Thank you for your consideration

B1 - does not account for bait boxes, and is hard to see how this could lead to personal injury or property damage.

B2 - "state of decline" is too vague, since a decline can be part of the natural cycle. Maybe replace with "failing". Also, provision should indicate that positive measures are being taken to remedy the failing colony, not limiting the beekeeper to two options of removal or combining.

B3 - delete "old", too subjective. Replace "worn, or defective" with "functionally defective".  Worn isn't necessarily a problem and a beekeeper should not be subject to liability if the equipment is functional, but not in a new, pretty state.

B4 - Instead of specifying specific time periods to replace comb, change it to replace comb when the cells become too narrow for effective brood rearing.  If comb is stored properly and not used for a few years, age has less relevance.  Also, honey super comb can be viable for longer if not used for brood.

B5 - Too arbitrary to specify amounts like "20 pounds" of honey, especially when store levels are expected to vary throughout the year. The proper amount varies with population, time of year, hive type (10 frame, 8 frame, nuc, top bar, etc). Also doesn't account for newly installed packages or nucs.  Better to reword this to more generally state that the beekeeper should maintain a hive with adequate stores and/or feed available based on the current state of the hive.

B6 - You can't 100% prevent disturbance by vertebrates.  A bear may find the hive, and an electric fence is not always practical.  Mice can squeeze through a hole the size of a pinky.  Perhaps reword to state "Reasonable measures to prevent disturbance..."

B7 - There are no specified thresholds to exceed with disease and pest levels, except perhaps AFB where the threshold is any number > 0.  I suggest deleting the entire first line "Monitoring disease and pest levels to ensure that treatment thresholds are not exceeded." and leaving the rest

C - Delete in its entirety.  Having sufficient stores (not defined by arbitrary amounts) will help you overwinter your bees successfully, but not having sufficient stores will cause the colony to collapse, not cause property damage or bodily injury.  Not relevant to liability.

E - Reword to state that an apiary operator shall orient hives to prevent individuals in neighboring properties from impeding normal bee flight activity from a hive, without listing specific distance/barrier/height requirements.  They are too onerous for urban beekeepers and the current language does not account for hive orientation.  Let local jurisdictions write their own requirements best suited to their circumstances if they feel the state BMPs are too vague.

F - Too onerous for operators with outyards, especially in rural areas.  Perhaps modifiy this requirement to only require a maintained water source if there is a reasonable expectation for the apiary presence to disturb others in the hive's quest for water.

G - Reword to prevent an operator from establishing an apiary under these conditions unless permission is obtained from the guardian of the constrained animals.  The BMP should not force an existing operator to close down because of how someone else treats their animals.

H - Not possible in urban areas and even some suburban.  This would in turn prevent proper management and violate other BMPs.  Let local jurisdictions decide what is proper for their areas

I - I would suggest changing "EHB or EHB hybrid stock" to "non-African or non-Africanized stock"

I2 - Good suggestion in another comment to require an inspection certificate from a supplier in Africanized areas declaring their supply to be free of Africanized genetics, rather than outright banning those suppliers.  Most packages sold in VA are coming from southern states that are in areas with some known Africanized colonies.

I3 - Delete.  Not relevant to property damage or personal injury.

I4 - reword to "Replace queens in captured or trapped swarms which exhibit aggressive behavior or undesirable traits".  If I happen to catch a swarm from a healty feral colony that overwintered without management, I WANT those traits in a queen.  It would be a travesty to kill her off to meet an arbitrary requirement.

I5 - Delete.  Not relevant to property damage or personal injury.  Swarms occur due to reasons other than the age of a queen.

I6 - Delete.  Provides no significant benefit, except to age a queen, and has no relevance to property damage or personal injury.