Loading...
HomeMy WebLinkAboutattachment-1-owts-questionnaire-survey Attachment 1 5-Yr Water Quality Assessment and LAMP Review Alameda County Department of Environmental Health General Policy/Procedures Issues 1. Variances for OWTS Repairs. Variances under the Alameda County OWTS Ordinance require approval by the Board of Supervisors, which is a formal, lengthy and costly process. Granting of a variance requires the County to make the following findings:  Special circumstances and conditions exist on the property which deprive the property owner of privileges enjoyed by other property subject to the Ordinance;  The granting of the variance will not constitute a grant of special privileges inconsistent with any limitation on other property subject to the Ordinance;  The granting of the variance will not be detrimental to other persons or property (including but not limited to watercourses or wetlands or the water quality of subsurface water) or to the public health, safety or welfare. The State OWTS Policy and most all counties do not require a formal variance process for OWTS repairs. Alameda County Counsel’s office has broadly interpreted that variance requirements in Alameda County pertain to any deviation from the code, and should be applied to OWS repairs as well as for new construction and replacement OWS. County EH staff recommends a change in this policy/interpretation that would: (a) exempt OWS repairs from formal variances, instead following “maximum extent practicable” guidelines; (b) apply variance provisions to new/replacement construction projects only; (c) support variances that pertain mainly to requirements such as building and property line setbacks rather than requirements related to soils, water, and geologic suitability; and (d) oppose variances needed solely for maximizing site development. Provide comments and suggestions on the above. Comments and Recommendations 1 2. ACDEH Staff Involvement in Site Evaluations/Field Work. Current ACEDH practice includes staff observation of soil and percolation tests, OWS installation inspections, and responses to complaints and failures. The intent is for ACDEH staff to observe but not direct site evaluation work. When unavailable, the policy is to allow waiver of staff inspection in order to avoid delays in field work. Provide any comments or suggestions on the above practice, how it is working, and how it can be improved. Identify practices followed in other county programs as examples and pros/cons, as appropriate. Also, should ACDEH staff have greater involvement in personally conducting some basic field measurements and evaluations, such as soil texturing and profile logging, slope measurements (clinometer), observations and interpretation of groundwater level/indicators, etc? Comments and Recommendations 3. Determining Wastewater Strength and Nitrogen Loading. Current regulations provide nitrogen loading factors for residential OWS to meet requirements defined by the groundwater basin manager (Zone 7). Comparable guidelines are lacking for commercial and other non-residential projects. Provide suggested methods or references that can be incorporated and made available to facilitate the nitrogen loading evaluation process for non-residential and commercial facilities. Comments and Recommendations 2 4. Streamlining the Design Review-Approval Process. The County recognizes the need to improve the OWS review and approval process. Some of the things the County has been working on include the following:  The Board of Supervisors has hired an outside consultant to review the County’s interagency permitting processes (Building, Planning, Environmental Health, Fire); a report of findings and recommendations is due in May of this year.  Expansion of permit portal to include upload of documents to ACDEH and review comments and integrating with building and planning approvals;  Implementing a scanning project for all existing OWS files to facilitate electronic access by staff and the general public.  Adjusted OWS review process to consist of two steps: (1) submittal of feasibility plan (e.g., site evaluation and system sizing information) to facilitate planning referrals; and (2) submittal of final design/drawings with building plans as the base map.  Planning to implement a standard checklist-type format for design review comments. Provide comments on the above as well as suggestions on other procedures/practices that can be implemented to streamline the OWTS design review-approval process. Comments and Recommendations 5. Remodels and Additions Policy. Some counties have written policies and procedures that deal specifically with OWTS requirements for building remodels, additions and ADUs. Is something of that nature recommended for Alameda County? Is there a good example(s) you can suggest? Comments and Recommendations 3 6. Training/Workshops/Meetings. Provide any suggestions on an appropriate level and frequency of training/workshops/meetings to improve communications between ACDEH and practitioners, and overall knowledge of OWTS design, construction and operations for all involved parties. Comments and Recommendations 4