10 July 2022

Dear Sir, 

I am responding to the DEQ's invitation for public commentary regarding the possibility of changes to the current guidelines for financial assurance by companies applying for the permitting of private landfills.   My comments are written with the proposed facility in Cumberland County in mind, as submitted by the corporation Green For Life (GFL).

Private enterprise should be required to have sufficient financial resources to protect against public liability should there be infrastructure failures or unforeseen closure of the facility.  In other words, the requirement for backup financial assurance should be structured such that there will be no need for state or federal intervention or funds to pay for closure, emergency repairs, etc. 

It is my understanding that currently the applicant would be allowed to choose its own method of guaranteeing financial resources should a problem arise, and that this financial assurance can be limited to only one entity for the guarantee of such financing. 

It is my opinion that it is the regulator (DEQ) that should be responsible for determining which methods should be used to determine the financial strength of the corporation, as well as for choosing which means should be used to provide the undergirding financial resources, not only at the onset of the project, but on an ongoing basis, subject to periodic review, throughout the life of the project and beyond.  Multiple sources of backup financing for closure or repair should be required, and, in order to prevent gaming of the process, these choices should not be left to the applicant.

I assume these comments will be read by members of the General Assembly. Therefore, I can only hope that all politicians, liberal and conservative, will recognize the need to protect their citizens' well being and quality of life, and that part of this awareness is not to sacrifice the human and natural environment to the sole goal of being open to all businesses while reducing all other concerns to secondary status. 

Thank you for your attention. 

Sincerely, 

Keith Oulie

146 Brown Road

Cumberland, VA  23040