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USEPA Onsite Wastewater Treatment Systems Manual (Click Here to Return to Bookmarks Page) 2-1

Chapter 2: Management of Onsite Wastewater Treatment Systems

2.1 IntroductionEffective management is the key to ensuring thatthe requisite level of environmental and publichealth protection for any given community isachieved. It is the single most important factor inany comprehensive wastewater managementprogram. Without effective management, even themost costly and advanced technologies will not beable to meet the goals of the community. Numeroustechnologies are currently available to meet a broadrange of wastewater treatment needs. Withoutproper management, however, these treatmenttechnologies will fail to perform as designed andefforts to protect public health and the environmentwill be compromised.

The literature on OWTSs is replete with casestudies showing that adequate management iscritical to ensuring that OWTSs are sited, designed,installed, and operated properly. As USEPApointed out in its Response to Congress on Use of

Chapter 2:Management of Onsite Wastewater Treatment Systems

Decentralized Wastewater Treatment Systems(1997), “Few communities have developed organi-zational structures for managing decentralizedwastewater systems, although such programs arerequired for centralized wastewater facilities andfor other services (e.g., electric, telephone, water,etc).”

Good planning and management are inseparable.The capacity of the community to manage anygiven technology should be factored into thedecision-making process leading to the planningand selection of a system or set of systems appro-priate for the community. As Kreissl and Otis notedin New Markets for Your Municipal WastewaterServices: Looking Beyond the Boundaries (1999),appropriate technologies should be selected basedon whether they are affordable, operable, andreliable. The selection of individual unit processesand systems should, at a minimum, be based onthose three factors. Although managing OWTSs isobviously far more complicated than assessingwhether the systems are affordable, operable andreliable, an initial screening using these criteria is acritical element of good planning.

Historically, the selection and siting of OWTSs hasbeen an inconsistent process. Conventional septictank and leach field systems were installed based oneconomic factors, the availability of adequate landarea, and simple health-based measures aimed onlyat preventing direct public contact with untreatedwastewater. Little analysis was devoted to under-standing the dynamics of OWTSs and the potentialimpacts on ground water and surface waters. Onlyrecently has there been an understanding of theissues and potential problems associated with

2.1 Introduction

2.2 Elements of a successful program

2.3 Types of management entities

2.4 Management program components

2.5 Financial assistance for management programs and system installation

In recognition of the need for a comprehensivemanagement framework that communities can use indeveloping and improving OWTS managementprograms, USEPA is publishing Guidelines forManagement of Decentralized Wastewater Systems(see http://www.epa.gov/owm/decent/index.htm). Atthe time of the publication of this manual, the finalguidelines and accompanying guidance manual arealmost complete. USEPA envisions that tribes, states,local governments, and community groups will use themanagement guidelines as a reference to strengthentheir existing onsite/decentralized programs. Theguidelines include a set of recommended programelements and activities and model programs that OWTSprogram managers can refer to in evaluating theirmanagement programs.


2-2 USEPA Onsite Wastewater Treatment Systems Manual

failing to manage OWTSs in a comprehensive,holistic manner.

Many case studies and reports from across thecountry provide documentation that a significantnumber of OWTSs lack adequate managementoversight, which results in inadequate pollutanttreatment (USEPA, 2000). The lack of systeminventories in many communities makes the task ofsystem management even more challenging.

As a result of the perception that onsite/decentral-ized systems are inferior, old-fashioned, lesstechnologically advanced, and not as safe ascentralized wastewater treatment systems from bothan environmental and public health perspective,many communities have pursued the constructionof centralized systems (collection systems andsewage treatment plants). Centralized wastewatercollection and treatment systems, however, are notthe most cost-effective or environmentally soundoption for all situations (e.g., sewage treatmentplants can discharge high point source loadings ofpollutants into receiving waters). They are costly tobuild and operate and are often infeasible or cost-prohibitive, especially in areas with low popula-tions and dispersed households. Many communitieslack both the revenue to fund these facilities andthe expertise to manage the treatment operations. Inaddition, centralized treatment systems can contrib-ute to unpredicted growth and development thatmight threaten water quality.

As development patterns change and increaseddevelopment occurs in rural areas and on the urbanfringe, many communities are evaluating whetherthey should invest in centralized sewage treatmentplants or continue to rely on OWTSs. The avail-ability of innovative and alternative onsite tech-nologies and accompanying management strategiesnow provides small communities with a practical,cost-effective alternative to centralized treatmentplants. For example, analysis included in USEPA’sResponse to Congress on Use of DecentralizedWastewater Treatment Systems (1997) shows thatthe costs of purchasing and managing an OWTS ora set of individual systems can be significantly (22to 80 percent) less than the cost of purchasing andmanaging a centralized system.

Regardless of whether a community selects moreadvanced decentralized systems, centralized sys-

tems, or some combination of the two, a compre-hensive management program is essential. AsUSEPA noted in Wastewater Treatment/Disposal forSmall Communities (1992), effective managementstrategies depend on carefully evaluating allfeasible technical and management alternatives andselecting appropriate solutions based on the needsof the community, the treatment objectives, theeconomic capacity, and the political and legislativeclimate.

The management tasks listed have become increas-ingly complex, especially given the need to developa management strategy based on changing prioritiesprimarily driven by new development activities.Rapid urbanization and suburbanization, thepresence of other sources that might dischargenutrients and pathogens, water reuse issues, increas-ingly stringent environmental regulations, andrecognition of the need to manage on a watershedbasis increase the difficulty of this task. Multipleobjectives (e.g., attainment of water quality criteria,protection of ground water, efficient and affordablewastewater treatment) now must be achieved toreach the overarching goal of maintaining eco-nomically and ecologically sound communities.Investment by small communities in collection andtreatment systems increases taxes and costs toconsumers—costs that might be reduced substan-tially by using decentralized wastewater treatmentsystems. From a water resource perspective achiev-ing these goals means that public health, contactrecreation activities, fisheries, shellfisheries,drinking water resources, and wildlife need to beprotected or restored. From a practical standpoint,achieving these goals requires that the managemententity develop and implement a program that isconsistent with the goal of simultaneously meetingand achieving the requirements of the Safe Drink-ing Water Act, the Clean Water Act, the Endan-gered Species Act, and other applicable federal,state, tribal, and local requirements.

Changing regulatory contexts point to scenarios inwhich system selection, design, and replacementwill be determined by performance requirementstied to water quality standards or maximumcontamination limits for ground water. Cumulativeeffects analyses and antidegradation policies mightbe used to determine the level of technology andmanagement needed to meet the communities’resource management goals. Comprehensive

USEPA Onsite Wastewater Treatment Systems Manual 2-3


coordinated management programs are needed tomeet this challenge. These programs requireinterdisciplinary consultations among onsite systemmanagement entities, water qualityagencies, land use planners, engineers, wildlifebiologists, public health specialists, and others toensure that these goals and objectives are efficientlyachieved with a minimum of friction or programoverlap.

Fortunately, there are solutions. Technologies thatcan provide higher levels of pollutant reductionthan were practical in the past appear to beemerging. Better monitoring and assessmentmethods are now available to determine theeffectiveness of specific technologies. Remotesensing is possible to help monitor and understandsystem operation, and more sophisticated inspec-tion tools are available to complement visualseptic tank/SWIS inspections.

2.2 Elements of a successfulprogram

The success or failure of an onsite wastewatermanagement program depends significantly onpublic acceptance and local political support;adequate funding; capable and trained technical andfield staff; and clear and concise legal authority,regulations, and enforcement mechanisms (Ciotoliand Wiswall, 1982). Management programs shouldinclude the following critical elements:

• Clear and specific program goals• Public education and outreach• Technical guidelines for site evaluation, design,

construction, and operation/maintenance• Regular system inspections, maintenance, and

monitoring• Licensing or certification of all service providers• Adequate legal authority, effective enforcement

mechanisms, and compliance incentives• Funding mechanisms• Adequate record management• Periodic program evaluations and revisions

Although all of these elements should be present in asuccessful management program, the responsibilityfor administering the various elements might fall ona number of agencies or entities. Regardless of thesize or complexity of the program, its components

must be publicly accepted, politically feasible,fiscally viable, measurable, and enforceable.

Many of the program elements discussed in thischapter are described in more detail in the otherchapters of this manual. The elements described indetail in this chapter are those essential to theselection and adoption of a management program.

2.2.1 Clear and specific program goals

Developing and meeting program goals is criticalto program success. Management programs typi-cally focus on two goals—protection of publichealth and protection of the environment. Eachonsite system must be sited, designed, and managedto achieve these goals.

Public health protection goals usually focus onpreventing or severely limiting the discharge ofpathogens, nutrients, and toxic chemicals to groundwater. Surface water bodies, including rivers, lakes,streams, estuaries, and wetlands, can also beadversely affected by OWTSs. Program goalsshould be established to protect both surface andground water resources.

Public participation opportunities duringprogram planning and implementation

• Agreement on basic need for program

• Participation on committees, e.g., finance, technical,educational

• Selection of a consultant or expert (request forproposal, selection committee, etc.)

• Choosing the most appropriate options from theoptions identified by a consultant or expert

• Obtaining financing for the preferred option

• Identifying and solving legal questions and issues

• Providing input for the enforcement/compliance plan

• Implementation and construction



2.2.2 Public education and outreach

Public education

Public participation in and support for planning,design, construction, and operation and mainte-nance requirements are essential to the acceptanceand success of an onsite wastewater managementprogram. Public meetings involving state and localofficials, property owners, and other interestedparties are an effective way to garner support forthe program. Public meetings should includediscussions about existing OWTS problems andcover issues like program goals, costs, financing,inspection, and maintenance. Such meetingsprovide a forum for identifying communityconcerns and priorities so that they can be consid-ered in the planning process. Public input is alsoimportant in determining management and compli-ance program structure, defining the boundaries ofthe program, and evaluating options, their relativerequirements and impacts, and costs.

Public outreach

Educating homeowners about the proper operationand maintenance of their treatment systems is anessential program activity. In most cases, systemowners or homeowners are responsible for someportion of system operation and maintenance orfor ensuring that proper operation and mainte-nance occurs through some contractual agreement.The system owner also helps to monitor systemperformance. Increased public support andprogram effectiveness can be promoted by educat-ing the public about the importance of OWTSmanagement in protecting public health, surfacewaters, ground water resources, and propertyvalues.

Onsite system owners are often uninformed abouthow their systems function and the potential forground water and surface water contaminationfrom poorly functioning systems. Surveys showthat many people have their septic tanks pumpedonly after the system backs up into their homes oryards. Responsible property owners who areeducated in proper wastewater disposal and mainte-nance practices and understand the consequences ofsystem failure are more likely to make an effort toensure their systems are in compliance with opera-tion and maintenance requirements. Educational

materials for homeowners and training courses fordesigners, site evaluators, installers, inspectors, andoperation/maintenance personnel can help reducethe impacts from onsite systems by reducing thenumber of failing systems, which potentiallyreduces or eliminates future costs for the systemowner and the management program.

2.2.3 Technical guidelines for siteevaluation, design, andconstruction

The regulatory authority (RA) should set technicalguidelines and criteria to ensure effective andfunctioning onsite wastewater systems. Guidelinesfor site evaluation, system design, construction,operation/maintenance, and inspection are neces-sary to maintain performance consistency. Siteevaluation guidelines should be used to determinethe site’s capability to accept the expected wastewa-ter volume and quality. Guidelines and standards onsystem design ensure the system compatibility withthe wastewater characteristics to be treated and itsstructural integrity over the life of the system.Construction standards should require that systemsconform to the approved plan and use appropriateconstruction methods, materials, and equipment.

2.2.4 Regular system operation,maintenance, and monitoring

An OWTS should be operated and maintained toensure that the system performs as designed for itsservice life. Both individual systems and sets ofsystems within a delineated management areashould be monitored to ensure proper performanceand the achievement of public health and environ-mental goals. A combination of visual, physical,bacteriological, chemical, and remote monitoringapproaches can be used to assess system perfor-mance. Specific requirements for reporting to theappropriate regulatory agency should also bedefined in a management program. The right toenter private property to access and inspect compo-nents of the onsite system is also an essentialelement of an effective management program.



2.2.5 Licensing or certification ofservice providers

Service providers include system designers, siteevaluators, installers, operation/maintenancepersonnel, inspectors, and septage pumpers/haulers.A qualifications program that includes certificationor licensing procedures for service providers shouldbe incorporated into a management program.Licensing can be based on examinations that assessbasic knowledge, skills, and experience necessaryto perform services. Other components includerequirements for continuing education, definedservice protocols, and disciplinary guidelines orother mechanisms to ensure compliance andconsistency. Many states already have, or areplanning, certification programs for some serviceproviders. These and other existing licensingarrangements should be incorporated when theycomplement the objectives of the managementprogram.

2.2.6 Adequate legal authority, effectiveenforcement mechanisms, andcompliance incentives

Onsite wastewater management programs need acombination of legal authorities, enforcementmechanisms, and incentives to ensure complianceand achievement of program goals. To ensureprogram effectiveness, some program mechanismsshould be enforceable. Although the types ofmechanisms management entities use will vary byprogram, the following mechanisms should beenforceable: construction and operating permits,requirements for performance bonds to ensureproper construction or system operation andmaintenance, and licensing/certification require-ments to ensure that service providers have thenecessary skills to perform work on treatmentsystems. Management entities should also have theauthority to carry out repairs or replace systemsand, ultimately, to levy civil penalties. Enforce-ment programs, however, should not be basedsolely on fines if they are to be effective. Informa-tion stressing public health protection, the mon-etary benefits of a clean environment, and thecontinued functioning of existing systems (avoid-ance of system replacement costs) can provideadditional incentives for compliance. Finally, itshould be recognized that the population served by

the management program must participate in andsupport the program to ensure sustainability.

2.2.7 Funding mechanisms

Funding is critical to the functioning of an effec-tive OWTS management program. Managemententities should ensure that there is adequate fundingavailable to support program personnel, educationand outreach activities, monitoring and evaluation,and incentives that promote system upgrades andreplacement. Funding might also be needed fornew technology demonstrations and other programenhancements.

2.2.8 Adequate record managementKeeping financial, physical, and operationalrecords is an essential part of a managementprogram. Accurate records of system location andtype, operation and maintenance data, revenuegenerated, and compliance information are neces-sary to enhance the financial, operational, andregulatory health of the management program.Electronic databases, spreadsheets, and geographicinformation systems can help to ensure programeffectiveness and appropriate targeting of programresources. At a minimum, program managersshould maintain records of system permits, design,size, location, age, site soil conditions, complaints,inspection results, system repairs, and maintenanceschedules. This information should be integratedwith land use planning at a watershed or wellheadprotection zone scale.

2.2.9 Periodic program evaluations andrevisions

Management programs for onsite systems aredynamic. Changing community goals, resources,environmental and public health concerns, develop-ment patterns, and treatment system technologiesrequire that program managers—with publicinvolvement—regularly evaluate program effec-tiveness and efficiency. Program managers mightneed to alter management strategies because ofsuburban sprawl and the close proximity of central-ized collection systems. Resource and staff limita-tions might also necessitate the use of serviceproviders or designated management entities to



ensure that systems in a jurisdiction are adequatelymanaged.

