Al Barrow Adds His Comments To The RWQCB’s Stealth Basin Update
Understand the CSD has also added about a gazillion pages of comments. I’ll try to attach Barry Tolle’s comments from the County, if I can get the document to cooperate. Now, the only question: Is anybody listening?
To;
Sorrel Marks and Howard Kolb RWQCB3
Subject: Basin Plan Update/Amendment and Onsite Treatment systems Management
From: Al Barrow Coalition for Low Income Housing and Citizens for Affordable and Safe Environment
Hello Staff:
Timing requirement of 48 is not realistic or reasonable. For several reasons:
Scheduling a site inspection by repair or pumpers often takes days.
If it is determined a replacement is necesary permit applications may take weeks
WASTEWATER MANAGEMENT PLAN FOR THE SAN LORENZO RIVER WATERSHED: County of Santa Cruz Health Service Agency is included by reference.Environmental Health Service February 1995 249 pages was an example of the testing, research and work task that was done for one area of the county. The tack was expensive and time consuming. Certainly rising to the impact level of an EIR CEQA.:
Letter from Barry Tolle, enclosed with Al’s letter:
What remains so puzzling, given some of the problems outlined by Mr. Tolle’s letter, is that, so far as I know, the county never notified onsite permit holders throughout the county that this stealth update was underway, didn’t hold any hearings, send out postcards, have a BOS agendized meeting on it, zip. Neither did the RWQCB, even though all septic tank owners ARE the stakeholders here. Or should I say Clueless stakeholders?
Sorrell Marks April 7, 2008
Sanitary Engineering Associate
Central Coast Waterboards
895 Aerovista Place Suite 101
San Luis Obispo, Ca. 93401-7906
RE: Comments on Basin Plan Revision
Ms. Marks:
Thank you for the opportunity to make comments on the latest draft of the Basin Plan. San Luis Obispo County has several serious concerns regarding the proposed plan. Many of the requirements require a large financial burden on the part of the County and property owners for conformance.
1. Section VIII.D1b. ONSITE WASTEWATER MANAGEMENT PLANS (pg 6)
Water Quality monitoring program
Water quality monitoring is going to be a big issue with our county. If our department has to take and test water samples it will be incredibly expensive and time consuming. The most streamline method for us to handle this issue will be to allow the home owner to take their own water samples. Unfortunately, this could lead to improper testing techniques and faulty samples.
Septage Management
This program will be very difficult to promote without a funding mechanism available or a program is figured in advance as part of the build-out of a sewer facility. If the RWQCB staff is intending to regulate this program away from sewer facilities it will make the process even harder. Septage management programs will require a lot of money and a reduction of environmental standards to allow the use of the by-product as fertilizer. If the by-product can not be used as fertilizer then land will have to be condemned for storage of the product. These storage facilities are never a friendly neighbor and are subject to numerous complaints. Without funding available no one will be willing to pursue such a project.
Program administration, staffing, records keeping etc.
This part of the program will be hard to accomplish immediately as all government agencies are having financial difficulties due to the economy and the State budget. San Luis Obispo County will need a minimum of four additional employees to follow-up on data, track records, issue inspection notices and complete inspections. (This is based on 20,000 systems or 5,000 systems per year. Each system will require one hour of data input, follow-up, and time to issue letters/reports. We will also need a technician to follow-up on mandatory repair inspections and spot check advanced treatment systems at a minimum of 2 hours per inspection).
2. Section VIII.D.2.a. Site Suitability (pg. 8 number 13, and number 21 on pg. 10)
Prohibitions
This section limits buildings to one house per acre. This will limit the number of lots allowed to be built in rural areas and seems to remove the term “favorable conditions” for building on ½ acre lots. This regulation seems a bit stringent and not based on any specific data that docuements problem with groundwater in areas where ½ acre lots have been allowed.
3. VIII.D.2.e ONSITE SYSTEM MAINTENANCE (pg 11 number 4)
Requirements
This regulation will require mandatory inspection and pumping every five years minimum. If county has 20,000 systems then we will have to issue 5,000 septic inspection / pumping letters a year. In order to keep up with the data, send out the notifications and follow-up, the county we will need additional employees. This is going to be difficult to fund with the current economy.
