The new addition of B.6. addressing emitter aspiration at depressurization is an element of the requirement C.4 for the placement of air relief valves.  Item “D” regarding prevention of gravity redistribution is also related.  Proper placement of air valves, coupled with appropriate piping configuration to prevent redistribution will minimize aspiration of particles into the emitter at end dose event depressurization.    Certain self-cleaning emitters will not clog due to aspiration as they are continuously self purging during operation.  B.6. is redundant. Removal of B.6 is recommended.

Regarding additional specific language to 610 955 C.3.C.3., the addition of actual design criteria may be in conflict with the elements of 12VAC5-613-80. Performance requirements; general. 12 a.b.& c.

As a pressurized dispersal system, drip dispersal systems, as Low Pressure Distribution Systems, are engineered “Alternative Systems” subject to 12VAC5-613.  12VAC5-613-80. 12 a.,b.,& c.  outlines the site specific considerations that must be addressed by the engineer in system design regarding specific site soil hydraulics.

Absorption area geometry is an important consideration in sites with shallow soil depths to limitations and larger flow systems in all slope classes.

Should Hydralic Linear Loading design criteria be applied to LPD systems?  Large flow systems?  Gravity 613 systems?

All systems >1000-1200 GPD require considerably more site hydraulic evaluation then as provided by prescriptive design values.

The concept of and specific design guidelines (specific values) for “Landscape Linear Loading” or “Hydraulic Linear Loading” have their origins in traditional above ground (mound) systems. The values are recommendations with considerable narrative discussion addressing site specific soil and landscape conditions.  Appropriately sized in situ dispersal involves addressing additional absorption dynamics as addressed in 12VAC5-613-80. 12.  The requirements (“shall”) in 610-955 C.3. are out of place.     The entire text of 610-955 C.3. should be removed.