The Henrico County Utilities Department requests that the proposed regulations be clarified regarding the owner’s provision of an educational program option to satisfy requirements for residential customers of their Cross- Connection Control Program. This program is reviewed periodically by the Virginia Department of Health’s Office of Drinking Water. Residential customers are generally required to adhere to the cross- connection control program due to their landscape and lawn irrigation systems.  We believe that the best use of our resources should be dedicated to protecting the utility system from the commercial/non- residential users with complex plumbing systems and/or with suspected high hazards.  The following modifications to the proposed regulation clarify the intent that an educational program be allowed for residential customers at the owner’s discretion rather than at the Office of Drinking Water’s discretion.

The Henrico County Utilities Department suggests that section 12VAC5-590-600 D. be changed to read:

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 has the option to provide a public education program to residential consumers. The owner may also provide a public education program, instead of annual operational tests and the related records and inventory of backflow prevention assemblies, backflow elimination methods, and backflow prevention devices (12VAC5-590-600 G), to commercial consumers whose premise plumbing is not complex and where there are no known or suspected high hazards as identified in Table 630.1.

In conjunction with the proposed changes requested to section 12VAC5-590-600 D., the Henrico County Utilities Department suggest that section 12VAC5-590-600 G. be changed to read:

G. Except for options allowed in 12VAC5-590-600.D., the owner shall maintain an inventory and records of testing, repairs, and maintenance of all backflow prevention assemblies, backflow elimination methods, and backflow prevention devices required and installed under 12VAC5-590-

610.