In summary if the proposed Basin Plan is approved as is, it will substantially increase the County’s operating costs and add to the cost of housing. Although it is very important to protect ground and surface waters of the State, it is equally important to provide reasonable regulations to maintain that end. This propsedBasin Plan asks for a substantial amount of protection yet does not offer any economic reward. It is important to balance protection with economic feasibility.
Section 13241 of the Porter Cologne Water Quality Control Act states:
Each regional board shall establish such water quality objectives in water quality control plans as in its judgment will ensure the reasonable protection of beneficial uses and the prevention of nuisance; however, it is recognized that it may be possible for the quality of the water to be changed to some degree without unreasonably affecting beneficial uses. Factors to be considered by a regional board in establishing water quality objectives shall include, but not be necessarily limited to, all of the following:
(d) Economic considerations.
(e) The need for developing housing within the region.
Thank you again for the opportunity to comment on the proposed draft.
Barry Tolle, REHS
County of San Luis Obispo Planning & Building Dept
(805) 781-5629
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40 comments:
Ann,
Your choice to use the word "stealth" suggests you believe the RWQCB or their staff is trying to pull a fast one.
What is interesting to me is that this issue is about as well publicized as any other issue discussed by the RWQCB, SWRCB, CCC, SLOCOBOS or LOCSD.
What is truly stealth in this whole Los Osos saga is some of the actions of the LOCSD board after the recall and before Joe's election. For example, the LOCSD's mis-spending of the revenues meant for paying a bond. For example, the choice to settle with CASE/CCLO/BWS/Biggs even though the LOCSD had already won the case.
Rhetoric is powerful and can often define the debate. Your choice to use the word stealth seems to be based on the fact you don't like the proposed changes and little else.
shark said > Your choice to use the word "stealth" suggests you believe the RWQCB or their staff is trying to pull a fast one..... / ..... Rhetoric is powerful and can often define the debate. Your choice to use the word stealth seems to be based on the fact you don't like the proposed changes and little else.
Uh, yeah. And what's your point? Ann is a particularly effective wordsmith. Meaning she uses words to good effect. I often read in wonder how she crafts a phrase or spins a line. Long after we're flushing without a thought or a care I'm still coming back just to enjoy her craft. I'm guessing you will too - LOCSD history aside ;-)
The RWQCB or their staff pulling a fast one? Sacre' bleu, say it ain't so.
Shark also said > What is interesting to me is that this issue is about as well publicized as any other issue discussed by the RWQCB, SWRCB, CCC, SLOCOBOS or LOCSD.
That, dear Shark, is exactly the point isn't it? Administrative acronyms setting policy with little (read: no) public input. The fact that this has become their normal modus operandi only begs the issue. How much are these acronyms administrative in function? And how much are they policy generators? If they are policy setters what is the process of their policy setting? Setting policy using administrative functions is a form of stealth. I like it. Kinda hits the issue dead on.
Plus, once again, Ann is a columnist. Not a reporter. She's supposed to use words to create interest (read also: spin). I don't think she's ever denied that. Granted, we all like to think of ourselves and our views as more objective - and less subjective - than those perspectives that run counter to our's. Fact is, its all spin depending only on where you stand.
Hi PG13,
Ann may use whatever words she wishes....but it does not mean that she (or you) are correct in your 'spin' that the RWQCB Basin Plan Update is 'stealth', 'illegal', 'lacking public input' or a 'power grab'.
In fact, the RWQCB is legislatively required and empowered by the people of California to perform a variety of tasks (such as the Basin Plan Update) to ensure that the State's waters are safe for consumption and protected from pollution. It is entirely a public health and safety issue.
For example, the RWQCB is turning the need for a County-wide SSMP by the County of SLO from a 'should' to a 'requirement'. I find is puzzling that the many folks that have for years vigorously criticized the RWQCB for not forcing the County to produce a countywide SSMP now criticize the RWQCB for now 'requiring' that the SSMP now be performed.
Another issue...the issue of natural versus manmade waterways and wetlands has been litigated in State and Federal Courts for over two decades. The Courts have ruled very clearly that manmade waterways and wetlands are subject to the same need for protection as natural waterways and wet lands; and that the public does not have any fundamental 'right' that these projects cost(s) be structured such that everyone can afford to pay them.
If Ann and you wish to make a real impact, you would be best to petition our decision makers to insist that the Federal Government return to the business of funding public sewer and water projects. (Not just roads and bridges). Since 1986, these sorts of projects were dropped from Federal funding; which is in my opinion a HUGE mistake. Why?....simply because such public works improve everyone’s standard of living; hence the costs should be borne by all.
