|Action||Compliance with Virginia’s Settlement Agreement with US DOJ|
|Comment Period||Ends 7/22/2020|
CAP - prevent?
The increase in the standard diminishes what the regulation previously stated as the function of the CAP. This means an agency can, actually, be meeting the related standard (“minimize”) while also being cited for not meeting the CAP regulation (“prevent”). This causes a severe impact in understanding the correct development and implementation of any CAP. These regulations, at the very least, contradict themselves.
It is unreasonable to expect anyone to be able to develop a CAP that will “prevent” the reoccurrence.