There is a real need for qualified and certified nutrient management planners to assist producers with  Nutrient Management Plans (NMP) which are required and needed in the Virginia agriculture industry.  

As the industry has changed and training evolved students are completing the 2 year Ag Tech program at Va. Tech and receive thorough training in NMP development.  Many also have the relevant experience in order to qualify to take the exam for certification. 

Virginia should add a section to the code in order to also allow students who have completed the 2 year Virginia Tech program and who possess at least 1.5 years of relevant experience---to take the exam for Nutrient Management Planner.    

As a current certified Nutrient Management Planner I am well aware of the shortage of and need for qualified planners who can and will develop these important tools for Virginia's agriculture future.  

Jim Riddell

1. As a certified nutrient management planner working in va., dealing with two regulatory agencies with respect to nutrient management issues is redundant and confusing. DEQ inspects the farms and the NMP. Remove the requirement in the regs requiring an approval letter from DCR. As long as it is prepared by a trained planner working closely with the farmer is acceptable by DEQ.
2. Abolish the "soils"management language from the Standards & Criteria. At the large scale of the soil surveys many of the soil types do not actually appear within a field boundary. The surveys may be relative on large (56 ac.) fields. In fact, there is a paragraph in every published soil survey where the scientists themselves recognized this issue and state;"do not use this information to manage a farm or field".
3. Flexibility for farmers to increase crop production and improve soil productivity or soil health is not allowed unless the farmer provides actual records which comes a great expense ($2500-3000) for a typical farm with animal manures. In these same soil surveys, every one has a statement to manage all soils for "increasing the soil's organic matter and tilth". 
4. Please review the 2016 document from Virginia Nutrient Management Leadership Team (VNMLT) deeper into the 100 page document to see the actual farmer comments to the survey instead of the public statements offered by the team.
5. Move the authority for this program to VDACS and fund it through WQIF dollars instead of Chesapeake Bay Funding, solely. Issues will have a better grassroots focus and landowners will have better access for representation.
6. Drop the requirement for a certified planner's signature on the cover page of a plan. i prepare the plan. My signature does not mean i implement the plan.

DEQ has a Fact Sheet distributed to poultry litter end-users that provides a template for nutrient management that is more understandable, more likely to be implemented and less costly to farmers. This should be used as the Nutrient Management requirement in Virginia. DEQ already inspects these field records with the farm production facility.

I am writing on behalf of Virginia Poultry Federation to encourage you to expand eligibility for the Nutrient Management Training and Certification Program to those who have completed a two-year agricultural associates degree with emphasis on nutrient management and have at least 1.5 years of relevant experience.  This would include the two-year Ag Tech program at Virginia Tech, which provides training in nutrient management.

There is a significant need for additional qualified planners who are certified in Virginia to assist farmers with nutrient management plans, and this is a way to expand Virginia's plan-writing capacity without compromising the quality and competence of plan-writers.  This will help Virginia achieve its water quality objectives, including achievement of Chesapeake Bay restoration goals.  Thank you for your consideration.  

I am writing on behalf of the Virginia State Dairymen’s Association to ask that you strongly consider expanding the eligibility of the Nutrient Management Training and Certification program to include those that have obtained 1.5 years of relevant experience as well as completed an associates degree with an emphasis on nutrient management. Our own land grant universities such as Virginia Tech offer training and coursework in nutrient management.

In order to meet Virginia's water quality goals, more plan writers with the proper training and experience will be needed. With the recent passage of the Dairy Margin Coverage reimbursement program, Virginia’s dairy farms will have increased interest in NMP’s written for their farms. Having a certified NMP is a requirement of the program and making sure that there are sufficient plan writers will be a  necessity in order for the program to succeed. Changes like this could expand the pool of potential plan writers while maintaining the standards of the program. This will continue the progress Virginia has made towards the Chesapeake Bay restoration and water quality. Thank you

On behalf of the farmers across Virginia, we would request that this regulations be opened for allowing additional students to be eligible for certification.  As Virginia is trying to provide the appropriate support and tools to help farmers in reducing the total amount of nutrients in their farming operations, one of the challenges has been a lack of total number of nutrient management planners available to work with farmers across the state.  My farm members have shared that some would like to have a NMP written but their aren't enough plan writers across Virginia to meet the demand.  Therefore, the section that addresses the eligibility for certification in the regulations needs an additional section that would allow an agriculture focused associates degree with some additional experience be eligible for certification as a nutrient management planner.  These degree programs can be developed and some exist with curriculum that would make these students be able to have this credential to help Virginia farmers to maintain and increase the number of active plans available.  If necessary, we would be happy to serve on a review committee to help with making changes to this regulation.

On behalf of the Virginia Agribusiness Council, we urge the Department to open the Nutrient Management Training and Certification Regulations [4 VAC 50 ? 85] in order to widen the eligibility requirements for individuals with a 2-year Associates Degree.

If Virginia is to meet our Chesapeake Bay goals, we need qualified planners who carry with them the experience necessary to work with producers to implement plans.  2-year degrees, such as Virginia Tech’s Ag Tech Program, offer the necessary experience and coursework to prepare applicants for their exam.  These students would still be required to prove their knowledge and qualifications by taking the exam and complete the required follow-on continuing education to maintain their certification.  The current regulations create an unnecessary roadblock for these students to be eligible for certification.

The Virginia Agribusiness Council urges the opening of the regulation and that as section be added clearly recognizing a 2-year agriculturally based degree program as meeting the necessary experience requirement for certification.

Thank you,

Kyle Shreve

Executive Director