April 10, 2017

Paul Kugelman, Senior Assistant Attorney General/Regulatory Coordinator

202 N. 9th Street

Richmond, VA 23219

RE: Human Rights Regulations transfer action

Dear Mr. Kugelman,

The disAbility Law Center of Virginia (dLCV) appreciates the opportunity to comment on the statutorily required transfer of Human Rights Regulations from VHRC to OAG's Division of Human Rights. We identified an error in identification of our agency in the language of this action which requires immediate remedy before this action goes into effect.

1VAC45-20-60, as amended, states the ‘council division has established interagency agreements with the following state agencies’ and names our predecessor, the Virginia Office for Protection and Advocacy (VOPA) in Section B.4. VOPA transitioned out of state government and became the disAbility Law Center of Virginia (dLCV), a 501-C non-profit in October 2013. dLCV is the federally designated protection and advocacy system for Virginians with disabilities. VOPA is a defunct state agency and should be removed from B.4. dLCV is not a state agency, has no such interagency agreement, and must not be included in this action.

Thank you for your time and diligence to correct this error.

Sincerely,

Colleen Miller

Executive Director