We are a family owned and operated dairy and poultry farm in the Shenandoah Valley. We believe there should continue to be provisions to manage a manure storage facility in the event of an imminent breach due to no fault of the manager. Land application of manure needs to be allowed in an emergency. 
  We work closely with the local DCR office to implement our nutrient management plan and have always contacted them if our application of manure is necessary outside of the plan guidelines. 
  We also oppose mandatory groundwater monitoring. Most streams are actually monitored voluntarily. Our children were involved in stream water monitoring projects while they were in public schools. There are also a number of environmental groups that are actively monitoring streams for excessive levels of fecal bacteria. 
  Please consider these thoughts when considering the new VPA and CAFO rules and please make the permit good for a 10 year period.