Dear Mr. Adcock,

I am requesting that the Department of General Services open a public comment period so that the regulation regarding certification of non-commercial environmental labs can be openly discussed and potential negative impacts to volunteer citizen monitoring efforts can be assessed.  

Governor Kaine and the Department of Environmental Quality have made the support of volunteer citizen water quality monitoring efforts in Virginia a high priority during the last several years.  Adoption of the proposed regulations regarding laboratory certification requirements would prove a great challenge to the continuation of water monitoring efforts in the Commonwealth and be a complete contradiction of the Governor's mandates.  Costs associated with volunteer water monitoring efforts are already high and difficult to fund.  The addition of potentially higher costs for laboratory certification would have a huge negative impact.

Friends of the North Fork of the Shenandoah River (FNFSR) has 30 volunteer water monitors that participate in a Shenandoah Basin wide water monitoring effort overseen by the Friends of the Shenandoah River.  We also are planning to expand our monitoring efforts to include bacteria assessment and benthic macroinvertebrate monitoring.  The laboratory run by Friends of the Shenandoah is the glue that holds the surface water monitoring program together and is an essential link to the expansion of FNFSR's monitoring efforts.  Cancellation of Department of Environmental Quality grant funding in 2007 has already impacted our current monitoring efforts and plans for expansion; the addition of further financial requirements will only create a further burden.  

Friends of the North Fork works with Friends of the Shenandoah not to replace DEQ monitoring efforts but to expand DEQ's reach to monitor more of Virginia's precious water resources. This combined basin wide monitoring effort is certified and accepted by DEQ and thus increases the amount of valuable data available for assessing Virginia's waterways at no expense to the Commonwealth.  We understand the importance of this data as well as the importance of quality assurance and control and good laboratory practices.  However, when formulating the regulations, it is essential to consider the financial impact that using a broad stroke approach to regulation will have on volunteer based organizations throughout Virginia.

Without adequate time and open discussion of the proposed lab certification regulations, these concerns will go unheard and unaddressed and thus may be the demise of volunteer water monitoring efforts throughout Virginia.  Please consider opeing a public comment period to discuss this regulation.

Thank you for your consideration,

Leslie Mitchell-Watson

Executive Director, Friends of the North Fork of the Shenandoah River

540-459-8550

P O Box 746

Woodstock VA 2664

Leslie.watson@fnfsr.org