Let me begin with my appreciation to the members of WAC for their hard work and diligence in the preparation of the regulatory changes to the water works. This is a daunting task and a lot of effort has been put into these thoughts and proposed changes. I strongly support the Cross Connection Control and Backflow Prevention industry and I am deeply concerned for the safety of our drinking water.

My comments are as follows:

12VAC5-590-580, with regard to para "A" - striking the approval requirements for permitting should I assume that the CCCP will no longer have to be approved by the department (VDH) and if approval is needed what would the process be?

12VAC5-590-590, with regard to para "D" - this paragraph should be withdrawn from the proposed regulatory change. Replacing minimum testing requirements with educational programs is irresponsible at best. Although a public education program should be integral part of any CCCP it does nothing to ensure that all of the mechanical devices that are put in place to protect the safe drinking water from backflow are performing as designed. Backflow preventers have a specific purpose from protecting low to high hazards as well as protecting from backsiphonage and/or backpressure. Testing by a certified technician with an approved and certified test kit is the only way to determine if a backflow prevention assembly is working properly and this must be done after installation, after repairs or maintenance or at a minimum annually. These standards are repeated throughout the industry by the manufacturers, industry associations and labs. (USC, ASSE, etc.) The requirement for testing must not be reduce in any way and in most cases needs reinforcing through tighter legislation and more aggressive enforcement.

The residential communities are feared by the very departments and people that are entrusted to protect them and with regards to the residential lawn systems the sheer numbers of backflows not being tested annually is grossly negligent.  Corpus Christi is a prime example of what not to do with regards to testing annually.

12VAC5-590-610 - Containment of backflow. This section can only work if the "Owner" and USBC officials come together in a common effort to enforce backflow prevention. This is an ongoing effort with some jurisdictions having a good working relationship with code officials and having a common interest in protecting the drinking water but in a lot of cases this does not happen and I see nothing here that will change that. Perhaps language that would promote the code officials communication with the owner and the owner taking responsibility for enforcement and record keeping.

One point of interest to add would be for the jurisdictions to not apply devices on connections with simple plumbing and that meet USBC. This is a wasteful practice and gives the jurisdiction a false sense of security and can in some cases create a hardship on the resident. (Hot water heater T&P valves)

with regards to para "E" - Why are we removing "Lawn Sprinkler systems"? Wording can get lost in a paragraph but on a list it is easier to locate. Removing or striking from the regulation can lead people to think that it is no longer necessary. Lawn sprinkler systems are high hazards even without chemical additives and again as mentioned earlier their numbers are insurmountable.

12VAC5-590-630, with regards to para "A" - shall comply with the USBC.  The USBC should not have authority over containment assemblies. That authority should be with the owner.

I will conclude that in my years of working throughout the Commonwealth I have had many conversations with CCC Managers that desired more guidance from state in order for them to better organize and enforce their programs and perhaps standardize the CCCP in Virginia. What I have read and understand with regard to the proposed changes that there are some good and some not so good changes. I would respectfully request that the WAC add Cross Connection Professionals to the board and that the state appoint a Cross Connection Director Office dealing specifically with backflow prevention. Thank you.