The City of Richmond Department of Public Utilities (Richmond DPU) fully endorses the comments submitted December 17, 2019 by Steve Herzog, Hanover County Department of Public Utilities Director, and available at https://townhall.virginia.gov/L/viewcomments.cfm?commentid=78531.

Therefore, Richmond DPU joins in recommending that 12VAC5-590-1170 and 12VAC5-590-600 D read as follows:

 12VAC5-590-1170

1. Where hydrant drains are not plugged, they shall be drained to the ground surface or to subsurface stone filled wells or other engineered solutions provided exclusively for this purpose.

2. Hydrant drains shall not be connected to sanitary sewers or storm drains.
3. Fire hydrants shall be connected only to water mains adequately designed for fire flows in accordance with the requirements of 12VAC5-590-1120 B.

12VAC5-590-600 D (in its entirety, without any subsections)

2. Instead of annual operational tests (12VAC5-590-600 C) and the related records and inventory of backflow prevention assemblies, backflow elimination methods, and backflow prevention devices (12VAC5-590-600 G), the owner has the option to provide a public education program to residential consumers.  The owner may also provide a public education program, instead of annual operational tests and the related records and inventory of backflow prevention assemblies, backflow elimination methods, and backflow prevention devices (12VAC5-590-600 G), to commercial consumers whose premise plumbing is not complex and where there are no known or suspected high hazards as identified in Table 630.1.