The comments from the Upper Occoquan Service Authority were well thought out, and well written. I would like to take things a little further.

The interests of the Commonwealth of Virginia would best be served by the elimination of 1VAC 30-45. The elimination of 1VAC 30-45 would relieve the state of all monetary shortfalls incurred by the certification of non-commercial laboratories.

The program requiring certification of non-commercial laboratories has already done irreparable damage to small laboratories and the program should be abandoned before it does more damage by increasing fees.

The only advantages developed by this program have been an increase in jobs and promaotions at DCLS, increased business for PT providers and commercial laboratories, and promotion of The NELAC Institute. Among the disadvantages are increased paperwork, redundant testing, and higher cost to the taxpayer.

For small laboratories that farmed out their testing to commercial laboratories rather than go thru the ordeal of the certification process; timely results of in house laboratory testing that could be used to improve operational efficiency are now gone. Most results from samples sent to commercial labs are only of historical value whereas real time resultscan actually be used to impact the environment and operational efficiency in a positive manner.

If commercial laboratories want to be certified so they can do business in other states; 1VAC 30-46 can be maintained, and the cost of that program can be borne by the entities that profit by that certification. If commercial laboratories cannot, or will not provide all of the support for the program, perhaps 1VAC 30-46 should be abandonded as well.

I attended the class about preparation for lab certification on 06/29/2009, in Appomattox, VA. I, along with many others in the room, was insulted when a paid environmental consultant stated that one of the big reasons for the program was to stop falsification of data. As pointed out in comments by the Upper Occoquan Service Authority, on-site laboratories "have a vested interest in the quality of their data".For operational reasons as well as the fact that our effluent is released into our own environment, affecting ourselves and our community; valid data is important to us. We are committed to protecting the environment and our taxpayers. These factors should be considered when regulations are written and promulgated. If it is still the contention of the laboratory certification program that data falsification is a problem, data could be run through a computer program designed to identify corrupt and falsified data.The Commonwealth of Virginia probably owns such a program as they are routinely used to verify data quality in university and other research projects.

Since DEQ is now requiring most wastewater plants to use the eDMR system for reporting purposes data is already digitized and could be run through a data verification program. Data verification coupled with annual PT samples should provide enough evidence that laboratories are being run in an appropriate manner. The stated goals of the laboratory certification program are reached in this way without additional cost to the taxpayer.

Although this approach does not undo the damage already inflicted on small laboratories that gave up their environmental testing; it could help to slow the spiraling costs of inflated bureaucracies.