Virginia Regulatory Town Hall
Virginia Department of Health
State Board of Health
Sewage Handling and Disposal Regulations [12 VAC 5 ‑ 610]
Action Addition of Design Elements for Treated Effluent
Stage Fast-Track
Comment Period Ended on 11/9/2022
Next Comment     Back to List of Comments
11/9/22  6:43 pm
Commenter: Kimberly W Harper

Pad Regs

I don't agree with the minimum install depth of 8 inches, especially here in the coastal plains section of Virginia. I have probably hundreds of properly working stone pads with install depths less than 8 inches. I'm curious about the "science" behind this specification. There was no minimum install depths in the original GMPs so why now? Is this just another grab by the engineering community to take design away from the AOSEs? Definitely in my area this will cost the citizens more money when they have to go to an engineered design. And what are we to fo with current sites that have site work completed with shallower placed stone Pads but haven't submitted due to waiting on Surveying to be complete? How do I explain they have to come up with $5k to $10k more now? I would hope there will be some grandfathering with these Fast Track regs. I can literally take anyone to numerous shallow stone Pads working perfectly and at the same time take anyone to numerous failing engineered mound systems. Where is the logic for this minimum installation depth? I think the minimum install depth should be removed.

CommentID: 205137