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G °�rtY Ned�f� <br />o, .6 <br />c M y <br />o W <br />0 3 <br />North Carolina Public Health <br />ORANGE COUNTY <br />HEALTH DEPARTMENT <br />Rosemary L. Summers, <br />MPH, DrPH <br />Health Director <br />Richard E. Whitted Human <br />Services Center <br />300 West Tryon Street <br />Post Office Box 8181 <br />Hillsborough, NC 27278 <br />Phone: (919) 245 -2411 <br />Fax: (919) 644 -3007 <br />www. co. orange, nc. us /hea /th <br />Animal Control Services <br />Central Administrative <br />Services <br />Dental Health Services <br />Environmental Health Services <br />Health Promotion and <br />Education Services <br />Personal Health Services <br />306 -C Revere Road <br />P 0 Box 8181 <br />Hillsborough, NC 27278 <br />Phone: (919) 245 -2361 <br />FAX: (919) 644 -3006 <br />LO <br />a) <br />Y <br />Q) <br />V) <br />flo <br />a� <br />a� <br />E <br />c <br />0 <br />w <br />17 <br />EXHIBIT C <br />MEMO <br />DATE: March 21, 2003 <br />TO: Rosie Summers <br />FROM: Ron Holdway <br />Tom Konsler <br />RE: Legislative Proposal for Licensed Soil Scientists to Permit Septic Sites <br />Rosie, <br />At the request of the County Attorney, we prepared this memo to address concerns <br />regarding the recent legislative initiative for the privatization of evaluations of sites <br />for wastewater systems in North Carolina. This idea is being proposed by the North <br />Carolina Coalition for Privatization of Wastewater Evaluations (NCCPWE) and a <br />copy of the most recent information from that group is attached. Please note that <br />there is some concern from the coalition members and others that the proposal does <br />not reflect the position of the group as a whole. (See attached email from Bill Jeter, <br />the section chief for the NCDENR On -Site Wastewater Section). We understand <br />that you have already notified the county manager and our local county <br />commissioners of this push and also that the Local Health Director's Association is <br />preparing a formal response. <br />The current proposal as presented is a three pronged approach to septic evaluations <br />and we will respond to each aspect individually as well as give you our general <br />comments on the idea. As you know, the permitting and approval for on -site <br />wastewater systems has historically been a responsibility of local health <br />departments in North Carolina since the early days of water carried sewage with <br />very few exceptions. The existing program is an excellent public health program <br />with its primary goals of improving water quality and minimizing disease <br />transmission from direct contact with sewage or ingestion of sewage contaminated <br />water. <br />In general, we perceive the allowance of private sector permits is fraught with <br />potential for exploitation. Since the private soils consultants will be hired for the <br />most part by the property owner or developer to assess the soil suitability, the <br />incentive is present for the consultant to find useable soils. There is some <br />experience that demonstrates problems with this approach as large septic systems <br />(larger than 3,000 gallons per day) were permitted by the State until 1992 in a <br />manner similar to the current proposal. There were at least three large systems <br />permitted here in Orange County that became problematic in large part due to poor <br />siting conditions including soil, topography and inappropriate loading rates. Some <br />