The current fee's for septic and well construction permits and Certification letters are unfair.  When an AOSE's prepares a report for a permit or certification letter he/she has done the majority of the work required.  The EHS is responsible for a review of paperwork only and a 10% field review.  This review of the paperwork should not take very long and when a site visit is made it takes much much less time than when the full evaluation is done. The fees collected for AOSE permits are being WAY over charged and is subsidizing other programs which is plain unfair.  Please look at the actual reasonable cost of an AOSE permit versus a Health Department permit.  There should be a significant difference maybe as much as 10 fold increase for bare applications.  If you think about it an EHS could process as much as 8-10 AOSE combination septic and well permits a day if that was his/her only responsibility.  I think that the most an EHS could process is 1 bare application combination septic and well permit a day.  The EHS that processes bare application must be more highly trained, visit the site multiple times including site visits, pre-construction visits with contractors, installation inspection, pump inspections, and final grading inspections.  Also consider the increased office time, increased support staff, increase liability, and increased training required to name a few.

The Health Department should re-evaluate their mission, to protect public health and the Environnment.  By continuing to process bare applications in direct competition with the private sector they are not accomplishing their mission.   Ask an EHS, Do they have failing systems in their county?  How many?  How do you find failing systems?  Are the alternative systems being maintained?  What are you going to do if they are not maintained?  What is the health of the streams in your area?  Do you monitor for bacteria?  Are their other pollutants that you monitor or look for?  What type of Education or outreach are you doing?

The unfair fees has a huge negative impact on my small business.  The private sector is/can save the State millions of dollars if the fees are done fairly.  Please read the Report titled VDH Re-Engineering Initiative Onsite Sewage Program 2006. Also read the 2007 Report to the Governor and the General Assembly.  It clearly stated that reviewing AOSE reports takes 30-60 minutes and the fees should reflect the actual cost.  Why was this not used to calculate the fees during the last adjustment?

Adam Herman, AOSE#104