PUBLIC CONCERNS OVER THE ADMINISTRATION OF DISCHARGING SEWAGE TREATMENT SYSTEM DESIGN, OPERATION, INSPECTION & MAINTENANCE ARE NOT ADDRESSED BY CURRENT REGULATORY ROLES AT EITHER AGENCY. VDH HAS FAILED TO SUSTAIN RIGOROUS INSPECTION OR MONITORING AND REPORTING REGIMEN, DEQ HAS STOOD ASIDE FROM CONCERNS OVER SISTER AGENCY INACTION AND LACK OF ACCOUNTABILITY. SUITABILITY FOR USE OF CERTAIN TECHNOLOGIES HAS NOT KEPT UP WITH TECHNOLOGICAL ADVANCEMENTS. SYSTEMS UTILIZING ELECTRICAL CONTROLS AND PUMP WORKS, MAY BE ALARMED AND UNDER MANAGEMENT BY RESPONSIBLE ENTITY &/OR ACTIVE TELEMETRY.

WATER QUALITY ISSUES RESULTING FROM FAILURE TO OPERATE SYSTEMS ARE A PUBLIC HEALTH THREAT. REVISED STANDARDS SHOULD INCLUDE DUTY OF NOTICE, MONITORING SUFFICIENT TO PROTECT INTERESTS OF DOWNSTREAM LANDOWNERS, RECREATIONAL USERS, OR CITIZENS UTILIZING SURFACE WATER, AND SUFFICIENT FEES OR FUNDING THAT AGENCIES PRIORITIZED THEIR DUTIES OF REGULATION.

AT MINIMUM WE RECOMMEND RENEWABLE OPERATING PERMITS UNDER CHARGE OF PRIVATE RME, REGULATIONS WHICH RECOGNIZE ROLE OF LICENSED OPERATORS IN MEETING WATER QUALITY PERMIT LIMITS, AND PUBLIC NOTICE & INVENTORY OF SYSTEMS WHICH ARE UNDER JURISDICTION OF AGENCY ACCOUNTABLE FOR DETERMINING COMPLIANCE WITH PERMIT LIMITS.