This is poorly coneived and implented set of regulations that serves only to validate a single private sector claim of product superiority.  There is no scientific basis for the claims made that a sownsized system is more likely to function over a period of time. 

VDH has no expertise in the evaluation or approval of materials or components.  They have no capcity for testing and efficacy of this regulation is based on unsupported documentation provided by a manufacturer.  There are other agencies and organizations that have as their reason for being, testing of components and processes.  

NSF hasn't developed a standard for these types of units.  Any approvals are based solely upon expectations and the manufacturer's unsubstatiated clains. 

VDH has a miserable track record of following up and confirming that products approved by Guidance, Memorandum and Policy are as effective as claimed and as approved.   

Person should ask for VDH to provide proof that they have the capacity, capabiliy and to determine if a product can deliver the performance defined by th manufacturer. 

While not disagreeing that the units addressed in these Reguations have a use, it not apparent to long term educated practitioners that the proposed  reductions in area for he onsite systems as allowed will in fact protect the homeowner from a premature failure from insufficent capacity.

The Board should interview the numerous soil evaluators and professional engineers who refuse to allow any reduction in area sizing for use of htese products.  It would alos be interesting for the Baord to interview VDH filed staff who have been involved in the failure of systems using these products for a better understanding of how the manufacturer is cooking the books to show his prodiucts are better than others. 

Additionally, some manufacturers do not agree with the reduced area guidlelines and will not warranty their products with the reduced absorption area allowed under these regulations.  

It is blantantly obvious that the elected representative that mandated and approved the legislation requiring VDH to promulgate these regulations were carrying a torch for ht emanufacturer, not for the publics health or long term well being.