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


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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

11/9/22  7:03 pm
Commenter: Adam C Herman

Shallow Pads

I don't agree with the minimum install depth of 8 inches. We have designed many shallow pads less than 8" in the coastal plain and they are working properly. Where did this limit on the install depth come from? Has there been a history of this type of pad not working or was this just an arbitrary number? This will cost citizens an inordinate amount of money for no foreseeable reason. What will happen with all drainfield areas and reserve areas that have all ready been approved. What is the logic behind the minimum install depth? Please consider removing the minimum installation depth of pads.

CommentID: 205138

11/9/22  8:55 pm
Commenter: eric debrosky

proposed pad regs

Over a 20 year career, I have quite a few Alt. pre-treat to existing pad systems, installed less than 8" ;  And none of them has had any issues. Not one... why exactly, is an 8" limit being proposed? has there been a substantial amount of failures?  I'm not seeing any data or science to back this proposal up? Feels arbitrary and capricious. 

CommentID: 205139