January 22, 2009

Mr. Rick Weeks

Chief Deputy

Department of Environmental Quality

629 East Main Street

Post Office Box 1105

Richmond, VA 23218

(Transmitted by fax 804-698-4346 and email rfweeks@deq.virginia.gov )

RE: Comment on Petition Title “Prevention of Degradation of Water Quality on the Eastern Shore as a Result of Large Scale Agricultural Operations”

Dear Mr. Weeks,

Per the Administrative Process Act this letter contains our response to the State Water Board regarding the above mentioned petition. Pacific Tomato Growers (PTG) does not support initiation of rulemaking until and unless peer reviewed science credibly supports such an action.

PTG annually farms approximately 200 net acres of grape tomatoes split between Accomack and North Hampton Counties. About 20 percent of that acreage is certified as organically grown. Our farmers and their families live and work on the Eastern Shore of Virginia.

Our family owned company and its operating managers have adopted the Best Management Practices (BMPs) developed by the Eastern Shore Soil and Water Conservation District (ESSWCD) as the basis for our farming activities on the Eastern Shore so that we can be confident that our farms contribute to the local economy and do not contribute to the degradation of the environment. Recently, we were named the Conservation Farmer of the Year by the ESSWCD in recognition of our efforts.

We laser level fields and utilize erosion controlled barriers. We research and select the most environmentally friendly pesticides.  Our irrigation systems are designed to meet the highest grade of efficiency, thus minimizing the amount of water needed during the crop cycle and consequently diminishing any run off water.  Our fertilizer program is designed to provide only the minimum amount of nutrients necessary to produce an economical crop and is based on the soil and leaf analysis taken from the fields. 

During the off season (fall and winter) all our fields are planted with a cover crop to eliminate wind and water erosion, as well as, absorb remaining nutrients, if any, left from the previous cycle of tomato production. The cover crop also adds a significant amount of organic matter to our land. 

We believe farmers are the consummate environmentalists. As the fourth generation assumes management responsibility PTG farming operations they remain firmly committed to improving the land and acting in an environmentally beneficial manner everywhere we farm. Our firm belief is that we are stewards of the resource for the next generation. It is hoped our comments and commitment to utilizing BMPs are helpful to your process.

Sincerely,

Billy L. Heller, Jr.

Chief Executive Officer