The Virginia Agribusiness Council participated in the work group to develop these proposed regulations. We find them to be reasonable and fulfilling the intent of the legislation. However, we would note that the regulations will have the greatest impact on the professional contractor-applicators of fertilizer on non-agricultural land who are already trained, have experience, and have registered with VDACS as legally required. The contractor-applicators who do not register with VDACS are mostly unknown and most probably the most untrained and inexperienced. Efforts need to made to identify these contractor-applicators and ensure their compliance with existing law and regulations.