On behalf of the Culpeper Soil and Water Conservation District Board of Directors.

Absolutely necessary for the effectiveness of the proposed ( or any ) methodology for identifying perennial streams related to any "requirement" for fencing out livestock is the inclusion of extensive field testing of adopted methodology(s)  prior to expecting any landowner to abide by it.  We recommend that this be included in the narrative of the draft guidance document as an essential step in the process. Secondly, we recommend that it be clearly identified in the draft what recourse any landowner has to appeal any such determination using the proposed methodology and what process will be utilized to reconcile the appeal. 

The Board appreciates the opportunity to provide comment.