Virginia Regulatory Town Hall
Agency
Department of General Services
 
Board
Department of General Services
 
chapter
Regulations Governing the Certification of Non-Commercial Environmental Laboratories [1 VAC 30 ‑ 45]
Action Establish Regulation
Stage Final
Comment Period Ended on 9/17/2008
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9/16/08  3:13 pm
Commenter: George L. Ohrstrom, II President, Friends of the Shenandoah River

Proposal to Charge Fees for Laboratory Certification for Citizen Water Quality Monitoring Groups
 

To Whom It May Concern:

I am President of the Friends of the Shenandoah River, a citizens volunteer water quality monitoring group.  We work in conjunction with several other groups (the Friends of the North Fork of the Shenandoah River, The Opequon Watershed, Friends of Page County....)  Our organization monitors 120 sites along the North Fork, the South Fork, and the Main Stem of the Shenandoah River.  The organization is deeply concerned with the proposed fees and I personally feel betrayed.

Our lab has been certified by DEQ and they use our published results as do many other important agencies, including the EPA.  We survive through our own fund raising efforts every year and the idea that we would have to pay fees to a private company for our on-going lab certification is absurd.  DEQ, a government agency, supports us and other water monitoring groups when it is able.  Last year after a 5% State budget reduction they pulled their grant (and all other grants to citizen water quality monitoring groups) off the table.  I am sure with the budget being what it is they will do the same this year. 

We rely on very dedicated volunteer monitors and with the price of everything, especially gasoline skyrocketing, it is difficult enough for everyone to be able to afford to volunteer.  Without our highly trained volunteers we could not exist. 

It seems counter intuitive to me to raise fees to volunteer organizations because all it is going to do is add yet another layer of difficulty for these organizations to follow their mission.  As I said above, many other organizations use our data but if these fees are imposed we might not be able to continue to supply that data. 

This proposal should be eliminated.  If it is, in fact, initiated, the signal sent to all water quality monitoring groups is that of discouragement.  All of these groups and myriad state and federal agencies have as their charter the achievement of goals of the Clean Water Act and the Chesapeake Bay Nutrient Reduction Act of 2010 and this proposal will do nothing to help anyone achieve those goals.

Respectfully submitted,  George L. Ohrstrom, II President - Friends of the Shenandoah River

 

 

CommentID: 2207