The management of the discharging systems has been severly lacking due to the lack of effective compliance and enforcement by the VDH.  These regulations need the civil penalty rules enacted to make them somewhat effective.  In addition, the regulations should mirror the Alternative Onsite Sewage System (AOSS) regulations as most things for these systems are the same.  Approval of technology should folow the same process as the AOSS regulations.  This rule in the same manner as the proposed AOSS regulation is lacking in terms of timely follow up to problems and non-compliance.  Requirements for a the development of a corrective action plan, its implementation and enforcement should be added.  The AOSS licensed operators should be allowed to operate these facilities also.

This is another government attempt to over step its control over its citizens.  It is a typical over kill law which will do nothing but  further add on to the huge tax burden of the taxpayer.  It must be done every year? What a waste of time and money. Maybe you should consider mandating that each system should be regulated or inspected on its own merits.   Since most systems out there are working and working well each system should only have to be tested tested every 5 years UNLESS a problem is discovered and that particular system should be checked every year until properly fixed.

More regulation is not the answer, help property owners (Tax Payers) to develop and use their land, not hinder them. There is so much federal, state, and local regulations today that it cost the land owner a small fortune to build a single family dwelling within the Chesapeake Bay watershed.  Support individual development, assist land owners, advise them on what they can do not just what they can’t do. The approach should be to work with land owners to develop green Single Family Dwellings not to regulate them the death. Once built, the taxes will come to help build infrastructure for the most critical areas. Continuing to regulate and deny land owners use of their property will eventually end in a law suit over constitutional rights and cost all of us millions in tax dollars to argue.

Why do we need two state agencies to permit a discharging system?  DEQ has 100% jurisdiction for all discharges except  those for SFDs that fall under the GP.  Why does VDH get involved with these?  This is wasteful, confusing, and goes against the Governor's "one-stop" philosophy.

How well is this discharge program currently being implemented?  To answer this question someone should insist on getting answers to the following questions:

1.  How often does VDH actually inspect each of these systems?  The answer falls somewhere between annually and never with never being closer to the truth.

2.  How often does VDH collect the required annual inspection fee?  This might shed some light on the answer to question #1.  However, don't rely on VDH to give you an accurate number of installed discharging systems under their jurisdiction.  DEQ would likely be a better source to get an accurate number of systems.

3.  How many of these systems were functioning properly the last time they were inspected?  The answer to this will shock you.

4.  When VDH discovers that a system is discharging untreated sewage, how long does it take to correct the problem?  This answer will shock you even more.

5.  What credentials do VDH employees have that make them qualified to perform annual inspections of these systems?

6.  When did VDH hold its last employee training session for these regulations and the implementation of these regulations?  I believe the answer is 1992.  This should shed some light on question #5 above.

Submit a FOIA request to your local health department and ask for a list of discharging systems and a copy of all VDH inspection reports.  Then, call your local newspaper to report your findings.

These regulations should be revised and then turned over to an agency capable of implementation.