Please include a metric in the final version of 2 VAC 5-115.  The original draft regulations proposed by VDACS had a 50% benchmark in them.  During last year's public comment period the number of organizations/citizens who asked that a metric be included was nearly three times greater than those who did not want a metric.  The currently proposed regulations have no metric, are general in nature and will not be effective in realizing the intent of SB 1381 which passed by a supermajority in the 2015 General Assembly session and enjoyed tremendous public support.  The final regulations should require that a private animal shelter adopt out (or transfer out for the purpose of adoption) at least 50% of the animals brought in, and may not euthanize more than 50% of the animals in their care.  The metric would be very simple to implement because each shelter and rescue (including private shelters) must report intake and disposition information to VDACS for every animal they take into custody each year.  One of the specific dispositions is the number of adoptions, so the information is already provided to VDACS.  Please include a metric in the final regulations to ensure that all private shelters in Virginia are the safe haven for homeless pets the General Assembly intended and the public trusts them to be.