2.3 Types of management entities

Developing, implementing, and sustaining amanagement program requires knowledge of thepolitical, cultural, and economic context of thecommunity, the current institutional structure, andavailable technologies. Also required are clearlydefined environmental and public health goals andadequate funding. A management program shouldbe based on the administrative, regulatory, andoperational capacity of the management entity andthe goals of the community. In many localities,partnerships with other entities in the managementarea (watershed, county, region, state, or triballands) are necessary to increase the capacity of themanagement program and ensure that treatmentsystems do not adversely affect human health orwater resources. The main types of managemententities are federal, state, and tribal agencies; localgovernment agencies; special-purpose districts andpublic utilities; and privately owned and operatedmanagement entities. Descriptions of the varioustypes of management entities are provided in thefollowing subsections.

2.3.1 Federal, state, tribal, and localagencies

Federal, state, tribal, and local governments havevarying degrees of authority and involvement in thedevelopment and implementation of onsite waste-water management programs. In the United States,tribal, state, and local governments are the mainentities responsible for the promulgation and enforce-ment of OWTS-related laws and regulations. Many ofthese entities provide financial and technical assis-tance. Tribal, state, and local authority determines thedegree of control these entities have in managingonsite systems. General approaches and responsibili-ties are shown in table 2-1.

At the federal level, USEPA is responsible forprotecting water quality through the implementa-tion of the Clean Water Act (CWA), the SafeDrinking Water Act (SDWA), and the Coastal ZoneAct Reauthorization Amendments (CZARA). Underthese statutes, USEPA administers a number ofprograms that affect onsite system management.The programs include the Water Quality StandardsProgram, the Total Maximum Daily Load Pro-gram, the Nonpoint Source Management Program,the National Pollutant Discharge EliminationSystem (NPDES) Program, the UndergroundInjection Control (UIC) Program, and the SourceWater Protection Program. Under the CWA and the

TTTTTwwwwwelvelvelvelvelve probe probe probe probe problems that can afflems that can afflems that can afflems that can afflems that can affect Oect Oect Oect Oect OWTS management progWTS management progWTS management progWTS management progWTS management progrrrrramsamsamsamsams

1. Failure to adequately consider site-specific environmental conditions (site evaluations)

2. Codes that thwart system selection or adaptation to difficult local site conditions and that do notallow the use of effective innovative or alternative technologies

3. Ineffective or nonexistent public education and training programs

4. Failure to include water conservation and reuse

5. Ineffective controls on operation and maintenance of systems

6. Lack of control over residuals management

7. Lack of OWTS program monitoring and evaluation, including OWTS inspection and monitoring

8. Failure to consider the special characteristics and requirements of commercial, industrial, andlarge residential systems

9. Weak compliance and enforcement programs

10. Lack of adequate funding

11. Lack of adequate legal authority

12. Lack of adequately trained and experienced personnel

Source: Adapted from USEPA, 1986.


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SDWA, USEPA has the authority to directlyregulate specific categories of onsite systems underthe UIC and NPDES programs. The CZARAsection 6217 Coastal Nonpoint Source Programrequires the National Oceanic and AtmosphericAdministration (NOAA) and USEPA to review andapprove upgraded state coastal nonpoint sourceprograms to meet management measures for newand existing OWTSs. These measures addresssiting, designing, installing, maintaining, andprotecting water quality. See chapter 1 for addi-tional information and Internet web sites.

State and tribes might manage onsite systemsthrough various agencies. Typically, a state or tribalpublic health office is responsible for managingonsite treatment systems. Regulation is sometimescentralized in one state or tribal government officeand administered from a regional or local stateoffice. In most states, onsite system managementresponsibilities are delegated to the county ormunicipal level. Where such delegation occurs, thestate might exercise varying degrees of localprogram oversight.

Leadership and delegation of authority at the statelevel are important in setting technical, manage-ment, and performance requirements for localprograms. In states where local governments areresponsible for managing onsite systems, stateauthority often allows flexibility for local programsto set program requirements that are appropriatefor local conditions and management structures aslong as the local program provides equal or greaterprotection than that of state codes. Statewideconsistency can be promoted by establishing

• Administrative, managerial, and technologicalrequirements

• Performance requirements for natural resourceand public health protection

• Requirements for monitoring and laboratorytesting

• Education and training for service providers• Technical, financial, and administrative support• Periodic program reviews and evaluations• Enforcement of applicable regulations

Many states set minimum system design and sitingrequirements for onsite systems and are activelyinvolved in determining appropriate technologies.Other states delegate some or all of this authority to

local governments. Some states retain the responsi-bility for the administrative or technical portions ofthe onsite management program; in these states, thelocal governments’ primary role is to implementthe state requirements.

2.3.2 Local government agencies

In many states, local governments have the respon-sibility for onsite wastewater program manage-ment. These local management programs areadministered by a variety of municipal, county, ordistrict-level agencies. The size, purpose, andauthority of county, township, city, or villagegovernment units vary according to each state’sstatutes and laws. Depending on the size of thejurisdiction and the available resources, an onsitewastewater management program can be adminis-tered by a well-trained, fully staffed environmentalor public health agency or by a board composed oflocal leaders. In some states, some or most of theresponsibility for onsite system management isdelegated by the legislature to local governments.In states with “home rule” provisions, local units ofgovernment have the authority to manage onsitesystems without specific delegation by the statelegislature. Some local home rule governments alsohave the power to enter into multiple agency orjurisdictional agreements to jointly accomplish anyhome rule function without any special authorityfrom the state (Shephard, 1996).

County governments can be responsible for avariety of activities regarding the management ofonsite systems. A county can assume responsibilityfor specific activities, such as OWTS regulation,within its jurisdiction, or it can supplement andsupport existing state, city, town, or village waste-water management programs with technical,financial, or administrative assistance. Counties canprovide these services through their normal opera-tional mechanisms (e.g., a county department oragency), or they can establish a special district toprovide designated services to a defined servicearea. County agency responsibilities might include

• Adoption of state minimal requirements ordevelopment of more stringent requirements

• Planning, zoning, and general oversight ofproposed development

• Review of system designs, plans, and installa-tion practices



• Permitting of systems and construction over-sight

• Inspection, monitoring, and enforcement• Reports to public and elected officials

Township, city, or village governments can beresponsible for planning, permitting, and operat-ing onsite wastewater facilities and enforcingapplicable regulations. The precise roles andresponsibilities of local governments depend onthe preferences, capabilities, and circumstancesof each jurisdiction. Because of the variability instate enabling legislation and organizationalstructures, the administrative capacity, jurisdic-tion, and authority of local entities to manageonsite wastewater systems vary considerably.

2.3.3 Special-purpose districts andpublic utilities

The formation of special-purpose districts andpublic utilities is usually enabled by state law toprovide public services that local governments donot or cannot provide. A special-purpose districtor public utility is a quasigovernmental entityestablished to provide specific services or toconduct activities specified by the enablinglegislation. Special districts (e.g., sanitation

districts) provide single or multiple services, suchas managing planning and development activities,conducting economic development programs,improving local conditions, and operating drinkingwater and wastewater treatment facilities. Theterritory serviced by this entity is variable and caninclude a single community, a portion of a commu-nity, a group of communities, parts of severalcommunities, an entire county, or a regional area.State enabling legislation usually outlines theauthority, structure, and operational scope of thedistrict, including service area, function, organiza-tional structure, financial authority, and perfor-mance criteria.

Special-purpose districts and public utilities areusually given sufficient financial authority to applyfor or access funds, impose service charges, collectfees, impose special assessments on property, andissue revenue or special assessment bonds. Somespecial-purpose districts have the same financingauthority as municipalities, including the authorityto levy taxes and incur general obligation debt.These districts are usually legal entities that mightenter into contracts, sue, or be sued. There mightbe situations where eminent domain authority isneeded to effectively plan and implement onsiteprograms. Special-purpose districts and public

Sanitation district management of onsite systems: New MexicoSanitation district management of onsite systems: New MexicoSanitation district management of onsite systems: New MexicoSanitation district management of onsite systems: New MexicoSanitation district management of onsite systems: New Mexico

Onsite systems in the community of Peña Blanca, New Mexico, are managed by the Peña Blanca Water andSanitation District, which is organized under state statutes that require a petition signed by 25 percent of theregistered voters and a public referendum before a district may be formed. Once formed, water and sanitationdistricts in New Mexico are considered subdivisions of the state and have the power to levy and collect advalorem taxes and the right to issue general obligation and revenue bonds.

Residents and public agency officials in Peña Blanca sought to improve the management of systems in thecommunity after a 1985 study found that 86 percent of existing systems required upgrades, repair, orreplacement. The water and sanitation district was designated as the lead agency for managing OWTSsbecause it already provided domestic water service to the community and had an established administrativestructure. The sanitation district relies on the New Mexico Environment Department to issue permits and monitorinstallation, while the district provides biannual pumping services through an outside contractor for a monthly feeof $10.64 for a 1,000-gallon tank. The district also supervises implementation of the community’s onsite systemordinance, which prohibits untreated and unauthorized discharges, lists substances that might not be dischargedinto onsite systems (e.g., pesticides, heavy metals), and provides for sampling and testing. Penalties fornoncompliance are set at $300 per violation and not more than 90 days imprisonment. Liens might be placed onproperty for nonpayment of pumping fees.

The program has been in operation since 1991 and serves nearly 200 homes and businesses. Septage poolingon ground surfaces, a problem identified in the 1985 study, has been eliminated.Source: Rose, 1999.



utilities will most likely have to work closely withstate or local authorities when program planning orimplementation requires the use of this authority.

Special districts and public utilities can be an effectiveoption for managing onsite systems. The specialdistrict and public utility models have been adoptedsuccessfully in many states. A good example is thecreation of water districts and sanitation districts,which are authorized to manage and extend potablewater lines and extend sewerage service in areasnear centralized treatment plants. The developmentof onsite system management functions under theauthority of existing sanitation districts providessupport for planning, installation, operation,maintenance, inspection, enforcement, and financ-ing of these programs. Traditional onsite manage-ment entities (e.g., health departments) can partnerwith sanitation or other special districts to build awell-integrated program. For example, a healthdepartment could retain its authority to approvesystem designs and issue permits while the sanita-tion district could assist with regional planning andconduct inspection, maintenance, and remediation/repair activities.

In some areas, special districts or public utilitieshave been created to handle a full range of manage-ment activities, from regional planning and systempermitting to inspection and enforcement. In 1971the City of Georgetown, California, developed andimplemented a comprehensive, community-wideonsite management program in the Lake AuburnTrails subdivision (Shephard, 1996). The districtdoes not own the onsite systems in the subdivisionbut is empowered by the state and county govern-ments to set performance requirements, review andapprove system designs, issue permits, overseeconstruction, access treatment system sites toconduct monitoring, and provide routine mainte-nance. The initial permit fees were approximately$550. Annual fees in 1995 were approximately$170 per dwelling and $80 for undeveloped lots(Shephard, 1996).

Onsite management districts or public utilities,whether wholly or partially responsible for systemoversight, can help ensure that treatment systemsare appropriate for the site and properly planned,designed, installed, and maintained. Typical goalsfor the management district or utility might include

• Providing appropriate wastewater collection/treatment service for every residence or business

• Integrating wastewater management with landuse and development policies

• Managing the wastewater treatment program ata reasonable and equitable cost to users

Management districts and public utilities generallyare authorized to generate funds from a variety ofsources for routine operation and maintenance,inspections, upgrades, and monitoring and forfuture development. Sources of funds can includeinitial and renewable permit fees, monthly servicecharges, property assessments, and special fees.Onsite wastewater management districts that areoperated by or closely allied with drinking watersupply districts can coordinate collection of systemservice charges with monthly drinking water billsin a manner similar to that used by centralizedwastewater treatment plants. Although some home-owners might initially resist fees and other chargesthat are necessary to pay for wastewater manage-ment services, outreach information on the effi-ciencies, cost savings, and other benefits of coop-erative management (e.g., financial support forsystem repair, upgrade, or replacement and no-costpumping and maintenance) can help to buildsupport for comprehensive programs. Such supportis especially needed if a voter referendum isrequired to create the management entity. Whencreating a new district, public outreach and stake-holder involvement should address the followingtopics:

• Proposed boundaries of the management district• Public health and natural resource protection

issues• Problems encountered under the current man-

agement system• Performance requirements for treatment systems• Onsite technologies appropriate for specific site

conditions• Operation and maintenance requirements for

specific system types• Septage treatment and sewage treatment plant

capacity to accept septage• Cost estimates for management program compo-

nents• Program cost and centralized system manage-

ment cost comparisons



• Potential program partners and inventory ofavailable resources

• Proposed funding source(s)• Compliance and enforcement strategies• Legal, regulatory, administrative, and manage-

rial actions to create, develop, or establish themanagement entity

Another type of special district is the publicauthority. A public authority is a corporate bodychartered by the state legislature with powers toown, finance, construct, and operate revenue-producing public facilities. A public authority canbe used in a variety of ways to construct, finance,and operate public facilities, including OWTSs.

It should be noted that some state codes restrict ordisallow a managed group of special districts frommanaging onsite systems. In other cases, clear legalauthority for program staff to enter private prop-erty to perform inspections and correct problemshas not been provided. These limitations can beaddressed through special legislation authorizingthe creation of entities with explicit onsite manage-ment responsibilities. Laws and regulations can alsobe changed to provide special districts the authorityto manage onsite systems and to conduct inspec-tion, maintenance, and remediation activities.

2.3.4 Privately owned and operatedmanagement entities

Private sector management entities are anotheroption for ensuring OWTS are properly managed.These entities are often responsible for systemdesign, installation, operation, and maintenance. Insome cases, these private firms also serve as thesole management entity; for example, a firm mightmanage an onsite system program for a residentialsubdivision as a part of a public-private partner-ship. Several options exist for public/privatepartnerships in the management of onsite systems.OWTS management programs can contract withprivate firms to perform clearly defined tasks forwhich established protocols exist, such as siteevaluation, installation, monitoring/inspection, ormaintenance. An example of such an arrangementwould be to contract with a licensed/certifiedprovider, such as a trained septage pumper/haulerwho could be responsible for system inspection,maintenance, and record keeping. Another examplewould be the case where treatment systems inresidential subdivisions are serviced by a privateentity and operated under a contract with thesubdivision or neighborhood association.

Private for-profit corporations or utilities thatmanage onsite systems are often regulated by thestate public utility commission to ensure continu-

Development company creates a service district in ColoradoDevelopment company creates a service district in ColoradoDevelopment company creates a service district in ColoradoDevelopment company creates a service district in ColoradoDevelopment company creates a service district in Colorado

The Crystal Lakes Development Company has been building a residential community 40 miles northwest of FortCollins, Colorado, since 1969. In 1972 the company sponsored the creation of the Crystal Lakes Water andSewer Association to provide drinking water and sewage treatment services. Membership in the association isrequired of all lot owners, who must also obtain a permit for onsite systems from the Larimer County HealthDepartment. The association enforces county health covenants, aids property owners in the development ofonsite water and wastewater treatment systems, monitors surface and ground water, and has developedguidelines for inspecting onsite water and wastewater systems. System inspections are conducted at the timeof property transfer.

The association conducts preliminary site evaluations for proposed onsite systems, including inspection of abackhoe pit excavated by association staff with equipment owned by the association. The county healthdepartment has also authorized the association to design proposed systems. The association currentlymanages systems for more than 100 permanent dwellings and 600 seasonal residences. Management servicesare provided for all onsite systems in the development, including 300 holding tanks, 7 community vault toilets,recreational vehicle dump stations, and a cluster system that serves 25 homes on small lots and thedevelopment’s lodge, restaurant, and office buildings. The association is financed by annual property ownerdues of $90 to $180 and a $25 property transfer fee, which covers inspections.

