It is my opinion that the regulation of large or high risk impoundments focuses too much on dealing with PMF induced impacts at the expense of addressing preventative measures for the so called "sunny day breach".   As one whose family and friends live in an inundation zone I am more concerned about the sudden breach than what would happen as a result of a PMF event.  The meteorological event triggering a PMF will provide warning that, coupled with a emergency notification system, will likely give me time to move to higher ground before all avenues of travel are flooded.  One should remember that most modes of transportation have storm systems designed for 10 to 100 yr events at best. 

It is my opinion that dams whose sudden failure would cause loss of life should be closely monitored for changes in piezometric surface within the dam or indication of sediment bearing leakage that would indicate piping/erosion within the dam.  The ability of a impoundment to withstand runoff from a PMF provides no assurance against a sunny day collapse.  I believe that owners of high or significant risk class impoundments not only have the ability and financial resources provide monitoring, but an obligation to their neighbors in the inundation zone to provide a means to detect possible sudden failure and prevent that failure by having the ability to lower the impoundment level until repairs are made to the structure.

It is respectively suggested that monitoring of high & significant risk impoundments be expanded to include active monitoring within the structure, an emergency response plan if a problem is detected, and require a means to lower the level of the impoundment until the structure is further evaluated and repaired.