As a side, the public's opposition to many of the current crop of public works projects stem directly to their cost; and the fact that these costs are borne by too small of a taxpayer base.
The core problem is not that the regulators are enforcing environmental laws to protect public health and safety;
The core problem is lack of sufficient funding from ALL taxpayers.
Regards, Richard LeGros
Richard:
The germ/seed of the problem is that government has not been held accountable by the citizens.
The core team of AES DES LLC continues its work to do that which is not being done, by law.
Congress stopped the grant funding for leaky polluting collection systems and failure prone publically owned treatment works for good reasons.
Richard, it is stupid, costly, senseless and now needless to "sewer". Your comment that there just isn't enough taxpayer money to pay for it, speaks volumes.
Those good citizens who voted to recall you acted properly. When you resisted their will be delaying the vote, you did not.
mark say, "Congress stopped the grant funding for leaky polluting collection systems and failure prone publically owned treatment works for good reasons."
Right mark, so we could all buy Wrecklamators, is that it?
Why are you having so little (any, even?) success after 10+ years of attempting to Wrecklamate the country? (Of course if you have had successes, you have oddly refused to tell us about them.)
PS - mark, you don't obviously "get" what the recall has cost us. Also, delaying the vote is what caused the recall to succeed, as is clear now in hindsight. And even at that, it only won by a thread.
Thanks Richard for your always thoughtful and polite replies!
During the Reagan years, the student loan amounts went down considerably too, as I recall.
I'm always amazed where the "no sewer" folks pop up again - their "we need a septic management plan" attempt to stop a sewer is now coming to pass with some teeth in it, and those same people are now screaming bloody murder. The plan as the draft indicates is a draft. It does have some problem spots but what draft plan doesn't? To quote the always polite Shark, "Sheesh!"
Toons:
Listen to Richard, he sounds right.
Build that leaky collection system and force hook up from our customers.
One question, how will you "pay" for the resource of value?
You might want to get Richard to help you with that.
We are aware of the law Richard is referring to regarding federal grant funding for POTWs.
The RECLAMATOR is an "other than publically owned treatment works".
Policy and law are very different, to be sure.
How is everyone's study of "C26" and Porter-Cologne coming along?
Toons:
Don't forget the massive college tuition increases of "these" Bush years.
Richard, as always thanks for your considered response. Leaving the past behind and looking only at our present situation and the actionable future we tend to be in greater agreement than ever before. Still, we tend to look at the same thing and see it somewhat differently.
> In fact, the RWQCB is legislatively required and empowered by the people of California to perform a variety of tasks (such as the Basin Plan Update) to ensure that the State's waters are safe for consumption and protected from pollution. It is entirely a public health and safety issue.
Couldn't agree with you more. I totally support the RWQCB in fulfilling their mandate. More power to them. Ooops, I better be more circumspect with my words. I think they have plenty of power already. They just need to use it more carefully. As so often discussed here in this blog, it is hard to imagine how much time has passed (30+ years); how much energy (and money) has been spent; how many votes have been tallied; and how much angst laden legislation, litigation and promulgation (to borrow ShedHead's most favorite word) has passed with so little progress (read: no real on-the-ground effect). As Ann has so often noted there has been absolutely no minimization of pollution or salt water intrusion despite all the drama/head banging/writs/CDO's/threats of fines/whatever. I mean, this much time and this much energy expended should have produced some real effect by now. And who's fault is that? There's plenty of fickle finger to go around but ultimately where does the buck finally and actually stop? As you say, the RWQCB is legislatively required and empowered by the people of California to perform a variety of tasks (such as the Basin Plan Update) to ensure that the State's waters are safe for consumption and protected from pollution.
It's not that the RWQCB is finally turning a should into a requirement and 'requiring' that the SSMP now be performed. Hooray for them! Its just how they're doing it. What about a Basin Plan is so confusing? Ergo, Basin + Planning = watershed intelligence. Haven't seen much of that in a long, long time. They haven't proven they understand even that and now they want to claim righteous dominion over every septic in the county? Isn't this where we came in? This, this and that septic in Los Osos is causing all the pollution. Few facts, even less data - but we've got hugely expensive solutions to address a small percentage of the problem. (sigh)
> If Ann and you wish to make a real impact, you would be best to petition our decision makers to insist that the Federal Government return to the business of funding public sewer and water projects. (Not just roads and bridges).....
