This regulation is confusing in many ways, one of which is the commercial/non-commercial lab designation of Virginia state college and university laboratories that collect and analyze water samples, and report the results of these analyses to Virginia DEQ.  In various sections of the regulation, it seems that a university/college lab could be considered either commercial or non-commercial, depending on who funds the work, and even those definitions aren't clear, leaving the distinction dangerously (for the labs involved) open to interpretation by someone else.  This distinction is more than academic, because whether a lab is classified as commercial or non-commercial involves substantially different certification procedures and fees.