Richard Weeks, Chief Deputy

Department of Environmental Quality

P.O. Box 1105

Richmond, VA 23218

 

Dear Mr. Weeks,

 

            The Eastern Shore Soil and Water Conservation District appreciates the opportunity to submit the following comments on Mr. Pete Terry’s request that consideration be given to regulating storm water from large-scale agricultural operations on the Eastern Shore.

            The District is proud of our work with the agricultural community on the Shore to implement best management practices that protect water quality. Since 2004, we have seen a significant increase in program participation with our grain farmers. Currently we are achieving about 15,000 acres in annual cover crops and nutrient management planning on over 35,000 acres.  Another aspect of our increasing engagement with the growers is that we have worked with each farm manager responsible for tomato production under plastic mulch. In tomato fields we have used both guidance developed in a 2002 Best Management Practices Handbook funded by DEQ and practical experience gained in recent field trials of measures funded by DCR and growers in 2006 and 2007 and defined in our booklet, “Conservation Resources for Plasticulture Farms on the Coastal Plain”. We fully support the use of proven BMP’s such as fall cover crop planted in a timely manner. We consider maintaining the integrity of riparian buffers as essential. Other effective BMP’s include the perimeter retention ditches and walk row cover establishment.   Work on maintaining walk row cover during the growing season is currently under study at the Ag Research Station. With grower assistance we identified and tested BMPs not traditionally used in agriculture that we consider to be helpful in retaining and treating agricultural runoff. Many of these measures, based on the Virginia Erosion and Sediment Control Manual, are being successfully adapted to production agriculture and implemented by the growers. Currently we are working on design and implementation of BMP’s at sites where the farm managers and the District agree that improvements can be made. In some instances this year the District believes that earlier planting of fall cover would have helped prevent erosion loss. We are working with the growers on timing and seeding methods to improve cover crop implementation.

            We support the ongoing voluntary implementation of BMP’s and continuing dialogue with growers, ag researchers, Cooperative Extension, and NRCS who know farming and its challenges. We also feel strongly that progress is being achieved. In addressing six recent Ag Stewardship complaints brought forward on tomato acreage, problems were found on only one of the sites where the District and farm manager had already concurred on improvement measures. We appreciate the high level of cooperation from the tomato growers and the efforts by many local partners in addressing water quality concerns.

 

Sincerely,

Eastern Shore Soil and Water Conservation District Board of Directors