Not sure if this applies, but the last time the Virginia Nutrient Management Standards & Criteria manual was last updated was July 2014. It needs some TLC, particularly with calculating lime. I stopped using the manual to check lime recommendations because it never matches with the VT soils lab, and I don't think it matches CAS either (haven't checked into that thoroughly yet).

The current information in the Standards & Criteria pertaining to pine tree nutrient applications is outdated and very limiting, especially when there is a huge potential for growth and nutrient uptake. Biosolids application in forests are currently once every 8 years at a 200lb N/ Acre rate. In the same 8 year span a Grass crop will receive roughly 640lbs N and double the amount of Phosphorous. Research shows that just the Forest soils themselves can retain 90% of Nitrogen applied and greater than 100% Phosphorous in the O horizon. The department of forestry has research applying 400lbs Nitrogen to loblolly pine plantations using lime stabilized biosolids and seeing a 40% increase in volume to the stand. The entire section on Pine and Hardwood Maintenance should be revised for organic nutrient sources. From the research I have found and my background in forestry and agriculture I believe 200lbs of Nitrogen should be allowed every 4 years for trees 5 years or older. Also with organic nutrient sources applications on younger pine trees should not be limited to just spring and summer. We should be able to use any Unbiased research including the department of forestry for pine tree applications.  

August 4, 2025

Re: Nutrient Management Training and Certification Regulations [4 VAC 50-85]

On behalf of the undersigned organizations, we are writing to support these regulations. 

From the perspective of producers in the Commonwealth, our goal is to safeguard the future of agriculture and ensure our farmers have the tools and resources to thrive. We support the current Nutrient Management Training and Certification Regulations as they directly benefit both producers and the health of Virginia’s environment.  We believe the Nutrient Management Training and Certification Regulations (4 VAC 50-85) are essential for developing nutrient management plans which maintain healthy soils, protect water quality, and strengthen the economic viability of farms of every size.

We support updating applicable tables and data sets in the regulations with the most current research-based science from our land-grant universities.  Making nutrient management planning more user-friendly through enhanced flexibility and simplicity would further benefit the grower.

Voluntary, incentive-based measures are critical to agriculture continuing to do its part in protecting the watersheds.  Our members utilize nutrient management plans to manage their crop and livestock production, and these regulations help guide their use of conservation practices.

We support these regulations because they deliver real benefits to our members.  Maintaining access to resources through cost-share programs and conservation incentives help drive innovation on the farm, preserving these vital resources for future generations.  Our memberships are committed to being the best stewards of their most valuable asset, their land.

The review period is open to determine “whether this regulation should be repealed, amended, or retained in its current form. Public comment is sought on the review of any issue relating to this regulation, including whether the regulation (i) is necessary for the protection of public health, safety, and welfare or for the economical performance of important governmental functions; (ii) minimizes the economic impact on small businesses in a manner consistent with the stated objectives of applicable law; and (iii) is clearly written and easily understandable.”  These standards protect public health, help farmers thrive in rural communities, and are written to a standard that help implement programs. 

Please reach out with any questions.

Sincerely,

Virginia Agribusiness Council

Virginia Cattlemen’s Association

Virginia Grain Producers Association

Virginia Soybean Association

Virginia State Dairymen’s Association