Virginia Regulatory Town Hall
Department of Environmental Quality
State Water Control Board
Virginia Pollution Abatement Regulation and General Permit for Poultry Waste Management [9 VAC 25 ‑ 630]
Chapter is Exempt from Article 2 of the Administrative Process Act
Action Develop requirements that will address concerns regarding transfer and off-site management of poultry waste in the Commonwealth.
Stage Proposed
Comment Period Ended on 8/21/2009
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8/12/09  9:36 am
Commenter: Derek Venable (Supporting Shenandoah Riverkeeper)

Please Pass The Poultry Litter Regulation


As a longtime Virginia resident and angler, I have unfortunately had a front row seat to many environmental disasters as they've played out on our watersheds.  The travails of the watermen on the Chesapeake Bay are well known, and more recently we've experienced the noticeable degradation of our native freshwater fisheries....first on the Shenandoah River, and more recently on the James River.  I read your white paper on the pending poultry litter regulation and would like to voice my strong support for closing the identified loophole in regulations.  It seems the fact that regulation is already in place to prevent the 'environmentally irresponsible' application of poultry litter in certain circumstances constitutes acknowledgment by regulatory agencies that improper use of this waste as fertilizer results in preventable harm to our land and water resources.   With this understanding in place, and regulations already enacted to prevent pockets of this behavior, my hope is that common sense prevails and the governing bodies tasked with protecting our resources on behalf of all constituents will continue their efforts by closing this 'transaction based' loophole.  Furthermore, I would challenge anyone to explain how the source of the waste litter being used as fertilizer (homegrown vs. purchased/obtained) in any way mitigates the hazardous impacts of use.  Clearly it shouldn't (and doesn't) matter how a farmer acquires this type of waste....the only thing that really impacts end results is the methods by which the waste is applied as fertilizer. 
I am a member of the Richmond based Old Dominion Smallmouth Club, a conservation minded collection of smallmouth fishermen on the front lines of this battle for our natural resources.  Through my association with this organization I have become knowledgeable on numerous ways our resources can be actively protected from environmental disaster.  Some examples include the creation of riparian buffers, recycling and river cleanup efforts, prevention programs targetting various waste products, and perhaps most the most effective.....creating awareness amongst fellow Virginians (sportsmen or otherwise) of current practices that affect our waterways and the true impact, both immediate and long-term, that these practices will ensure.  

I am an avid angler and spend significant time enjoying the spectacular fisheries our state offers, including the James, Shenandoah, New, and countless other rivers, streams and lakes.  Over the course of my time on the water I've witnessed firsthand the true tragedy of an environmental disaster.  I've seen flows like the Shenandoah deteriorate rapidly over the course of two to three years from 50 healthy fish days to 5 lesioned fish days.  I've caught fish with horrific lesions and avoided stretches of certain rivers out of concern for my own health and well being.  I've felt a sense of 'closing in'...wondering how long we have before there are no healthy waters left, and thinking about the inevitability of such a future.   

I am also a father, and thus take a longer term view with regards to responsibility for our environment and its stewardship.  While the crisis you are spearheading efforts to address is no doubt a current issue, I believe it is one in a long line of similar challenges we've faced and will face.  History suggests that because environmental disasters are slow to crescendo and often unobservable at a point in time, political will is nearly impossible to muster proactively.  Rather, it is often reactionary....usually in response to resource degradation so significant it is too late to mitigate, and so broadreaching that it is impossible to ignore. 

My interest in this regulation and others like it is certainly selfish, however it is not my personal benefit for which I am most concerned.  Future generations of Virgnians, my children included, are the constituents with the most at stake in these battlefield skirmishes for our environment.  If our generation doesn't demonstrate an understanding of stewardship and an ability to shift from reactive to proactive, the writing is on the wall and our resources will surely become bankrupt.  One of the greatest minds of our time (IMO), Dr. Jared Diamond, posed a question in his book "Collapse" that I unfortunately believe is relevent to our situation...."What did the Easter Islanders think as they were cutting down the last tree on their island?".  I pray their fate is not ours. 

Sincere Regards,

Derek Venable
212 East Brook Run Drive
Richmond, VA 23238 

CommentID: 9490