Making Sense in the Onsite Field

To the Editor: 

I really enjoyed your article in the December Onsite Installer (Breaking Ground, “What Doesn’t Make Sense?”). You hit the nail on the head with three of my pet peeves!

Trials of technology. This goes back to the EPA’s 1997 Report to Congress, which says we have the technology to put a septic system anywhere, but regulations generally haven’t caught up with the technology.

Local control. This is my biggest peeve. Pennsylvania went to a state code in 1972. Local ordinances can always supercede the state regulations, but they never do! They don’t have to because the state code is sound and, contrary to other arguments, works across the state in all types of soils and terrain. 

Credentialing. Although I like the Pennsylvania state code system, ironically we have no credential requirements. The hodgepodge of different credentials sure helps keep our industry looking like a bunch of fly-by-nighters.

 I think the local control issue is the root of most of the problems. County health departments who continue to do things as they have for the past 50 years with their heads in the sand don’t have the interest or motivation to keep up with the new. I think when we go to events such as the SORA and NEHA conferences, we surely see the cream of the crop, because most of these people seem to want to learn – although none of them want to give up their control.

On a negative note, I thought the Pennsylvania state code would be managed by a brain trust of highly technical and interested individuals who would keep the state’s onsite program on the leading edge. That has not happened. Sometimes things seem more based in politics than in science. Pennsylvania does accept any NSF-approved equipment, but the process to get something approved that is not an NSF device is mind-boggling.

Please note all the above comments are mine personally and should not be taken as representing the opinions of NAWT or any other organization with which I am or have been affiliated. Again, thanks for a great article. Now, who helps us fix all this?

Tom Ferrero

Chief Operating Officer

Franc Environmental

Horsham, Pa.

To the Editor:

I have a few comments on your column, “What Doesn’t Make Sense?”

On trials of technology, while NSF testing protocol is a place to start, it is not, from my more than 35 years of field experience in the residential wastewater industry in Arizona, fairly reflective of the relative BOD influent strength of raw sewage most NSF treatment devices receive.

Moreover, this influent is not the homogeneous product used by NSF taken from a municipal sewer line. This influent is highly irregular, as there are days when the influent is extremely high (such as on laundry day) and highly chemical (as when the household toilets are sanitized). Under actual field conditions I have not found even one NSF treatment plant that consistently produces secondary treated effluent.

On state and local regulations and their differences, my comment is that tradition and regulatory power are at stake, and I have not found any regulatory body willing to give up jurisdiction on anything once it has attained that power.

On the subject of local jurisdictions, perhaps if I lived in a state where voters adequately funded their state’s Department of Environmental Quality and Enforcement, I could be amenable to one-size-fits-all approval.

In 2001, Arizona instituted what was to be precisely that: statewide rules and regulations for the design, installation, operation, maintenance and sale of all residential onsite wastewater treatment and effluent disposal systems. That lasted until the ink dried. Then the 15 individual counties found out they were stuck with the program but were not given funding to provide the manpower necessary to implement the program.

Fast forward to 2011, and Arizona has 15 separately orchestrated jurisdictions, policies and practices, and all the while the state agency, Arizona DEQ, is further curtailed as our legislature cut its funding, making it essentially dependent upon those they regulate to support it – the fox guards the henhouse.

I believe that if county environmental departments were adequately funded and provided with sufficient manpower, they most likely would be amenable to implementing a state standard. There is one caveat: In a state like Arizona, with extreme topographic conditions and elevations, devising a one-size-fits-all set of rules and regulations would be extremely difficult, and in the end might well require some flexibility in decision-making by the county environmental agency.

Paul F. Miller

Phoenix, Ariz.