Source: Mancl, 1999.



ous, acceptable service at reasonable rates. Serviceagreements are usually required to ensure privateorganizations will be financially secure, provideadequate service, and be accountable to theircustomers. These entities can play a key role inrelieving the administrative and financial burden onlocal government by providing system managementservices. It is likely that in the future private firmswill build, own, and operate treatment systems andbe subject only to responsible administrativeoversight of the management entity.

2.3.5 Regulatory authorities andresponsible management entities

Most regulatory authorities (e.g., public healthdepartments and water quality authorities) lackadequate funding, staff, and technical expertise todevelop and implement comprehensive onsitesystem management programs. Because of this lackof resources and trained personnel, programmanagers across the country are considering orimplementing alternative management structuresthat delegate responsibility for specified manage-ment program elements to other entities. Hooverand Beardsley (2000) recommend that managemententities develop alliances with public and privateorganizations to establish environmental qualitygoals, evaluate treatment system performanceinformation, and promote activities that ensure

onsite system management programs meet perfor-mance requirements.

English and Yeager (2001) have proposed theformation of responsible management entities(RMEs) to ensure the performance of onsite andother decentralized (cluster) wastewater treatmentsystems. RMEs are defined as legal entities thathave the technical, managerial, and financialcapacity to ensure viable, long-term, cost-effectivecentralized management, operation, and mainte-nance of all systems within the RME’s jurisdiction.Viability is defined as the capacity of the RME toprotect public health and the environment effi-ciently and effectively through programs that focuson system performance rather than adherence toprescriptive guidelines (English and Yeager, 2001).RMEs can operate as fully developed managementprograms under existing oversight programs (e.g.,health departments, sanitation districts) in stateswith performance-based regulations, and they areusually defined as comprehensive managemententities that have the managerial, technical, andfinancial capacity to ensure that proposed treatmentsystem applications will indeed achieve clearlydefined performance requirements. System technol-ogy performance information can be ranked alonga continuum that gives greater weight to confirma-tory studies, peer-reviewed assessments, and thirdparty analysis of field applications. Under thisapproach, unsupported performance assertions byvendors and results from limited field studies

Responsibilities of a ComprehensivResponsibilities of a ComprehensivResponsibilities of a ComprehensivResponsibilities of a ComprehensivResponsibilities of a Comprehensive Onsite e Onsite e Onsite e Onsite e Onsite WWWWWasteasteasteasteastewwwwwater Management Progater Management Progater Management Progater Management Progater Management Progrrrrramamamamam• Power to propose legislation and establish and enforce program rules and regulations

• Land use planning involvement, review and approval of system designs, permit issuance

• Construction and installation oversight

• Routine inspection and maintenance of all systems

• Management and regulation of septage handling and disposal

• Local water quality monitoring

• Administrative functions (e.g., bookkeeping, billing)

• Grant writing, fund raising, staffing, outreach

• Authority to set rates, collect fees, levy taxes, acquire debt, issue bonds, make purchases

• Authority to obtain easements for access to property, enforce regulations, require repairs

• Education, training, certification, and licensing programs for staff and contractors

• Record keeping and database maintenance

Source: NSFC, 1996.



receive less emphasis in management entity evalua-tions of proposed treatment technologies (Hooverand Beardsley, 2001).

Management responsibilities can be assigned to anentity designated by the state or local governmentto manage some or all of the various elements ofonsite wastewater programs. The assignment ofmanagement responsibilities to a comprehensiveRME or to some less-comprehensive managemententity (ME) appears to be a practical solution to thedilemma of obtaining adequate funding andstaffing to ensure that critical management activi-ties occur. The use of an RME, however, makesdeveloping and implementing an onsite manage-ment program more complex. Increased coordina-tion and planning are necessary to establish aneffective management program. All of the manage-ment program activities described below can beperformed by an RME; some may be executed by amanagement entity with a smaller scope of capa-bilities. In jurisdictions where management pro-gram responsibilities are delegated to an RME, theregulatory authority (RA; e.g., local health depart-ment) must oversee the RME to ensure that theprogram achieves the comprehensive public healthand environmental goals of the community. De-pending on state and local codes, a formal agree-ment or some other arrangement between the RMEand the RA might be required for RME executionof some program elements, such as issuing permits.

The accompanying text insert, adapted from theNational Small Flows Clearinghouse (1996),contains an example of activities that a comprehen-sive RME typically must incorporate into itsmanagement program. It should be noted that theinvolvement of an ME to perform some manage-ment program tasks or an RME to perform the fullrange of management tasks should be tailored toeach local situation. Given the evolving nature ofonsite wastewater management programs, activitiesin some cases might be performed by an RME,such as an onsite system utility or private serviceprovider. In other cases, these responsibilities mightbe divided among several state or local governmentagencies, such as the local public health depart-ment, the regional planning office, and the statewater quality agency. Changes in managementstrategies (movement toward performance-basedapproaches, institution of model managementstructures) have resulted in the addition of other

responsibilities, which are discussed later in thissection.

When a less-comprehensive ME conducts a speci-fied set of these activities, the RA usually retainsthe responsibility for managing some or all of thefollowing activities:

• Defining management responsibilities for theRA and the ME

• Overseeing the ME• Issuing permits• Inspecting onsite systems• Responding to complaints• Enforcement and compliance actions• Monitoring receiving water quality (surface and

ground water)• Regulation of septage handling and disposal• Licensing and certification programs• Keeping records and managing databases for

regulatory purposes• Coordinating local and regional planning efforts

The RA, however, will often delegate to the MEthe responsibility for implementing some of theactivities listed above. The activities delegated tothe ME will be determined by the capacity of theME to manage specific activities, the specificpublic health and environmental problems to beaddressed by the ME, and the RA’s legal authorityto delegate some of those activities. For example, ifthe ME is an entity empowered to own and operatetreatment systems in the service area, the MEtypically would be responsible for all aspects ofmanaging individual systems, including settingfees, designing and installing systems, conductinginspections, and monitoring those systems to ensurethat the RA’s performance goals are met. Otis,McCarthy, and Crosby (2001) have presented aframework appropriate for performance manage-ment that illustrates the concepts discussed above.

2.4 Management programcomponents

Developing and implementing an effective onsitewastewater management program requires that asystematic approach be used to determine necessaryprogram elements. Changes and additions to the



management program should be based on evalua-tions of the program to determine whether theprogram has adequate legal authorities, funding,and management capacity to administer bothexisting and new OWTSs and respond to changingenvironmental and public health priorities andadvances in OWTS technologies.

The management program elements described inthe following sections are common to the mostcomprehensive onsite management programs (e.g.,RMEs). USEPA recognizes that states and localgovernments are at different stages along thecontinuum of developing and implementingcomprehensive management programs that addresstheir communities’ fiscal, institutional, environ-mental, and public health goals.

2.4.1 Authority for regulating andmanaging onsite treatmentsystems

Onsite wastewater program managers shouldidentify all legal responsibilities of the RA that

might affect the implementation of an effectiveprogram. Legal responsibilities can be found instate and local statutes, regulations, local codes,land use laws, and planning requirements. Otherlegal mechanisms such as subdivision covenants,private contracts, and homeowner association rulesmight also affect the administration of the pro-gram. In many jurisdictions, legal authorities thatdo not specifically refer to onsite programs andauthorities, such as public nuisance laws, statewater quality standards, and public health laws,might be useful in implementing the program. Atypical example would be a situation where thepublic health agency charged with protectinghuman health and preventing public nuisancesinterprets this mandate as sufficient authorization torequire replacement or retrofit of onsite system thathave surface seepage or discharges.

The extent and interpretation of authority assignedto the RA will determine the scope of its duties, thefunding required for operation, and the personnelnecessary to perform its functions. In many juris-dictions, the authority to perform some of theseactivities might be distributed among multiple RAs.

TTTTTypical Aypical Aypical Aypical Aypical Authoruthoruthoruthoruthorities of a Regulatorities of a Regulatorities of a Regulatorities of a Regulatorities of a Regulatory Ay Ay Ay Ay Authoruthoruthoruthoruthorityityityityity

• Develop and implement policy and regulations

• Provide management continuity

• Enforce regulations and program requirements through fines or incentives

• Conduct site and regional-scale evaluations

• Require certification or licensing of service providers

• Oversee system design review and approval

• Issue installation and operating permits

• Oversee system construction

• Access property for inspection and monitoring

• Inspect and monitor systems and the receiving environment

• Finance the program through a dedicated funding source

• Charge fees for management program services (e.g., permitting, inspections)

• Provide financial or cost-share assistance

• Issue and/or receive grants

• Develop or disseminate educational materials

• Provide training for service providers and staff

• Conduct public education and involvement programs

• Hire, train, and retain qualified employees



Where this is the case, the organizations involvedshould have the combined authority to perform allnecessary activities and should coordinate theiractivities to avoid program gaps, redundancy, andinefficiency. In some cases, the RA might delegatesome of these responsibilities to an ME. When acomprehensive set of responsibilities are delegatedto an RME, the RA should retain oversight andenforcement authority to ensure compliance withlegal, performance, and other requirements.

Each state or local government has unique organi-zational approaches for managing onsite wastewatersystems based on needs, perceptions, and circum-stances. It is vitally important that the authorizinglegislation, regulations, or codes allow the RAs andMEs to develop an institutional structure capable offulfilling mandates through adoption of appropriatetechnical and regulatory programs. A thoroughevaluation of authorized powers and capabilities atvarious levels and scales is necessary to determinethe scope of program authority, the scale at whichRAs and MEs can operate, and the processes theymust follow to enact and implement the manage-ment program. Involving stakeholders who repre-sent public health entities, environmental groups,economic development agencies, political entities,and others in this process can ensure that the linesand scope of authority for an onsite managementprogram are well understood and locally supported.In some cases, new state policies or regulationsmust be implemented to allow for recognition ofonsite MEs.

2.4.2 Onsite wastewater managementprogram goals

Developing and implementing an effective manage-ment program requires first establishing programgoals. Program goals should be selected based onpublic health, environmental, and institutionalfactors and public concerns. Funding availability,institutional capability, and the need to protectconsumers and their interests typically affect theselection of program goals and objectives. One ormore entities responsible for public health andenvironmental protection, such as public health andwater quality agencies, can determine the goals.The development of short- and long-term compre-hensive goals will most likely require coordinationamong these entities. Community development andplanning agencies as well as residents should also

play a role in helping to determine appropriategoals.

Traditionally, the main goals of most onsitemanagement programs have been to reduce risks topublic health (e.g., prevent direct public contactwith sewage and avoid pathogenic contamination ofground water and surface waters); abate publicnuisances (e.g., odors from pit privies and cess-pools); and provide cost-effective wastewatertreatment systems and management programs.More recently, there has been an increased focus onpreventing OWTS-related surface and groundwater quality degradation and impacts on aquatichabitat. Program goals have been expanded toaddress nutrients, toxic substances, and a broaderset of public health issues regarding pathogens.Onsite wastewater-related nutrient enrichmentleading to algae blooms and eutrophication or lowdissolved oxygen levels in surface waters is ofconcern, especially in waters that lack adequateassimilative capacity, such as lakes and coastalembayments or estuaries. The discharge of toxicsubstances into treatment systems and eventuallyinto ground water has also become a more promi-nent concern, especially in situations where onsite/decentralized treatment systems are used by com-mercial or institutional entities like gasoline servicestations and nursing homes. The potential impactsfrom pathogens discharged from OWTS on shell-fisheries and contact recreation activities have alsomoved some OWTS program managers to adoptgoals to protect these resources.

Historically, in many jurisdictions the public healthagency has had the primary role in setting programgoals. Without documented health problemsimplicating onsite systems as the source ofproblem(s), some public health agencies have hadlittle incentive to strengthen onsite managementprograms beyond the goals of ensuring there wasno direct public contact with sewage or no obviousdrinking water-related impacts, such as bacterial orchemical illnesses like methemoglobinemia (“bluebaby syndrome”). The availability of more ad-vanced assessment and monitoring methodologiesand technologies and a better understanding ofsurface water and ground water interactions,however, has led to an increased focus on protect-ing water quality and aquatic habitat. As a result, inmany states and localities, water quality agencieshave become more involved in setting onsite



program goals and managing onsite wastewaterprograms. Some water quality agencies (e.g.,departments of natural resources), however, lackdirect authority or responsibility to regulate onsitesystems. This lack of authority points to the needfor increased coordination and mutual goal settingamong health agencies that have such authority.Regardless of which agency has the legal authorityto manage onsite systems, there is the recognitionthat both public health and water quality goals needto be incorporated into the management program’smission. Achievement of these goals requires acomprehensive watershed-based approach to ensurethat all of the program’s goals are met. Partnershipswith multiple agencies and other entities are oftenrequired to integrate planning, public healthprotection, and watershed protection in a meaning-ful way. Because of the breadth of the issuesaffecting onsite system management, many pro-grams depend on cooperative relationships withplanning authorities, environmental protection andpublic health agencies, universities, system manu-facturers, and service providers to help determineappropriate management goals and objectives.

2.4.3 Public health and resourceprotection goals

OWTS programs should integrate the followingtypes of goals: public health protection, abatementof nuisances, ground and surface water resourceprotection, and aquatic ecosystem protection.Setting appropriate program goals helps onsiteprogram managers determine desired performancegoals for treatment systems and influence siting,design, and management criteria and requirements.Examples of more detailed goals follow.

Public health protection goals:• Reduce health risk due to sewage backup in

homes.• Prevent ground water and well water contami-

nation due to pathogens, nitrates, and toxicsubstances.

• Prevent surface water pollution due to patho-gens, nutrients, and toxic substances.

• Protect shellfish habitat and harvest areas frompathogenic contamination and excessive nutri-ents

• Prevent sewage discharges to the ground surfaceto avoid direct public contact.

• Minimize risk from reuse of inadequatelytreated effluent for drinking water, irrigation, orother uses.

• Minimize risk from inadequate management ofseptic tank residuals.

• Minimize risk due to public access to systemcomponents.

Public nuisance abatement goals:• Eliminate odors caused by inadequate plumbing

and treatment processes.• Eliminate odors or other nuisances related to

transportation, reuse, or disposal of OWTSresiduals (septage).

Environmental protection goals:• Prevent and reduce adverse impacts on water

resources due to pollutants discharged to onsitesystems, e.g., toxic substances.

• Prevent and reduce nutrient overenrichment ofsurface waters.

• Protect sensitive aquatic habitat and biota

2.4.4 Comprehensive planningComprehensive planning for onsite systems hasthree important components: (1) establishing andimplementing the management entity, (2) establish-ing internal planning processes for the managemententity, and (3) coordination and involvement in thebroader land-use planning process. Comprehensive

The Department of Environmental Resources andHealth Department in Maryland’s Prince George’sCounty worked together to develop geographicinformation system (GIS) tools to quantify andmitigate nonpoint source nutrient loadings to thelower Patuxent River, which empties into theChesapeake Bay. The agencies developed adatabase of information on existing onsite systems,including system age, type, and location, withadditional data layers for depth to ground waterand soils. The resulting GIS framework allows usersto quantify nitrogen loadings and visualize likelyimpacts under a range of management scenarios.Information from GIS outputs is provided todecision makers for use in planning developmentand devising county management strategies.

