Action | Amendment to Virginia Impounding Structure Regulations to grandfather certain dams from changes made to the Regulations in 2008 for one permit cycle |
Stage | Fast-Track |
Comment Period | Ended on 12/7/2011 |
3 comments
I don't see why we need a regulation to give dam owners more time. The board should be able to solve this problem without a regulation. The board could choose not to enforce the regulation or it could choose to work out a consent agreement or other enforcement agreement with each owner of each dam not in compliance with the regulations. Why is a regulation required when regulatory enforcement of the regulations is discretionary? Why is a regulation necessary when the board and owner could work out a compliance agreement as part of its enforcement powers?
If the regulations represent the minimum safety standards to protect life and safety, then I don't understand why it should matter that prior dam owners have spent a lot of money making their dams more safe (but still not safe enough if they don't meet the current regulations that are the MINIMUM standards).
I don't see why we need a regulation to cover 12-14 cases. How much time and energy is being spent to create a regulation. Just don't enforce the regulation on those people if you don't want to. Otherwise, work with each owner to enter into a compliance agreement that spells out when they must comply. Why are we creating unnecessary regulations to deal with a small issue?