The James City County Citizens' Coalition (J4C) finds it difficult to believe that state regulators would seriously contemplate permitting septic systems in wetlands or near streams at a time when the EPA has imposed a more restrictive pollution diet on the states and localities within the Chesapeake Bay watershed.  These new restrictions will already cost Virginia and its localities millions of dollars in compliance without the Department of Health permitting yet more effluent to be discharged.  Further, placing septic systems in wetlands without adequate dry land through which pollutants can percolate is at odds with the intent of the state's new Watershed Implementation Plan.

1.  Our group strongly urges the septic systems be permitted only on a dry soil zone with at least twelve inches of dry, pervious soil between the system and groundwater. 

2.  Septic clusters should be permitted only after the assessment of the cumulative impact - not the impact of any individual system.

3.  Any permits must restrict nutrient dispersion.

Sincerely,

John Haldeman, Board Member