Over the last three years, the Eastern Shore of Virginia Ground Water Committee (ESVGWC) has expressed their concerns about privatization of the onsite sewage system soil evaluation and design services that our local Virginia Department of Health (VDH) district efficiently supplies to citizens in our region. The Hardship Guidelines (the Guidelines), to be designed in compliance with § 32.1-248.4, will set the ease with which residents in need can receive necessary services, the efficiency and effectiveness of VDH staff, and will shape the impact of new privatization policies to public health in our region. The Committee wants to reemphasize that it does not wish for the timeliness, quality, or cost of these services to suffer due to the reduction of services by VDH and increased dependency on the private sector. The private sector should be held to at least the same standard that has been set by the local VDH office with regards to timeliness and quality of work. On the Eastern Shore, this standard is quite high.

During previous versions of the draft Guidelines, some of the concerns of the Committee were addressed. This final version, however, removes those sections and most of the vital aspects as mandated by the General Assembly and the Code of Virginia are neglected entirely. Thus, rather than going into specific concerns and details, the Committee recommends VDH have an attorney review the guidelines on behalf of the Commonwealth of Virginia and that the SHIFT program and these associated Guidelines be submitted to the Commonwealth of Virginia Environmental Justice Commission before implementation.

The ESVAGWC appreciates the role that the VDH has historically played in relation to protecting public and environmental health and recognize that many of the residents on the Eastern Shore will continue to rely on VDH to provide vital well and septic evaluation and design services.