Again, I couldn't agree with you more. With just a minor variation. There's a time and place for big public sewers. But just because something has been done a certain way for 100+ years - that in itself is grounds for reconsideration - doesn't mean it is something we should continue for another 100 years. Time and place, specific situations, are sometimes best served with unique solutions. What's good for Chicago might not be best for Los Osos. Duh!
> The core problem is not that the regulators are enforcing environmental laws to protect public health and safety; The core problem is lack of sufficient funding from ALL taxpayers.
Again, we are in heated agreement. With a minor variation. Government needs to process with intelligence. Haven't seen much of that recently either. So when dumb decision making gets called out why are you protecting it?
Regards, *PG-13.
Ooops, sorry. I missed a point:
> Ann may use whatever words she wishes....but it does not mean that she (or you) are correct in your 'spin' that the RWQCB Basin Plan Update is 'stealth', 'illegal', 'lacking public input' or a 'power grab'.
How you jumped from 'stealth' to 'illegal' or even 'power grab' is mystifying. I don't believe anybody said they were acting illegally. Nor did anybody say they were grabbing power although I can see how you interpreted that. It is the RWQCB's responsibility and they should be addressing the issues. I do believe there has been minimal public input. So far. How can you suggest that the public has been given a full and fair opportunity for such wide sweeping policy with so much impact on so many given so little opportunity to get involved?
Sewertoons notes > The plan as the draft indicates is a draft.
Cool. I can accept that. Put something up on the board and then give everybody a chance to get involved. If I had any confidence that that was the way it would play I wouldn't have any problem with the process. But I don't have such confidence. And there has been precious little in recent process history to indicate that that is the way it is going to play. Yeah, I've got a short fuse. Sue me ;-) (No, no, please, that's a joke!)
mark, why do you think the RWQCB is going to give your Wrecklamator a pass on 6 months of data - or even a year - when they required that the former ponding solution have 10 years of data (which it did not)?
What's a "Wrecklamator"?
"watershed intelligence" SWEET 13! Why do the citizens get a pass?
mark, heard of CDO's and NOV's?
The problem here, Mark, is that you don't have evidence of your system working longterm ... but the RWQCB required longterm proof of the denitrification benefits of a ponding system before they would approve of one.
Presumably, the LOCSD could have picked or the County could pick a system which doesn't have the appropriate proof behind it ... however, the LOCSD or the County would not do so because it would not allow for a low interest SRF loan. The RWQCB could also fine us for no progress toward reduced nitrates.
So ... what sort of deal with the RWQCB do you have worked out ... how often will each reclamator be tested for the content of its output?
Don't forget the pending CAO's...
Shark wrote: but the RWQCB required longterm proof of the denitrification benefits of a ponding system before they would approve of one.
Shark, got link, report number/date page paragraph, any ink at all?
When it comes to loans, please read "Just the Facts" posted on www.NOwastewater.blogspot.com
Federally supplied SRF money will be sensitive regarding "pretreatment" requirements as specified in C26.
Once again, Inlet, you missed the key point. (also, how you jumped from "stealth" to "illegal" is beyond me. Question: How many septic tanks are out there in this county? How many of those septic tank owners got so much as a post card telling them about this update and where they could read the proposed changes and requirements and post comments etc? I didn't see so much as a peep in the Tribune. How many people in Los Osos living outside the PZ got a card? Notice? This community is really tuned into all things septic and I'd challenge you to find the average man in the street who knows anything about this. Stealth is stealth. The real question is WHY? If ou read some of the comments on the draft posted here you'd see some good suggestions that would IMPROVE the updates. Why not invite MORE IMPROVEMENTS? Or MORE CORRECTION and PROBLEMS POINTED OUT NOW WHEN YOU CAN EASILY FIX THEM. Unless your intention is to stealth these changes by until they get voted into law and then when real problems show up, oh, well, it's too late. Think about what would have happend here if MORE people got involved EARLY ON with our own LOPZ, not to mention the proposed sewers.
There are at least 25,000 septic tanks in SLO County.
1,000 septic tank waste discharge permits were handed out in 2007.
There are approximately 1,400,000 septic tanks in California.
http://www.nesc.wvu.edu/nodp/nodp_reports.htm The information on this site is many years old and should be used for estimate puroposes only.
