Your regs confuses “rebuys” and “add-ons”

“Rebuys” occur AFTER a player has lost all of their chips, so you can’t have a rule limiting rebuys before a player is eliminated. 

you're literally creating a rule that adds administrative and legal costs associated with compliance with regs published that clearly lack the competency to regulate the game.....

This imposes an additional restriction on VA citizens without compelling justification.  VDACS confuses the industry by publishing guiding rules that do not match how the industry and the game works.

Easy solution -

Strike 11VAC20-30-100.H.  If the justification is to limit the duration of a tournament, § 18.2-340.33.16 already provides that tournaments must have a predetermined end time (which is strange in its own right).

Thanks. Please do your homework.