Poultry litter is an inevitable by-product of poultry production.

If the goal is to reduce pollution in the Chesapeake, while not destroying the poultry industry in Virginia through over-regulation, a better course of action is to improve the utilization of the litter product as an fertilizer product in other agricultural production.

As a hay producer, we are facing large increases in chemical fertilizer products and expect this trend to continue.  Purdue AgriRecycle has a facility in Seaford, DE that produces a pasteurized, USDA certified organic pelletized litter product that we use successfully on our hay fields.  Phosphate levels are being controlled through the use of phytase (http://en.wikipedia.org/wiki/phytase) enzyme in the animal feed.

Rather viewing poultry litter as a problem that must be solved through regulation, it would be a better use of Virginia state government resources to promote the value added processing of the valuable poultry litter to encourage wider geographic use in Virginia's agricultural community.  Concentration of the litter in the production areas would be reduced.

In our area of Northern Virginia, the unregulated runoff of residential lawn fertilizers into streams and watershed are doing far greater harm than agricultural applications.  We have to pay for every pound of fertilizer we apply to our fields and make every effort to ensure that it is used productively.