On behalf of the 39,000 producer members of the Virginia Farm Bureau Federation I offer in opposition to further regulation poutry litter the following comments :

• There is little or no evidence that show end users of poultry litter are utilizing it in a manner that causes pollution.  Neither Agriculture Stewardship complaints nor enforcement actions of DEQ demonstrate a water quality problem. Farmers don’t waste things they pay for!

• The Poultry Litter Management Act does not apply to end users and to do so will strand litter on the farms that produce it.

• Requiring soil samples and nutrient management plans for the purchase of litter will make the poultry grower the “policeman” of litter and perhaps acceptance of liability for the actions of purchasers.

• Recent federal court decisions have stated that environmental agencies may only regulate actual pollution not potential pollution.  Requiring this type of permit will regulate the potential for pollution.

• Litter once it leaves the farm of origin is fertilizer; nothing more.  This regulation will establish a precedent for all fertilizer applications.