I would suggest adding some specific minimum criteria regarding UV disinfection, and encourage the use of UV over chlorine. Since the initial regulations were written small scale UV systems have become more economical, dependable, and readily available. Although periodic bulb changes are necessary, the frequency of maintenance would typically be much less than is required to maintain chlorine and de-chlorination tablets, which we often find are empty even in larger "package plant" installations.

Rather than labeling the VPDES permit for "single family dwellings", consideration should be given to officially making the permit applicable for all discharges less than or equal to 1,000 GPD. Examples would be for connecting multiple residences to a single treatment system, or small business in rural where only basic sanitary facilities are provided such as gas stations or small offices.

There should also be specific instructions regarding required submissions to DEQ too. As I understand the process, as was explained by DEQ staff, both DEQ and VDH require a copy of the permit application and approval. Clarification as to what paper work needs to go to who in the regs would be helpful.