The "Hardship Proposal" is contrary to every study VDH has commissioned; RD32, E.L. Hamm SHIFT, in ignoring the facts, VDH budgets 5 hours for an EHS (Environmental Health Specialist) to evaluate a lot being permitted for new construction, and subsequently due to errors or ommissions in that EHS's conduct of assessment then results in an request for a repair permit which captures at least 36 hours of an EHS time to mitigate sewage on the surface or infiltrating the groundwater. As stated by others benefiting from transfer of liability through gift of Sovereign Immunity. If an EHS is paid $50k/year, perhaps the public and the tax payer would benefit from laying these people off to pursue a private tax paying business in service to the private landowner, at private expense. The facts also indicate there are at least two (2) OSE w/in 50 miles of practically every landowner in the state. The faux formula proposed by the agency negates the unused capacity of these people who have invested in offering competent services. There is no reason for VDH to employ OSE if the mission is to review and approve certified work, with all liability carried by the firm. Indeed there has been too little discussion about the Indemnification Fund rather than the privatization of risk and liability.

VDH has already allocated the people's resources to study the "privatization" of the onsite business, every study has endorsed the movement of site evaluation to the private sector. The Agency would be well advised to shift it's focus to enforcement of the Regulation, rather than market management. Private business have shown the initiative to use technology and invest in the tools to provide the most efficient solutions in compliance with regulation. It is time for VDH to completely remove it's staff from any competitive interest in septic design, and focus completely on public health.