The legislation says that the program is available to "an individua registered with VDACS as a beekeeper.".  It does not say VDACS will register "prospective" beekeepers.   Therefore by statute applicants are already beekeepers.  VDACS either has already or has now been authorized to define "beekeeper."  I will share a few thoughts which VDACS may consider.  Obviously planning to keep bees does not constitute being a beekeeper.  Neither does buying bees that die before the next spring.  The beekeeping literature and the beekeeping community in Virginia have distinguished for many years between "beekeepers" and bee-havers."     Bee-havers do not get or apply the knowledge necessary to successfully keep bees alive and thriving.  Beekeepers do so.   The purpose of encouraging the health of honey bees will be best served by using equipment to help beekeepers expand their apiaries; conversely, using equipment to help or entice poorly prepared and motivated people to jump into beekeeping will often be detrimental to the health of honey bees.

Two items in the proposed regulations should be changed; the first seems to be required to be consistent with the statute, the second will aid efficiency  (1) The proposed guideline to have VDACS register eligible applicants as beekeepers requires that they already be beekeepers, not prospective beekeepers or bee-havers.      VDACS therefore must as part of the application provide questions for the applicant to substantiate the claim that he/she is a beekeeper, not a prospective beekeeper or a bee-haver.   I suggest evidence could include winter survival rates of 70% or better in the most recent one or two year(s), and the number and health status (such as mite counts) of hives owned at the time of application.   Although I prefer beekeepers take a good course, the knowledge necessary to be a beekeeper could be demonstrated in other ways. (2) The W-4 should continue to be required at the time of application, in order to deem the application as complete, which will avoid expensive and wasteful follow up work, as well as delays in distributing equipment.   The form needs to be completed at some point, it might as well be done on the front end.  A fifteen day or longer application period affords plenty of time to complete and submit the W-4.  Doing tasks that are necessary in a timely manner is an important component of being a beekeeper.