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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