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Our Public Comment on Vermont’s Required Agricultural Practices

We submitted the following letter to the Vermont Agency of Agriculture, Food, and Markets on the last day that they were accepting public comment on the Required Agricultural Practices—or RAPs. Now that the rule has been formally submitted by the Agency, we thought we’d publish our final comments.

See the bottom of this post for an explanation of the featured “before” image (above), and the “after” image (at the bottom).


First I’d like to thank you for taking on the monumental task of addressing the water quality and environmental degradation issues facing Vermont. As a farmer, this issue is of paramount importance to me, my business, and the future of our state. If we stand idly by and allow the land and waterways we hold dear to be slowly (and not-so-slowly) degraded by widespread and short-sighted agricultural practices, we further impair our children’s ability to make lives here in Vermont.

You are not standing idly by, and for that, I thank you.

For the record, I would like to submit the following recommendations for improving the Agency’s efforts to clean Vermont’s waterways through the Required Agricultural Practices.

1. Manure is not the problem. Manure is the answer.

The RAPs villainize manure. In reading the RAP documents and attending the Agency’s RAP presentation, it is made perfectly clear that the Agency of Agriculture views manure—and the livestock that produce it—as the leading contributor to Vermont’s water quality problems. This is not the case.

The RAPs, as you know, define how and when manure must be spread, how it is stored, how livestock must be fenced, and so on. The RAPs focus so heavily on the management of manure, they distract us from—and downplay the far greater importance of—the real problem: the heavy and repeated spreading of synthetic NPK fertilizers on degraded soils. This is the larger issue that the RAPs fail to address adequately—or even mention by name.

Buffers, riparian areas, ditches and so forth are simply attempts to contain the problem. They are not attempts to solve the problem. The RAPs should focus solely on increasing the organic matter in the soils of Vermont’s agricultural production areas. This is done with proper livestock management, manure, compost, green manures, cover cropping, and other regenerative practices. For example, if one farmer was able to increase the organic matter in one 1-acre field by 1%, that field would retain 16,000 gallons more water—keeping it, and all the agricultural “wastes” it contains, out of the state’s waterways. The Agency can solve Vermont’s water quality problems quickly and cheaply by convincing, enticing, or requiring Vermont’s farmers to increase the organic matter in their fields.

And, of course, poor management of high concentrations of manure is damaging to the environment and needs to be addressed state-wide. Manure should not be contained in piles, or lagoon, or pits. It should be spread on the soil as widely and as quickly as possible—preferably, of course, by the livestock creating it. But, by focusing on manure management and missing the larger issue created by synthetic fertilizers, the RAPs are doing nothing more than blowing out the dinner candles while the house is burning down.

2. Focus on Practices, Not on Numbers

The RAPs are built on two fatal assumptions: first, that every farm farms the same way; and second that livestock are inherently damaging to land.

Both assumptions are incorrect. The number of livestock, the size of the farm, and the types of animals are all insignificant. The only factor that matters is management.

Any number of animals contained within any amount of space will—given enough time—overgraze the forage and degrade the soil. However, any number of animals contained within any amount of space will—if limited to the biologically-appropriate amount of time—restore and rejuvenate the soil. Animals must move.

We are using sheep, chickens, and turkeys to rejuvenate the soils on our farm one quarter-acre at a time. We’re building topsoil, restoring biodiversity, improving the health of our forage, improving our crop yields, retaining more water in the ground, and effortlessly incorporating our manure into the ground. Yet, a farm of similar size, with similar numbers and types of animals, using conventional management practices of set stocking and manure storage could be an ecological disaster—degrading soils, water, and plant health. The RAPs make no distinction between these two types of farms.

The RAPs should not define farms by their size, but by their practices and their effect on the soil.

3. Rewarded Agricultural Practices

Farmers have no incentive to abide by the RAPs other than out of fear of legal action. This is a horrible motivator, particularly for stubborn, protective, proud, and suspicious populations of people…like us farmers.

These new RAPs make farmers’ lives harder. They make their businesses less profitable. They threaten a farmer’s ability to feed his or her family. Therefore, we find these new rules terrifying. The RAPs cement a combative relationship between the Agency of Agriculture and the farmers over which it hopes to govern.

If the Agency wishes to create, instead, a receptive population of farmers, it should consider changing Required Agricultural Practices to Rewarded Agricultural Practices. If the Agency was in the business of making the lives of farmers in Vermont easier, more sustainable, less stressful, then it should make clear the benefits farmers would see from alternative—regenerative—farming methods: more resilient fields, higher yields, fewer inputs, and so on.

Also, the Agency should take its RAP enforcement budget (if it has one) and use it to create new opportunities for Vermont farmers to sell their products. These new markets, grants, or programs would be eligible to farmers who adopted the rules set out in the RAPs. Environmental stewardship would be rewarded and make the job of any farmer willing to put in the extra work to maintain and improve Vermont’s ecosystem a little bit easier.

Thank you for accepting public comment. I would like to invite you all down to our 4th-generation family farm in Shaftsbury, Vermont where we are using livestock to regenerate soils that have been degraded by 40 years of plowing, tilling, spraying, and fertilizing. I’d be happy to give you all the farm tour—which ends with frosty beverages and food on the grill.

Respectfully Submitted,
Jesse S. McDougall
Studio Hill, LLC
Pullman Farm


Photo: We know overgrazing. The following photo was taken on our farm in the spring of 2016. This soil was degraded over decades through overgrazing. This particular patch of ground sits above a wet area, a stream, and a pond. Every drop of water that fell here ran directly into the state’s waterways. We stopped overgrazing. We now manage regeneratively. And this ground is now recovering, just a few months later. (See the second photo below.) Why? We’re using organic matter to keep the water uphill—which has tremendous implications for the stated water-improvement goals of the RAPs.