My name is Allison Wickham and I am a pollinator professional. I have over two decades of experience in various forms of agriculture including grain crop production, hay, dairy, beekeeping, and pollinator habitat/native flowers. I have a degree in chemistry with minors in environmental studies and geography and a Master’s degree in soil and crop science. I have worked in agriculture my entire career and have been specifically managing bee hives and installing pollinator habitat time-and-a-half for the last five years.

1. The spirit of the proposed amended code is fantastic and critically important to environmental quality in the Commonwealth as solar grows, this is awesome.
2. You forgot beekeeping. Beekeeping should be specifically included in this code the same way sheep and other livestock, hay cutting, and crop farming have been specifically called out in the language. I assume those activities were called out because they are feasible on solar sites. I keep bees at solar sites and can testify that running an apiary on a solar site is feasible and therefore should be included. Here is the data to support the inclusion of specific language around beekeeping in this amended code:

The United States Department of Agriculture (USDA) considers beekeeping agriculture, and defines honey bee hives as livestock just like sheep. Beekeeping has its own chapter in the Virginia Code. Chapter 44. It falls under Title 3.2. Agriculture, Animal Care, and Food, just like the other specifically highlighted agricultural activities in this amended code. Bees and beekeepers are regulated and monitored by the Virginia Department of Agriculture and Consumer Services just like sheep, hay, and crops. The North American Industry Classification System (NAICS), which establishes specific codes for industries in which US companies participate, is used by federal agencies to establish data on the US economy. Companies are also taxed, regulated, and contracted with the federal government based on these codes. The NAICS code for beekeeping is 112910, which is also known as apiculture. Apiculture falls under the primary category of “Agriculture, Forestry, Fishing, and Hunting”. 2VAC5-20-20 of the “Standards for Classification of Real Estate Devoted to Agricultural Use and to Horticultural Use Under the Virginia Land Use Assessment Law” includes apiary operations as qualifying activities.

The National Agricultural Statistics Service (NASS) falls under the USDA and collects agricultural data from farmers to produce annual reports to monitor the health of American agriculture. The most recent agricultural census report is from 2022. The report shows the United States apicultural industry to have 73,496 farms with 3.8 million hives, with a combined $7.5 million in honey revenue and pollination contracts. Compare that with the US sheep industry: 88,852 farms with 5.1 million sheep and an economic value of $7.0 million. Economically equivalent industries with near equivalent professional members should be given equivalent consideration under this code. Federal and state agencies agree the bees and sheep are both livestock, and the economic data supports the validity of each industry as near equivalent.

The most obvious food production associated with beekeeping is honey. According to market.us the global honey market is a $10 billion industry that is growing rapidly. It is expected to reach $15 billion in the next 10 years. In the United States, the per capita consumption of honey has nearly doubled since 2000 as people look for healthier alternatives to processed foods. Unfortunately, due to economic pressures and weather, honey production has decreased in the United States since the 1990’s. Imports of honey from other countries, however, has more than doubled since surpassing domestic production near 2005. To me, this signifies an opportunity for American agriculture to fill a domestic demand with domestic product. This should be encouraged legislatively. Virginia consistently ranks in the bottom 10% of honey producing states while states with similar environments make the top 50% such as Tennessee, North Carolina, Pennsylvania, and Ohio. However, when I compare the USDA’s published price received for honey, I see that in 2023, Virginian beekeepers received $8.58 per pound compared to $4.96 in Pennsylvania, and $6.00 in Tennessee. What is see is a growing domestic demand, room for improvement within the Commonwealth, and a premium for Virginia-grown products. It has become obvious that partnering sheep grazing with the solar industry creates savings for solar, environmental benefits, and economic opportunity to the sheep industry. When I look at beekeeping data, I see the equivalent opportunity. There is not only economic opportunity in honey. That honey can be transformed into a value-added product like mead, or honey wine. Mead, the oldest intentionally made alcoholic beverage, is catapulting back into acclaim. As a rapidly growing sector, the option to make mead or work with meaderies is an important opportunity for beekeepers. Additionally, farm meaderies contribute to the Commonwealth’s agritourism sector.

Honey aside, bees provide a critical ecosystem service to the 3-5 miles surrounding their placement. Honey bees are the top pollinators of the food crops we find in the grocery store and pollinators are responsible for the reproduction of 90% of flowering plants and about 35% of all the food we eat. Without pollinators, we lose 1/3 of the diversity of our diet and that sector of agriculture goes to $0. In the United States, almonds, blueberries, melons, apples, pumpkins, oranges, nuts, and other fruits and vegetables are pollinated by honey bees. It is estimated that pollinators add a staggering $18 billion dollars in revenue to the US agricultural economy through the services they provide. There is a free tool available online called Beescape which estimates the economic contribution of pollinators in the 3 mile radius surrounding a chosen point. When the address for VA DEQ headquarters is entered, there is an estimated $6,000 pollinator economic impact even though the area is considered 84% developed. When you switch the search location to a well-known solar site, Spotsylvania Solar, that climbs to $30,000-$57,000 depending on where you stick the bees. The 3-mile radius encloses most of the site as well as thousands of acres of surrounding farmland, forest land, and residences. This economic contribution is difficult to see but cannot be ignored. There is economic value to the neighboring homes and farms when beehives are placed.

