1.      Performance based regulations should be separate from Operation and Maintenance Regulations.

2.      The need for secondary effluent should be based on soil conditions and not gallons per day. I.E. the requirement for large AOSS to discharge TL-2 or better effluent.

3.      Spray systems should not be limited to 1000 gallons per day or less.

4.      Reporting by O & M providers should be free of charge. Particularly in light of the fact that it is supposed to be electronic.

5.      12vac6-613-70 #9 seems to conflict with table 2 with respect to when disinfection is required.

6.      The local interpretation of these regulations has included requiring TL-3 effluent and disinfection on repairs of failing systems. The cost, both initial and ongoing is extremely prohibitive. It is ironic that surface discharges are allowed with equivalent to TL-2 and disinfection.

7.      These regulations should not supersede the SHDR and existing GMPs