Daniel Deal

Virginia Tech M.P.A.

ddeal1@vt.edu

Ryan Davis 

Program Manager, Office of Dairy and Foods

PO Box 1163

Richmond, VA 23218

Dear Mr. Davis,

Thank you for the opportunity to comment on the proposed regulatory amendment regarding the somatic cell and bacteria count limits in milk. I am writing to oppose this amendment because of the financial impacts it will have on the diminishing number of dairy farms throughout the Commonwealth.

Since 2014, the number of Virginia dairy farms has decreased by nearly 20 percent. Often, reduced milk prices have forced farmers to sell milk for less than their costs of production. The projected median income for a dairy farmer this year is -$1,316. Amending 2 VAC 5-490 will only add to the financial costs of milking process.

The VSDA argues in favor of this amendment claiming the marketability of Virginia milk will increase resulting in more overseas exports, expansion of local processers, and a prideful notion to declare Virginia as the highest standard east of the Mississippi. However, these claims are unsubstantial because each of them are merely speculative and indeterminate. It is clear that the most important of these goals is to tout this “pride statement”, which is absurd considering it will come at the expense of Virginia farmers.

Lowering the bacteria counts and somatic cell accounts to the proposed levels will not require processors to pay a significantly higher price when they purchase it from the farm because the vast majority of consumers choose the cheapest option on the self. With the current status of dairy farming nationwide, regulations that put more pressure on farmers with minimal return on investment need to be avoided.

Regards,

Daniel Deal