I have little to no confliect with the material covering drip technology.  The systems have been well proven locally and nationally to be a viable and now reliable system.  Technological advances with control systems have made the drip systems reliable and safe.  I am not comfortable with some of the gravelless systems using open chambers in certain situtations and conditions. 

I object to any unauthorized substitution of materails within any permit AOSE or PE derived; additionally the health departments issuing permits should be using licensed employees and grant the employee similiar latitude or accept the full responsibility for substitutions in code obsolving liability for the permit issuer.

I believe gravel substitutions have been widely accepted with past legislation specifically pipe bundled styrofoam peanuts and tire chips.  I see absolutely no reason they should be granted any reduction in footprint unless the reduction is given for gravel and pipe.  I'm sure its very possible to produce a pipe replacement system that can provide more biological treatment but I've yet to see one thats been proven.

My primary concerns with chamber systems are the lack of pipe (splash plates are a unacceptable in my opinion) within the trench with pump systems, dosing volumes equal to gravel are excessive,  and the installation of chambers in various soil classes, specifically soils with high mica content. 

It is my belief the chamber systems work very well in many soils with gravity flow systems.  I don't feel there has been enough hardline data collected from the state and complied by the state to permit the proposed reduction in footprint that essentially strips all of the built in safety factor.  I want to see more data collected from systems installed in a variety of soils within the state of Virginia from West to East including Valley and Peidmont soil not just coast plain.  Maybe the reduction in footprint should require a physical water or K-Sat test to insure the entire area of install is suitable (not an average rate across a large site).

As a designer and AOSE I don't perscribe systems with a one size fits all approach, I would be a fool to do so.  No one system will work under all the conditions found in my area.  I don't feel chambers have the ability to be used in every soil condition and in every design situation.  I strongly object to any contractor or installer substituting ANY product without the explicit and written consent of the AOSE/ designer or VDH employee.  The VDH employee issuing a permit (who should be DPOR licensed) is accepting responsiblity for that system and should have the right to determine exactly what can be used in its construction. 

There have been enough failures reported to be associated with gravelless chamber systems to warrant the state to examine all facts and data on the installed and functioning systems and failures to determine if this is a real threat to public health or a rumour.  The information is available from Virginia local health departments (Venus, Carmody, RME) and manufacturers, its important to look at the data from both entities as it relates specifically to Virginia and the various soils, conditions and environments in Virginia.  A thorough examination of the data still requires field work to check the longterm viability of these alternative products, field study must not be left out.   The Great State of Virginia has spent millions of dollars requiring the data collection of alternative systems, now is a good time to put that money to use and help make an educated decision that truly serves the taxpayers, environmental and public health.