In response to the Notice of Intended Regulatory Action (NOIRA) for the Rules and Regulations for Licensing Providers by the Department of Behavioral Health and Developmental Services, 12 VAC 35- 105-10, et seq, please reconsider the proposed action of separating regulations into a general chapter and service specific chapters.  With pending regulation and service changes related to the Behavioral Health Redesign, the proposed action action would not be in alignment with the ending of certain services and establishing of other services in the Redesign model. We should be moving forward with one process that can both overhaul regulations while speaking to the services of Behavioral Health Redesign.