Virginia Regulatory Town Hall
Agency
Department of Conservation and Recreation
 
Board
Virginia Soil and Water Conservation Board
 
chapter
Resource Management Plans [4 VAC 50 ‑ 70]
Action Establishment of new Resource Management Plan Regulations (4VAC50-70-10 et seq.)
Stage Proposed
Comment Period Ended on 9/14/2012
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9/12/12  11:15 pm
Commenter: John Blair Reeves Sr. Citizen & engineer in Rockingham County, Va.

Va. DCR- Proposed Regs.- Farms implement needed BMPs & gain 9 year "Safe Harbor"
 

1) Subject regs. have large import to tens of thousands property owners in Va.- especially those doing real farming for a significant profit (not hobby farming); however, this record so far only has 6 comments--and few of 6 are affected farmers.  Suggest allowing more time here and much more out reach to the farming stakeholders-- are farmers really going to support doing these BMPs?

2) The e-mail received today from Va. Conservation Network helped explain these regs. and some of the many "pros" and efforts to gain them-- to this milestone.  However, I'm submitting and supporting their conclusion paragraph:

"The Department has now developed the details and there are many positive aspects. Unfortunately, the Department has failed to determine whether or not these practices meet Virginia’s water quality objectives. Please stand with us to urge the Soil and Water Conservation Board not to approve these regulations until we have certainty that these practices actually achieve our water quality objectives."

3) I've been fortunate to live in Rockingham since 1977.  For some years, Robert Whitescarver has become a leader and expert of these farm runoff/ water pollution issues.  I support his most current comments on subject regs--copied below:

Commenter: Robert Whitescarver You set a high bar - congratulations

 I would like to commend the people that no doubt spent long hours developing the proposed regulations. They have set a high bar for conservation and if passed, as is, will surely improve the waters of the Commonwealth.

I strongly support that cropland, pasture and hay-land meet the "T" value for soil erosion as defined by NRCS.

I strongly support the 35-foot buffers on perennial streams.

I would like to make the following comments and suggestions:

As a conservationist and farmer I am curious as to why only perennial streams are addressed in the RMP. I have seen many intermittent streams that are more polluted than the perennial streams they flow into. Therefore I would recommend that intermittent streams be addresses at least in pastures.

I would rather see both perennial and intermittent streams, as defined by USGS be excluded from livestock with a minimum setback of 10 feet. I think this would be more effective than requiring a minimum of 35 feet on perennial streams alone.

The published regulations do not mention feedlots or barnyards. In many cases these land uses do more damage to the waters than the surrounding pastures.

I would suggest that the term "perennial stream" be defined.

CommentID: 24032