The following proposed regulation statement has  potential to create additional hazards by allowing for interpretation as to who has a complex plumbing system, and who knows (or doesn't) about "known or suspected" high hazards.

It's understandable that Backflow Prevention Assemblies (BPA) annual testing can be viewed as frustrating or inconvenient, much similar to the Virginia registered automobile safety inspection program, in which both programs require that equipment shall be verified in good mechanical working condition, annually.  The only way to verify that a BPA is operating as designed is to perform an annual test.  Through my experience in the industry, education will not take the place of insuring a BPA functions correctly, or identify where a BPA should be installed. Please consider the proposed regulation to provide concise direction and hazard identification through table 630.1, while requiring annual inspection/test of a BPA.

Proposed:   

D. Instead of annual operational tests (12VAC5-590-600 C) and the related records and inventory of backflow prevention assemblies, backflow elimination methods, and backflow prevention devices (12VAC5-590-600 G), the owner may provide a public education program to residential and commercial consumers whose premise plumbing is not complex and where there are no known or suspected high hazards as identified in Table 630.1. For all other residential consumers, the department may approve a public education program provided by the owner as part of the CCCP.