Letter Regarding Vermont RAP Rules


Shroom Flowers

To the Agency of Agriculture:

The proposed Required Agricultural Practices (RAPs) rules in Vermont are going about it all wrong and will have many unintended consequences that are destructive to small farms and local agriculture without solving the water quality issues.

It is fundementally wrong to be changing the definition of a small farm. The small farms under the old definition are not the cause of the water quality problems. The threshold between medium and small farms should not be lowered.

Farms that are not spreading manure, fertilizer, pesticides nor herbicides should be completely exempt from these rules. They are not contributing to the problem. In fact, farms like ours are the solution. Our land filters the air and water, cleaning it and making up for others. The added paperwork the RAPs will create are an unnecessary and undue burden for us.

RAP should not be telling farmers how to graze their livestock. That is the farmer’s business and will vary with many conditions that are outside the scope of rules handed down by bureaucrats and legislation. Some times a farm needs to do mob grazing, sometimes light grazing, depending on the goals for the paddock.

Inspectors and any other government officials going farm to farm are a prime vector of disease. The RAPs are going to create problems by transmitting disease from farm to farm. Inspectors should be required to take maximum biosecurity precautions at their cost which means completely new clothing, boots and equipment at each farm, disposable coveralls changed between each farm, vehicles parked off farm, vehicles washed between each farm including tires sanitized. Biosecurity is very serious and an event can wipe out a farm.

The RAP rules are a serious overextension of government that will be an onerous burden on small farms driving many out of business, making it less profitable for those who remain, destroying the farming future for the next generation and driving further development of farm land as farms close. The RAP rules are destructive to Vermont’s food sovereignty by destroying local farm production.

If you live in Vermont, or visit Vermont, then please write the Agency of Agriculture at AGR.RAP@vermont.gov about the proposed RAPe Rules for small farms. The deadline for comments is Friday, December 18th, 2015.

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Daily Spark: Don’t confuse common sense with government rules.

About Walter Jeffries

Tinker, Tailor...
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11 Responses to Letter Regarding Vermont RAP Rules

  1. Matt says:

    I agree with a lot of what you say. It seems part of your argument is to counter there legislation, with legislation. For example, you don’t want their rules imposed, so part of the counter is to impose rules on them. I’m not sure if that works, I don’t know. I agree with the thrust of their idea, in that I understand that AG needs to be redesigned, but lets have leaders in the field guide this process, not legislators. I can think of some Vermonters who could guide this process, and some folks from afar.

  2. aminthepm says:

    Great, just when things can’t be worse . Instead of when it rains it pours, it’s more like deluge !

  3. Charles says:

    I am also concerned about the draft RAPs. They treat Manure and Compost as the same thing and in so doing, I think they are driving small farms away from composting. Under the Draft rules any application of compost to farm acres moves any small or micro farm into the Certified Small Farm category requiring a 590 Nutrient Management Plan. So anyone composting all of a sudden has to spend a lot of time and energy preparing a plan and money doing soil and nutrient tests. There are no thresholds, it just says any compost applied to any acres. That is really going to discourage using compost to treat crop residuals, animal bedding, manure, animal mortalities and slaughter residuals before returning them to the soil. Composting is a responsible and cost effective way to deal with those things, but having to do a 590 plan looks daunting. Without composting, it is going to be a lot harder to farm.

    I made comments to this effect a couple of weeks ago after attending the WRJ hearing.

  4. Chris says:

    The rules were created to protect the ~150,000 folks that drink Lake Champlain’s water.
    It’s a shame the non-farmers drinking the water aren’t held to the same standards as the farmers.
    The 590 plans seems quite reasonable for homes and businesses with lush green lawns that use that water.

    It’s for the safety of those consuming the lake water.
    And shouldn’t the lake water consumers take responsibility for their own safety?
    Shouldn’t the lake water consumers fund their own safety?

    P.S. Has anyone done “Follow the money” on this legislation? I expect backing from lawn care companies, municipal sewage treatment, and possibly a GIS aggregator.

    • The non-farmers make up the vast majority of the pollution from parking lots, roads, lawns and such. Within the small minority of pollution that does come from farms most of it comes from big farms spreading fertilizers and virtually none comes from small farms and pasture based farms. We don’t spread manure. We don’t spread fertilizer. We use legumes like clover, alfalfa, vetch, trefoil and such to gather nitrogen from the air and those and other plants to sequester carbon from the air. Farms like ours soak up pollution rather than producing it. According to research on per acre sequestering our farm sequesters over 1,500 tons of carbon a year in addition to using up other pollutants that come down on us in the rain and via wind. At the Paris talks they said that they need to sequester 7 billion tons a year which is one ton per person. Thus our farm is sequestering enough for 1,500 people. We’re not the problem, we’re the solution. Unfortunately, there aren’t many farmers and they’re an easy group to target. This is but one of many things like this that has gone through or been attempted in recent years. If you look at the fines it’s really about raising money for the state.

  5. Peter says:

    It is unfortunately a problem that has no one right solution. There is the same sort of problem here in in Maryland since pretty much the majority of the state is in the Chesapeake Bay watershed. DC, Northern Virginia and a lot of the Maryland DC suburbs get drinking water from the Potomac. I think people would still be surprised to know you can drive 20 minutes from the DC border into Maryland and be in farm country….and also that the watershed for the Bay stretches all the way into the Southern Tier of New York State.

    Nutrient runoff is still a big issue in the Bay. The Eastern Shore has a lot of chicken farms so there is a huge nitrogen load there that has to be dealt with.

    re: “Unfortunately, there aren’t many farmers and they’re an easy group to target.” Yeah this is true…and the other unfortunate part is that, as with everything else, it’s the bad apples out there that don’t care about being more effective stewards of the land, that bring about this sort of stuff.

    • Cary Howe says:

      They’re trying to farm chickens like they produce cars never considering the waste load the land can properly absorb and filter. In truth there’s little attempt to allow the waste to be processed naturally. They overload farmer’s fields trying to get rid of the factory barns’s output so much of it ends up in the bay. I’ve seen film of it running directly from the chicken barns into creeks and streams. Tyson and the rest forcing contractors into using unsafe practices is the problem and there is an easy solution, do not allow Tyson and the rest to hide behind contracts. They produce the chicks, they own the chickens every step of the way yet the small farmer is blamed for the run off when all they do is feed and house the birds. It’s a scam so the corporations can claim to be innocent yet they force the conditions on the sub contractors. It’s easier for our governments to go after small farmers and claim they are working to fix the problem then to go after the real cause and risk angering their corporate masters.

  6. Cary Howe says:

    I find these rules specifically target small farms where as larger farms can more easily comply. One of the most ridiculous things that I’ve heard proposing is tagging individual chickens that are free ranged yet allowing factory farms to use a single tag for an entire barn full of chickens. The situation gets even sillier when you factor in the disease problems are coming from the factory farms. The claim that it’s for the public’s own good tends to end the debate before it starts. Small farms provide a tiny percentage of the food production but the corporations are so greedy they want even that percentage so they are helping to write the legislation to drive out small farmers.

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