I am submitting the following comments on behalf of the Thomas Jefferson Soil and Water Conservation District Board of Directors:

If Virginia’s intention is to implement a resource management plan program which encourages voluntary participation, the program will be more successful if it is economically feasible for more farmers.  Flexible criteria and smaller buffers may actually result in more participation and greater environmental benefits than larger buffers and strict, inflexible criteria.  Additionally, a longer plan lifespan would offer more certainty to a farmer and would therefore provide a greater incentive for a farmer to participate.

One suggestion to address both of these issues and provide a greater participation incentive is to have a sliding scale where more water quality protection would allow a longer plan lifespan.  For instance, a 10’ buffer may mean a nine year plan, while a 35’ buffer may allow for a 20 year plan.  (i.e. The “gold standard” would be rewarded with additional years of surety.)

Another concern is that the 35-foot buffer for livestock fencing is incompatible with existing cost share programs (NRCS CBI; TMDL-specific funds).  It is illogical for government funding to encourage farmers to install fencing 10 feet from streams, require farmers to sign a 10-year contract for that fencing, and then expect them to move that fencing to meet RMP criteria.

Finally, Soil and Water Conservation Districts are given significant responsibilities in these regulations with no assurance for compensation.  The regulations should specifically stipulate that SWCDs will receive funding to cover the costs of implementing these regulations within their boundaries.

Thank you for the opportunity to provide input.