As farmers weighed in on the third and final draft of proposed new agricultural practices regulations designed to clean up Vermont’s steams, rivers and lakes, Vermont Agriculture Secretary Chuck Ross made it clear that stricter regulation is not an option — it is essential. 
“While the rules are necessary, my personal opinion is they are not sufficient,” Ross said at the Brandon American Legion Hall on June 22 during hearings on the Agency of Agriculture’s Required Agricultural Practices regulation.
“We really need to change the culture of Vermont if we are going to effect real change,” he added.
This round of public hearings, which included stops in seven Vermont cities and towns, collected input from farmers before the agency finalizes an updated version of RAPs (as they are known) to the Legislative Rules Committee this fall. 
The proposed rules outline best practices and regulations for farmers in manure, nutrient and floodplain management as it relates to stormwater runoff. The need for them became painfully clear last summer when the U.S. Environmental Protection Agency released the final draft of its plan to reduce the amount of phosphorous that drains into Lake Champlain.
On June 17, EPA established new limits for how much phosphorus is allowed to make its way into the lake. Manure and farm chemicals are substantial sources of phosphorus pollution.
Roughly 50 farmers and stakeholders attended the hearing in Brandon.
“The rule applies to all farms and reflects a lot of input we’ve had from the farming community,” Ross said. “Not just from the last six or seven months, but the last few years. We’re trying to find the right balance.”
WATER QUALITY 101
In Western Vermont, most streams and rivers lead to Lake Champlain, where water quality is affected by the amount of phosphorus in the water. Phosphorus is a naturally occurring nutrient found in manure. For over a decade now, the state has been working with Vermont’s farming community to set best practices and stem the tide of phosphorus running into the lake. 
The Agency of Agriculture was directed by the Legislature to draft the RAPs pursuant to Act 64, signed into law on June 16, 2015. Act 64, also known as the Vermont Clean Water Act, enacted multiple requirements related to water quality and requires that the revised RAPs include requirements for small farm certification, nutrient storage, soil health, buffer zones, livestock exclusion, and nutrient management on Vermont’s farms. The state offers financial support to help farmers implement many of these best practices.
As a result of the Vermont Clean Water Act, the Agency of Agriculture was charged with updating the Accepted Agricultural Practices (AAPs) to further reduce the impact of agriculture on water quality across the state. The RAPs are an updated version of the AAPs, the rules in place since 1995 that regulate farms in order to protect water quality.
The agency has held over 80 small stakeholder and large public meetings on the RAPs to solicit feedback from farmers, stakeholders and the public. According to the agency, over 1,800 people have attended these meetings since October 2015 to learn more about the RAP Proposed Rule and to share testimony and comment.
A SHIFTING TIDE
While Vermont remains an agriculture state, farming has changed over the last 20 years. Where large dairy farms were once the rule, falling milk prices and a shift in dietary priorities have given way in some part to value-added farming. Cheesemaking, alpaca and sheep fiber farming, vineyards, beekeeping, specialty meat livestock, berry farms, maple sugaring and organic vegetable farming are now the norm in Vermont as farmers have become more entrepreneurial in their quest for a profitable agricultural life in Vermont.
The Brandon meeting drew farmers from all over Addison and Rutland counties, most of them considered small farm operators and certified small farm operators, meaning they have no more than 100 dairy cows or 300 beef cows.
In her comments at the hearing, Hannah Davidson of Good Earth Farm in Brandon, urged the agency to consider another reality with smaller-scale farming in Vermont, that there are often multiple farmers on the same plot of land.
“You have several folks managing the land, and they’re not sure who bears the burden (of implementing best practices),” she said.
“You can have 10 acres where someone is doing the right thing, and one area where someone is doing the wrong thing,” she added. “The rule should be more practice-based.”
Davidson also said she thought the language in the proposed rule is skewed toward  mitigating runoff and doesn’t speak enough to using regenerative crops. Regenerative agriculture is a form or organic farming that implements no-till, cover crops and reduced use of pesticides. There are also certain some types of mushrooms and garlic, as well as perennial vegetables like kale, asparagus and rhubarb, that add nutrients to the soil rather than draw them out, improving soil health without adding manure.
Mark Baldwin of Addison described himself as a “reformed dairy farmer who now grows soybeans and corn.
“We are looking at the wrong thing,” he said in his comments. “The phosphorus in the lake is not the problem. The phosphorus on the land is not the problem. The water runoff is the problem.”
Baldwin also said he had come to previous public hearings and felt the five-minute limit on comments was not enough.
But Laura DiPietro, the agency’s deputy director of agricultural resource management, reminded Baldwin that additional comments can be made at the end of the official comment period of each hearing as time allows. Written comments are also being accepted. 
Secretary Ross told those gathered at last week’s hearing in Brandon that he has seen a significant change in the way Vermont farmers perceive their role in improving water quality. Agricultural soil also contains phosphorus and soil erosion via storm water runoff and contributes to the phosphorus levels. Cover crops like oats, winter rye and buckwheat are cover crops that can be planted to prevent soil erosion.
“Ten years ago, there were 50 acres of cover crop in Vermont,” Ross said. “Now, there are 14,000 acres. That’s an amazing amount of change.”
Ross said he has been heartened by the effort he’s seen in the state’s farming community to get on board the clean water effort. 
“We’ve seen a record number of requests seeking best management practices,” he said. “Those are the kinds of signs I’ve been witnessing since my first day, and it’s because the farming community is putting their shoulder to the wheel and really trying to effect change and best management practices.”
The public comment period on the RAP Proposed Rule is open until July 7. Written public comment can be submitted by sending an email to [email protected] or by U.S. mail to the Agency of Agriculture, 116 State St., Montpelier, VT 05620. 
A print copy of the RAP Proposed Rule can be requested by e-mail, phone or in writing.  Email [email protected] or call 802-828-2431 for more information.