FREQUENTLY ASKED QUESTIONS. New Subsurface Sewage Treatment System (SSTS) Ordinance

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1 FREQUENTLY ASKED QUESTIONS New Subsurface Sewage Treatment System (SSTS) Ordinance General SSTS and Ordinance Questions: 1. How do SSTS treat wastewater? The best website to review SSTS system components and information is on the Minnesota Pollution Control Agency website. The address is The purpose of the design and construction of a sub-surface sewage treatment system consistent with the new standards is to treat wastewater, not just dispose of it. Wastewater consists of a variety of pollutants that, if left untreated, will pollute surface and/or groundwater. Through mechanical systems and biological activity within the system and in the soil dispersal area, the wastewater is treated to a level that reduces the impact of the wastewater entering the SSTS. Wastewater is treated in the septic tank, dispersal system/distribution media and in the soil. Pretreatment systems also provide advanced treatment reducing pollutant loads prior to reaching soil treatment. 2. Why is the county preparing to adopt a new ordinance? The Minnesota Pollution Control Agency (MPCA) adopted new rules for SSTS beginning in 2006 that require counties and other Local Governmental Units (townships and cities) to adopt ordinances in compliance with the new rules. Olmsted County s ordinance was adopted in 1985 and therefore is not compliant with the new rules. The current county ordinance does not reflect current technology and science in the siting, design, products, training, and maintenance of SSTS. The citation for the new state rules is Minnesota Rules (MR) and can be found at the website listed in question #1. 3. What do state rules require of Local Governmental Units (LGU)? MR , Subp. 2: All counties must adopt and implement SSTS ordinances in compliance with chapter 7080 and 7081 that also comply with this chapter. Ordinances must apply to all land area within the county, except in towns and cities that have adopted ordinances that are in conformance with the county ordinance and this chapter. MN Rules , Subp. 3: Cities and townships with SSTS ordinances must effectively administer and enforce an ordinance that conforms with this chapter and is administratively and technically as strict as the county ordinance, as determined by the agency. ( Agency is MPCA) MN Rules , Subp. 4: All LGU s that administer programs must have 1) adequate personnel (certified inspector) and 2) an enforceable ordinance. 1 P age

2 4. When will the ordinance go into effect? The Olmsted County Board has requested that staff hold two open houses in October. The County Board will likely schedule discussion and a hearing in November. Once the hearing is completed the County Board will vote to adopt a new ordinance. 5. Who is affected by the ordinance? Any property located within Olmsted County would be affected by the ordinance if the primary means of wastewater treatment is by use of a SSTS. This includes lands within city limits and townships. Property split by the county line will be covered by the Olmsted County ordinance or the adjacent county ordinance. All of the surrounding counties have adopted or are in the process of adopting an SSTS ordinance that is compliant with the new state rules. 6. Why do we have an ordinance and what does it do for me? The proper location, design, installation, use, and maintenance of a SSTS leads to the protection of general public health, property values, the health and safety of owners and neighbors, and the protection of groundwater and surface water resources in the county. 7. What do the state rules require the ordinance to include? The Association of Minnesota Counties developed a model ordinance to assist counties and other jurisdictions in developing a local ordinance that complies with Minnesota Rules Refer to Minnesota Rules for details (see website address in Question #1). The requirements are listed on the attached MPCA Checklist. 8. What is the approximate cost difference between an in-ground system and a mound? This is a difficult question to answer given the many variables that come with the proposed or existing use, sewage flow, site features including parcel size/dimensions, soil types, depth to limiting features, topography, well location, etc. However, generalized numbers that have been reported may be considered approximate costs that are dependent on a number of variables. In ground SSTS base price (3-4 bedroom): $8,000 - $9,000 Pressurized system components add: $1,500 - $2,500 Mound systems (3-4 bedroom): $11,500 $16,000 Design and permit fees are separate Assuming a $15,000 cost for a new or replacement SSTS (mound) and a 25 year life for the system the annual cost is $640 or $53.33/month. Pumping the tank on an average of once every three years may add an additional $200/3 years. Pumping over the life span of the system may add approximately $1800 or about $72/year or $6/month. 9. What regulations will make me replace all or portions of my SSTS? The state rules and the proposed county ordinance identify several situations that would require system upgrade/repair/replacement including: A non-compliant system based on the compliance inspection. The compliance inspection may indicate Failing to Protect Groundwater or Imminent Threat to Public Health and Safety noted below; An Imminent Threat to Public Health or Safety ( Ch. 3402, Definitions), for example surfacing of wastewater; 2 P age

