I agree there appears to be a lot of prescriptive requirements in the proposed regulations 12VAC5-613. Especially in section 80 and 90 which are titled as performance requirements. Table 1 and Table 3 specifically. However, all prescriptive requirements should be remove from these sections.  Section 32.1 – 163.6 provides that a PE’s design of a “Treatment Works” be compliant with performance requirements established by the Board.  A suggested change under section 12VAC5-613 80 11. Recommended Mmaximum trench bottom hydraulic loading rates for pressure-dosed systems using TL-2 and TL-3 effluent are found in Table 1 and are to be used as follows: and 11  c. Trench bottom hydraulic loading rates for pressure-dosed systems shall not exceed the values in Table 1 except when designed under Section 32.1- 163.6 of the Code of Virginia;  add.  If alternative trench widths are proposed the area loading rate (gpd/square foot of drainfield area) should not exceed 1/3 of trench bottom rate as indicated in Table 1.  Higher area loading rates shall be justifield and additional safety factors included in the design of the “Treatment Works.”  12VAC5-613 80. 15. Should be DELETED.  Also. Table 3 should be deleted or at least modified because it limits the engineer on the use of the soil component of the “Treatment Works”.  Soil treatment will remove nitrogen and there are methods to determine the soils ability to remove nitrogen.

In Section 12VAC5-613-10, DELETE the last sentence in the definition of “Ground water”.  “Ground water “ is defined in section 62.1-255 of the Code of Virginia and does not include this sentence.

I also agree with Mr. Pinnx’s paragraph. “Constructed drainage improvement is an important engineering strategy for managing surface and groundwater in the Coastal Plain (essentially all land area east of I-95). Constructed drainages (a surface swale or ditch, a gravel filled interceptor, or a vertical sand drain) have been effectively used to manage and mitigate saturated natural soils under and around drainfields. Typically, these systems are used in concert with high levels of wastewater treatment and disinfection. They are primarily used to maintain an unsaturated zone of underlying soil, which is beneficial to the treatment and ultimate disposal of wastewater. “

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