I would like to see gubment doing more to keep the info fresh. But hey I am in business to maske a profit because I do not have the abilty to raise prices/taxes to pay for bad business decisions and poor behaviour.
As a citizen I say: quit handing our waste discharge permits that will later become the sbject of enforcement activity.
Technology makes that possible.
Ann,
Think of the notification issue this way;
When a Governmental Decision-Making Body (aka GDMB) passes new rule which, let's say......requires that homeowners paint their homes green (for environmental safety and health reasons)....does the GDMB have to send a postcard to each citizen affected telling them of the new rule?
No, they do not. The only posting requirement is to post the GDMB's intent in a legally proscribed manner.
Same with the RWQCB.....posting was done in the legally proscribed manner.
After having posted their intent, the RWQCB is receiving agency and public comments regarding the DRAFT Basin Plan Update.....and will later post when they are reviewing the FINAL Basin Plan Update; at which time they will receive additonal comment prior to the Basin Plan being approved. The legal protocol will have been followed.
So if you do not like the posting / notification process, take the issue up with the State Legislature as they made the rules to begin with.
In the meanwhile, nobody other then you and a few other folks are upset about the Basin Plan Update. Why? Because the RWQCB is following the rules of protocol AND is performing as they are legally REQUIRED and EMPOWERED to do in order to protect States water. This is strictly a public health and safety issue. None of your 'rights' are being violated or cutailed.
So again, if you do not like the legal reqirements or powers vested in the RWQCB, take ithe issue up with the State Legislature. That is what process is all about.....you change legalities via the Legislature. If you do not like the laws the Legislature makes, replace them with those individuals who will make laws you agree with.
Regards, Richard LeGros
No wonder Richard was removed from office.
Ann,
Perhaps you are confused. I did not write "illegal" at all. With that careful attention to detail you show in your read of my comment ... I wonder whether it is worth replying to you at all. Well, because others do seem to read carefully, I'll continue.
You suggest that the RWQCB should have sent us all postcards informing us of changes which are rather technical. Fair 'nuff. Why didn't you complain at least this much when the LOCSD chose to, without notifying the public at all (let alone in advance), spend money slated for bond re-payment (and only for this purpose) on a whole host of other things, including paying Ripley and BWS?
If stealth is stealth, why do you only rail against it sometimes?
If you want to chastise the Trib for not reporting on this, fine. The fourth estate should bear responsibility. Perhaps there should be a web-based "newspaper" somewhat akin to the Federal Register for SLO County and all government business related to any community in SLO would need to appear there.
Mark, the reason Richard was recalled from office was that a few folks who misunderstand the process were upset by the outcome of the process and they believed that they could just make things magically better by ignoring the laws which they also seemed to completely misunderstand.
Ann seems to be voicing concerns with the update on behalf of CSD's and developers. Those are the groups/people who will need to have some points clarified. The rest of us schlubs on septics shouldn't have to worry as long as our septics/leachfields are working and well maintained.
But then, there are those who just don't like to have to comply with anything and sure don't want some official entity poking around their yards to see if things are working properly.
Richard, mark has just recently jumped on the "recall" bandwagon and has no idea what he is talking about. He doesn't realize that that bandwagon was abandoned long ago by those who were only onboard because they were duped by the inflamatory rhetoric. All that's left on that one are the nut-jobs.
Richard, listen to Toons, she sounds right.
How will the "sewer schlubs" pay for the resource of value and the leaky/polluting sewerage?
Don't forget to factor in the "Facts" and "Pretreatment" into the financing equation...:-)
Welcome to the world of "NOwastewater"...:)
That's all Folks!
Richard wrote: Because the RWQCB is following the rules of protocol AND is performing as they are legally REQUIRED and EMPOWERED to do in order to protect States water. This is strictly a public health and safety issue. None of your 'rights' are being violated or cutailed.
What color is the sky in your world?
mark, your Wrecklamator isn't getting within 100 ft of my septic tank. NO ONE has yet proved it works over a period of years, least of all YOU. In cleaning up our water we do not have the obligation to use untested equipment.
PS - You have aligned yourself with the wrong groups mark. They are out of juice and out-voted.
Mark's being a dick because he has nothing else to offer this discussion.
He's tried to tell us what the law says ... but he didn't provide any legal references to justify his comment.
He's tried to tell us that his device will work forever and will never need any monitoring ... but he won't provide any data to justify that claim either.
