Among issues to be addressed please elevate consideration of fees sufficient to fund inspection and verification of compliance with discharge limits. Currently VDH & DEQ through memorandum share responsibility for implementing a consistent program of inspection & reporting. Wastewater treatment & discharging systems rely on electrical control & mechanical systems, which require maintenance to assure these systems actively reduce BOD, TSS, FOG, NO3, pathogens and other constituents though use of engineering principals including: aeration, settlement of solids, disinfection & de-chlorination of wastewater flows associated with single-family dwellings prior to discharge to surface water. While considering options for implementing electronic reporting requirements, certification that maintenance and monitoring requirements are fulfilled, there are few opportunities to reduce burden. Historically the Commonwealth has failed to protect surface water from residential sewage contamination, both permitted and scofflaw "straightpipe" installations. This notice of intent,  and technical advisory committee seems ignorant of the risk to public health and water quality at risk due to non-compliance. Waters of the US, and vested rights of downstream users are under continuous threat absent monitoring, and publishing of compliance reports.
Absent user fees for general permits, the general fund carries expense of monitoring compliance, thus these duties have been unfulfilled. A renewable general permit places responsibility to the public squarely on the beneficiary of permitting the responsible management entity. Virginia has a population of small businesses providing services to landowners, including licensed operator or inspection entities which service private wastewater plants. These entities also merit consideration in drafting regulations which assure compliance. Absent stringent standards landowners are likely to violate pollutant limits. General permit fees should be sufficient for DEQ or VDH to recover cost of resources required to review applications, issue and periodically confirm compliance prior to renewal.

PUBLIC CONCERNS OVER THE ADMINISTRATION OF DISCHARGING SEWAGE TREATMENT SYSTEM DESIGN, OPERATION, INSPECTION & MAINTENANCE ARE NOT ADDRESSED BY CURRENT REGULATORY ROLES AT EITHER AGENCY. VDH HAS FAILED TO SUSTAIN RIGOROUS INSPECTION OR MONITORING AND REPORTING REGIMEN, DEQ HAS STOOD ASIDE FROM CONCERNS OVER SISTER AGENCY INACTION AND LACK OF ACCOUNTABILITY. SUITABILITY FOR USE OF CERTAIN TECHNOLOGIES HAS NOT KEPT UP WITH TECHNOLOGICAL ADVANCEMENTS. SYSTEMS UTILIZING ELECTRICAL CONTROLS AND PUMP WORKS, MAY BE ALARMED AND UNDER MANAGEMENT BY RESPONSIBLE ENTITY &/OR ACTIVE TELEMETRY.

WATER QUALITY ISSUES RESULTING FROM FAILURE TO OPERATE SYSTEMS ARE A PUBLIC HEALTH THREAT. REVISED STANDARDS SHOULD INCLUDE DUTY OF NOTICE, MONITORING SUFFICIENT TO PROTECT INTERESTS OF DOWNSTREAM LANDOWNERS, RECREATIONAL USERS, OR CITIZENS UTILIZING SURFACE WATER, AND SUFFICIENT FEES OR FUNDING THAT AGENCIES PRIORITIZED THEIR DUTIES OF REGULATION.

AT MINIMUM WE RECOMMEND RENEWABLE OPERATING PERMITS UNDER CHARGE OF PRIVATE RME, REGULATIONS WHICH RECOGNIZE ROLE OF LICENSED OPERATORS IN MEETING WATER QUALITY PERMIT LIMITS, AND PUBLIC NOTICE & INVENTORY OF SYSTEMS WHICH ARE UNDER JURISDICTION OF AGENCY ACCOUNTABLE FOR DETERMINING COMPLIANCE WITH PERMIT LIMITS.

May the actions, decisions, and authorities with respect to this regulatory action, take into account a FOIA (Freedom Of Information Act) level inventory of State Agencies, with respect to what works and what does not work to safeguard the public's health and safety.

"We all live downstream."