Furthermore, there is pressure from counties, the solar industry, and neighbors of solar projects for sites to incorporate pollinator plantings. This is common sense and, in my opinion, should be required at every site in the Commonwealth. When solar companies install pollinator habitat and accompany that with beehives, there will be increased seed set in the pollinator plants and increased flower yields. This decreases the cost for the solar operator to replant annuals and failed perennials and provides much needed forage for native pollinators and honey bees alike. Pollinators directly contribute to enriching ecosystem biodiversity and increase in forage for wildlife, including T&E wildlife. Honey bees are generalists, and unlike many of our native specialist pollinators, will visit almost any flower with nectar or pollen which includes the fruits and vegetables in Virginian’s gardens and farms.

I have often heard the argument that bees are not native here and therefore shouldn’t have a place in our solar sites. Cattle as we know them are not native here, only bison. Sheep as we know them aren’t native here, only the long horned in the mountains. Pigs are not native here. Chickens are not native here. Goats as we know them are not native here, only the rock goats of the Northwest. If we are encouraging solar companies to incorporate livestock into their sites, we cannot forget the honey bee under any circumstance.

Another argument against honey bees is their competition with native pollinators. This is an emerging body of science which needs further study and development. There are examples of high-density beekeeping operations that displace native pollinators in certain conditions, but other studies which show neutral effects. Many studies show convincing evidence that there are appropriate stocking rates which optimize honey production per hive and minimize or negate impact on native pollinator populations. There is also good evidence that increasing floral density decreases negative impacts on native pollinators. When I average the papers I have read, an ecologically responsible stocking rate of managed bees is 25 hives for a 3-mile radius point/site. This is in close agreement with the Xerces society’s more conservative published recommendation of having apiaries with no more than 20 hives, ideally separated from other apiaries by 4 miles. Combining science and recommendations, I’d recommend a maximum of 20 hives at a small site to optimize beekeeper success and minimize any potential detrimental impact on native pollinator populations. It would be good practice to determine if any apiaries larger than 20 hives exist within a 4-mile radius of the site to cautiously protect native pollinators as we learn more about this interaction.

I have also heard that if beekeeping is included then solar companies will shove a few hives on a site just to qualify. I fully advocate that just as qualified engineers are required to certify the size of the project in MW, professional beekeepers (existing bona fide beekeeping businesses) be responsible for maintenance of the hives. Additionally, I advocate that any apiary installation must be in combination with pollinator smart habitat installations to qualify. Planting pollinator habitat ensures there is enough food for the honey bees and the native pollinators. 

I propose either adding a subsection in section 9VAC15-60-60 E.4 to include beekeeping as a management alternative in combination with pollinator smart plantings OR to change the definition of “Establishment and maintenance of pollinator smart habitat/vegetation" to:

“Establishment and maintenance of pollinator smart habitat/vegetation" means establishment and maintenance of pollinator smart vegetation in accordance with the DCR/DEQ POLLINATOR–SMART Comprehensive Manual. This shall meet short-term and long-term erosion and sediment control (ESC) standards and may require change of cover type or species mix following initial ESC stabilization. Pollinator habitat shall cover at least 35% of the disturbed area claimed for this credit or 30% if an apiary is managed on the site at appropriate stocking rates of no more than 20 colonies in a 4-mile radius from the apiary location, by a professional beekeeper.

Or something like that wording. By including the beekeeper in the definition and increasing the pollinator habitat requirement, several good things are accomplished. First, we recognize Virginia beekeepers as bona fide farmers with the same respect and consideration given to sheep farmers and hay cutters in this proposed amendment. Secondly, we encourage a connection between Virginia beekeepers and the Virginia solar industry. Third, we provide economic opportunities to Virginia beekeepers which contributes to Virginia’s agricultural landscape at large. Fourth, by increasing the percentage of pollinator habitat without bees, but maintaining the percentage deemed appropriate to offset adverse impacts and qualify for reduced mitigation, we either have the same impact intended in the original language, or an even greater impact on pollinator habitat land cover without them. This is a win-win-win.

3. Under the section “analysis of beneficial and adverse effects on natural and historic resources, section C.2 A completed DCR Virginia Solar Site Pollinator/Bird Habitat Scorecard, some clarification would be good. Section C references “desktop” analysis. Does this mean the scorecard should grade the proposed vegetation management plan? Or should the scorecard grade the pre-construction condition of the site? In my opinion, both would be good so that any stark change in impact is made clear. Solar has the potential to have enormous benefits to pollinators and endangered birds, especially in comparison to current crop and forestry land uses. Not only would this provide critical data for DEQ on land use changes and their impact on pollinators, but it would strengthen the vegetation monitoring industry and the pollinator smart program.
4. It is well known at this point that incorporating agriculture and pollinator habitat into solar sites is beneficial to the local economy, the local ecosystem, the solar industry, and governing agencies. I present concern that a 25% reduction in the mitigation requirement due to agricultural /pollinator activities on the site is not enough incentive and is potentially disproportionate to the ripple effect of “good” that comes from agrivoltaics. I recommend increasing this percentage to 30-33% to better incentivize agrivoltaics activities in Virginia so that we can serve as a model to other states for how to encourage, incentivize, and support the co-existence of agriculture and energy production. What is the average economic and environmental value of a 25% reduction in mitigation compared with the estimated economic and environmental value of soil preservation and establishment of pollinator habitat plus beekeeping and sheep grazing? How do we make it so that the in-lieu fee is not the cheapest way out?

I am happy to provide references cited upon request. 

Plant more flowers, keep more bees. Do it in solar.