I believe that it is of the utmost importance to protect and improve this beautiful and unique environment in which we all live.  I also believe that many of your efforts to do this have been very beneficial, and I agree with many of the regulations you have implemented in the past in order to do this.  Upon saying that, I would like to state that this document is not one of them.  It contains no sound, science-based information and the entire report is full of assumptions.  Much of the statistical information it does contain is five and ten years old.  Not having the assured information required, this report turns to using phrases such as “likely”, “DCR expects”, and “not possible to make a sound determination at this time.”

Due to the already stringent regulations farmers have been confronted with, as well as the increased cost of supplies and resources, farming has become more and more difficult to maintain as a viable occupation.  Throughout the report, however, these costs have not been quantified.  It appears as though the economic analysis was rushed through and many critical pieces were forgotten or just ignored altogether.    

The use of the P-Index is a very good method, and when used in association with other BMP’s, will accomplish our goal of protecting our environment much more efficiently.  Using crop removal as the application rate is already restrictive enough and encourages organic nutrients to be moved to fields with a higher need.  There is no scientific basis for the 50% saturation limit, and I recommend that it be removed from the regulation altogether.