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.