I am writing first to confirm my support for the 17 recommendations made by Mary Carwile of the Commonwealth Coalition which has representation from nearly 30 counties. This group has worked to bring a united voice to citizens' concerns about the influence of the sludge industry within the political, and more importantly, the regulatory process. Citizen concerns regarding the land application of sewage sludge have been and continue to be dismissed by the VDH, and their office, along with the Division of Waste Water Engineering , shows indifference and a lack of professional credibility and objectivity. What is obvious is the cozy relationship these offices have with the sludge industry while nuisance complaints, public health concerns and regulation violations are discounted and dismissed. Most importantly has been the fact that the VDH ignores the independent, peer-reviewed studies of Dr. David Lewis whose work on sludges has never been refuted. Additionally, the "International Journal of Occupational Health" published an article by Dr. Caroline Snyder on the "Dirty work of promoting "recycling" of America's Sewage Sludge" which addressed the public health concerns and industry misinformation--it should be required reading for anyone in any office dealing with land application. Why are there no medical buffers for immune-compromised neighbors of sludge sites and why are setbacks so low? Why do VA taxpayers foot the bill (nearly 3/4 of a million dollars) for the private sludge industry for administration and permitting by the departments? Why is the permitting process rushed and secretive with poor notification? And with 300,000 acres already permitted (and only about 60,000 used last year) is there some hidden agenda to  push for Virginia to move from #2 in the nation for importing sewage sludge to #1? Nearly 60% of land-applied sludge is from out-of-state and citizens feel they are being dumped-on--literally. The JLARC report of 2006 highlighted the "poor oversight" where there were 19 inspections out of over 1100 sites applied.--more failed bueaucracy in a terribly flawed system. As DEQ prepares to adopt this hideous stepchild of a sludge program, please be aware that thousands of Vrginians are watching to see if meaningful and significant changes occur. Public health and environmental protections cannot continue to be overlooked. The 17 recommendations of the Coalition deserve serious consideration. I  remember in 1999 when both DEQ and VDH were blasted for sitting on information on PCB contamination in the Staunton River in my county  for nearly 20 years before releasing the "don't eat the fish" warnings to the public. We are watching and waiting and guarded--DEQ has one chance to learn from the many mistakes at VDH and do it right the first time--I pray there is the political will to fully protect the citizens of the Commonwealth of Virginia.

Lorraine Potter