We were paying $500 annually to NRC for small business license. We were assured before the Virginia Department of Health took over this program that rates would not increase and would probably decrease.

We are now being charged $1,000 annually by the Virginia Department of Health, a 100% increase.

Following are two excerpts from  proposed regulation The Virginia Register 12VAC5-490. Virginia Radiation Protection Regulations: Fee Schedule (adding 12VAC5-490-30, 12VAC5-490-40).

"It is also advantageous to businesses currently using radioactive materials under a federal license to pay a lesser fee when the Commonwealth enters into an agreement with the NRC.

Pertinent matters of interest to the regulated community: VDH does not anticipate any issues from most of the radioactive materials licensees, since the proposed fee schedule for radioactive materials will be significantly reduced in most cases from the fees the licensees are currently paying to the NRC."

We hope that you will correct this injustice, either by instituting a small business rate or some other method. Being a small business, we consider this 100% fee increase (especially under the above cited circumstances) unfair and unreasonable.

Thank you for your consideration.