The proposed definition for "place of public accomodation" is probably too broad for states to achieve enforcement. While bed and breakfast homes and inns are included under the authority of North Carolina rules, single-family residential structures are excluded, even if they are operated as weekly rental cottages and cabins. These places are beyond the reach of the state regulatory authority. Most rental houses on the outer banks have pools and spas that would be rendered non-compliant and the home-style spas in those structures cannot be easily brought into compliance. I think a definition this broad makes the law unenforceable at the state level.
Comment from James Hayes
This is comment on Proposed Rule
Virginia Graeme Baker Pool and Spa Safety Act; Public Accommodation
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