Oliver Grievson – Board Chair:On behalf of WasteWater Education 501(c)3, I am inviting, and would welcome, your participation in this consensus building process.
In 2019, Board of Directors of WasteWater Education 501(c)3, a national and international water resources education organization, applied for a 3 year $540,000 grant to enable a comprehensive, consensus based, rule making process for what to now has been a highly contentious and politically fraught subject – a statewide Code governing onsite wastewater in Michigan.
Even though that particular application was unsuccessful the Board has made a commitment to proceed using the resources we already have in hand.
Previous attempts, at enacting a ‘statewide septic code’, became bogged down in politics, turf battles, and exclusionary tactics. By holding all planning meetings in one location many of those who wanted to were unable to participate either due to distance, time or financial travel budget constraints – leading, inevitably, to suspicion and opposition.
Taking a leaf out of the State of Ohio playbook, WasteWater Education will make available their online meeting platform. Acting as the host and facilitator, this online, live sessions, consensus building meeting space will allow anyone who wants to participate – regardless of location or travel budget.
WasteWater Education has pulled together an impressive collaboration of partnerships to move forward of which I am honored to be included.
The purpose is to allow an equal playing field to resolve conflict and achieve consensus.
Attendees will be asked to set aside any pre-conceived positions and turf protection and agree to be civil and respectful – even if you don’t personally agree with the consensus position.
Using the Ohio Admin Rules as a starting point, the final goal is to draft a comprehensive Michigan Public Health Code governing all aspects of non municipal wastewater systems _ and then present it as a precursor to eventual enabling legislation.
Using 2015 Ohio Administrative Code for Sewage Treatment Systems as a template, participants will address:
Regulation:
- Training, Licensing, Certification
- a. Designers
- b. Installers
- c. Service personnel
- d. Inspectors
- System Components
- a. Certification
- b. ASTM standards
- c. NSF/ANSI Certification
- d. Maintenance Contracts
- e. Warranty
- Treatment Facilities
- a. Residential
- b. Community Systems
- c. Treatment plants
- d. Land application
- e. Commercial Waste
Enforcement:
- Regional/Local oversight
- a. License to operate for practitioners
- b. Installation review
- c. Service Permit to Operate
- d. Inspector certification
- e. Regional Control Board
- System Components
- a. Definition of ‘performance’
- b. Order to remedy or prosecution
- c. Collection of fines and fees
- d. License revocation
Administrative Actions:
- Appeals
- Variances
- Permit Revocation
- Injunctive Relief
Funding:
- Statewide Budget appropriation
- a. Department of Health and Human Services
- b. Revolving loan/grant fund for repair or replacement
- Regional Components
- a. Collection of fees for permits, inspections and licenses
- b. Collection of fines and fees
- c. Responsible Management Utilities
This an open and transparent process designed to allow anyone to participate live or via online resources. If you have a mobile device or a computer or a conference room you can be part of this Rule making process.
The essence of consensus is that those who participate create a workable, sustainable and fundable program. There will be ground rules for civility and we are asking for a once a month commitment of your time.
The inaugural meeting will take place via the web in March at 10 AM. We anticipate meetings will run no longer than 90 minutes. However sub groups who may wish to meet more frequently and for longer can be accommodated. Also for specialist topics attendance at all meetings is not required – but we do ask each participant to review each section as it is drafted.
To accept this invitation, and participate in what may finally achieve a sensible onsite wastewater administration format for Michigan, please respond by email or telephone to:
Executive Director Dendra Best. 231 233 1806. info [at]wastewatereducation.org
Do you agree that a disciplined approach to a comprehensive drafting of proposed administrative rules should come before moving on to introduction of enabling legislation?
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