As the grower-members of the Association of Virginia Potato and Vegetable Growers, Inc. we are strongly in favor of clean water. However we take exception to the allegations behind the proposed regulation of plasticulture operations and we oppose continuing with the NOIRA.

We believe that structuring the Department of Environmental Quality (DEQ) as a regulator of agricultural activities will have profound negative impacts on our agricultural economy. The whole idea does not take into account the well-established context of cooperation and improvements that farmers have undertaken to improve soil and water quality. Even within the environmental community, organizations like the Chesapeake Bay Foundation, recognize that farmers have made significant progress in reducing pollution loads to the Chesapeake Bay, and tomato growers can be counted among them. They have worked closely with conservation partners to improve field conditions. The poor stand of cover crop this year was entirely weather-related. By the 8^th of November, the fields were too wet to work and much of what was planted was drowned. In 2009, rainfall was 10” above average, and that 10” fell in November and December. It affected not only cover crops, but all of our grain farmers, as well. Only about 1/3 of the wheat crop was planted, which will affect the bottom line for many.

We are very concerned that the non-science-based anecdotal evidence paints such a negative picture of agriculture, and plasticulture in particular. According to studies funded by DEQ, there is no “smoking gun” that correlates tomato plasticulture with adverse effects on clam or oyster mortality. The conclusion of the 1999-2000 study stated, “We did not find any association between the presence of plasticulture and sediment toxicity, benthic invertebrate or fish communities, growth or mortality of oysters, or bioaccumulation of copper or organic pesticides in oysters.” The conclusion of a 2008 study of sixteen watersheds on the Eastern Shore noted, “It is not apparent from our dataset that impervious surface attributable to tomato cultivation is correlated with elevated loadings of these materials (fecal coli form bacteria, suspended solids, nitrogen, phosphorus, Chlorophyll a). This finding is somewhat surprising given our casual observations over the past decade of high levels of run-off from tomato fields.” We would also like to point out that in that same study, the watershed with the most plasticulture has some of the best water quality.

Plastic mulch systems are themselves a best management practice (BMP) for agricultural production. Plastic mulch systems utilize drip irrigation and reduce evaporation; thereby reducing water use up to 50% compared to conventional irrigation systems. Similarly, plastic mulch produces a micro-climate under the tomato plants that allows the farmer to have complete control over fertilizer management; which increases efficiency and reduces fertilizer use and losses to the environment.

For a number of years tomato growers have been involved with research projects to improve production practices, most notably cooperating with scientists at both the Virginia Institute of Marine Science (VIMS), and at the Virginia Tech Agricultural Research Center, to study the effects of different BMP’s on local water quality.

On the ground, growers and their conservation partners recognize the value of BMP’s. In conjunction with a local working group, tomato growers have voluntarily implemented, refined, and innovated on a variety of measures to improve runoff management. Much of the runoff recycles to ponds for use in irrigation and never enters the tidal creeks or Chesapeake Bay. Growers have spent hundreds of thousands of dollars on BMP’s including sediment retention ponds, rock check dams, and vegetated buffer strips to minimize potential water quality impacts. Scientists at the Virginia Tech Eastern Shore Agricultural Research and Extension Center continue to work with the agricultural companies to conduct studies that cover the full gamut of agricultural production and conservation. Unfortunately, this work has not bee acknowledged by industry detractors.

The Association fully supports the ongoing efforts of the conservation partners who understand agricultural production. As evidenced by the great strides that have been made to address cropland concerns, the partnership works. We applaud the efforts made by the tomato growers to date. They have stepped up to the plate to install best management practices and these efforts have been undertaken with a cooperative and open dialogue involving many partners such as the Soil and Water Conservation District, NRCS, Virginia Cooperative Extension, the Virginia Department of Agriculture and Consumer Services and private consultants, among others.

We fully agree with the comments submitted by Robin Rich-Coates, Chair of the Eastern Shore Soil and Water Conservation District (and 19-year Director). “There is already a way to ensure that farmers are not violating the law through the Agricultural Stewardship Act. The Ag Stewardship program works well and it is not necessary to reinvent the wheel.”

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