3 Failing to protect groundwater (MR , Subp. 4(B), such as a cesspool or lack of tank integrity, or non-compliant vertical separation; Existing SSTS that are not designed to handle the flows of a proposed use, such as the addition of a bedroom or changing uses from residential to a residence with a home office and employees, or restaurant. 10. How will the ordinance affect me if I am not making changes to my property and not selling it? If the SSTS is functioning adequately, such that there is no backup into a building or surfacing of wastewater, the ordinance does not make further demands, other than the property owner must have the system inspected and possibly pumped on a three year basis. If a compliance inspection is completed for some reason and the system is found noncompliant the state rules and proposed ordinance require that the system be brought into compliance. 3 P age

4 Questions about Specific Standards: 1. Why are some of our regulations stricter than the state requirements? The MPCA rules are minimum standards for proper SSTS design, installation, site review, and maintenance. The Association of Minnesota Counties model ordinance provided a number of recommended additions to the state rules that improve the overall program. The additional standards will lead to more effective protection of public health, safety, groundwater and surface water. A number of area counties have adopted the model ordinance. Some elements of the existing 1985 county ordinance have been included in the proposed ordinance. Olmsted County is located in a sensitive hydrogeologic setting, commonly referred to as karst geology, making it highly sensitive to groundwater pollution. Poorly designed, installed, or operated/maintained SSTS can be a source of groundwater pollution. The Upper Aquifer (Galena formation and others) is polluted and can no longer be used as a potable water source and deeper wells in some areas are showing signs of pollution also. It is critical to protect groundwater since it is the sole source of drinking water for the citizens and businesses of Olmsted County. The intent with this ordinance is to provide a reasonable level of protection from SSTS wastewater pollutants along with meeting the minimum requirements of the state rules. 2. Why do we have a four foot vertical separation in our ordinance and why are we still recommending it? Olmsted County has required a four foot vertical separation and a minimum lot size since the 1970 s to reduce the risk and strength of pollutants entering the groundwater system. Given previous and current ordinances, the added information from the Geologic Atlas on geology, hydrogeology, sensitivity of the groundwater system, and additional data on groundwater pollution, the staff determined that the vertical separation would be based on the 1985 and previous public health regulations. It was not considered an issue during the early development of the proposed ordinance. The state rules indicate that the minimum acceptable vertical separation is three feet. The focus of the staff in making the recommendation has been to continue the additional groundwater protection and risk reduction. This is based on groundwater sensitivity to pollution, the variability of site data on depth to bedrock within proposed drainfields and the additional treatment capacity especially prior to the formation of the biomat below the drainfield. The Environmental Commission identified additional concerns related to contaminants of emerging concern that has been reviewed in the scientific literature on water resources. The Environmental Commission has recommended a combination of 3 and 4 vertical separation 3 above the confining layer of saturated soils and 4 above first encountered bedrock. 3. Why do we disallow the 15% reduction in vertical separation that is mentioned in the rules. Minnesota rules allow a Local Governmental Unit to include a 15% reduction in the vertical separation applied to existing systems. LGU s have the option to adopt the provision and under what circumstances. To be clear, the proposed ordinance does specifically address this matter. MR , Subp. 4 (D) states that the 15% reduction applies to existing systems that were designed with at least a three foot 4 P age