Source: County Environmental Quarterly, 1997.



planning provides a mechanism to ensure that theprogram has the necessary information to functioneffectively.

It is necessary to ensure that onsite managementissues are integrated into decisions regarding futuregrowth and development. An effective onsite waste-water management program should be representedin the ongoing land use planning process to ensureachievement of the goals of the program and toassist planners in avoiding the shortcomings of pastplanning efforts, which generally allowed thelimitations of conventional onsite technologies todrive some land use planning decisions. Suchconsiderations are especially important in situationswhere centralized wastewater treatment systems arebeing considered as an alternative or adjunct toonsite or cluster systems. Comprehensive planningand land use zoning are typically interrelated andintegrated: the comprehensive planning processresults in the development of overarching policiesand guidance, and the land use zoning processprovides the detailed regulatory framework toimplement the comprehensive plan. Honachefsky(2000) provides a good overview of comprehensiveplanning processes from an ecological perspective.In general, the comprehensive plan can be used toset the broad environmental protection goals of thecommunity, and the zoning ordinance(s) can beused to

• Specify performance requirements for indi-vidual or clustered systems installed inunsewered areas, preferably by watershed and/orsubwatershed.

• Limit or prevent development on sensitivenatural resource lands or in critical areas.

• Encourage development in urban growth areasserviced by sewer systems, if adequate capacityexists.

• Factor considerations such as system density,hydraulic and pollutant loadings, proximity towater bodies, soil and hydrogeological condi-tions, and water quality/quantity into planningand zoning decisions.

• Restore impaired resources.

Integrating comprehensive planning and zoningprograms with onsite wastewater program manage-ment also can provide a stronger foundation fordetermining and requiring the appropriate level oftreatment needed for both the individual site andthe surrounding watershed or subwatershed. Theintegrated approach thus allows the programmanager to manage both existing and new onsitesystems from a cumulative loadings perspective orperformance-based approach that is oriented towardthe protection of identified resources. Local healthdepartments (regulatory authorities) charged withadministering programs based on prescriptive codestypically have not had the flexibility or the re-

Comprehensive planning program elementsComprehensive planning program elementsComprehensive planning program elementsComprehensive planning program elementsComprehensive planning program elements

• Define management program boundaries.

• Select management entity(ies).

• Establish human health and environmental protection goals.

• Form a planning team composed of management staff and local stakeholders.

• Identify internal and external planning resources and partners.

• Collect information on regional soils, topography, rainfall, and water quality and quantity.

• Identify sensitive ecological areas, recreational areas, and water supply protection areas.

• Characterize and map past, current, and future development where OWTSs are necessary.

• Coordinate with local sewage authorities to identify current and future service areas and determine treatmentplant capacity to accept septage.

• Identify documented problem areas and areas likely to be at risk in the future.

• Prioritize and target problem areas for action or future action.

• Develop performance requirements and strategies to deal with existing and possible problems.

• Implement strategy; monitor progress and modify strategy if necessary.



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sources to deviate from zoning designations and asa result often have had to approve permits fordevelopments where onsite system-related impactswere anticipated. Coordinating onsite wastewatermanagement with planning and zoning activitiescan ensure that parcels designated for developmentare permitted based on a specified level of onsitesystem performance that considers site characteris-tics and watershed-level pollutant loading analyses.To streamline this analytical process, some manage-ment programs designate overlay zones in whichspecific technologies or management strategies arerequired to protect sensitive environmental re-sources. These overlay zones may be based on soiltype, topography, geology, hydrology, or other sitecharacteristics (figure 2-1). Within these overlayzones, the RA may have the authority to specifymaximum system densities, system design require-ments, performance requirements, and operation/maintenance requirements. Although the use ofoverlay zones may streamline administrativeefforts, establishing such programs involves the useof assumptions and generalizations until a sufficientnumber of site-specific evaluations are available toensure proper siting and system selection.

Internally, changes in program goals, demograph-ics, and technological advances require informationand coordination to ensure that the short- and long-term goals of the program can continue to be met.Many variables affect the internal planning process,including factors such as the locations and types oftreatment systems within the jurisdictional area, thepresent or future organizational and institutionalstructure of the management entity, and the fundingavailable for program development and implemen-tation.

The box “Performance-based program elements”(page 2-21) provides guidance for planning pro-cesses undertaken by an onsite/decentralizedwastewater management entity. At a minimum, theonsite management entity should identify anddelineate the planning region, develop programgoals, and coordinate with the relevant publichealth, resource protection, economic development,and land-use planning agencies.

Figure 2-2 shows a process that might be useful indeveloping and implementing a performance-basedprogram whose objectives are to protect specificresources or achieve stated public health objectives.

2.4.5 Performance requirements

Many state and local governments are currentlyadopting or considering the use of performancerequirements to achieve their management goals.The management entity can use performancerequirements to establish specific and measurablestandards for the performance of onsite systemsthat are necessary to achieve the required level ofenvironmental or public health protection for anidentified management area and resource. All onsitewastewater management programs are based tovarying degrees on this concept. Traditionalprograms have elected to use prescriptive siting,design, and setback requirements to dictate whereand when conventional septic tank/SWIS systemsare appropriate. The prescriptive standards werebased on the presumption that systems sited anddesigned to these standards would protect publichealth. In most cases, this assumption provided anadequate level of protection, but the prescriptionsoften were based on standards adopted by othersand not based on scientific evaluations of the siteconditions of the community using them. As aresult, many programs based on prescriptiverequirements do not adequately protect theresource. (See chapter 5 for more detailed informa-tion about performance-based approaches.) TheNOWRA Model Framework for Unsewered Waste-water Infrastructure, discussed in chapter 1, alsoprovides a model for the development of perfor-mance-based programs (Walsh et al., 2001; seehttp://www.nowra.org).

Performance requirements provide the onsitesystem regulatory agency with an objective basis tooversee siting, system selection and design, installa-tion, maintenance, and monitoring of OWTS inorder to protect an identified resource or achieve astated public health goal. In jurisdictions whereperformance requirements are used, the regulatoryagency should not conduct site evaluations andspecify system designs because of potential conflictof interest issues regarding enforcement andcompliance; that is, the agency would be evaluatingthe performance of systems it designed and sited.The role of the regulatory agency in such a situa-tion should be to establish performance require-ments and provide oversight of management,operation, maintenance, and other activities con-ducted by private contractors or other entities.



Figure 2-2. Process for developing onsite wastewater management



Where appropriate, prescriptive guidelines forsiting, design, and operation that are accepted bythe management entity as meeting specific perfor-mance requirements for routine system applicationscan be appended to local codes or retained to avoidcost escalation and loss of qualified service provid-ers (Otis et al., 2001). Designating performancerequirements for areas of a management districtwith similar environmental sensitivities and siteconditions can provide property owners withvaluable information on performance expectationsand their rationale (Otis et al., 2001). Performancestandards can be determined based on the need toprotect a site-specific resource, such as residentialdrinking wells, or they can be based on larger-scaleanalyses intended to manage cumulative OWTSpollutant loadings (e.g., to protect a lake orestuary from nutrient enrichment).

Implementation of performance-based programsmight result in increased management expendituresdue to the need for staff to conduct site or areawide(e.g., watersheds, subwatersheds, or other geo-graphic areas) evaluations, inspect, and monitorsystem performance as necessary. Service providertraining, the evaluation and approval of new oralternative system designs, public outreach effortsto establish public support for this approach, andnew certification/licensing or permit programs willalso increase program costs. These increases canusually be recovered through permit/license fees.Also, system owners will be responsible foroperation and maintenance costs. The following

box contains a recommended list of elements for aperformance-based program.

2.4.6 Performance requirements andthe watershed approach

USEPA encourages the use of performance require-ments on a watershed, subwatershed, or sourcewater protection zone basis. These are usefulnatural units on which to develop and implementperformance-based management strategies. Insituations where jurisdictional boundaries crosswatershed, subwatershed, or source water rechargeboundaries, interagency coordination might beneeded. Setting performance requirements forindividual watersheds, subwatersheds, or sourcewater areas allows the program manager to deter-mine and allocate cumulative hydraulic and pollut-ant loads to ensure that the goals of the communitycan be met. To do so, an analysis to determinewhether the cumulative pollutant or hydraulicloadings can be assimilated by the receivingenvironment without degrading the quality of theresource or use is necessary. There is some uncer-tainty in this process, and program managersshould factor in a margin of safety to account forerrors in load and treatment effectiveness estimates.(Refer to chapter 3 for more information onestimating treatment effectiveness.)

Onsite systems are typically only one of manypotential sources of pollutants that can negativelyaffect ground or surface waters. In most cases other

Performance-based program elementsPerformance-based program elementsPerformance-based program elementsPerformance-based program elementsPerformance-based program elements

• Obtain or define legal authority to enact management regulations.

• Identify management area.

• Identify program goals.

• Identify specific resource areas that need an additional level of protection, e.g., drinking wateraquifers, areas with existing water quality problems, and areas likely to be at risk in the future.

• Establish performance goals and performance requirements for the management area and specificwatersheds, subwatersheds, or source water protection areas.

• Define performance boundaries and monitoring protocols.

• Determine and set specific requirements for onsite systems based on protecting specificmanagement areas and achieving of a specified level of treatment (e.g., within a particularsubbasin, there will be no discharge that contains more than 1.0 mg/L of total phosphorus).

• Develop or acquire information on alternative technologies, including effectiveness information andoperation and maintenance requirements (see chapter 4).

• Develop a review process to evaluate system design and system components (see chapter 5).



site level; that is, the individual OWTS must meetthe performance requirements at the treatmentperformance boundary or the point of compliance.

It should be noted that the performance-basedapproach is a useful program tool both to preventdegradation of a water resource and to restore adegraded resource. Additional information onantidegradation is available in USEPA’s WaterQuality Standards Handbook. (See http://www.epa.gov/waterscience/library/wqstandards/handbook.pdf. For general information on theUSEPA Water Quality Standards Program, seehttp://www.epa.gov/OST/standards/.) The CleanWater Act Section 303(d) program (Total Maxi-mum Daily Load [TMDL] program) has publishednumerous documents and technical tools regardingthe development and implementation of pollutantload allocations. This information can be found athttp://www.epa.gov/owow/tmdl/. (NOTE: Theidentification of other pollutant sources and theanalyses of loadings and modeling related toTMDL are beyond the scope of this document.)

The text above contains a list of steps that the OWTSprogram manager should consider in developingperformance requirements at a watershed scale.

Establishing performance requirements at a watershed scaleEstablishing performance requirements at a watershed scaleEstablishing performance requirements at a watershed scaleEstablishing performance requirements at a watershed scaleEstablishing performance requirements at a watershed scale

Establishing performance requirements involves a sequential set of activities at both the landscape level andthe site level. The following steps describe the general process of establishing performance requirements foronsite systems:

• Identify receiving waters (ground water, surface waters) for OWTS effluent.

• Define existing and planned uses for receiving waters (e.g., drinking water, recreation, habitat).

• Identify water quality standards associated with designated uses (check with state water agency).

• Determine types of OWTS-generated pollutants (e.g., nutrients, pathogens) that might affect use.

• Identify documented problem areas and areas likely to be at risk in the future.

• Determine whether OWTS pollutants pose risks to receiving waters.

• If there is a potential risk,

– Estimate existing and projected OWTS contributions to total pollutant loadings.

– Determine whether OWTS pollutant loadings will cause or contribute to violations of water quality ordrinking water standards.

– Establish maximum output level (mass or concentration in the receiving water body) for specifiedOWTS effluent pollutants based on the cumulative load analysis of all sources of pollutant(s) ofconcern.

– Define performance boundaries for measurement of OWTS effluent and pollutant concentrations toachieve watershed- and site-level pollutant loading goals.

sources of OWTS-generated pollutants (primarilynutrients and pathogens), such as agriculturalactivities or wildlife, are also present in the water-shed or subwatershed. To properly calculate thecumulative acceptable OWTS-generated pollutantloadings for a given watershed or subwatershed, allother significant sources of the pollutants thatmight be discharged by onsite systems should beidentified. This process requires coordinationbetween the onsite program manager and theagencies responsible for assessing and monitoringboth surface waters and ground water. Once allsignificant sources have been identified, the relativecontributions of the pollutants of concern fromthese sources should be determined and pollutantloading allocations made based on factors thecommunity selects. State water quality standardsand drinking source water protection requirementsare usually the basis for this process. Once loadingallocations have been made for all of the significantcontributing sources, including onsite systems, theOWTS program manager needs to develop orrevise the onsite program to ensure that the overallwatershed-level goals of the program are met.Cumulative loadings from onsite systems must bewithin the parameters set under the loading alloca-tions, and public health must be protected at the



The use of a watershed-based approach also affordsthe water quality and onsite program managerssome flexibility in determining how to most cost-effectively meet the goals of the community. Giventhe presence of both onsite systems and othersources of pollutants of concern, evaluations can bemade to determine the most cost-effective means ofachieving pollutant load reductions. For example,farmer or homeowner nutrient managementeducation might result in significant loadingreductions of nitrogen that could offset the need torequire expensive, more technically advancedonsite systems designed for nitrogen removal.

Watershed-level evaluations, especially in caseswhere new and refined monitoring methods areemployed, might also negate the need for systemupgrade or replacement in some watersheds. Forexample, new genetic tracing methods can providethe water quality program manager with a reliabletool to differentiate between human sources offecal coliform and animal contributions, bothdomestic and wild (see chapter 3). The use of thesenew methods can be expensive, but they mightprovide onsite program managers with a means ofeliminating onsite systems as a significant contrib-uting source of pathogens.

Onsite program managers have legitimate concernsregarding the adoption of a performance-basedapproach. The inherent difficulty of determiningcumulative loadings and their impacts on a watershed,the technical difficulties of monitoring the impactsof OWTS effluent, the evaluation of new technolo-gies and the potential costs, staffing and expertiseneeded to implement a performance-based programcan make this option more costly and difficult toimplement. (NOTE: In general, the RA should nothave the responsibility for monitoring systems

other than conducting random quality assuranceinspections. Likewise, the RA should not have theprimary responsibility of evaluating new or alterna-tive technologies. Technologies should be evaluatedby an independent entity certified or licensed toconduct such evaluations, such as an RME.)

Prescriptive regulatory codes that specify technolo-gies for installation under a defined set of siteconditions have worked reasonably well in the pastin many localities. The use of this approach, inwhich baseline design requirements and treatmenteffectiveness are estimated based on the use of thespecified technology at similar sites, will continueto be a key component of most managementprograms because it is practical, efficient, and easyto implement. Programs based purely on prescriptiverequirements, however, might not consistentlyprovide the level of treatment needed to protectcommunity water resources and public health.Many programs using prescriptive requirements arebased on empirical relationships that do not neces-sarily result in appropriate levels of treatment. Site-specific factors can also result in inadequatetreatment of OWTS effluent where a prescriptiveapproach is used. Political pressure to approvespecific types of systems for use on sites where

Performance requirements in Texas

In 1996 Texas eliminated percolation test requirementsfor onsite systems and instituted new performancerequirements for alternative systems (e.g., dripsystems, intermittent sand filters, leaching chambers).Site evaluations in Texas are now based on soil and siteanalyses, and service providers must be certified. Theseactions were taken after onsite system installationsnearly tripled between 1990 and 1997.

Source: Texas Natural Resource ConservationCommission, 1997.

