I am writing as a Trustee of the Boy's Home in Covington, VA. Boy's Home just celebrated it's 100 year anniversary and now it appears that it's operation could be hindered due to undue and unneed regulation. In a review of the proposed regulations it appears that they are designed to cover all types of homes and treatments, therefore hurting some and helping others. While I realize the intent of the regulations is the safety of the children, our residents are not institutionalized and our mission will be imparied by undue regulation.

There are four areas of concern. First, I think that the term "Substantial Compliance" should be used instead of "Total Complaiance". Using the term "Total" could allow areas not related to the mission or safety of the children hurt programs or institutions.

Secondly, combining all four departments, Social Services, Juvenile Justice, Education, and Mental Health, is too comprehensive and therefore make the regulations too restictive for some homes like the Boy's Home. Third, proposed Executive Director's educational levels and the veto power enjoyed by Licensing means that the responsiblity of the Boards will be eliminated.

Finally, additional training requirements will add to costs and in many cases it is not needed. Perhaps, a review of what training is actually needed in each facility, not universal requirements.