Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
chapter
Regulations for Alternative Onsite Sewage Systems [12 VAC 5 ‑ 613]
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2/25/16  7:45 pm
Commenter: Mary Friedman

Alternative Systems
 
  1. The consumer cost for alternative systems is being manipulated by "additional" testing requirements set forth by the Virginia Department of Health (VDH) with no benefit to consumers. 
  2. With no "state" benefits of testing, owners are being forced to purchase goods from a limited number of dealers.  On their face, the regulations appear to set the Virginia markeplace as an entity exempt from Federal Commerce Clause requirements.
    1. Suggest removing TL3 requirements.
    2. Suggest removing VDH from product approvals while participating in the marketplace.
    3. Suggest requiring all product approvals to at minimum, posess a Virginia licensed engineer stamp with appropriate supporting calculations.
  3. Recommend that all systems designed in coastal plain shall be designed to the estimated 75 year mean sea level rise estimate.
  4. Recommend that all systems installed in the coastal plain province be supported by disinfection.
CommentID: 49668