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.