On behalf of the Virginia Cattlemen's Association, it's members and Virginia beef cattle producers, I respectfully offer the following comments regarding the proposed Resource Management Plans offered from the Virginia Department of Conservation and Recreation.

1. A significant portion of the beef cattle produced in Virginia are managed on rented or leased land that is privately owned/held by individuals with no ownership of agricultural commodities.  Long term rental/lease agreements are difficult for many producers to acquire with these landowners due to both competition from other farmers to rent the land at a higher value and land use pressures that raise the posibility of taking the land out of agricultural production and place it on a course for development.  Many conservation programs, including this one, require a commitment of many years, and while this may be desireable to the farmer renter, it may not be of interest to a renting landowner to enter into long term agreements for conservation programs when the land can be taken out of production or rented elsewhere.  Please consider that all farmers are not operating on 100% owned land where they have control over the ability to implement conservation programs with or without cost share and therefore even consider participating in the RMP.  It is our fear that this and similar proposed/exisitng regulation of conservation practices will force beef producers to downsize due to inability to manage leased land decisions for the long term and lack of incentive for land owners renting to livestock producers to commit to long term agreements necessary for conservation program implementation.

2. The proposed RMP requires a riparian buffer setback of at least 35' which is NRCS standard.  The proposed RMP will provide participating producers "safe harbor" from further regulation over the course of the RMP agreement in the coming years.  Our concern is that the 35' buffer is excessive and not scientifically justified as well as vulnerable to being increased due to political pressures for further environmental regulation without scientific reinforcement for effectiveness.  There is a tremendous amount of money being spent on consservation programs to meet a still undetermined TMDL nutrient reduction goal for Virginia.  Without scientific validation of the minimum necessary riparian buffer width for all environments, we are concerned that the RMP will be exposed to new revisions and possibly costly adjustments in the future and within the terms of exisiting RMPs where implemented.

3. The local Soil and Water Conservation Districts throughout the Commonwealth are valuable resources for information dissemination and program marketing to farmers.  The proposed RMP places an unecessary regulatory burden on the local Soil and Water Conservation Districts and associated staff that they are ill equipped to execute and we feel is outside of the purpose of these Districts.  Soil and Water Conservation Districts are not going to remain effective in a potential regulatory role that they were not created to fill.