Virginia Regulatory Town Hall
Department of Environmental Quality
State Water Control Board
Virginia Pollution Abatement Regulation and General Permit for Poultry Waste Management [9 VAC 25 ‑ 630]
Chapter is Exempt from Article 2 of the Administrative Process Act
Action Develop requirements that will address concerns regarding transfer and off-site management of poultry waste in the Commonwealth.
Stage Proposed
Comment Period Ended on 8/21/2009
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8/14/09  11:15 pm
Commenter: Rob Arner (Supporting Shenandoah Riverkeeper)

Please Pass The Poultry Litter Regulation

Jeff- I hope your well. Below and attached are my comments!  Be well, Rob


Poultry Waste  Affecting the Shenandoah Valley
June 1, 2009
By Robert Arner, 1925 Ridge Hollow Rd, Edinburg, VA 22824
The mismanagement of poultry waste has been a problem in this valley for as long as this industry has become a huge business in the Shenandoah Valley.  As a former Director on the Lord Fairfax Soil and Water Conservation District, Watershed Coordinator for Holmans Creek and Pollution Prevention Specialist for Southeast Rural Community Assistance Program, in the last 14 years I have observed first hand improper practices and the lack of stewardship by the poultry industry.  It will be years before we will fully realize the impacts of this waste upon our health, economy and environment.
Poultry waste greatly impacts the future prosperity within the Shenandoah Valley, Virginia.  Next to soil erosion poultry waste is one of the leading pollution sources to the 3055 square miles of the Shenandoah Valley River Basin.  This basin consists of 7,200 miles of streams, with 59 different watersheds containing 60,000 acres of forest buffer.  The River itself is over 100 miles of fresh water providing life to hundreds of thousands of people, plants, birds, animals and other types of life.  
Here are the facts based on 2007 figures 75% of the poultry farms in the state are in the Shenandoah Valley. Just in Rockingham County, there are more than 520 poultry farms.  Augusta County has more than 130 poultry farms, Page more than 180 and Shenandoah more than 70.
Now there are many ways poultry waste will affect us in the Valley.  For example poultry waste management must make equal preventative measures.  Towns now are making a multi-million dollar investment in wastewater pollution controls.  Just the towns of Woodstock and New Market are investing upwards of $30 million dollars each to remove nutrients from the water.  Also factor tens of millions dollars spent in watershed restoration.   So allowing poultry waste to enter our watersheds waste valuable taxpayers investments and makes no sense.
If you review all the ways this poultry waste impacts the valley from a health, and environmental perspective allowing for such waste not to be monitored is foolish. 
In 2000 the Shenandoah Valley received $1,270,484,000 in revenue from tourism accounting for 9.7 percent of the state's tourism revenue.  Recreation use associated with the Shenandoah River is increasing annually, with current use estimated at 250,000 recreation visitor days a year.
While the exact are cause of fish kills unknown the high concentrations of poultry waste generated may be a contributing factor.  In the seven Shenandoah Valley counties affected by the ongoing fish kills, it was estimated that freshwater anglers generated $16.2 to $21.4 in economic value for small businesses and the Commonwealth in 2001.[1]  In 2005, a conservative estimated was made that the fish kill resulted in 2100 few licenses and this loss in anglers in the region equated to $686k in lost retail sales and revenues to the state.[2]
Integrating poultry waste pollution prevention the Shenandoah Valley requires a collaborative approach.  Throughout the Valley, numerous organizations are working to improve water resources management.  For example the Soil and Water Conservation Districts and Planning Districts serve as examples of integrating various county and federal, state, regional and local agencies to address various water quality improvement efforts. 
The introduction of the Total Maximum Daily Load (TMDL) program and the Tributary Strategies program involve similar processes (both micro- and macro-nutrient reduction programs) to improve our water. The integration of such efforts is imperative given tighter and tighter resource constraints.
In closing I hope the Commonwealth of Virginia establishes better poultry waste management incentives and regulations.


[1] Economic Impact of 2005 Fresh Kill: Preliminary Assessment, Shenandoah River Fish Kill Task Force, July 2006, Center for Energy and Economic Sustainability, Maria Papadakis, James Madison University, Harrisonburg, VA 22827, pg 1
[2]  Ibid pg 1


Kindest regards,

Rob Arner


CommentID: 9589