I am suggesting two changes to make implementation of VPA general permits easier to enforce and follow.

1. Change outside storage of poultry litter from 14 days to 24 hours. The 14 day allowance as caused more confusion and waste of state resources. A simple requirement that poultry litter stored outside meaning not in the poultry house or litter shed shall be covered at all times. The exception would be if the pile is being added to or subtracted from.
2. Nutrient management plans should be required for all end users of poultry litter. Without this requirement it is unlikely that Virginia will ever meet the Chesapeake Bay Watershed implementation nutrient reduction requirements.

Thanks,

Tad Williams

3054 Crystal Spring Lane

Rockingham, VA 22801

540-810-8648