Governor McDonnell,

I fully support our great govenor and his  Calvin Coolidge philosophy for how to run government.  Let's look at facts:

1)  Too much regulation hurts economic growth but some is needed to keep the economy healthy.

2)  Let the market correct the problems for consumers when possible rather than regulation.

3)  Remove conflicts of interest when you can.  The VA USBC requires and architect or engineer for a fire rated assembly in a building exceeding a certain amount of floors.  Mold Aid has lost their mind if they really believe the consumer is helped by their business plan. The precedent is their in our own state laws.  I can supply witness to several situations in the Manassas Va area where the one stop shop method was a nightmare if the board would like to hear from consumers.

4)  Make everyone carry insurance specific to microbial inspection for inspector or assessors.  Make mold remediators carry insurance specific to microbial remediation.  The insurance carriers will make sure the market gets corrected at no cost to the state of Virginia because Mold Aids business model will leave them with no insurance.  Insurance carriers will demand ACAC or similar certifications for insurance.   The ACAC will cut people loose for violating the "code of conduct" when a consumer or other certificant makes a valid complaint.  This is another example of how the market corrects the problem with little regulation or cost in Virginia.

5)  Let people whine about the cost of insurance.  I pay a minimum of $5,000.00 per year for professional, pollution and CGL insurance with $1,000,000.00 coverage with a $5,000.00 deductible to make an insurance claim.  I pay just above 2% if I claim to do more than $250,000.00 year which is easy to do as a contractor.  If a consultant /inspector can't afford $100 per week for professional insurance, the citizens of Virginia need to be spared the debacle waiting to happen.

6)  The home is the greatest investment made by the average person.  I think we learned a lesson from the subprime mortagage situation.  Some mold firms take advantage of desperate real estate situations and realtors who fear doing anything that may kill the sale or lead to litigation for disclosing.  The real estate board needs to get into this situation.

7)  Construction companies and insurance restoration firms need to be able to respond to water damage with small amounts of mold when the source and locations are obvious to the naked eye.

8)  The ACAC was formerly called the American Indoor Air Quality Council.  This organization was the first professional organization specific to indoor air quality including microbial problems in 1995.  The American Board of Industrial Hygiene did not have any certification specific to microbial consulting until after 2000 by contrast.

9)  Don't try to regulate how a remediation job is done as far as test methods or remediation.  Different structures have different problems.  Some customer have health problems and some don't.  Some test methods may work in some circumstances but, better test methods may be necessary when there are no visual clues.  Please read my chapter in "Surviving Mold" at www.survivingmold.com

10)  The mold remediation industry is as devoid or physics as the asbestos industry.  Does anyone understand laminar airflow in cleanrooms, adhesion forces for particles,  how dry air affects particles, etc?  Apparently OSHA and the EPA don't but they could have checked with DOE since 1961 which predates AHERA and any OSHA regulaitons....sadly.

Thanks for your efforts,

Greg Weatherman, CMC

aerobioLogical Solutions, Inc.

Arlington VA 22202