Draft regulations prompt questions about technical standards and training for advanced septic systems

The Sewage Disposal Working Group’s regulations and legal subcommittee reported gaps and inconsistencies in a proposed Department of Public Health regulation and urged the working group to clarify training and technical standards before moving forward.

The concern was summarized by a member identified in the meeting as Bob, who said the subcommittee "identified actually a couple of missing sections, and there are some citation errors in there." Bob added that the draft regulation repeatedly references specific sections of technical standards that, in the subcommittee's review, do not appear in the 2024 version publicly posted on the environmental engineering website.

A staff participant identified as Dante explained that the DPH approach is to codify technical standards in statute and then use regulations to refer to those standards. "The technical standards are now codified in statute," Dante said, and the plan is to roll the proposed regulations and an updated set of technical standards "together as a package" once the regulation is close to approval.

The subcommittee also raised workforce and training issues tied to adopting AT systems. Bob said many installers and some regulators would "have absolutely no idea what they're looking at when they go out to do an inspection or do a plan review," and proposed training delivered in partnership with organizations such as the Connecticut Environmental Health Association (CIHA) and COWRA that could be provided "at no cost to the state." Dante and other participants said training and technical standards should be aligned so that inspections and plan reviews are practical and consistent across local health departments.

Cost and operation-and-maintenance considerations remain under review. The regulations subcommittee reported preliminary installation cost estimates for an AT system on an unconstrained three-bedroom site as "somewhere between 30 and $40,000," while noting that operation-and-maintenance requirements could be annual or semiannual depending on the technology. The subcommittee said it is still collecting data on long-term O&M costs.

The group flagged a sequencing question: whether technical standards should be finalized before or after the regulation is approved. Dante summarized the intended sequence: regulations approved or nearly approved first, then internal approval of updated technical standards, and then deployment together.

The subcommittee plans to continue weekly meetings and to seek input at upcoming professional gatherings; several members will present the group's work at the CIHA annual meeting to gather feedback from installers and regulators. The working group chair suggested subcommittees join on overlapping topics such as funding and training to develop coordinated recommendations.

The subcommittee's findings were presented as work in progress; no formal recommendations or votes were taken during this meeting.