On behalf of the farmers across Virginia, we would request that this regulations be opened for allowing additional students to be eligible for certification.  As Virginia is trying to provide the appropriate support and tools to help farmers in reducing the total amount of nutrients in their farming operations, one of the challenges has been a lack of total number of nutrient management planners available to work with farmers across the state.  My farm members have shared that some would like to have a NMP written but their aren't enough plan writers across Virginia to meet the demand.  Therefore, the section that addresses the eligibility for certification in the regulations needs an additional section that would allow an agriculture focused associates degree with some additional experience be eligible for certification as a nutrient management planner.  These degree programs can be developed and some exist with curriculum that would make these students be able to have this credential to help Virginia farmers to maintain and increase the number of active plans available.  If necessary, we would be happy to serve on a review committee to help with making changes to this regulation.