5 vertical separation distance. Thus the 15% reduction is not a factor for a new or replacement system because the vertical separation is known prior to the system design due to the licensed designer and licensed inspector verifying the separation distance. The county recognizes that there have been improvements in soils science and training. Thus rather than utilize a 15% reduction with a 4 separation, the county has instead chosen to use a 3 separation and no reduction. Ch states that an existing system is compliant with either a two or three foot vertical separation for older systems. Given that the previous ordinances have required a 4 vertical separation, a 15% allowable reduction is less likely to be a factor in determining compliance. 4. If I am adding a bedroom to my existing house, and it passes a compliance inspection with 2 or 3 feet of separation, do I need to replace my drainfield because it does not meet the proposed ordinance s 4 foot separation requirement? This question is full of variables that one answer will not cover adequately. The sections of the proposed ordinance that appear to apply to this scenario include: Bedroom Additions; Amendments to the Adopted Standards ; Compliance Criteria for Existing SSTS; Construction Permit; 3409 Compliance Management. Olmsted County has required a four foot vertical separation since the 1970 s. If located within a shoreland or wellhead protection area (SWF) the vertical separation requirement in state law has been 3 feet even prior to State law says compliance is achieved if there is a 2 foot separation outside SWF areas for systems installed prior to April 1, Section incorporates those standards for existing systems. So there should be many systems that meet the vertical separation standard as noted above. A bedroom addition requires that the system be inspected for compliance (state rules Subp. 3(C) and proposed ordinance). A construction permit is required for the SSTS changes. The existing system will need to be able to handle the added hydraulic loading, and if it is an older system it is likely to need a new tank to handle the increased water use. In addition to a new tank, there will be a need to add on to the existing drainfield. Utilizing the existing drainfield would depend wholly on the site/system characteristics and existing SSTS vertical separation for the additional drainfield area. Other factors such as changes in soils conditions or better soils information generally or on site, covered under the new state rules, may require a new drainfield regardless of the vertical separation distance. 5. What happens if the house I live in is destroyed; can I use the existing SSTS on the property if the replacement house is the same size with the same number of bedrooms? There are a number of factors that affect the answer to the question. Zoning and well permitting matters must be determined along with the question on SSTS. The first step in making a determination for the use of the existing SSTS would be to obtain a copy of the existing SSTS permit and design. Where a building permit is required as would be the case for the house reconstruction, a compliance inspection is required based on 5 P age

6 If the inspection shows that it is compliant and is consistent with the permit the SSTS could be reconnected. If it is not compliant, the SSTS would have to be brought into compliance with the current requirements of the ordinance. Again what elements of the system that must be repaired or replaced is dependent on what is found during the compliance inspection. 6 P age

7 Questions about Permits/Applications: 1. Who does compliance inspections and who does design of systems? A private sector appropriately licensed business must be hired to gather information on the proposed construction site and do the design of the SSTS. Compliance inspections for new or replacement SSTS, or repairs needing a construction permit are inspected by the Local Governmental Unit (LGU) licensed inspector. An inspection is done prior to construction to verify soils information and then during construction to verify that the SSTS is constructed as designed. Compliance inspections for existing systems are done by appropriately licensed businesses with the compliance certificate being reported to the owner and the LGU. LGU s are required to retain permits and all related information submitted for the permit, including compliance inspections. 2. What types of permits are required and when are they required? Section states that a construction permit is required for new or replacement SSTS, repairs that alter the function of the system, tank replacement or reconstruction of a soil disposal area. Operating permits apply only to certain types of systems - holding tanks, MSTS (mid-sized systems), and Type IV and V systems which include pretreatment elements to the SSTS. The operating permit covers such matters as monitoring and disposal contracts and how the SSTS will be maintained. Abandonment certificates are also a part of the chapter on SSTS permits in the proposed ordinance. 3. The question is one about adding to an existing mound system built in The current vertical separation is not 48 as constructed but 44. Does an existing system have to be completely replaced if I plan to add a fourth bedroom to the house? There are a number of variables in the question that make it difficult to provide a simple answer. However, what is critical to know is if the system was designed for four bedrooms except for the size of the mound. The first step is to review the permit and design. If so the system can be expanded. A compliance inspection is required unless one has been completed in the last three years. If the drainfield was not designed for four bedrooms than the rules require the drainfield to be replaced. It is possible to salvage parts of the mound but that is a decision for the designer, contractor and inspector to make based on what is seen at the site. Section states that for existing systems there must be a three foot separation. 4. A system was found to be noncompliant. The vertical separation is 42 inches to course gravel and an obstruction at 48 inches. My neighbor had an inspection and groundwater was found at 42 inches and course gravel at 72 inches. My system requires a mound and the neighbor is a pressurized trench. Why does the proposed ordinance treat the sites differently for system design? This is a question with many variables that makes it difficult to answer simply. The state rules indicate that course gravel is not given credit for wastewater treatment so the measurement used for design would be 42 inches. An obstruction can be a rock shard in the gravel bed or bedrock and would need to be further investigated, which most designers will do. Assuming it is bedrock a mound system would be required. The neighbor has a site with groundwater at 42 inches and bedrock deeper than 4 feet so the vertical separation standard in the proposed ordinance to apply is to 7 P age

8 groundwater. The neighbor would need to build a pressurized system with fill above the drainfield. The recommendation of the Environmental Commission was to require adequate treatment. The mound will provide additional treatment capacity while the pressurized system distributes the wastewater more evenly across the in place soils profile reducing the potential for mounding of groundwater below the drainfield 8 P age

