I strongly support the proposed amendments to the Virginia Pollution Abatement (VPA) Permit Regulation for Poultry Waste Management [9 VAC 25 ? 630].

Virginia’s waterways and the Chesapeake Bay are heavily polluted by nutrients.  Virginia is making major efforts to address point source pollution from sewage treatment facilities.  In addition Virginia is in the process of amending its stormwater regulations to reduce the amount of phosphorus from urban sources. However, these actions will not by themselves solve the problem of phosphorus pollution.  According to the Chesapeake Bay Foundation agricultural runoff accounts for 50 percent of the phosphorus entering the Chesapeake Bay.  According the Chesapeake Bay Program (CBP) animal manure and poultry litter contribute about one-half of the Bay watershed's agricultural nutrient load, or approximately 25% of the total phosphorus pollution in the Chesapeake Bay.

Animal manure and poultry litter are often applied to cropland as a form of fertilizer However, as the CBP points out, when excess manure is carried from the land via runoff, those nutrients, as well as bacteria and pathogens that manure often contains,  end up in our waterways.

While the Virginia Pollution Abatement program requires nutrient management when applying hog, sheep and cattle waste, regardless of who owns the land, in the case of poultry only the growers are required to have nutrient management plans when they apply on their  land; other end users currently do not have this requirement.  DCR estimates that 85% of poultry litter is transferred to farms with no nutrient management planning requirement.  Poultry litter is an imbalanced fertilizer which contains several times more phosphorous than crops use when it is applied at the rate needed to meet nitrogen needs of the crops.  Many producers in the region have applied so much phosphorus that it is no longer able to absorb all of the excess nutrients.

The proposed regulation will require all significant poultry waste end users and poultry brokers to test soil and to prevent the accumulation of phosphorous. It will also guide the timing of application to minimize spreading outside of the growing season and on frozen ground.  It will also finally end the practice of storing litter in huge piles out in the rain and then applying litter right down to the stream-banks, and into or around environmentally sensitive areas.  The revised regulations should be implemented as written.   They are an integral and indispensible part of addressing Virginia’s responsibilities to reduce phosphorus pollution in our rivers and streams, and in the Chesapeake Bay.