Virginia Regulatory Town Hall
Department of Environmental Quality
State Water Control Board
Virginia Stormwater Management Program (VSMP) Regulation (formerly 4VAC50-60) [9 VAC 25 ‑ 870]
Action Plasticulture Operations Regulation - Initial Adoption
Comment Period Ended on 3/29/2010
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3/17/10  12:04 pm
Commenter: John Chubb

Plasticulture BMPs Need to Be Implemented


- I live downstream from over 100 acres of plasticultured tomatoes. For more than ten years I have observed the effects of this practice on the waters adjacent to my property (less than 1/2 mile from the fields).

- I cannot comment on the quantity of nutrients flowing from these fields.

- In years past (but not the past 3 or 4) I have observed serious marine fauna kills after heavy rains when active tomato growing was in progress.

 - Every year the amount of sediment transferred to the tidal creek where I live is HUGE; the entire creek will turn chocolate brown after a major rain event. The water depth has decreased an estimated 3 feet during the past decade. The soft, unconsolidated sediment is 4 to 5 feet thick. I recommend focusing on sediment control.

- The Northampton County E&S Control Ordinance "exempts farming" from sediment control. Therein lies some of the problem. While traditional farming (tilling, etc) should be exempt, the growers who use plasticulture employ large, heavy equipment like that used to build roads to sculpt the land, sometimes even changing drainage direction. This is no longer "traditional" farming. I have sent several pictures to Melanie Davenport at DEQ.

- A Pasticulture BMP manual was issued in 2002 geared specifically for near coastal growing conditions. Effective practices for preventing degraded waters are known. They have been available for nearly 8 years.

- The ESSWCD has worked with some growers to implement BMPs with limited, but meaningful, success. The ESSWCD has drafted a standard MOU for growers re: having fields evaluated and BMPs recommended and checked. Grower agreement is pending (and completely voluntary).

-  The Eastern Shore Soil and Water Conservation District (ESSWCD) should not regulate of enforce environmental standards. It is an advisory service and manages BMPs.

CommentID: 13503