9 Questions about Management and Compliance: 1. What if my system was installed prior to 1996? Will I have to replace my SSTS? These dates are related to state law and rule and proposed county ordinance Chapter 3409 Compliance Management. An existing SSTS that is not involved in a change to its use or expansion (such as a bedroom addition) and is functioning properly can continue to be used by the property owner. 2. What is a management plan and when is one required? Management plans are required for all new or replacement SSTS. It is a new requirement of state rules and as a result appears in the proposed county ordinance. The management plan covers operations and maintenance of the SSTS. SSTS that do not have a management plan must have tanks inspected and solids removed, if needed, every three years. Chapter 3408 of the ordinance lists the contents of a management plan. 3. What is a compliance inspection and certificate; when do I need one? A compliance inspection for existing systems is carried out by a private appropriately licensed business. As noted by the MPCA it is an evaluation, investigation, inspection conducted for the purpose of issuing a Certificate of Compliance or Notice of Non- Compliance. The Certificate of Compliance certifies that the SSTS complies with state requirements, and also local ordinance requirements if chosen by the county. A Notice of Non-compliance is a notice that a system does not meet the state requirements. There are two types of non-compliance, Failing to Protect Groundwater or Imminent Threat to Public Health and Safety, both described in other answers. Compliance inspections are required for, New and replacement SSTS during construction; Repair, modification, or upgrade of an existing system; Expansion of a building such as the addition of a bedroom; Change of use of a property that impacts SSTS performance; Any time the County deems it appropriate based on a verified SSTS compliant/malfunction; Transfer of property and metes and bounds involving existing systems. 4. Why require compliance inspections for land transfers or metes and bounds? Minnesota Statutes , Subd. 6 requires disclosure in writing by the owner on how sewage is managed. If managed on site additional information about the SSTS is required. Realtors, lenders, and buyers are provided this information even before compliance inspections are identified as a need or requirement. The new state rules require that compliance inspections be a part of any ordinance adopted. Many realtors and lenders are already requiring compliance inspections for properties to avoid future problems. Many counties, including surrounding counties that have already adopted new ordinances include compliance inspections for land transfer. A land transfer which in many cases includes a metes and bounds subdivision is an appropriate time to address the determination that a SSTS is functioning properly. 9 P age

10 Metes and bounds that involve existing buildings and SSTS in most cases are part of a land transfer, so the applicant would be required to have a compliance inspection. Just as we review a metes and bounds for zoning standards, a review would be highly useful for SSTS standards. The purpose is to make sure that new parcels created are buildable and that existing parcels are still able to meet the standards of the ordinances. The county does not want to allow new parcel boundaries that create immediate non-conformities or create a situation that does not allow for future expansion or other changes that affect zoning, well, or SSTS requirements. This is protection for the current and future property owners. This requirement would not apply where there are no existing SSTS on parcels involved in a transfer or metes and bounds. 5. Do I have to have my system pumped every three years? Minnesota Rules state that the owner or an owners agent shall regularly assess sewage tanks and measure the accumulations of waste in the tanks in no case less frequently than every three years. The proposed ordinance reflects this provision in the rules. The result is that an inspection must be completed every three years, and if it is determined that the tank must be pumped either for the inspection or due to accumulation of waste material (based on the requirements of , Subp. 3) then the tank is pumped in addition to the inspection. In the final analysis, the intent of the state rules is to see to it that the SSTS components are maintained in compliance with the standards and the manufacturers requirements so that the SSTS functions to properly treat wastewater. Average costs for the inspection range from $200 to $225, and for the tank pumping, $200 to $ Why is proper tank maintenance necessary and who performs maintenance? Proper maintenance protects your investment in the SSTS. Proper maintenance reduces the risk of the SSTS malfunctioning, thus reducing the risk of potential health and property impacts but also environmental impacts. Repairs of SSTS due to lack of maintenance can be costly to the owner. Over the long term the owner(s) will benefit from proper maintenance of their SSTS thus ensuring the protection of their property from health or safety impacts and environmental impacts. Maintenance is performed by an appropriately licensed maintainer. The MPCA licenses the businesses. 7. What is SSTS failure as determined by a compliance inspection; why do I need to fix it and how does the ordinance affect me in fixing the SSTS? Failure as noted in question #3 on compliance inspections and in state rules consists of Failure to Protect Groundwater or an Imminent Threat to Public Health or Safety (ITPHS). ITPHS may be the backup of sewage into the building or release of sewage onto the ground surface or into surface waters. MR , Subp. 4(B) describes a failure to protect groundwater as: seepage pits, cesspools, drywells, leaching pits, or other pits; a system with less than the required vertical separation distance as specified in MR , Subp 4 (D and E); a SSTS not abandoned in accordance with MR Minnesota Rules require a time frame for upgrade, repair or replacement; that time frame is ten months. 10 P age

