Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
Guidance Document Change: This policy outlines the procedure for means testing of owners who petition the Virginia Department of Health (VDH) for onsite sewage and private well evaluation and design services pursuant to § 32.1-248.4 of the Code of Virginia (the Code). This policy also establishes Hardship Guidelines whereby VDH may serve as a provider of last resort for onsite sewage and private well evaluation and design services pursuant to § 32.1-248.4 of the Code.
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6/18/19  12:25 pm
Commenter: bob marshall / cloverleaf env. cnslt., inc.

GMP 2019-01 Hardship Guidelines
 

Almost eight days into this 30-day comment period, and the proposed document provided is sixteen (16) blank pages as empty as the failed promise to change VDH's business model.

Until VDH publicly demonstrates it will manage its conflicts of interest, the imposition of any hardship guideline constitutes nothing less than restraint of trade across 40% or more of the State. Is anyone willing to investigate?

C. If a written comment is received during a public comment period asserting that the guidance document is contrary to state law or regulation, or that the document should not be exempted from the provisions of this chapter, the effective date of the guidance document by the agency shall be delayed for an additional 30-day period. During this additional period, the agency shall respond to any such comments in writing by certified mail to the commenter or by posting the response electronically in a manner consistent with the provisions for publication of comments on regulations provided in this chapter. Any person who remains aggrieved after the effective date of the final guidance document may avail himself of the remedies articulated in Article 5 (§ 2.2-4025 et seq.).

CommentID: 72596