I encourage VDEQ to retain this regulation as written for the protection of human health and the environment in the Commonwealth of Virginia. As organizations attempt to dispose of contaminated property, the UECA ensures that the location of the contamination and the recommended remediation of the contamination are properly identified and addressed.

I question, however, the fee structure. Based on fees alone, it is cheaper if the VDEQ is neither the holder nor the agency. VDEQ clearly has little desire to be the holder of the environmental covenant. It is unclear to this commenter when VDEQ would not be the agency.  Perhaps examples would be appropriate. Is there any instances of a state quasi-governmental entity holding the lien? Are there memoranda-of-understanding with other state governmental entities

Thank you for the opportunity to comment..