To whom it may concern:

I am writing to you regarding the proposed regulatory changes at 12VAC5-613 for alternative, onsite sewage systems (AOSS).  As a hydrogeologist with over 18 years experience studying groundwater and groundwater contamination problems, I am very concerned about the placement of these systems in areas previously considered unsuitable for traditional septic systems.  Particularly in low lying water front properties in the coastal region of Virginia which is subject inundation, flooding, storm surges, water table fluctuations, and power outages on a regular basis. As a Planning Commissioner in James City County, when we had the power to do so, decided against allowing these systems to discharge directly to a intermittent streambed...research into these systems indicated that the systems, as designed, were to discharge into a drainfield with a sufficient zone of separation between the drainfield and the groundwater.  I certainly hope that the General Assembly Members have reviewed all the technical details associated with these systems and understand that the hydrogeology and site conditions should dictate the use of these systems...one size does not fit all!!!

Legislation in the last General Assembly (HB 132), emphasized the need for these regulations to: 1) prevent AOSS from being installed in wetlands;  2) allow localities to regulate AOSS permits in response to the need for nutrient reduction in the Chesapeake Bay impaired tributaries; 3) require a 50 foot setback from the shoreline of an impaired watershed; 4) require a one-foot vertical separation between an AOSS treatment zone and the groundwater, and: 5) ban direct discharge of effluent into groundwater.

I support the prohibition on installation of AOSS in wetlands, the additional nutrient reduction standards, and the mandatory operation and maintenance requirements.

However; 12VAC5-613 falls short of satisfying all of HB132.  I do not support the placement of these systems above groundwater with no zone of dry insitu soil separation.  I view the proposed conditions on the placement of these systems in those situations as inadequate to protect public health.  I see no definition of “wet season” that would guide the installation of these systems and object to any septic system being installed on a site that is flooded at any time.  I do not support the allowance of direct dispersal of sewage effluent into groundwater.

Sincerely,

Shereen Hughes

103 Holly Road

Williamsburg, VA 23185