The City of Lynchburg appreciates the opportunity to comment on the Proposed Revisions to the VDH Waterworks Regulations.

In the interest of public safety we oppose the changes to 12VAC5-590-600.D. Specifically we oppose allowing the substitution of education programs for the annual testing and record keeping requirement.  The determination of whether the premise plumbing is not complex is subjective and allowing options opens water utilities further scrutiny and conflict over our CCCP.  A review of a high hazard from Table 630.1, reinforces the need for annual operational tests, and the related records and inventory of backflow prevention assemblies, backflow elimination methods, and backflow prevention devices.

As a result of irrigation, irrigation-related, and fire sprinkler systems being added more frequently by residential consumers, as well as frequent changes to commercial consumer sites, etc., and restrictions on the owner with regard to determining if premise plumbing is or is not complex, we propose that 12VAC5-590-D be eliminated.