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23 <br />Another concern that I have regarding the proposed treatment <br />system is the fact that the treatment system may operating <br />at the permitted maximum capacity before all mobile home lots <br />are occupied. This would certainly be the situation if some <br />lots are occupied by units with more than three bedrooms. In <br />terms of number of units and the corresponding waste loading, <br />the occupation of spaces by units of more than three bedrooms <br />is something that could vary significantly with time. The <br />issuance of CO's by Planning staff could require a bedroom <br />count for the entire park each time a CO is issued after the <br />park begins to approach capacity. To me this seems very <br />inefficient and an undue burden on the Planning Department. <br />A second alternative would be to let DEM handle the problems <br />of waste loadings and overburdening the treatment system by <br />the process of adjudication of the violation(s) of the <br />system's operating permit. I must warn you, however, that <br />this process is very clumsy at best and that DEM's <br />enforcement record in dealing with spray irrigation systems <br />is somewhat spotty. Spray systems are given a lower <br />enforcement priority by DEM, because the agency is <br />understaffed and gives higher priority to systems which <br />discharge to surface waters. The most simple solution to the <br />problem of the bedroom count and potential overburden of the <br />treatment system is to restrict the park to two bedroom units <br />only. <br />If I may provide any additional input'or information, please <br />advise. <br />