With respect to Virginia’s exemptions to the requirements, I urge the board to allow local, state and federal governments to lead the way by not exempting regulants employed by these agencies. Any regulation that furthers a perception that governments are above the law is flawed. Exemptions or time extensions are appropriate for regulants who are service members deployed overseas and perhaps for those stationed outside the Commonwealth. These exemptions or extensions may even be obligatory under the “Soldiers and Sailors Relief Act”. Exemptions for others, including government employees, who elect to spend extended periods outside Virginia or the United States, are not appropriate.
