Virginia Regulatory Town Hall
Virginia Department of Health
GDForum ID: 2275
Step 1
Description of Proposed Guidance Document Changes
The proposed Enforcement Manual (ODW-2023-03) is an amended document arising from an update to the current version of the manual (Enforcement Manual 1.0, WTR-2020-02), which was adopted in October 2020. The proposed Enforcement Manual reflects current best practices related to VDH ODW’s enforcement program, refining and expanding upon the Enforcement Manual 1.0. The changes include updates to the glossary to better and more accurately describe terms as needed; updates to the description of VDH ODW’s general approach to enforcement to more specifically describe VDH ODW’s approach to enforcement, the formal enforcement options, the structure of ODW and how it relates to enforcement; the process for monitoring noncompliance including expanded discussion of the use of the Enforcement Target Tool and the Enforcement Targeting Tool Assistant for monitoring federal violations, an expanded discussion of tracking state violations for purposes of triggering the need for enforcement; more in-depth discussion of the process of, and methodology behind, determining whether and when to transfer a matter from a compliance status to an enforcement status; a much deeper discussion of receivership as an option; a more in-depth discussion of the various enforcement options than is found in the current manual including a deeper and more specific discussion of when to transition from informal enforcement measures to formal enforcement; more specific discussion of the particular roles to be played by certain staff in the VDH ODW central office and the field offices; guidance on collecting civil charges; expanded discussion of the process for monitoring compliance with administrative orders and for closing enforcement cases; the addition of an entire chapter focused on civil charges and civil penalties, rather than just several paragraphs as contained in the current manual; and a short chapter on enforcement training and directing the development of performance metrics. The proposed Enforcement Manual also corrects and updates as needed citations to the Code of Virginia and the Waterworks Regulations and makes other improvements in form and style in comparison to the current manual.
Step 2
Guidance Document(s) for this Comment Forum
Document ID Document Title Current Document Proposed Document
WTR-2020-02 (W) Enforcement Manual pdf Document     To Be Deleted
ODW-2023-03 Enforcement Manual n/a pdf Proposed Document
Step 3
Contact Information
Grant Kronenberg
ODW, Dir. of Div. of Compliance, Enf. & Policy
109 Governor Street
6th Floor
Step 4
ORM Review
ORM Review in progress. Agency will be notified when ORM review is complete and the guidance document forum is ready to be submitted to Register.
pdf ORM Economic Review Form     posted: 9/8/2023   modified: 10/10/2023       submitted to ORM: 9/8/2023
Step 5
The Virginia Register
Not yet submitted to the Virginia Registrar for Publication.
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