Association of Soil and Water Conservation Districts offers the following comments regarding the proposed Regulations for the Application of Fertilizer to Nonagricultural Lands (2VAC5-405):

1. Under Section 2VAC5-405-20.B(2), the referenced “standards and criteria” should be clarified with a title and date of the specific manual.  (It should also be confirmed that the “standards and criteria” require that soil test results and associated recommendations be followed.)

2. Section 2VAC5-405-100 requires record-keeping of fertilizer applications.  Requirements for record-keeping of soil test results and recommendations should also be included in this section.

3. In addition to record-keeping, reporting of fertilizer applications and associated nutrient management activities should be mandatory.  This will facilitate Virginia’s reporting of actions taken to accomplish goals of the Chesapeake Bay clean-up programs.

4. We recommend striking #2 of Section 2VAC5-405-50, or at a minimum, restricting its application to small acreages.

5. We recommend that a fee structure be implemented to ensure that the program is self-supporting.