Department of Planning and Budget is advised to take notice of economic impacts related to these regulations. Small Business interests have been neglected or given little consideration during prior regulatory reviews. As have impacts upon homeowners affected by damage to their natural resources including ground or surface water.

Economic impact of onsite system design, permitting, installation, and operation under regulations include:

1. Assurances of reliable development of real property improvements and infrastructure,
2. Valuation and tax assessment of real property,
3. Expectation of future transactions including transfer of title,
4. Effects of restrictions on advanced systems, including stigmatization and penalization of owners,
5. Anti-competitive effects on small business, such as- dual standards, impacts of subsidized services or unregulated monopolies,
6. Mitigation of ground water pollution, and need for performance bonding,
7. Adequacy of regulatory review and approval preventing contamination of economic resources,
8. Loss of use through condemnation proceedings,
9. Responsibility for threats to health, welfare and safety accruing via product approval.

In summary please consider the value of real estate served by functioning onsite systems, as opposed to the cost of mitigating failed or non-compliant systems.

I assert the avoided cost of properly designed and operated systems has not been properly established; some seem confused by the misconception that septic systems are temporary solutions until the big pipe is built. In most cases this is impractical, a broken model. The value of reliable decentralized onsite systems in support of rural development should be recognized and supported by any future regulation.