To the Department of Behavioral Health and Developmental Services:

I'm writing to raise concerns about the proposed amendments to 12VAC35-260 from a landlord's perspective.

It is necessary to hold recovery residences to real safety and accountability standards. Specific to Oxford House, which has been an exemplary organization, several requirements in this proposal don't fit how an Oxford House actually operates, and I think the state needs to address that before this moves forward.

1. The proposal repeatedly requires a "staff member" to handle complaints, serve as a community liaison, and walk residents through the handbook. OH is run entirely by a democratic process through the residents. The proposal itself acknowledges this, describing Oxford House residences as "self-governed and unstaffed," which makes the staffing requirements impossible to implement.
2. I'd like the state to clarify who qualifies as the "operator", That term carries significant responsibility throughout the proposal. As owner, I am not involved in the day-to-day operation of the house — the residents run it themselves. I need to understand clearly what, if anything, is expected of me as the landlord versus what falls to the residents, so that neither side is caught off guard by an obligation nobody knew was theirs
3. Business insurance and registration with the State Corporation Commission. The house on my property is not a business. It's a group of residents sharing a lease and splitting household costs, the same as any family. Requiring business registration and commercial insurance for an arrangement like this doesn't match what the house actually is.
   I have rented to this house because I've seen it run responsibly and I want it to be able to continue. I'd ask the department to adjust these three provisions so the regulation reflects how self-governed, unstaffed houses actually operate, rather than requirements built for a staffed business.
   Sincerely,
   Peter