ArArArArArizizizizona’ona’ona’ona’s perfs perfs perfs perforororormance-based technical standardsmance-based technical standardsmance-based technical standardsmance-based technical standardsizona’s performance-based technical standards

In 2001 Arizona adopted a rule containing technical standards foronsite systems with design flows less than 24,000 gallons per day(Arizona Administrative Code, Title 18, Chapters 5, 9, 11, and 14). Keyprovisions of the rule include site investigation requirements,identification of site limitations, design adjustments for better-than-primary treatment to overcome site limitations, and design criteria andnominal performance values for more than 20 treatment or effluentdispersal technologies. Applications for proposed systems are requiredto contain wastewater characterization information, technologyselections that address site limitations, soil treatment calculations, andeffluent dispersal area information. Technology-specific general groundwater discharge permits required under the new rule specify designperformance values for TSS, BOD, total coliforms, and TN. Productswith satisfactory third-party performance verification data might receiveadditional credits for continuing performance improvement. TheArizona rule contains important elements of performance-based andhybrid approaches through adoption of performance values andspecific use criteria for certain systems.

Source: Swanson, 2001.



prescriptive criteria are not met is another factorthat leads to the installation of inadequate systems.

2.4.7 Implementing performancerequirements through a hybridmanagement approach

RAs often adopt a “hybrid” approach that includesboth prescriptive and performance elements. To setappropriate performance requirements, cumulativeload analyses should be conducted to determine theassimilative capacity of the receiving environ-ment(s). This process can be costly, time-consum-ing, and controversial when water resource charac-terization data are incomplete, absent, or contested.Because of these concerns, jurisdictions might electto use prescriptive standards in areas where it hasbeen determined that onsite systems are not asignificant contributing source of pollutants or inareas where onsite systems are not likely to causewater quality problems. Prescriptive designs mightalso be appropriate and practical for sites whereprevious experience with specified OWTS designshas resulted in the demonstration of adequateperformance (Ayres Associates, 1993).

In those areas where problems due to pollutantstypically found in OWTS discharges have beenidentified and in areas where there is a significantthreat of degradation due to OWTS discharges(e.g., source water protection areas, recreationalswimming areas, and estuaries), performancerequirements might be appropriate. The use of aperformance-based approach allows jurisdictions toprioritize their resources and efforts to targetcollections of systems within an area or subwater-shed or individual sites within a jurisdictional area.

2.4.8 Developing and implementingperformance requirements

OWTS performance requirements should bedeveloped using risk-based analyses on a watershedor site level. They should be clear and quantifiableto allow credible verification of system perfor-mance through compliance monitoring. Perfor-mance requirements should at a minimum includestipulations that no plumbing backups or groundsurface seepage may occur and that a specifiedlevel of ground/surface water quality must bemaintained at some performance boundary, such asthe terminus of the treatment train, ground water

FlorFlorFlorFlorFlorida’ida’ida’ida’s perfs perfs perfs perforororormance-based permance-based permance-based permance-based permit progmit progmit progmit progrrrramamamamida’s performance-based permit program

Florida adopted provisions for permitting residential performance-based treatment systems in September 2000.The permit regulations, which can be substituted for provisions governing the installation of onsite systems underexisting prescriptive requirements, apply to a variety of alternative and innovative methods, materials, processes,and techniques for treating onsite wastewaters statewide. Discharges under the performance-based permitprogram must meet treatment performance criteria for secondary, advanced secondary, and advanced wastewatertreatment, depending on system location and the proximity of protected water resources. Performancerequirements for each category of treatment are as follows:

• Secondary treatment: annual arithmetic mean for BOD and TSS < 20 mg/L, annual arithmetic mean for fecalcoliform bacteria < 200 cfu/100 mL.

• Advanced secondary treatment: annual arithmetic mean for BOD and TSS < 10 mg/L, annual arithmetic meanfor total nitrogen < 20 mg/L, annual arithmetic mean for total phosphorus < 10 mg/L, annual arithmetic mean forfecal coliform bacteria < 200 cfu/100 mL.

• Advanced wastewater treatment: annual arithmetic mean for BOD and TSS < 5 mg/L, annual arithmetic meanfor total nitrogen< 3 mg/L, annual arithmetic mean for total phosphorus < 1 mg/L, fecal coliform bacteria count for any onesample < 25 cfu/100 mL.

Operation and maintenance manuals, annual operating permits, signed maintenance contracts, and biannualinspections are required for all performance-based systems installed under the new regulation. The operatingpermits allow for property entry, observation, inspection, and monitoring of treatment systems by state healthdepartment personnel.

Source: Florida Administrative Code, 2000.



surface, property line, or point of use(e.g., water supply well, recreational surface water,aquatic habitat area; see chapter 5).

If prescriptive designs are allowed under a perfor-mance-based program, these systems should beproven capable of meeting the same performancerequirements as a system specifically designed forthat site. Under this approach, the managemententity should determine through experience (monitor-ing and evaluation of the prescribed systems onsites with similar site characteristics) that thesystem will perform adequately to meet statedperformance requirements given sufficientlyfrequent operating inspections and maintenance.

Performance monitoring might be difficult andcostly. Although plumbing backups and groundsurface seepage can be easily and inexpensivelyobserved through visual monitoring, monitoringthe receiving environment (surface receiving watersand ground water) might be expensive and compli-cated. Monitoring of ground water is confoundedby the difficulty of locating and sampling subsur-face effluent plumes. Extended travel times,geologic factors, the presence of other sources ofground water recharge and pollutants, and thedispersal of OWTS pollutants in the subsurface allcomplicate ground water monitoring.

To avoid extensive sampling of ground water andsurface waters, especially where there are othercontributing sources of pollutants common toOWTS discharges, performance requirements canbe set for the treated effluent at a designatedperformance boundary before release into thereceiving environment (refer to chapters 3 and 5).Adjustments for the additional treatment, disper-sion, and dilution that will occur between theperformance boundary and the resource to beprotected should be factored into the performancerequirements. For example, pretreated wastewateris typically discharged to unsaturated soil, throughwhich it percolates before it reaches ground water.The performance requirement should take intoaccount the treatment due to physical (filtration),biological, and chemical processes in the soil, aswell as the dispersion and dilution that will occurin the unsaturated soil and ground water prior tothe point where the standard is applied.

As a practical matter, performance verification ofonsite systems can be relaxed for identified types of

systems that the RA knows will perform as antici-pated. Service or maintenance contracts or otherlegal mechanisms might be prerequisites to waivingor reducing monitoring requirements or inspec-tions. The frequency and type of monitoring willdepend on the management program, the technolo-gies employed, and watershed- and site-specificfactors. Monitoring and evaluation might occur ator near the site and include receiving environmentor water quality monitoring and monitoring toascertain hydraulic performance and influent flows.In addition, the OWTS management program needsto be evaluated to ascertain whether routine mainte-nance is occurring and whether individual systemsand types of systems are operating properly.

Chapter 4 contains descriptions of most of theonsite wastewater treatment processes currently inuse. OWTS program managers developing andimplementing performance-based programs willoften need to conduct their own site-specificevaluations of these treatment options. The text boxthat follows documents one approach used tocooperatively evaluate innovative or alternativewastewater treatment technologies. Many tribal,state, and local programs lack the capability tocontinually evaluate new and innovative technologyalternatives and thus depend on regional evalua-tions and field performance monitoring to providea basis on which to develop their programs.

2.4.9 Public education, outreach, andinvolvement

Public education and outreach are critical aspects ofan onsite management program to ensure publicsupport for program development, implementation,and funding. In addition, a working understandingof the importance of system operation and mainte-nance is necessary to help ensure an effectiveprogram. In general the public will want to knowthe following:• How much will it cost the community and the

individual?• Will the changes mean more development in my

neighborhood? If so, how much?• Will the changes prevent development?• Will the changes protect our resources (drinking

waters, shellfisheries, beaches)?



• How do the proposed management alternativesrelate to the above questions?

A public outreach and education program shouldfocus on three components—program audience,information about the program, and public out-reach media. An effective public outreach programmakes information as accessible as possible to thepublic by presenting the information in a nontech-nical format. The public and other interestedparties should be identified, contacted, and con-sulted early in the process of making major deci-sions or proposing significant program changes.Targeting the audience of the public outreach andeducation program is important for both maximiz-ing public participation and ensuring publicconfidence in the management program. For onsitewastewater system management programs, theaudiences of a public outreach and educationprogram can vary and might include:

• Homeowners• Manufacturers• Installers• System operators and maintenance contractors• Commercial or industrial property owner• Public agency planners• Inspectors• Site evaluators• Public• Students

• Citizen groups and homeowner neighborhoodassociations

• Civic groups such as the local Chamber ofCommerce

• Environmental groups

Onsite management entities should also promoteand support the formation of citizen advisorygroups composed of community members to buildor enhance public involvement in the managementprogram. These groups can play a crucial role inrepresenting community interests and promotingsupport for the program.

Typical public outreach and education programinformation includes:

• Promoting water conservation• Preventing household and commercial/industrial

hazardous waste discharges• Benefits of the onsite management program

Public outreach and education programs use avariety of media options available for informationdissemination, including:• Local newspapers• Radio and TV• Speeches and presentations• Exhibits and demonstrations• Conferences and workshops• Public meetings

A cooperative approach for approving innovative/alternative designs in New EnglandA cooperative approach for approving innovative/alternative designs in New EnglandA cooperative approach for approving innovative/alternative designs in New EnglandA cooperative approach for approving innovative/alternative designs in New EnglandA cooperative approach for approving innovative/alternative designs in New England

The New England Interstate Water Pollution Control Commission is a forum for consultation and cooperative actionamong six New England state environmental agencies. NEIWPCC has adopted an interstate process for reviewingproposed wastewater treatment technologies. A technical review committee composed of representatives from NewEngland state onsite wastewater programs and other experts evaluates innovative or alternative technologies orsystem components that replace part of a conventional system, modify conventional operation or performance, orprovide a higher level of treatment than conventional onsite systems.

Three sets of evaluation criteria have been developed to assess proposed replacement, modification, or advancedtreatment units. Review teams from NEIWPCC assess the information provided and make determinations that arereferred to the full committee. The criteria are tailored for each category but in general include:

• Treatment system or treatment unit size, function, and applicability or placement in the treatment train.

• Structural integrity, composition, durability, strength, and corresponding independent test results.

• Life expectancy and costs including comparisons with conventional systems/units.

• Availability and cost of parts, service, and technical assistance.

• Test data on prior installations or uses, test conditions, failure analysis, and tester identity.

Source: New England Interstate Water Pollution Control Commission, 2000.



• School programs• Local and community newsletters• Reports• Direct mailings, e.g., flyers with utility bills

2.4.10 Site evaluation

Evaluating a proposed site in terms of its environ-mental conditions (climate, geology, slopes, soils/landscape position, ground water and surface wateraspects), physical features (property lines, wells,hydrologic boundaries structures), and wastewatercharacteristics (anticipated flow, pollutant content,waste strength) provides the information needed tosize, select, and site the appropriate wastewatertreatment system. In most cases (i.e., under currentstate codes and lower-level management entitystructures) RAs issue permits—legal authorizationsto install and operate a particular system at aspecific site—based on the information collectedand analyses performed during the site evaluation.(NOTE: Detailed wastewater characterizationprocedures are discussed in chapter 3; site evalua-tion processes are presented in section 5.5.)

2.4.11 System design criteria andapproval process

Performance requirements for onsite systems canbe grouped into two general categories—numericrequirements and narrative criteria. Numericrequirements set measurable concentration or massloading limits for specific pollutants (e.g., nitrogenor pathogen concentrations). Narrative require-ments describe acceptable qualitative aspects of the

wastewater (e.g., sewage surface pooling, odor). Anumerical performance requirement might be thatall septic systems in environmentally sensitive areasmust discharge no more than 5 pounds of nitrogenper year, or that concentrations of nitrogen in theeffluent may be no greater than 10 mg/L. Some ofthe parameters for which performance requirementsare commonly set for OWTSs include:

• Fecal coliform bacteria (an indicator of patho-gens)

• Biochemical oxygen demand (BOD)• Nitrogen (total of all forms, i.e., organic,

ammonia, nitrite, nitrate)• Phosphorus (for surface waters)• Nuisance parameters (e.g., odor, color)

Under a performance-based approach, performancerequirements, site conditions, and wastewatercharacterization information drive the selection oftreatment technologies at each site. For knowntechnologies with extensive testing and field data,the management agency might attempt to instituteperformance requirements prescriptively bydesignating system type, size, construction prac-tices, materials to be used, acceptable site condi-tions, and siting requirements. For example, theArizona Department of Environmental Quality hasadopted a rule that establishes definitions, permitrequirements, restrictions, and performance criteriafor a wide range of conventional and alternativetreatment systems. (Swanson, 2001). Alaskarequires a 2-foot-thick sand liner when the receiv-ing soil percolates at a rate faster than 1 minute perinch (Alaska Administrative Code, 1999). At aminimum, prescriptive system design criteria

Site evaluation program elements

• Establish administrative processes for permit/siteevaluation applications.

• Establish processes and policies for evaluating siteconditions (e.g., soils, slopes, water resources).

• Develop and implement criteria and protocols forwastewater characterization.

• Determine level of skill and training required for siteevaluators.

• Establish licensing/certification programs for siteevaluators.

• Offer training opportunities as necessary.

Performance requirements and system design inMassachusetts

Massachusetts onsite regulations identify certain wellhead protectionareas, public water supply recharge zones, and coastal embaymentsas nitrogen-sensitive areas and require OWTSs in those areas to meetnitrogen loading limitations. For example, recirculating sand filters orequivalent technologies must limit total nitrogen concentrations ineffluent to no more than 25 mg/L and remove at least 40 percent ofthe influent nitrogen load. All systems in nitrogen-sensitive areas mustdischarge no more than 440 gallons of design flow per acre per dayunless system effluent meets a nitrate standard of 10 mg/L or othernitrogen removal technologies or attenuation strategies are used.Source: Massachusetts Environmental Code, Title V.



should consider the following. (See chapter 5 fordetails.)• Wastewater characterization and expected

effluent volumes.• Site conditions (e.g., soils, geology, ground

water, surface waters, topography, structures,property lines).

• System capacity, based on estimated peak andaverage daily flows.

• Location of tanks and appurtenances.• Tank dimensions and construction materials.• Alternative tank effluent treatment units and

configuration.• Required absorption field dimensions and

materials.• Requirements for alternative soil absorption

field areas.• Sizing and other acceptable features of system

piping.• Separation distances from other site features.• Operation and maintenance requirements (access

risers, safety considerations, inspection points).• Accommodations required for monitoring.

2.4.12 Construction and installationoversight authority

A comprehensive construction management pro-gram will ensure that system design and specifica-tions are followed during the construction process.If a system is not constructed and installed prop-erly, it is unlikely to function as intended. For

example, if the natural soil structure is not pre-served during the installation process (if equipmentcompacts infiltration field soils), the percolationpotential of the infiltration field can be signifi-cantly reduced. Most early failures of conventionalonsite systems’ soil absorption fields have beenattributed to hydraulic overloading (USEPA,1980). Effective onsite system managementprograms ensure proper system construction andinstallation through construction permitting,inspection, and certification programs.

