Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
chapter
Regulations Governing Application Fees for Construction Permits for Onsite Sewage Disposal Systems and Private Wells [12 VAC 5 ‑ 620]
Action Update regulations to reflect changes in the Code of VA
Stage NOIRA
Comment Period Ended on 5/25/2011
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5/25/11  4:53 pm
Commenter: Private Sector

Cost disparity.
 

 

Having worked in for both the health department and the private sector please allow me to echo many of the other comments made here with respect to cost verses services provided. Currently there is only a nominal cost difference between a “bare application” and a AOSE/PE application. Having performed bare applications as well as Level I and II reviews  the fees charged do not begin to reflect the amount of time spent on each. Mr. Herman indicated that multiple AOSE permits can be performed in a day versus spending at least a day on a site visit(s) and drafting a permit for a bare application. This does not even include the required final inspection(s) which can eat up several hours to half a day each depending on the distance required. I stated inspections plural because many times I had to make two or three trips to inspect a system as contractors did not seem as concerned for they did not have to pay a fee for the inspections.   Knowing the time involved and what billable rates should be for EHSs, support staff the fees for bare applications are way too low for what services should be provided (a construction permit or a flagged area for certification by an AOSE). Additionally I am aware that many health districts will locate drainfield sites for property subdivisions at these same low costs, a service that in no way should be providing. When combined these issue point to the state providing a service at significantly reduced costs, subsidizing development, and competing with the public sector.  This is a poor use of resources for an agency whose main goal is to protect public health. To echo others I cannot think of another case where a governmental agency provides this kinds of design services for the public.
CommentID: 17593