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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3/27/10  4:50 pm
Commenter: Richard Ayers, resident, Northampton County

I support preemptive controls for row-crop plasticulture practices.

I commend the State Water Control Board for considering rules to protect our waters from runoff from row-crop plasticulture operations.

As a current resident of Northampton County, former resident of Accomack County, and someone who has worked on the Bay and coastal waters most of my life, I have seen many detrimental impacts of land conversion over the decades.

While commercial row-crop plasticulture practices create acres of impervious surface, it seems to be the leveling, channeling and deep ditching of the lands that creates these huge conveyances for mud to discharge into our waters.

I acknowledge the benefits of plasticulture. Our nurserymen employ similar practices with much success.  I also recognize that the row-crop plasticulture industry has been an important part of the Eastern Shore for over thirty years. But it’s the routine modification and changes to the land to quickly drain some of these row-crop operations that concerns me.

The local farming community has done an amazing job adopting conservation tillage practices to many of our local grain crops.  Meanwhile, the row-crop plasticulture industry has seemingly focused on practices that facilitate rapid drainage.

Following litigation in the late 90’s, the row-crop plasticulture industry and the state and local agriculture community came together to develop Best Management Practices (BMP’s), specific for the industry. Back then it was touted that the industry was going to “voluntarily” comply with the practices they helped to develop.  Some operators did employ many of these BMP’s and were commonly acknowledged for their effort. But by 2004 bulldozers, levelers, and excavators returned to wholesale drainage modification.

During 2004 a local group of citizen formed to try to work with the plasticulture industry and the local agriculture community.  Regular flights over some of the plasticulture operations documented massive soil erosion and sediment plumes into our tidal waters.  These efforts seemed to reluctantly bring the industry back to the table to discuss more “voluntary” compliance. And some progress was made.

Then the NOIRA announcement seemed to really bring the industry back to the table. And as could be predicted, the row-crop plasticulture industry wants an opportunity to “voluntarily” comply…

The question for me is should companies who wish to employ row-crop plasticulture on coastal lands install adequate sediment controls before it rains or after it rains and then only if someone complains.

I think before it rains…

CommentID: 13618