Construction should conform to the approved planand use appropriate methods, materials, andequipment. Mechanisms to verify compliance withperformance requirements should be established toensure that practices meet expectations. Typicalexisting regulatory mechanisms that ensure properinstallation include reviews of site evaluationprocedures and findings and inspections of systemsduring and after installation, i.e., before cover-upand final grading. A more effective review andinspection process should include

• Predesign meeting with designer, owner, andcontractor

• Preconstruction meeting with designer, owner,and contractor

• Field verification and staking of each systemcomponent

• Inspections during and after construction• Issuance of a permit to operate system as

designed and built

Simplified incorporation of system design requirementsinto a regulatory program: the Idaho approach

Idaho bypasses cumbersome legislative processes when makingadjustments to its onsite system design guidelines by referencing atechnical manual in the regulation that is not part of the stateregulation. Under this approach, new research findings, newtechnologies, or other information needed to improve system designand performance can be incorporated into the technical guidancewithout invoking the regulatory rulemaking process. The regulationscontain information on legal authority, responsibilities, permitprocesses, septic tanks, and conventional systems. The referenceguidance manual outlines types of alternative systems that can beinstalled, technical and design considerations, soil considerations, andoperation and maintenance requirements.Source: Adapted from NSFC, 1995b.

Construction oversight program elements

• Establish preconstruction review procedure for siteevaluation and system design.

• Determine training and qualifications of systemdesigners and installers.

• Establish designer and installer licensing andcertification programs.

• Define and codify construction oversightrequirements.

• Develop certification process for overseeing andapproving system installation.

• Arrange training opportunities for service providersas necessary



Construction oversight inspections should be con-ducted at several stages during the system installa-tion process to ensure compliance with regulatoryrequirements. During the construction process,inspections before and after backfilling should verifycompliance with approved construction documentsand procedures. An approved (i.e., licensed orcertified) construction oversight inspector, prefer-ably the designer of the system, should overseeinstallation and certify that it has been conductedand recorded properly. The construction process forsoil-based systems must be flexible to accommo-date weather events because construction duringwet weather can compact soils in the infiltrationfield or otherwise alter soil structure.

2.4.13 Operation and maintenancerequirements

A recurring weakness of many existing OWTSmanagement programs has been the failure toensure proper operation and maintenance ofinstalled systems. Few existing oversight agenciesconduct inspections to verify basic system perfor-mance, and many depend on uninformed, untrainedsystem owners to monitor tank residuals buildup,schedule pumping, ensure that flow distribution isoccurring properly, check pumps and floatswitches, inspect filtration media for clogging, andperform other monitoring and maintenance tasks.Complaints to the regulatory authority or severeand obvious system failures often provide the onlyformal notification of problems under presentcodes. Inspection and other programs that monitorsystem performance (e.g., Critical Point Monitor-ing; see chapter 3) can help reduce the risk of

premature system failure, decrease long-terminvestment costs, and lower the risk of groundwater or surface water contamination (Eliasson etal., 2001; Washington Department of Health,1994).

Various options are available to implement opera-tion and maintenance oversight programs. Theserange from purely voluntary (e.g., trainedhomeowners responsible for their system operationand maintenance activities) to more sophisticatedoperating permit programs and ultimately toprograms administered by designated RMEs thatconduct all management/maintenance tasks. Ingeneral, voluntary maintenance is possible onlywhere systems are nonmechanical and gravity-based and located in areas with very low populationdensities. The level of management should increaseif the system is more complex or the resource(s) tobe protected require a higher level of performance.

Alarms (onsite and remote) should be considered toalert homeowners and service providers that systemmalfunction might be occurring. In addition tosimple float alarms, several manufacturers havedeveloped custom-built control systems that canprogram and schedule treatment process events,remotely monitor system operation, and notifytechnicians by pager or the Internet of possibleproblems. New wireless and computer protocols,cellular phones, and personal digital assistants arebeing developed to allow system managers toremotely monitor and assess operation of manysystems simultaneously (Nawathe, 2000), furtherenhancing the centralized management of OWTSsin outlying locations. Using such tools can saveconsiderable travel and inspection time and focus

Operation, maintenance, and residuals management program elementsOperation, maintenance, and residuals management program elementsOperation, maintenance, and residuals management program elementsOperation, maintenance, and residuals management program elementsOperation, maintenance, and residuals management program elements

• Establish guidelines or permit program for operation and maintenance of systems.

• Develop reporting system for operation and maintenance activities.

• Circulate operation and maintenance information and reminders to system owners.

• Develop operation and maintenance inspection and compliance verification program.

• Establish licensing/certification programs for service providers.

• Arrange for training opportunities as necessary.

• Establish procedures for follow-up notices or action when appropriate.

• Establish reporting and reminder system for monitoring system effluent.

• Establish residuals (septage) management requirements, manifest system, and disposal/usereporting.



field personnel on systems that require attention orregular maintenance. Telemetry panels at thetreatment site operating through existing or dedi-cated phone lines can be programmed to log andreport information such as high/low water alarmwarnings, pump run and interval times, water levelreadings in tanks/ponds, amperage drawn by systempumps, and other conditions. Operators at acentralized monitoring site can adjust pump runcycles, pump operation times, alarm settings, andhigh-level pump override cycles (Stephens, 2000).

Some management entities have instituted com-prehensive programs that feature renewable/revocable operating permits, mandatory inspec-tions or disclosure (notification/inspection) uponproperty transfer (e.g., Minnesota, Wisconsin,Massachusetts), and/or periodic monitoring bylicensed inspectors. Renewable operating permitsmight require system owners to have a contract with acertified inspection/maintenance contractor orotherwise demonstrate that periodic inspection andmaintenance procedures have been performed forpermit renewal (Wisconsin Department of Commerce,2001). Minnesota, Wisconsin, Massachusetts, andsome counties (e.g., Cayuga and other counties inNew York, Washtenaw County in Michigan) requirethat sellers of property disclose or verify systemperformance (e.g., disclosure statement, inspectionby the local oversight entity or other approvedinspector) prior to property transfer. Financialincentives usually aid compliance and can vary fromsmall fines for poor system maintenance to preventingthe sale of a house if the OWTS is not functioningproperly. Inspection fees might be one way tocover or defray these program costs. Lendinginstitutions nationwide have influenced the adoptionof a more aggressive approach toward requiring

system inspections before home or property loansare approved. In some areas, inspections at the timeof property transfer are common despite theabsence of regulatory requirements. This practice isincorporated into the loan and asset protectionpolicies of local banks and lending firms.

RAs, however, should recognize that reliance onlending institutions to ensure that proper inspec-tions occur can result in gaps. Property transferswithout lending institution involvement mightoccur without inspections. In addition, in caseswhere inspections are conducted by privateindividuals reporting to the lending agents, theinspectors might not have the same degree ofaccountability that would occur in jurisdictions thathave mandatory requirements for state or locallicensing or certification of inspectors. RAs shouldrequire periodic inspections of systems based onsystem design life, system complexity, andchanges in ownership.

Wisconsin’s new Private Onsite Wastewater Treat-ment System rule (see http://www.commerce.state.wi.us/SB/SB-POWTSProgram.html)requires management plans for all onsite treatmentsystems. The plans must include information andprocedures for maintaining the systems in accor-dance with the standards of the code as designedand approved. Any new or existing system that isnot maintained in accordance with the approvedmanagement plan is considered a human healthhazard and subject to enforcement actions. Themaintenance requirements are specified in the code.All septic tanks are to be pumped when the com-bined sludge and scum volume equals one-third ofthe tank volume. Existing systems have the addedrequirement of visual inspections every 3 years for

Onsite system disclosure requirements in MinnesotaOnsite system disclosure requirements in MinnesotaOnsite system disclosure requirements in MinnesotaOnsite system disclosure requirements in MinnesotaOnsite system disclosure requirements in Minnesota

Minnesota law requires that before signing an agreement to sell or transfer real property, a seller must disclose toa buyer in writing the status and location of all septic systems on the property, including existing or abandonedsystems. If there is no onsite treatment system on the property, the seller can satisfy the disclosure requirementby making such a declaration at the time of property transfer. The disclosure must indicate whether the system isin use and whether it is, to the seller’s knowledge, in compliance with applicable laws and rules. A map indicatingthe location of the system on the property must also be included. A seller who fails to disclose the existence orknown status of a septic system at the time of sale and who knew or had reason to know the existence or knownstatus of a system might be liable to the buyer for costs relating to bringing the system into compliance, as wellas reasonable attorney’s fees incurred in collecting the costs from the seller. An action for collection of thesesums must be brought within 2 years of the closing date.

Source: Minnesota Statutes, 2000.



wastewater ponding on the ground surface. Onlypersons certified by the department may performthe inspections or maintenance. Systems requiringmaintenance more than once annually requiresigned maintenance contracts and a notice ofmaintenance requirements on the property deed.The system owner or designated agent of the ownermust report to the department each inspection ormaintenance action specified in the managementplan at its completion (Wisconsin Department ofCommerce, 2001).

2.4.14 Residuals managementrequirements

The primary objective of residuals management isto establish procedures and rules for handling anddisposing of accumulated wastewater treatmentsystem residuals to protect public health and theenvironment. These residuals can include septageremoved from septic tanks and other by-productsof the treatment process (e.g., aerobic-unit-generatedsludge). When planning a program a thoroughknowledge of legal and regulatory requirementsregarding handling and disposal is important. Ingeneral, state and local septage managementprograms that incorporate land application or burialof septage must comply with Title 40 of the U.S.Code of Federal Regulations (CFR), Parts 503 and257. Detailed guidance for identifying, selecting,developing, and operating reuse or disposal sitesfor septage can be found in the USEPA ProcessDesign Manual: Land Application of SewageSludge and Domestic Septage (USEPA, 1995c),which is posted on the Internet at http://www.epa.gov/ORD/WebPubs/sludge.pdf. Addi-tional information is provided in Domestic SeptageRegulatory Guidance (USEPA, 1993b), posted athttp://www.epa.gov/oia/tips/scws.htm. Anotherdocument useful to practitioners and small commu-nities is the Guide to Septage Treatment andDisposal (USEPA, 1994).

States and municipalities typically establish otherpublic health and environmental protection regula-tions for residuals handling, transport, treatment, andreuse/disposal. In addition to regulations, practical

Requiring pump-outs to ensure propermaintenance

Periodic pumping of septic tanks is now required by lawin some jurisdictions and is becoming establishedpractice for many public and private managemententities. In 1991 Fairfax County, Virginia, amended itsonsite systems management code to require pumpingat least every 5 years. The action, which was based onprovisions of the Chesapeake Bay Preservation Act,was accompanied by public outreach notices and newsarticles. System owners must provide the county healthdepartment with a written notification within 10 days ofpumpout. A receipt from the pumpout contractor, whomust be licensed to handle septic tank residuals, mustaccompany the notification.

Source: Fairfax County Health Department, 1995.

Installer and designer permitting in New HampshireInstaller and designer permitting in New HampshireInstaller and designer permitting in New HampshireInstaller and designer permitting in New HampshireInstaller and designer permitting in New Hampshire

Onsite system designers and installers in New Hampshire have been required to obtain state-issued permits since1979. The New Hampshire’s Department of Environmental Services Subsurface Systems Bureau issues thepermits, which must be renewed annually. Permits are issued after successful completion of written examinations.The designer’s test consists of three written sections and a field test for soil analysis and interpretation. Theinstallers must pass only one written examination.

The tests are broad and comprehensive, and they assess the candidate’s knowledge of New Hampshire’s codifiedsystem design, regulatory setbacks, methods of construction, types of effluent disposal systems, and newtechnology. Completing the three tests designers must take requires about 5 hours. The passing grade is80 percent. The field test measures competency in soil science through an analysis of a backhoe pit,determination of hydric soils, and recognition of other wetland conditions. The 2-hour written exam for installersmeasures understanding of topography, regulatory setbacks, seasonal high water table determination, andacceptable methods of system construction.

Sources: Bass, 2000; New Hampshire Department of Environmental Services, 1991.



limitations such as land availability, site conditions,buffer zone requirements, hauling distances, fuelcosts, and labor costs play a major role in evaluatingseptage reuse/disposal options. These optionsgenerally fall into three basic categories—landapplication, treatment at a wastewater treatmentplant, and treatment at a special septage treatmentplant (see chapter 4). The initial steps in theresiduals reuse/disposal decision-making process arecharacterizing the quality of the septage and determiningpotential adverse impacts associated with various reuse/disposal scenarios. In general, program officials strive tominimize exposure of humans, animals, ground water,and ecological resources to the potentially toxic or

hazardous chemicals and pathogenic organismsfound in septage. Other key areas of residualsmanagement programs include tracking or manifestsystems that identify septage sources, pumpers,transport equipment, final destinations, and treat-ment methods, as well as procedures for controllinghuman exposure to residuals, including vectorcontrol, wet weather runoff management, andlimits on access to disposal sites. (Refer to chap-ter 4 for more details.)

2.4.15 Certification and licensing ofservice providers and programstaff

Certification and licensing of service providers suchas septage haulers, designers, installers, and mainte-nance personnel can help ensure management pro-gram effectiveness and compliance and reduce theadministrative burden on the RA. Certification andlicensing of service providers is an effective means ofensuring that a high degree of professionalism andexperience is necessary to perform specified activities.Maine instituted a licensing program for site evalua-tors in 1974 and saw system failure rates drop toinsignificant levels (Kreissl, 1982). The text box thatfollows provides a list of activities that managemententities should consider in setting up certification andlicensing programs or requirements.

RAs should establish minimum criteria for licens-ing/certification of all service providers to ensureprotection of health and water resources. Mainerequires that site evaluators be licensed (certified)and that designers of systems treating more than

RA/ME activities for training, certifying, andlicensing service providers

• Identify tasks that require in-house or contractorcertified/licensed professionals.

• Develop certification and/or licensing program basedon performance requirements.

• Establish process for certification/licensingapplications and renewals if necessary.

• Develop database of service providers, serviceprovider qualifications and contact information.

• Establish education, training, and experiencerequirements for service providers.

• Develop or identify continuing training opportunitiesfor service providers.

• Circulate information on available training to serviceproviders.

• Update service provider database to reflect verifiedtraining participation/performance.

Statewide training institute for onsite professionals in North CarolinaStatewide training institute for onsite professionals in North CarolinaStatewide training institute for onsite professionals in North CarolinaStatewide training institute for onsite professionals in North CarolinaStatewide training institute for onsite professionals in North Carolina

http://wwwhttp://wwwhttp://wwwhttp://www.soil.ncsu.edu/s.soil.ncsu.edu/s.soil.ncsu.edu/s.soil.ncsu.edu/swwwwetc/subsurfetc/subsurfetc/subsurfetc/subsurface/ace/ace/ace/subsurface.htmsubsurface.htmsubsurface.htmsubsurface.htm

North Carolina State University and other partners in the state developed the Subsurface WastewaterSystem Operator Training School (see http://www.soil.ncsu.edu/swetc/subsurface/subsurface.htm) in response to state rules requiring operators of some systems (e.g., large systemsand those using low-pressure pipe, drip irrigation, pressure-dosed sand filter, or peat biofiltertechnologies) to be certified. The school includes classroom sessions on wastewater characteristics,laws, regulations, permit requirements, and the theory and concepts underlying subsurface treatmentand dispersal systems. Training units also cover the essential elements of operating small and largemechanical systems, with field work in alternative system operation at NCSU’s field laboratory.Participants receive a training manual before they arrive for the 3-day training course. Certification ofthose successfully completing the educational program is handled by the Water Pollution ControlSystem Operators Certification Commission, an independent entity that tests and certifies systemoperators throughout North Carolina.

