I am requesting the adoption of this regulation be postponed to allow for an adequate public comment period. 

1) Citizens monitoring groups simply do not have the financial resources that may be required by this proposed regulation.  This will negatively impact citizen monitoring at a time when DEQ is seeking to increase emphasis on citizen stream monitoring. Citizen monitoring groups provide accurate, useful data to DEQ. We operate on limited budgets and in many cases do not have the financial resources to support the additional expenses they would incur under the proposed regulation. 

2) I understand that this proposed regulation was developed in 2005 and that there is direct conflict with current DEQ policy regarding the data utilized for their biennial assessment report. The public engagement process for adopting the regulation is questionable.  There has not been sufficient public involvement or input to the regulation.  Many affected stakeholders were not adequately notified of this upcoming action in a timely manner.  There are too many unanswered questions about how this regulation will affect citizen monitoring programs in Virginia.

3) There have been significant changes regarding citizen volunteer water monitoring programs since this regulation was originally proposed.  The DEQ has developed a QA/QC program that defines how citizen monitoring data will be utilized by the agency.  The proposed regulation does not reflect this update.  This regulation creates a conflict between two state agencies.

David Ward
Loudoun Watershed Watch