I offer the following comments on behalf of the Virginia Farm Bureau Federation. We believe the regulations are generally consistent with the intent of the legislation authorizing the creation and development of the Resource Management Plan program. However, we remain concerned about the buffer requirements for pastures and the duration of the certificates.

The Code that authorizes this program does not require a buffer of any width for pastures; it requires “as needed”… “A system that limits or prevents livestock access to perennial streams”. Buffers while they may be part of the plan are not required for pastures. We believe the regulations should mirror the wording of the Code of Virginia for crops, pasture and hayland. This will accurately reflect the intent of the General Assembly and minimize the current confusion among the industry. 

Regarding the duration of the certificate. Resource Management Plans address water quality in an aggressive manner if implemented to achieve certification. If maintained to the standards prescribed (i.e. “T” for soil loss) the certification should be good for as long as the standards are maintained and field checked. Nine years appears will fit some operations cleanly; for others it will seem arbitrarily short (i.e. pastures and hayland). Regardless, the certification duration must reflect the time necessary to finance the aggressive BMP’s required to meet the standard.

Outside of the regulatory process we believe funding for SWCD’s for implementation of these regulations is critical for the success of the program. We also believe that implemented properly these plans provide and opportunity of significant water quality improvements with additional incentives for their development and implementation.

We appreciate the opportunity to comment and join other agriculture organizations and others in the stakeholder group.