As a certified nutrient management planner working in va., dealing with two regulatory agencies with respect to nutrient management issues is redundant and confusing. DEQ inspects the farms and the NMP. Remove the requirement in the regs requiring an approval letter from DCR. As long as it is prepared by a trained planner working closely with the farmer is acceptable by DEQ.
Abolish the "soils"management language from the Standards & Criteria. At the large scale of the soil surveys many of the soil types do not actually appear within a field boundary. The surveys may be relative on large (56 ac.) fields. In fact, there is a paragraph in every published soil survey where the scientists themselves recognized this issue and state;"do not use this information to manage a farm or field".
Flexibility for farmers to increase crop production and improve soil productivity or soil health is not allowed unless the farmer provides actual records which comes a great expense ($2500-3000) for a typical farm with animal manures. In these same soil surveys, every one has a statement to manage all soils for "increasing the soil's organic matter and tilth".
Please review the 2016 document from Virginia Nutrient Management Leadership Team (VNMLT) deeper into the 100 page document to see the actual farmer comments to the survey instead of the public statements offered by the team.
Move the authority for this program to VDACS and fund it through WQIF dollars instead of Chesapeake Bay Funding, solely. Issues will have a better grassroots focus and landowners will have better access for representation.
Drop the requirement for a certified planner's signature on the cover page of a plan. i prepare the plan. My signature does not mean i implement the plan.