Source: NCSU, 2001



2,000 gallons per day or systems with unusualwastewater characteristics be registered professionalengineers. Prerequisites for applying for a siteevaluator permit and taking the certificationexamination are either a degree in engineering,

soils, geology, or a similar field plus 1 year ofexperience or a high school diploma or equivalentand 4 years of experience (Maine Department ofHuman Services, 1996). State certification andlicensing programs are summarized in table 2-2.

Table 2-2. Survey of state certification and licensing programs

Source: Noah, 2000.



2.4.16 Education and training programsfor service providers andprogram staff

Onsite system RAs, RMEs, and service providerstaff should have the requisite level of training andexperience to effectively assume necessary programresponsibilities and perform necessary activities.Professional programs are typically the mechanismfor ensuring the qualifications of these personnel.They usually include licensing or certificationelements, which are based on required courseworkor training; an assessment of knowledge, skills, andprofessional judgment; past experience; anddemonstrated competency. Most licensing programsrequire continuing education through recommendedor required workshops at specified intervals. Forexample, the Minnesota program noted previouslyrequires 3 additional days of training every 3 years.Certification programs for inspectors, installers,and septage haulers provide assurance that systemsare installed and maintained properly. States arebeginning to require such certification for allservice providers to ensure that activities theproviders conduct comply with program require-ments. Violation of program requirements or poorperformance can lead to revocation of certificationand prohibitions on installing or servicing onsitesystems. This approach, which links professionalperformance with economic incentives, is highlyeffective in maintaining compliance with onsiteprogram requirements. Programs that simply

register service providers or fail to take disciplinaryaction against poor performers cannot provide thesame level of pressure to comply with professionaland technical codes of behavior.

Some certification and licensing programs for thoseimplementing regulations and performing siteevaluations require higher educational achievement.For example, Kentucky requires a 4-year collegedegree with 24 hours of science coursework,completion of a week-long soils characterizationclass, and another week of in-service training forall permit writers and site evaluators (KentuckyRevised Statutes, 2001). Regular training sessionsare also important in keeping site evaluators,permit writers, designers, and other service person-nel effective. For example, the Minnesota Coopera-tive Extension Service administers 3-day work-shops on basic and advanced inspection and mainte-nance practices, which are now required forcertification in 35 counties and most cities in thestate (Shephard, 1996). Comprehensive trainingprograms have been developed in other states,including West Virginia and Rhode Island.

Sixteen states have training centers. For moreinformation on training programs for onsitewastewater professionals, including a calendar ofplanned training events and links to trainingproviders nationwide, visit the web site of theNational Environmental Training Center for SmallCommunities at West Virginia University at http://www.estd.wvu.edu/netc/

NSF onsite wastewater inspector accreditation programNSF onsite wastewater inspector accreditation programNSF onsite wastewater inspector accreditation programNSF onsite wastewater inspector accreditation programNSF onsite wastewater inspector accreditation programNSF International has developed an accreditation program designed to verify the proficiency of personsperforming inspections of existing OWTSs. The accreditation program includes written and field tests and providescredit for continuing education activities. Inspectors who pass the tests and receive accreditation are listed on theNSF International web site and in the NSF Listing Book, which is circulated among industry, government, andother groups.

The accreditation process includes four components. A written examination, conducted at designated locationsaround the country, covers a broad range of topics related to system inspections, including equipment, evaluationprocedures, troubleshooting, and the NSF International Certification Policies. The field examination includes anevaluation of an existing OWTS. An ethics statement, required as part of the accreditation, includes a pledge bythe applicant to maintain a high level of honesty and integrity in the performance of evaluation activities. Finally,the continuing education component requires requalification every 5 years through retesting or earningrequalification credits by means of training or other activities.

To pass the written examination, applicants must answer correctly at least 75 of the 100 multiple-choice questionsand score at least 70 percent on the field evaluation. A 30-day wait is required for retesting if the applicant failseither the written or field examination.

Source: Noah, 2000.



NETCSC_curricula.html. For links to state onsiteregulatory agencies, codes, and other information,visit http://www.estd.wvu.edu/nsfc/NSFC_links.html.

2.4.17 Inspection and monitoringprograms to verify and assesssystem performance

Routine inspections should be performed to ascer-tain system effectiveness. The type and frequencyof inspections should be determined by the size ofthe area, site conditions, resource sensitivity, thecomplexity and number of systems, and the re-sources of the RA or RME. The RA should ensurethat correct procedures are followed.

Scheduling inspections during seasonal rises inground water levels can allow monitoring ofperformance during “worst case” conditions. A siteinspection program can be implemented as a systemowner training program, an owner/operator con-tract program with certified operators, or a routineprogram performed by an RME. A combination of

visual, physical, bacteriological, chemical, andremote monitoring and modeling can be used toassess system performance. Specific requirementsfor reporting to the appropriate regulatory agencyshould be clearly defined for the managementprogram. Components of an effective inspection,monitoring, operation, and maintenance programinclude

• Specified intervals for required inspections(e.g., every 3 months, every 2 years, at time ofproperty transfer or change of use).

• Legal authority to access system components forinspections, monitoring, and maintenance.

• Monitoring of overall operation and perfor-mance, including remote sensing and failurereporting for highly mechanical and complexsystems.

• Monitoring of receiving environments atcompliance boundaries to meet performancerequirements.

• Review of system use or flow records, (e.g.,water meter readings).

• Required type and frequency of maintenance foreach technology.

• Identification, location, and analysis of systemfailures.

• Correction schedules for failed systems throughretrofits or upgrades.

• Record keeping on systems inspected, results,and recommendations.

Inspection programs are often incorporated intocomprehensive management programs as part of a

Providing legal access for inspections inColorado

Colorado regulations state that “the health officer or his/her designated agent is authorized to enter uponprivate property at reasonable times and uponreasonable notice . . . to conduct required tests, takesamples, monitor compliance, and make inspections.”

Source: NSFC, 1995a.

Inspection and monitoring program elementsInspection and monitoring program elementsInspection and monitoring program elementsInspection and monitoring program elementsInspection and monitoring program elements

• Develop/maintain inventory of all systems in management area (e.g., location, age, owner, type, size).

• Establish schedule, parameters, and procedures for system inspections.

• Determine knowledge level required of inspectors and monitoring program staff.

• Ensure training opportunities for all staff and service providers.

• Establish licensing/certification program for inspectors.

• Develop inspection program (e.g., owner inspection, staff inspection, contractor inspection).

• Establish right-of-entry provisions to gain access for inspection or monitoring.

• Circulate inspection program details and schedules to system owners.

• Establish reporting system and database for inspection and monitoring program.

• Identify existing ground water and surface water monitoring in area and determine supplemental monitoringrequired.



seamless approach that includes planning siteevaluation, design, installation, operation, mainte-nance, and monitoring. For example, the Town ofParadise, California, established an onsite wastewa-ter management program in Butte County in 1992after voters rejected a sewage plant proposal for acommercial area (NSFC, 1996). The programmanages 16,000 systems through a system ofinstallation permits, inspections, and operatingpermits with terms up to 7 years. Operating permitfees are less than $15 per year and are included inmonthly water bills. Regular inspections, tankpumping, and other maintenance activities areconducted by trained, licensed service providers,who report their activities to program administra-

tors. Paradise is one of the largest unseweredincorporated towns in the nation.

Outreach programs to lending institutions on thebenefits of requiring system inspections at the timeof property transfer can be an effective approachfor identifying and correcting potential problemsand avoiding compliance and enforcement actions.Many lending institutions across the nation requiresystem inspections as part of the disclosure require-ments for approving home or property loans. Forexample, Washington State has disclosure provi-sions for realtors at the point of sale, and manylending institutions have incorporated onsite systemperformance disclosure statements into their loanapproval processes (Soltman, 2000)

Source: Adapted from Ciotoli and Wiswall, 1982; USEPA, 2000.Table 2-3. Components of an onsite system regulatory program



2.4.18 Compliance, enforcement, andcorrective action programs

Requiring corrective action when onsite systemsfail or proper system maintenance does not occurhelps to ensure that performance goals and require-ments will be met. Compliance and enforcementmeasures are more acceptable to system owners andthe public when the RA is clear and consistentregarding its mission, regulatory requirements, andhow the mission relates to public health and waterresource protection. An onsite wastewater compli-ance and enforcement program should be based onreasonable and scientifically defensible regulations,promote fairness, and provide a credible deterrentto those who might be inclined to skirt its provi-sions. Regulations should be developed withcommunity involvement and provided in summaryor detailed form to all stakeholders and the publicat large through education and outreach efforts.Service provider training programs are mosteffective if they are based on educating contractorsand staff on technical and ecological approaches forcomplying with regulations and avoiding knownand predictable enforcement actions. Table 2-3describes the components of a regulatory programfor onsite/decentralized systems.

Various types of legal instruments are available toformulate or enact onsite system regulations.Regulatory programs can be enacted as ordinances,management constituency agreements, or local orstate codes, or simply as guidelines. Often, localhealth boards or other units of government canmodify state code requirements to better addresslocal conditions. Local ordinances that promoteperformance-based approaches can reference

technical design manuals for more detailed criteriaon system design and operation. Approaches forenforcing requirements and regulations of amanagement program can include

• Response to complaints• Performance inspections• Review of required documentation and reporting• Issuance of violation notices• Consent orders and court orders• Formal and informal hearings• Civil and criminal actions or injunctions• Condemnation of systems and/or property• Correcting system failures• Restriction of real estate transactions (e.g.,

placement of liens)• Issuance of fines and penalties

Some of these approaches can become expensive orgenerate negative publicity and provide little interms of positive outcomes if public support is notpresent. Involvement of stakeholders in the devel-opment of the overall management program helpsensure that enforcement provisions are appropriatefor the management area and effectively protecthuman health and water resources. Stakeholderinvolvement generally stresses restoration ofperformance compliance rather than more formalpunitive approaches.

Information on regional onsite system perfor-mance, environmental conditions, managementapproaches by other agencies, and trends analysesmight be needed if regulatory controls are in-creased. Most states establish regulatory programsand leave enforcement of these codes up to thelocal agencies. Table 2-4 contains examples ofenforcement options for onsite managementprograms.

A regulatory program focused on achievingperformance requirements rather than complyingwith prescriptive requirements places greaterresponsibilities on the oversight/permitting agency,service providers (site evaluator, designer, contrac-tor, and operator), and system owners. The man-agement entity should establish credible perfor-mance standards and develop the competency toreview and approve proposed system designs that amanufacturer or engineer claims will meet estab-lished standards. Continuous surveillance of theperformance of newer systems should occur

Corrective action program elements

• Establish process for reporting and responding toproblems (e.g., complaint reporting, inspections).

• Define conditions that constitute a violation ofprogram requirements.

• Establish inspection procedures for reportedproblems and corrective action schedule.

• Develop a clear system for issuing violation notices,compliance schedules, contingencies, fines, or otheractions to address uncorrected violations.



through an established inspection and complianceprogram. The service providers should be involvedin such programs to ensure that they develop theknowledge and skills to successfully design, site,build, and/or operate the treatment system withinestablished performance standards. Finally, themanagement entity should develop a replicableprocess to ensure that more new treatment tech-nologies can be properly evaluated and appropri-ately managed.

2.4.19 Data collection, record keeping,and reporting

Onsite wastewater management entities require avariety of data and other information to functioneffectively. This information can be grouped in thefollowing categories:

• Environmental assessment information: climate,geology, topography, soils, slopes, ground waterand surface water characterization data (includ-ing direction of flow), land use/land coverinformation, physical infrastructure (roads,water lines, sewer lines, commercial develop-ment, etc.).

• Planning information: existing and proposeddevelopment, proposed water or sewer lineextensions, zoning classifications, populationtrends data, economic information, informationregarding other agencies or entities involved inonsite wastewater issues.

• Existing systems information: record of siteevaluations conducted and inventory of allexisting onsite systems, cluster systems, packageplants, and wastewater treatment plants, includ-ing location, number of homes/facilities servedand size (e.g., 50-seat restaurant, 3-bedroom

Table 2-4. Compliance assurance approaches

Source: Ciotoli and Wiswall, 1982.



home), system owner and contact information,location and system type, design and sitedrawings (including locations of property lines,wells, water resources), system components(e.g., concrete or plastic tank, infiltration linesor leaching chambers), design hydraulic capac-ity, performance expectations or effluentrequirements (if any), installation date, mainte-nance records (e.g., last pumpout, repair,complaints, problems and actions taken, namesof all service providers), and septage disposalrecords. Many states and localities lack accurate

system inventories. USEPA (2000) recommendsthe establishment and continued maintenance ofaccurate inventories of all OWTSs within amanagement entity’s jurisdiction as a basicrequirement of all management programs.

• Administrative information: personnel files(name, education/training, work history, skills/expertise, salary rate, job review summaries),financial data (revenue, expenses, debts and debtservice, income sources, cost per unit of serviceestimates), service provider/vendor data (name,contact information, certifications, licenses, jobperformance summaries, disciplinary actions,work sites, cost record), management programinitiatives and participating entities, programdevelopment plans and milestones, septagemanagement information, and available resources.

Data collection and management are essential toprogram planning, development, and implementa-tion. The components of a management informa-tion system include database development, datacollection, data entry, data retrieval and integration,data analysis, and reporting. A variety of softwareis commercially available for managing systeminventory data and other information. Electronicdatabases can increase the ease of collecting,storing, retrieving, using, and integrating data afterthe initial implementation and learning curve havebeen overcome. For example, if system locations

Record keeping and reporting programelements

Establish a database structure and reporting systems,at a minimum, for

• Environmental assessments

• Planning and stakeholder involvement functions

• Existing systems

• Staff, service providers, financial, and otheradministrative functions

• Inspection and monitoring program, includingcorrective actions required

• Septage and residuals management, includingapproved haulers, disposal sites, and manifestsystem records

Use of onsite system tracking software in the Buzzards Bay watershedUse of onsite system tracking software in the Buzzards Bay watershedUse of onsite system tracking software in the Buzzards Bay watershedUse of onsite system tracking software in the Buzzards Bay watershedUse of onsite system tracking software in the Buzzards Bay watershed

The Buzzards Bay Project is a planning and technical assistance initiative sponsored by the stateenvironmental agency’s Coastal Zone Management Program. The Buzzards Bay Project was the first NationalEstuary Program in the country to develop a watershed Comprehensive Conservation and Management Plan,which the Governor and USEPA approved in 1991. The primary focus of the Buzzards Bay management plan isto provide financial and technical assistance to Buzzards Bay municipalities to address nonpoint sourcepollution and facilitate implementation of Buzzards Bay Management Plan recommendations. The Buzzards BayProject National Estuary Program provided computers and a software package to municipal boards of health inthe watershed to enable better tracking of septic system permits, inspection results, and maintenanceinformation. The software, along with the user’s manual and other information, can be downloaded from theInternet to provide easy access for jurisdictions interested in its application and use (see http://http://http://http://http://wwwwwwwwwwwwwww.b.b.b.b.buzzardsbauzzardsbauzzardsbauzzardsbauzzardsbayyyyy.org/septrfct.htm.org/septrfct.htm.org/septrfct.htm.org/septrfct.htm.org/septrfct.htm). This approach is designed to help towns and cities reduce the time theyspend filing, retrieving, and maintaining information through a system that can provide—at the click of amouse—relevant data on any lot in the municipality. The software program can also help towns respond toinformation requests more effectively, process permit applications more quickly, and manage new inspectionand maintenance reporting requirements more efficiently.

