I am requesting that the adoption of this regulation be postponed until a study can be completed that identifies the possible adverse impact, and how to mitigate it, of this regulation on the extent and quality of citizen monitoring programs, such as those of the Friends of the Shenandoah River. I believe there is a strong possibility that the impact of the regulation could be very adverse, and that the FOSR and similar organizations might have to significantly reduce or stop their valuable efforts.

The FOSR has been monitoring the quality of the water in the streams within the Shenandoah River Watershed since 1989. The data are analyzed and the findings regarding “hot spots”, and adverse trends, etc. are regularly documented in newsletters, their web page, and in reports such as “The Status of Water Quality in the Rivers and Tributaries of the Shenandoah River Watershed.” (this report is posted on www.fosr.org).

The monitoring by voluntary organizations does not replace the efforts by the DEQ and other government organizations. Rather, it augments their efforts because collecting water samples is labor intensive, and whereas the 75 FOSR volunteer monitors and their cooperating partners, such as the Friends of the North Fork of the Shenandoah River monitor twice a month in over 120 sites, the intensity of monitoring by the government agencies is far less. As such, the efforts of the volunteer monitoring supports and increases the statistical reliability of the data, at no additional cost to the government.

To be effective, however, the valuable efforts by the volunteer volunteers need to be supported by a laboratory that can analyze the products of the volunteer’s labor. Unfortunately, laboratory chemicals and the staff to operate sophisticated laboratory equipment are very expensive. And providing the funding for the laboratory is a real struggle. Imposing extra expenses on the laboratory operations, such as being considered by the proposed regulations may very well severely curtail or perhaps cause closure of the FOSR effort.