He's told us that the RWQCB will (by Fall 2008) approve his device. Well, I'm not going to petition the County to wait until the RWQCB takes action. Once they do, the County should pay attention.
Until then, Mark should be assumed to be Al Barrow ... with a device ... full of bluster to be sure but with no certain way of solving our nitrate problem.
If Mark wants to be a player, he should do more than offer us rhetoric and threats ... he should either do something (by convincing the RWQCB and/or County) or he should provide evidence that justifies his bold claims.
You are right, Shark. And one would think since he'd had this Wrecklamator for over 10 years he'd have some data by now - well, maybe he does, but it isn't any good so he is not showing us. He only has page 52 to offer up.
Toons:
Every septic tank is under the gun including yours.
You are free to stick with the county's consulting engineer's study of leaky polluting sewerage and failure prone treatment facilities.
Be careful what you wish for, we want a customer for the resource of value.
What groups are you referring to Toons?
Shark:
Why the need to use "bad words"?
Quoting law is not interpretation of the law.
"The law is reason, free from passion."
Your reading comprehension is on the line here, Shark: He's told us that the RWQCB will (by Fall 2008) approve his device.
You'll need to cut and paste my words which support your statement, if you want my continued respect. Take your time...
Al Barrow has more institutional knowledge and a better understanding of "process" than anyone in Los Osos who I have had the pleasure to meet. Al is to be considered a Patriot. I an honored and appreciate your comparing me with Al Barrow on these "qualities". Attempting to smear him from "the closet" speaks volumes about you, it is cowardly.
The one big difference between Al and myself is that I am representing AES DES LLC an entity that actually has the technology and business plan to solve the septic tank discharges.
There are several other differences which are irrelevant for the purposes of this discussion.
The LOSTDEP RECLAMATOR Solution solves the nutrient loading problem and will conserve money, energy and time while it conserves water without a leaky, polluting sewer and failure prone treatment facility with a huge carbon footprint.
Again, once you can talk with someone you respect about process design and biological processs you should be in a better position to handle the discussion in a more appropriate manner.
BTW-The RWQCB has already taken action in the form of CDO's and NOV's didn't you get one?
Once the CAO's are issued you should be even more interested in the RECLAMATOR service as no other will provide elimination and remediation for $15,000.00 and $45.75 a month.
Mark,
At this point I don't care if you respect me or not and I don't want to bother digging up a quote from you where you told us to expect some sort of announcement by Fall. Clearly you don't bother justifying your claims (for example, that a Nitrogen level of 7 or less is not a discharge but that more than 7 is) so why should I?
As to your other claims ... that your company has technology and a business plan to solve our problem. Funny that you yet again make this claim but yet again refuse to justify either part of your statement.
I will refuse a medical treatment unless there is evidence that (on the balance) it is safe and effective. The scientific method is the way by which we judge both the safety and efficacy of various possible treatments. Why have you not bothered to test your device over the long term to assess it's long term benefits? (Or, if you have, why aren't you showing us the data?)
Shark:
Why the need to use "bad words"?
Quoting law is not interpretation of the law.
"The law is reason, free from passion."
mark, does common sense tell you to invest in something unproven? You have proven NOTHING to us yet, except that YOU believe in the Wrecklamator and can offer us famous quotes. Ring a ding. I have a Bartlett's, too.
Sewertoons sez:"Ann seems to be voicing concerns with the update on behalf of CSD's and developers. Those are the groups/people who will need to have some points clarified. The rest of us schlubs on septics shouldn't have to worry as long as our septics/leachfields are working and well maintained."
Wrong. An update that deals with onsite systems and watersheds will affect EVERY schlub. That's why I want, at the very least, postcards to go out to all onsite schlubs in the county, so they can read the proposed updates, get more information, and consider how it might affect them and offer public comment as to how it can be made better or have people point out EARLY IN THE PROCESS, where trouble spots lie ahead & etc. Groundwater laws are being updated and rewritten as we learn more and more. Good Old regular septic tanks ain't gonna cut it any more, so schlubs need to be prepared for what's coming. (And, remember, he who defines the terms, makes the rules, even if they're looney -- doesn't matter, if I SAY something is something, and I'm a Regulator, then it is, even if it isn't.)
I'm happy to see that I am not the only one subject to being mis-interpreted...
Regulate the Regulators...
RECLAMATE the Regulators
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