With yard space becoming tighter and lot sizes smaller, it has always been a challenge on smaller lots to get 10 feet off foundations without going into a utility easement. With the new changes of 15 feet off of foundations and now 5 feet off property lines, thousands of homes will no longer be able to legally have a irrigation well. This change alone is going to reduce by my estimate 30% of irrigation wells which for me is easily going to be 100 wells a year. ($30,000 in permits) This rule is going to empower those who don't pull permits and inhibit the rule abiding drillers that pull permits. If termite treatment is no longer an issue, I don't understand and was never explained why the new rule has moved us even farther from foundations. And the explanation for being 5 feet off property lines is so wells don't accidently get drilled on wrong property, which in my 15 years of doing this (roughly 10,000 wells) this has never happened. 

Also for us shallow well drillers, shallow wells (Example a 30 foot well), it doesn't make sense to pump grout on shallow wells, and isn't practical in field. We have to pour the grout and truthfully speaking a pour fills the void better than pumping ever could. Lastly also pertaining to new grouting standards. Casing is now to be cut off 5 feet underground then grouted. Many of our static water tables are above 5 feet, and in many areas here you will hit water 3-4 feet in the ground, making this impossible.