I applaud the Department in acting on the topics discussed in the "footprint forum" it seems a critical time to incorporate the relevant discussions and concerns of the participants into revisions of the Code.

I would like to register my concern that the Department seems to believe that an Engineered solution to the reduction of organic load or the dispersal of treated wastewaters into the soil precludes the necessity of understanding or predicting the effect of such wastewaters on the soil "receiving environment." I would like to remind the governing authority that there exists a body of scientists that make a practice of studying and applying our understanding of soils to the tertiary treatment and dispersal of wastewaters as well as other applications for the soil medium. I refer to the Certified Professional Soil Scientist, regulated under DPOR, this practice is complemented by the on-site design training afforded those credentialed as AOSE. As these professions move toward integration under legislation approved this year I hope the Departments will recognize the importance of these professions to the homeowners, developers and communities that rely on septic systems to provide economical and efficient waste disposal. It is appropriate to emphasize that soil is the medium best suited to renovating wastes, and that soil scientists are best qualified to predict the suitability of a particular environment to be utilized for this purpose.

I also am pleased to see the integration of current affairs into the revisions due on the Code. An example may be the writing of regulations for the disposal of "special wastes" such as peat filter media, I believe that there should be efforts to treat and dispose of this material on site, to avoid the transportation and handling costs; it is not difficult to imagine the permitting of onsite disposal under a short term permit to sequester these wastes until the biological materials have been rendered harmless by natural aerobic process.

Another example concerns the re-use of water or gray-water as an irrigant or for non potable domestic purposes. The Department in cooperation with other agencies concerned with land and water use should make a concerted effort to encourage the conservation of water for as we have seen in these times of drought we have made an unfortunate policy of routing water away from the storage vessels of the aquifer and vadose zone.

This seems an appropriate forum to call for the publication of research and case histories conducted on experimental and alternative systems by the Department, in cooperation with Virginia Tech, and the Contract Soil Scientists. This information as well as the experiences with repairs to failing systems should become part of On-site training and available in a technology library or publications which the onsite practioners should have access to. Indeed as a public agency it seems unusual that such a database would not be available to the public.


Jeff T. Walker; CPSS/AOSE