Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
chapter
Onsite Sewage Regulations [12 VAC 5 ‑ 611]
Action Adoption of Updated Regulations
Stage NOIRA
Comment Period Ended on 11/3/2006
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11/3/06  12:00 am
Commenter: Tri-County Lake Administrative Commission

Onsite Sewage Regulations (12VAC 5-611)
 

The Tri-County Lake Administrative Commission (TLAC) is a Department of the Counties of Bedford, Franklin and Pittsylvania which was created to address issues of concern at Smith Mountain Lake.

 

Our Environmental Committee recently learned of proposed regulations that address Operation and Maintenance of Alternative Wastewater Systems, among many other issues.  The Commission is very concerned about the recent large numbers of local installations of small, less than 1,400 hundred gallons per day, systems without any mandatory “operation and maintenance requirements” or tracking of sites of these systems.  All parties that we have discussed these systems with agree that periodic maintenance is absolutely necessary on these systems to insure safe and proper operation, but the regulations are not in place at the state level to insure that this happens. 

 

We request that you insure that there are Tracking and “Operations and Maintenance” requirements by the appropriate state agency included in any new regulations.  This would include a clear definition of which State Agency, not County Agency, is responsible for tracking and enforcement of the new regulations. There should also be penalties defined for violators of the regulations.

 

We are also concerned that the regulations do not address the issue of mass deployment of these small systems in development areas.  We feel that the developer should be required to utilize larger centralized sewage systems when soil or other conditions dictate the need for pretreatment.  This can include large centralized Alternative Wastewater Systems or a municipal-type central system, but not a proliferation of small systems in a development.  Our concern is that the probability for a failure in multiple systems outweighs the protection that mandatory maintenance for individual systems gives.  Also, multiple system maintenance places a large economic penalty on the individual homeowners, as compared to spreading the cost for maintenance of a central system over the whole development.  In addition, there is a very much higher cost to the State of Virginia of tracking these many systems vs one central system, solely for the benefit of the developer who may not wish to install a central system.  Please address this issue in your proposed regulations.

 

Pam L. Dinkle

Lake Management and Project Coordinator
Tri-County Lake Administrative Commission

Department of Bedford County, Franklin County, and Pittsylvania County

Telephone:  (540) 721-4400

CommentID: 272