Here are a couple revisions that I would like to see considered with these Regulations.

1. 12VAC5-613-70-9 -- This section appears to require TL-3 effluent with disinfection for both new systems as well as for the repair/replacement of existing systems.  This will place tremendous hardships on existing homeowners in the Commonweath who will have to incur the additional expense of TL-3 treatment with disinfection when faced with repairing their failing septic system.  It may also force more existing homeowners to seek waivers to repair their failing septic systems that were previously permitted by VDH (under previous regulations) with another septic tank effluent drainfield when conditions are such that TL-3 treatment w/ disinfection would otherwise be required.  I feel that legitimate, existing septic tank effluent sewage systems, when repair is necessary, should be exempted from the requirements of the Emergency Regulations in regards to TL-3 w/ disinfection.  Homeowners should be allowed the option of installing a less expensive TL-2 system w/o disinfection which would still be an improvement over their original septic tank effluent system.
2. 12VAC5-613-70-10 -- I feel the requirement for water mounding calculations for small AOSS under 1,000 gpd where a vertical separation to a permeability-limiting feature is <18" is unnecessary and overburdensome on the sewage system permitting process.  It may also create a conflict with the exemption to the licensing requirements of Title 54.1 of the Code of VA which allows AOSEs (Alternative Onsite Soil Evaluators) to design certain manufactured systems under 1,000 gpd.  Water mounding calcs may be argued to fall within the practice of engineering and thus outside of the AOSE licensing exemption.  This requirement could thus severely handicap the AOSE licensed profession and I feel insufficient data has been provided by VDH to show that water mounding of small AOSS has been a significant problem in VA to warrant such a regulatory requirement.