Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
 
Board
Virginia Waste Management Board
 
chapter
Financial Assurance Regulations for Solid Waste Disposal, Transfer and Treatment Facilities [9 VAC 20 ‑ 70]
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7/11/22  9:13 am
Commenter: Robin Mead

Amendments to improve standards for financial assurance are necessary
 

The purpose of the regulating agency (DEQ) is to protect the Commonwealth of Virginia and its citizens, not the interests of landfill applicants.  As indicated by the previous commenter, the current standards for financial assurance for solvency have often proven inadequate, most recently in the case involving the landfill in Bristol, VA.  These inadequacies create significant liability for affected communities and in turn the Commonwealth.

Updates to these regulations are needed to improve the protection of public health, safety and welfare.  

"Mega landfills" under consideration for permitting within close proximity to populated communities have incalculable risks associated with the health, safety and welfare of individuals and communities as a whole.  Costs associated with safe landfill operation over time have proven to be ever-changing thereby creating significant unknowns.  These operational uncertainties make thirty year forecasting for closing and post operational activity costs nearly impossible.  For these reasons, regulations which provide leniency or optional choices for the selection of financial assurance mechanisms on behalf of the applicant should be amended, giving DEQ the ability to provide more intense scrutiny over a variety of methods of the highest standards. 

 

 

CommentID: 122231