11 8. My SSTS is old and there is not a permit for it. What do I have to do and what are my options? If you have a functioning SSTS you do not need to do anything. A compliance inspection would be required for certain circumstances as noted in previous questions. Section of the proposed ordinance establishes minimum requirements for existing systems without permits. If there is no permit of record the requirement states that SSTS must be brought into compliance where: a SSTS is being upgraded; or repairs requiring a permit; or a SSTS is determined to be an Imminent Threat to Public Health or a Failure to Protect Groundwater; or, a SSTS is not compliant with the minimum setback requirements to an existing well. 9. I have a SSTS that was built in 1980/1997 and am located outside of a shoreland area. What does the ordinance require for the system to be considered compliant? Compliance inspections require the use of a MPCA form that determines the minimum items that must be inspected. The MPCA required compliance inspection form includes several sections. Necessary or locally required attachments such as boring logs; Determination of impact on public health; Tank integrity; Other conditions such as manhole cover integrity; Soil separation; Operating permit and nitrogen BMP if it applies. Outside of a shoreland, the minimum vertical separation requirement for a SSTS built before April 1, 1996 is two feet as required by state law, and after that date it is three feet. The tank must meet standards related to leakage and failure to protect groundwater, and the system must not be an Imminent Threat to Public Health and Safety. 10. Under what conditions is an operating permit required? Operating permits are required for four specific SSTS designs including holding tanks, mid-sized SSTS, Type IV and V systems which have pretreatment components included in the SSTS. Typical SSTS serving residences do not require these types of systems and therefore do not require an operating permit. 11. I own several parcels of land which include dwellings. If I want to connect or join two parcels do I need to have the systems inspected? The joining of parcels if approved by the Olmsted County Property Records Division does not trigger any other application process that might then required an inspection. The joining of parcels does not require a metes and bounds process or other permitting process. If any of the properties are transferred at a later date a compliance inspection would be required. Also, if a property is split through a metes and bounds process a compliance inspections are required 11 P age

12 FOR MORE INFORMATION: PLEASE CONTACT THE ROCHESTER-OLMSTED PLANNING DEPARTMENT P age

13 SSTS Ordinance Checklist Subsurface Sewage Treatment Systems (SSTS) Program Doc Type: Self Audit Instructions: This checklist is to be completed and sent with a copy of the ordinance to the Minnesota Pollution Control Agency (MPCA) Commissioner at least 30 days prior to adoption of the ordinance. The Commissioner has up to six months to respond. The ordinance may be adopted and implemented during this time. Note: To unlock this form for editing for MS Word 2003 users, select the Tools Menu/Unprotect Document; for MS Word 2007 users, select the Developer Tab/Protect Document/Restrict Formatting & Editing and click on Stop Protection in lower right corner of screen. (To add Developer Tab to Ribbon, click on the icon in the upper left corner of screen, select Word Options/Popular and check Show Developer Tab.) Submit checklist, list of differences, and a copy of the ordinance to: Minnesota Pollution Control Agency Attn: Commissioner s Office 520 Lafayette Road North St. Paul, Minnesota Local Unit of Government: Olmsted County Administrator: Rochester-Olmsted Planning Department Date (mm/dd/yyyy): 7/9/2014 County Programs Regulatory model chosen: Conventional Performance Alternative Local Standards (for existing systems) Alternative Local Standards (for new or replacement systems) City, Township, or Other Program County in which your jurisdiction lies: Regulatory model chosen: Conventional Performance All Ordinance Requirements 1. A provision requiring upgrade, replacement, repair, or discontinued use of systems failing to protect ground water as defined in Minn. R , subp , p. 15 Upgrade time period: 10 months 2. A provision requiring upgrade, replacement, repair, or discontinued use of systems posing an imminent threat as defined in Minn. R , subp , p If the local unit issues permits to add a bedroom, a provision requiring a Certificate of Compliance (COC) or Notice of Noncompliance (NON) be issued on the system prior to issuance of a building permit or variance for the addition of a 13 P age

