The Virginia Campground Association is pleased to have the opportunity to provide our comments on the periodic review of 12VAC5-450; Rules and Regulations Governing Campgrounds under Executive Order 14 (2010) and §§ 2.2-4007.1 and 2.2-4017 of the Code of Virginia.

The VCA proposes the following amendments to 12VAC5-450:

12VAC5-450-10- Definitions

The VCA proposes amending the definition of “outdoor bathing facilities” to include “swimming pools.” The new definition would read:

Outdoor bathing facilities - means swimming pools, lakes, ponds, rivers, tidal waters, impoundments, beaches, streams or other places, whether natural or man-made, in which an area is held out for swimming or bathing purposes.

The VCA proposes amending the definition of “self-contained camping unit” to include
“generator.” The new definition would read:

Self-contained camping unit - means a unit, which contains a water-flushed toilet, lavatory, shower and kitchen sink, all of which are connected, and/or a generator, as an integral part of the structure, to water storage and sewage holding tanks located within the unit.

12VAC5-450-100- Service Buildings

The VCA proposes adding the following exemption to 12VAC5-450-100:

Campgrounds that exclusively serve self-contained recreational vehicles and provide potable water and sewer hook-up at every site shall be exempt from the sanitary facilities requirements in 12VAC5-450-100, except when other provisions apply.

Thank you for your attention to this important matter.

Section 150, Safety, should include wording which addresses general safety matters such as trip / slip hazards, as well as accessory structures such as benches and fencing in common areas and especially playground equipment.

Since many campgrounds now offer rental units such as cabins, stationary RVs, and even units which more resemble rental housing, there should be some guidelines for minimum standards for such facilities.

The effective date of the regulations should be included with, or as a part of the regulations, especially when giving consideration to a facility that may not be in compliance with parts of the regulations, but may have been in existence prior to the effective date of the 'chapter'; see section -230. 

Regarding section -80, D.: many campgrounds have several to numerous individual water supplies, which are those serving the individual campsites.  While prudence suggests that ALL such water supply sources be protected against backflow / back siphonage, it  would be helpful if this were indicated in the regulations.  Or, if it is acceptable to have one backflow device on the main supply, say from the well, that this also be clarified, with thought given to whether this would likely to be readily evident during an annual inspection.

Many campgrounds have pools, restaurants, and other facilities which receive permits from VDH for their operation.  As is done with the hotel regulations, consideration should be given to including 'Relationship to Food, Swimming Pool, etc. Regulations, so that it is clear that there are regulations governing these other facilities.