Agencies | Governor
Virginia Regulatory Town Hall
Virginia Department of Health
State Board of Health
Regulations for Alternative Onsite Sewage Systems [12 VAC 5 ‑ 613]
Action Amend Regulations Following Periodic Review
Comment Period Ends 6/28/2019
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6/7/19  8:21 am
Commenter: Anonymous, VDH


Both the private sector and the health department have recognized that there's clearly a significant lack of enforcement regarding operation and maintenance of alternative onsite sewage systems.  A recent response from the health department was as follows: "VDH noted that a stronger enforcement policy is in the works and proposed changes to the regulations will help with enforcement".  This is an absurd statement.  It's simply an answer to deflect from the real issue.  No matter what policy VDH puts in place and no matter what revisions occur to the regulations, an inadequate number of staff can only do so much.  If this program is to be successful, a large amount of money will be needed for additional staff.  No additional staff (and I mean many, many more staff) equals no success.

Use the Loudoun County Health Department as an example.  They have roughly one FTE dedicated per 500 AOSSs (i.e. the person's job is AOSS enforcement period!).  There are many districts that have one or two staff members that are responsible for issuing hundreds of permits, certification letters, and hundreds of subdivision lot reviews per year.  They also are now mandated to conduct 100% 'inspections' of OSE/PE systems (another "stronger policy" that is failing due to limited staff).  Some of these staff members are also involved in other programs (rabies, marina inspections, complaint investigations, etc., etc.).

VDH also has very poor data regarding the number of installed AOSSs in Virginia.  So, until the local health department gets an accurate inventory (again, impossible to do without additional staff), no one really knows how many staff members are needed to successfully implement this program.

Until VDH can fund a very large increase in the number of staff dedicated to enforcement, this program will continue to fail.  Please stop implementing policies/programs without an adequate number of staff to perform the job duties.  It's extremely challenging to maintain job satisfaction when one is failing miserably.

Thank you for reading my comments.

CommentID: 72528