COMMENTS FROM THE VIRGINIA CHAPTER OF THE AMERICAN BACKFLOW PREVENTION ASSOCIATION

The majority of the Proposed Regulations are a welcome update.  As backflow professionals from across the industry, the VA ABPA appreciates the Department for clarifying and aligning these regulations with the USBC, in cooperation with the DHCD.  Waterworks owners & building officials share the responsibility of enforcing cross-connection control, while consumers and other stakeholders must install, maintain & test backflow preventers.  Eliminating redundancy & improving efficiency are important goals, but the Department must not lose sight of the ultimate goal: to ensure that waterworks furnish potable water to consumers, which requires protecting it from backflow & contamination.  Waterworks and government agencies across the country are being scrutinized and legally challenged on the failure to protect this vital resource.  The Department should not lower the standards of protection, especially for high hazard cross-connections of any kind.  If waterworks are too complex or lack personnel or funding to implement an effective CCCP, the Department and each waterworks should develop ways to ensure regulatory compliance, rather than lowering the standards of protection.  To do otherwise risks the safety of potable water and the public health, and could irreparably breach the public’s trust.  A mistrustful public could resort to installing auxiliary systems and create cross-connections with these systems, and negatively impact the public health.  In the spirit of cooperation, and to ensure that potable water remains potable, we submit the following general and technical concerns that should be addressed and resolved before legislation.  (Recommendations follow, with one partially duplicated section).