The proposed text states that it will be a violation to “modify or cause to modify... an onsite or alternative discharging sewage system without a permit.” What constitutes modification of a system? This needs to be defined. If it is already defined in other regulations, a reference needs to be made to this definition.
At what level is a permit required? Some may consider replacing a pump with another brand of pump or a float switch with another type to be a modification. Changing the timing of a distribution box or replacing that box if it has been damaged or replacing a control panel with another brand may be modification of the system. Without definite guidelines as to what can be done without a permit, those contractors who repair or maintain systems may be left wondering if their work could result in penalties.