Chesterfield Fire and EMS is concerned that language changes within 12VAC-590-1170 may lead to engineered weep holes being plugged and subsequently having fire hydrants highly susceptible to freezing during cold weather. We recommend that no language be added that would imply or indicate that weep holes should be plugged. 

Weep holes are an engineered solution to prevent water accumulation within fire hydrants so they would not be susceptible to freezing, removing this engineered design would require that water removal be a manual process. Relying on a manual process over an engineered solution is not the most effective means to drain hydrants. We believe the probability and risk of having a frozen hydrant far outweighs the risk of contamination through a weep holes