14 bedroom. Issue bedroom permits included Ordinance citation: , pp 15; , p Provision requiring all SSTS work to be done by appropriately licensed businesses, qualified employees or person exempt from licensing in Minn. R , subp , p Provision requiring abandonment of systems no longer in use , p.15; , pp Technical standards and criteria for new and existing SSTS , p. 18; , p.20; , p Provision specifying whether local variances may be allowed and if so, how to apply. 3404, pp Provisions for design review, permit issuance, construction inspection and system operation. 3407, pp Provision requiring space for two Type I soil treatment areas , p Provision specifying conditions for holding tanks , pp Provision prohibiting surface discharge of sewage without MPCA National Pollutant Discharge Elimination System (NPDES) permit , p Provision specifying the allowable use and location for SSTS in floodplains , p Provision requiring a management plan for all new and replacement SSTS p Provision requiring operating permit for Type IV and V systems, and Midsized Sewage Treatment Systems , pp Provision, for systems not with a management plan or operating permit, requiring SSTS maintenance as specified in Minn. R P age

15 , p Provision requiring that owners of Class V wells submit inventory information to the U.S. Environmental Protection Agency (EPA) and that Class V wells be identified as such in property transfer disclosures , p Provision outlining how periodically saturated soil disagreements between licensed SSTS businesses or between licensed SSTS businesses and a local unit of government will be resolved , pp Provision specifying what level of local approval is needed for repair, rejuvenation or remediation of SSTS as defined in local ordinance , pp Provision specifying the allowed methods to determine the loading rate from Minn. R , subp. 3, item E, Tables IX or IXa , p Provision that requires all sewage generated in the jurisdiction to be treated either in an agency-permitted facility or a system designed under Minn. R. chs and 7081 standards , p. 2 (Reference to 7080) 21. Does the ordinance include a provision that allows a reduced separation distance as described in Minn. R , subp. 4, item D?. If so, this reduction must not be more than 15 percent in the vertical separation distance ordinarily required for that system , Subp. 1C, p List of technical differences between Minn. R. chs and 7081, and the local ordinance. Additional Requirements for Performance Programs 1. An education program for SSTS owners 2. A program to evaluate risks of SSTS receiving environments and work with local planning authority to evaluate impacts of SSTS regulation on land use. 3. A program to determine performance requirements necessary for each receiving environment that ensures that underground sources of drinking water are protected to the standard of Minn. R. ch and surface water are protected to the standards of Minn. R. ch P age

16 4. Specify site evaluation requirements to define the process to characterize the receiving environment. 5. A program for operating permits for all system owners, including tracking and review of compliance monitoring reports. 6. A program to track residuals hauling, treatment and disposal according to EPA s 503 regulations and applicable state, tribal and local requirements. 7. A program for notifying owners of pending scheduled submittals and for performing system inspections randomly or at the time of operating permit reissuance. 8. An enforcement program including penalties for failure to comply with the compliance schedule and requiring system inspection by certified inspection at the time of operating permit reissuance. 9. A recordkeeping program that includes a database inventory with locations, site evaluations, record drawings, permits, inspection reports, tracking for operating permits and compliance reporting. 10. A financial assistance and funding program to support the management program. Additional Requirements for Alternative Local Standards The draft local ordinance must be submitted to the MPCA at least 30 days before adoption. The submittal package must include the following: For existing systems: 1. The draft standard that is less restrictive than the Minn. R. ch standard for existing systems. 2. Demonstration that the alternative local standards adequately protect public health and the environment. Include information on soil separation, soil classification, vegetation, system use, localized well 16 P age

17 placement and construction, localized density of systems and wells, ground water flow patterns, and existing natural or artificial drainage. For new or replacement systems: 1. The draft standard that is less restrictive than the Minn. R. ch standards for new or replacement systems. 2. A map showing the areas of the county covered by the alternative local standards for new or replacement systems. 3. Documentation of population density in the area covered by the alternative local standard. 4. Description of the reasons why conformance to Minn. R. ch standards is difficult or otherwise inappropriate. 5. Description of the hardship that would result from strict conformance to Minn. R. ch Evidence of sustained and projected low population density. 7. Demonstration that the alternative local standards adequately protect public health and the environment. Include information on soil separation, soil classification, vegetation, system use, localized well placement and construction, localized density of systems and wells, ground water low patterns, and existing natural or artificial drainage. 8. Date the draft ordinance was submitted to the county s local water planning advisory committee, and any comments that may be been received. 17 P age

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