1. Requirements to remove all woody vegetation from the dam and from within 25' of the dam - this requirement could be relaxed for existing dams. I agree with this requirement for the dam crest and slopes. But extending 25 feet from the toe could be relaxed for existing dams to lets say 10 ft.

2. Defining the dam height - the existing definion of hydraulic height of a dam sometimes not quite applicable. For example, a 10 ft tall dam constructed on top of a 10H:1V fill slope. The height of the foundation fill slope from the dam toe to the nearest stream is about 100 ft. According to the existing definition, the hydraulic height of the dam is 110 ft, but in reality it is only 10 ft tall.

Thanks

Shaikh Rahman
Dominion Energy