VDH in failing to comply with it's own regulations has become the favorite for local government representatives concerned over cost of development; not so much cost of compliance, or the effect of non-compliance which too often incurs the added cost of public water and sewer at public expense.

As others have noted, Shellfish Water Closures seem to coincide with new developments which were designed and approved by VDH staff. Public documents supporting improvements to real property merit competent professionals, which expect to be paid for these services, including verification of boundaries, scale drawings, full assessment of soils and documentation of the property both existing and proposed.

We heard at SHIFT the opposition to private sector services due to cost, and availability, and preference for government employees; which coincidentally are tax-payer funded, and have discretion to waive regulations. In total we find that VDH designed systems are more likely to fail, and contaminate ground and surface waters. Publicly supported systems also more likely to be undersized or utilize questionable area reductions, rather than fully comply with Code, or invoke advanced treatment systems to protect the environment especially sensitive locations such as high water table, or small lots utilizing private wells.

Something to consider when comparing costs, and selecting service providers; is does that professional owe his allegiance to the Governor; or the client, his obligations and the licensing boards? The discerning public will come to realize the "bad apples" claim sovereign immunity, and fail to disclose the risks transferred to the public; persisting in utilizing the VDH model of site assessment and design adds risk to all concerned.