We support the implementation of the regulations and submit the following comments:

24 VAC 35-70-30 (B) 8 - We do not believe the provision of this section should apply to an Alcohol Safety Action Program approved by the commission and acting as a third-party service provider.

24 VAC 35-70-50 (D) 22 - We believe long term calibration stability should be documented by a testing facility.

24 VAC 35-70-60 (C) 1 - There are instances in the document where "enrollment" is used versus "orientation".  Enrollment is not defined and "orientation" appears to be used where "enrollment" may be implied.

24 VAC 35-70-80 (E) - We want to ensure service center locations (addresses) are not required to be included in the training video.  This would force the editing of the training video each time a service location relocated.  

24 VAC 35-70-80 (F) - We believe a wait period should be enforced before testing and the remote alcohol monitoring device should otherwise comply with these rules, particularly as they relate to calibration and data retention.

24 VAC 35-70-90 (A) - We agree with this requirement and would encourage allowing the use of calibration units that have been tested and approved for inclusion in the next publication of the relevant NHTSA CPL since the NHTSA CPL has not been published for quite some time.

24 VAC 35-70-90 (B) (1) c - We believe the purge should not be required if there is less than six inches of unpressurized tubing.

24 VAC 35-70-110 (D) 5 - We believe this should mirror the language in 24 VAC 35-70-110 (E) 4.

24 VAC 35-70-130 (A) 4 - There appears to be two different certification exams referenced in this section.

24 VAC 35-70-130 (B) - There appears to be an incorrect citation related to the administrative fee.

24 VAC 35-70-130 (G) - We support this but would like to ensure no additional fee is charged for the retake.