These regulations need to be amended. Processing of applications should consider todays business environment where there are different types of customers with different needs. The entire regulation is based on the assumption that the owner of a single lot needs a permit to build a new septic system or repair an old one and the health department will be the provider of the service, the permit issuer and inspector.  These regulations are not friendly to businesses providing private sector designs or builders who are not going to be the occupant of the property. Regulations do not reflect the current business model of the Health Department but are essential to public health. 

Most importantly, there are multiple regulations and policies at VDH that referr to or are supplemental to other regulations and policies that are inconsistent and require daily interpretation from central office and local staff which is a waste of time and resources. (in my opinion). VDH seems to be afraind to issue black and white regulations and policy.  Anytbhing that is not enforceable needs to be removed from the regulation.  

I agree with Mr. Lynns comments entirely.  The current model is out of date and does not meet todays standards of business practice (sometimes not meeting standard practices of engineering either).  Additionally, VDH is supposed to be stepping away from design practice and the direct competition from the private sector OSE's and Engineers and businesses in the State of Virginia.  When was the last time a homeowner had the local county government design their building plans for a house or engineer a retaining wall? I need not answer that silly question but why am I forced to point it out with VDH?  At this point there is little to no accountability for this work; the water is too muddy and the taxpayers deserve better.  Professional licensed people are accountable for their work and the public deserves this when it comes to value added (or lost) to real estate and property. 

The model for service to the public as far as VDH is concerned should be strictly regulatory oversight and compliance as well as record keeping and data collection.  Regulation and compliance is a must with all aspects of building, construction and code.  Issues over economics and services to poorer communities in the state seem to have been the major platform to continue practice of public subsidized work.  I have yet to see this practice in any other government agency outside welfare and public assistance agencies.  The continued hang up over repair work has delayed the change in regulations well beyond the point of being reasonable.  The perceived lack of private sector services in Southern VA etal areas is nothing more than a myth and an excuse to drag this issue out until its forgotten by the legislature.  One more study isn't going to get the program back on track.

As with any regulatory change, all vested parties should be represented in regulatory change, specifically those performing those services such as the OSE/PE community.  VDH and DPOR should respectfully involve these parties of any proposed change in policy or regulation and not create policy without the involvement of this community through other outside organizations or special interest groups.  Backroom legislation is not acceptable in todays age with the power of FOIA.  The citizens of Virginia and vested parties deserve transparency in this process and integrity of proposed regulations in a manner best serving public health, safety and preservation of groundwater resources and the value added to real property in the Great State of Virginia.

If the private sector is forced to compete with subsidized public serves we will eventually close up shop and the already overwhelmed public services will no longer be able to keep up with building in Virginia.  The current model is not sustainable for the citizens and development community of Virginia and surely will erode groundwater resources (like the Eastern Shore and Chesapeake Bay Environments) and continue to endanger public health if continued as is.  Currently many local agencies are still accepting bare applications and processing "conventional" systems, leaving the "engineering and design" work alternative systems for the private sector, while this sounds like a co-operation of services it is nothing more than cherry picking leaving the complicated and labor intensive work (in much smaller quantities) to be completed by the private sector.  Those bare applications are what it takes to stay in business year round, have the ability to hire a VA-Tech Grad student or another licensed individual trained. 

As a vested member (and VA taxpayer) serving the citizens of Virginia I feel any exclusion of my trade and its constituency is nothing less of backroom legislation benefiting someone other than the taxpayers.  Lets us work cooperatively to fix these problems and give the public what it deserves with integrity and accountability.

VOWRA recommends that we open up and review the Septic Tank Design standards that are currently included in the Sewage Handling and Disposal Regulations.   Re-examine and consider a standard that that is beyond what we have now.