VDH OSE designs include specifications which provide a 25% reduction in area for infiltration with a substitution worded as follows:
“Gravel-less material may be used, in lieu of gravel and pipe, within the approved distribution area in accordance with Table 5.4 of 12VAC5-610. If gravel-less material is used the distribution box location remains the same”

This statement leaves critical factors open to interpretation. Please address the following examples:

1. To date VDH construction permits do not offer guidance or specifications for corresponding alterations in systems designed with pump or siphon dosing.

Could VDH offer guidance on who is responsible for alteration of the pump design to reflect the change in area and/or number of trenches?

2. The statement does not clarify whether the selection of materials is made by a contractor, a homeowner, or the designer (PE or OSE).

How does the VDH intend to amend policy requiring design of onsite systems to conform with the engineering responsibilities of the licensed designer?

3. The onsite wastewater system design is under the auspices of the professional engineering the system, this includes source, conveyance and dispersal.

Does the substitution of specified generally approved products require endorsement by the designer subsequent to the issuance of the permit, and does the public have any reliable means to discern the responsible charge for this alteration?

4. To date contractors have been expected to counsel their clients regarding the installion of a onsite sewage systems with only 75% of the prescribed surface area. The manufacturer claims:

"Chamber systems are easy to install. Engineered for strength and performance, they have greater design flexibility including a smaller footprint as compared with stone and pipe, and are made from recycled materials. These advantages of Infiltrator chambers add up to cost savings on labor, materials and time savings on the job." (emphasis addedd)

How will the VDH assure the public that the consumer has been advised regarding increased area loading rate, and risk of reduced system performance?

5. VDH central staff responded to a request for gravel-less system performance statistics with the following statement: "...there is not currently a standard VENIS report for the malfunction report that I can pull to provide you with the requested sample data."

In light of the record of usage dating to 1991, and controversy amongst some designers in disparate regions when will VDH provide a public accounting of systems in place, and malfunction assessment associated with repair statistics?