VBDPU opposes the changes to allow the substitution of education programs in lieu of annual testing and record keeping.  The determination of whether the premise plumbing is or is not complex is subjective, subject to change, brings scrutiny on the safety of the public water system  and conflicts with current CCCP in Virginia Beach. Ponding water in lawns is not potable water and this water can cover sprinkler heads. 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. Educational outreach has limited success and are not equivalent of the prevention provided by an annually tested device. VBDPU has encounter numerous homeowners who are not aware of our public water supply, its connection to their premise plumbing which they own should maintain.

VBDPU proposes that 12VAC5-590-D be eliminated.