Source: Buzzards Bay Project National Estuary Program, 1999.



are described in terms of specific latitude andlongitude coordinates, a data layer for existingonsite systems can be created and overlaid ongeographic information system (GIS) topographicmaps. Adding information on onsite wastewaterhydraulic output, estimated mass pollutant loads,and transport times expected for specifiedhydrogeomorphic conditions can help managersunderstand how water resources become contami-nated and help target remediation and prioritizationactions. Models can also be constructed to predictimpacts from proposed development and assist insetting performance requirements for onsitesystems in development areas.

System inventories are essential elements formanagement programs, and most jurisdictionsmaintain databases of new systems through theirpermitting programs. Older systems (those installedbefore 1970), however, are often not included inthe system inventories. Some onsite managementprograms or other entities conduct inventories ofolder systems when such systems are included in aspecial study area. For example, Cass County andCrow Wing County in Minnesota have developedprojects to inventory and inspect systems at morethan 2,000 properties near lakes in the north-centralpart of the state (Sumption, personal communica-tion, 2000). The project inventoried systems thatwere less than 5 years old but did not inspect themunless complaint or other reports indicated possibleproblems. Costs for inventorying and inspecting234 systems in one lake watershed totaled $9,000, ornearly $40 per site (Sumption, personal communica-tion, 2000). Mancl and Patterson (2001) cite a costof $30 per site inspection at Lake Panorama, Iowa.

Some data necessary for onsite system managementmight be held and administered by other agencies.For example, environmental or planning agenciesoften collect, store, and analyze land and waterresource characterization data. Developing datasharing policies with other entities through coop-erative agreements can help all organizationsinvolved with health and environmental issuesimprove efficiency and overall program perfor-mance. The management agency should ensure thatdata on existing systems are available to health andwater resource authorities so their activities andanalyses reflect this important aspect of publichealth and environmental protection.

2.4.20 Program evaluation criteria andprocedures

Evaluating the effectiveness of onsite managementprogram elements such as planning, funding,enforcement, and service provider certification canprovide valuable information for improvingprograms. A regular and structured evaluation ofany program can provide critical information forprogram managers, the public, regulators, anddecision makers. Regular program evaluationsshould be performed to analyze program methodsand procedures, identify problems, evaluate thepotential for improvement through new technolo-gies or program enhancements, and ensure fundingis available to sustain programs and adjust programgoals. The program evaluation process shouldinclude

• A tracking system for measuring successand for evaluating and adapting programcomponents

• Processes for comparing program achievementsto goals and objectives

• Approaches for adapting goals and objectives ifinternal or external conditions change

• Processes for initiating administrative or legalactions to improve program functioning

• An annual report on the status, trends, andachievements of the management program

• Venues for ongoing information exchangeamong program stakeholders

A variety of techniques and processes can be usedto perform program evaluations to assess adminis-trative and management elements. The methodchosen for each program depends on local circum-stances, the type and number of stakeholders in-volved, and the level of support generated bymanagement agencies to conduct a careful, unbiased,detailed review of the program’s success in protectinghealth and water resources. Regardless of themethod selected, the program evaluation should beperformed at regular intervals by experienced staff,and program stakeholders should be involved.

A number of state, local, and private organizationshave implemented performance-based managementprograms for a wide range of activities, from statebudgeting processes to industrial productionoperations. The purpose of these programs is



twofold: linking required resources with manage-ment objectives and ensuring continuous improve-ment. Onsite management programs could also askpartnering entities to use their experience to helpdevelop and implement in-house evaluation processes.

2.5 Financial assistance formanagement programs andsystem installation

Most management programs do not construct orown the systems they regulate. Homeowners orother private individuals usually pay a permit fee tothe agency to cover site evaluation and permittingcosts and then finance the installation, operation,maintenance, and repair of their systems them-selves. During recent years, however, onsitemanagement officials and system owners havebecome increasingly supportive of centralized operation,maintenance, and repair services. In addition, somemanagement programs are starting to provideassistance for installation, repair, or replacement in theform of cost-share funding, grants, and low-interestloans. Some communities have elected to make atransition from individual systems to a clusteredapproach to capitalize on the financial and otherbenefits associated with the joint use of lagoons,drain fields, and other system components linked bygravity, vacuum, or low-pressure piping. Developers ofcluster systems, which feature individual septic tanksand collective post-tank treatment units, have beenparticularly creative and aggressive in obtainingfinancing for system installation.

Funding for site evaluation, permitting, andenforcement programs is generally obtained frompermit fees, property assessments (e.g., health districttaxes), and allocations from state legislatures forenvironmental health programs. However, manyjurisdictions have discovered that these fundingsources do not adequately support the full range ofplanning, design review, construction oversight,inspection and monitoring, and remediation functionsthat constitute well-developed onsite managementprograms. Urbanized areas have supplementedfunding for their management programs with feespaid by developers, monthly wastewater treatmentservice fees (sometimes based on metered wateruse), property assessment increases, professionallicensing fees, fines and penalties, and local generalfund appropriations. This section includes anoverview of funding options for onsite systemmanagement programs.

2.5.1 Financing options

Two types of funding are usually necessary forinstallation and management of onsite wastewatersystems. First, initial funding is required to pay forany planning and construction costs, which includelegal, administrative, land acquisition, and engi-neering costs. Once the construction is complete,additional funding is needed to finance the ongoingoperation and maintenance, as well as to pay forthe debt service incurred from borrowing the initialfunds. Table 2-6 lists potential funding sources andthe purposes for which the funds are typically used.As indicated in the table, each funding source hasadvantages and disadvantages. Decision makersmust choose the funding sources that best suit theircommunity.

Primary sources of funds include• Savings (capital reserve)• Grants (state, federal)• Loans (state, federal, local)• Bond issues (state, local)• Property assessments

Publicly financed support for centralized wastewa-ter treatment services has been available fordecades from federal, state, and local sources.Since 1990 support for public funding of onsitetreatment systems has been growing. The followingsection summarizes the most prominent sources of

Performance-based budgeting in Texas

Since 1993 state agencies in Texas have been requiredto develop a long-term strategic plan that includes amission statement, goals for the agency, performancemeasures, an identification of persons served by theagency, an analysis of the resources needed for theagency to meet its goals, and an analysis of expectedchanges in services due to changes in the law. Agencybudget line items are tied to performance measuresand are available for review through the Internet.Information on the budgeting process in Texas isavailable from the Texas Legislative Budget Board athttp://www.lbb.state.tx.us.

Source: Texas Senate Research Center, 2000.



Suggested approach for conducting a formal program evaluationSuggested approach for conducting a formal program evaluationSuggested approach for conducting a formal program evaluationSuggested approach for conducting a formal program evaluationSuggested approach for conducting a formal program evaluationForm a program evaluation teamForm a program evaluation teamForm a program evaluation teamForm a program evaluation team

Define the goals, objectives, and operational elements Define the goals, objectives, and operational elements Define the goals, objectives, and operational elements Define the goals, objectives, and operational elements

Review the program components checklist and feedbackReview the program components checklist and feedbackReview the program components checklist and feedbackReview the program components checklist and feedback

Identify program components or elements in need of improvementIdentify program components or elements in need of improvementIdentify program components or elements in need of improvementIdentify program components or elements in need of improvement

Communicate suggested improvements to program managersCommunicate suggested improvements to program managersCommunicate suggested improvements to program managersCommunicate suggested improvements to program managers

Form a program evaluation team composed of management program staff, service providers, public healthagency representatives, environmental protection organizations, elected officials, and interested citizens.

Define the goals, objectives, and operational elements of the various onsite management programcomponents. This can be done simply by using a checklist to identify which program components currently exist.Table 2-5 provides an excellent matrix for evaluating the management program.

Review the program components checklist and feedback collected from staff and stakeholders to determineprogress toward goals and objectives, current status, trends, cost per unit of service, administrative processesused, and cooperative arrangements with other entities.

Identify program components or elements in need of improvement, define actions or amount and type ofresources required to address deficient program areas, identify sources of support or assistance, discussproposed program changes with the affected stakeholders, and implement recommended improvement actions.

Communicate suggested improvements to program managers to ensure that the findings of the evaluationare considered in program structure and function.

Table 2-5. Example of Functional Responsibilities Matrix

*Management functions that require local agency input.



grant, loan, and loan guarantee funding and outlineother potential funding sources.

2.5.2 Primary funding sources

The following agencies and programs are among themost dependable and popular sources of funds foronsite system management and installation programs.

Clean Water State Revolving FundThe Clean Water State Revolving Fund, or CWSRF(see http://www.epa.gov/owm/finan.htm), is a

low- or no-interest loan program that has tradition-ally financed centralized sewage treatment plantsacross the nation. Program guidance issued in 1997emphasized that the fund could be used as a sourceof support for the installation, repair, or upgradingof onsite systems in small towns, rural areas, andsuburban areas. The states and the territory ofPuerto Rico administer CWSRF programs, whichoperate like banks. Federal and state contributionsare used to capitalize the fund programs, whichmake low- or no-interest loans for water qualityprojects. Funds are then repaid to the CWSRF overterms as long as 20 years. Repaid funds are re-cycled to fund other water quality projects. Projects

a Principal and interest payment (debt service) on various loans used for initial financing.Sources: Ciotoli and Wiswall, 1982, 1986; Shephard, 1996.

Table 2-6. Funding options



that might be eligible for CWSRF funding includenew system installations and replacement ormodification of existing systems. Costs associatedwith establishing a management entity to overseeonsite systems in a region, including capital outlays(e.g., for trucks on storage buildings), may also beeligible. Approved management entities includecity and county governments, special districts,public or private utilities, and private for-profit ornonprofit corporations.

U.S. Department of Agriculture RuralDevelopment programsU.S. Department of Agriculture Rural Develop-ment programs provide loans and grants to low andmoderate-income persons. State Rural Develop-ment offices administer the programs; for stateoffice locations, see http://www.rurdev.usda.gov/recd_map.html. A brief summary of USDA RuralDevelopment programs is provided below.

Rural Housing ServiceThe Rural Housing Service Single-Family HousingProgram (http://www.rurdev.usda.gov/rhs/Indi-vidual/ind_splash.htm) provides homeownershipopportunities to low- and moderate-income ruralAmericans through several loan, grant, and loanguarantee programs. The program also makesfunding available to individuals to finance vitalimprovements necessary to make their homes safeand sanitary. The Direct Loan Program (section502) provides individuals or families direct finan-cial assistance in the form of a home loan at anaffordable interest rate. Most loans are to familieswith incomes below 80 percent of the medianincome level in the communities where they live.

Applicants might obtain 100 percent financing tobuild, repair, renovate, or relocate a home, or topurchase and prepare sites, including providingwater and sewage facilities. Families must bewithout adequate housing but be able to afford themortgage payments, including taxes and insurance.These payments are typically within 22 to 26percent of an applicant’s income. In addition,applicants must be unable to obtain credit else-where yet have reasonable credit histories. Elderlyand disabled persons applying for the program mayhave incomes up to 80 percent of the area medianincome.

Home Repair Loan and Grant Program

For very low-income families that own homes inneed of repair, the Home Repair Loan and GrantProgram offers loans and grants for renovation.Money might be provided, for example, to repair aleaking roof; to replace a wood stove with centralheating; or to replace a pump and an outhouse withrunning water, a bathroom, and a waste disposalsystem. Homeowners 62 years and older areeligible for home improvement grants. Other low-income families and individuals receive loans at a1 percent interest rate directly from the RuralHousing Service. Loans of up to $20,000 andgrants of up to $7,500 are available. Loans are forup to 20 years at 1 percent interest.

Rural Utilities ServiceThe Rural Utilities Service (http://www.usda.gov/rus/water/programs.htm) provides assistance forpublic or not-for-profit utilities, including waste-water management districts. Water and wastedisposal loans provide assistance to develop waterand waste disposal systems in rural areas and townswith a population of 10,000 or less. The funds areavailable to public entities such as municipalities,counties, special-purpose districts, Indian tribes,and corporations not operated for profit. Theprogram also guarantees water and waste disposalloans made by banks and other eligible lenders.Water and Waste Disposal Grants can be accessed toreduce water and waste disposal costs to a reason-able level for rural users. Grants might be made forup to 75 percent of eligible project costs in somecases.

Financial assistance program elements

• Determine program components or system aspectsthat require additional financial assistance.

• Identify financial resources available for systemdesign, installation, operation, maintenance, andrepair.

• Research funding options (e.g., permit or user fees,property taxes, impact fees, fines, grants/loans).

• Work with stakeholder group to execute or establishselected funding option(s).



Rural Business-Cooperative ServiceThe Rural Business-Cooperative Service (http://www.rurdev.usda.gov/rbs/busp/b&i_gar.htm)provides assistance for businesses that provideservices for system operation and management.Business and Industry Guaranteed Loans can bemade to help create jobs and stimulate ruraleconomies by providing financial backing for ruralbusinesses. This program provides guarantees up to90 percent of a loan made by a commercial lender.Loan proceeds might be used for working capital,machinery and equipment, buildings and realestate, and certain types of debt refinancing.Assistance under the Guaranteed Loan Program isavailable to virtually any legally organized entity,including a cooperative, corporation, partnership,trust or other profit or nonprofit entity, Indian tribeor federally recognized tribal group, municipality,county, or other political subdivision of a state.

Community Development Block GrantsThe U.S. Department of Housing and UrbanDevelopment (HUD) operates the CommunityDevelopment Block Grant (CDBG) program, whichprovides annual grants to 48 states and Puerto Rico.The states and Puerto Rico use the funds to awardgrants for community development to smaller citiesand counties. CDBG grants may be used fornumerous activities, including rehabilitatingresidential and nonresidential structures, construct-ing public facilities, and improving water andsewer facilities, including onsite systems. USEPAis working with HUD to improve access to CDBGfunds for treatment system owners by raisingprogram awareness, reducing paperwork burdens,and increasing promotional activities in eligibleareas. More information is available at http://www.hud.gov/cpd/cdbg.html.

Nonpoint Source Pollution Program

Clean Water Act section 319 (nonpoint sourcepollution control) funds can support a wide rangeof polluted runoff abatement, including onsitewastewater projects. Authorized under section 319of the federal Clean Water Act and financed byfederal, state, and local contributions, these projectsprovide cost-share funding for individual andcommunity systems and support broader watershedassessment, planning, and management activities.Projects funded in the past have included directcost-share for onsite system repairs and upgrades,assessment of watershed-scale onsite systemcontributions to polluted runoff, regionalremediation strategy development, and a widerange of other programs dealing with onsitewastewater issues. For example, a project con-ducted by the Gateway District Health Departmentin east-central Kentucky enlisted environmentalscience students from Morehead State University tocollect and analyze stream samples for fecalcoliform “hot spots.” Information collected by thestudents was used to target areas with failingsystems for cost-share assistance or otherremediation approaches (USEPA, 1997b). TheRhode Island Department of EnvironmentalManagement developed a user-friendly systeminspection handbook with section 319 funds toimprove system monitoring practices and thendeveloped cost-share and loan programs to helpsystem owners pay for needed repairs (USEPA,1997). For more information, see http://www.epa.gov/OWOW/NPS/.

2.5.3 Other funding sources

Other sources of funding include state financeprograms, capital reserve or savings funds, bonds,

PENNVESTPENNVESTPENNVESTPENNVESTPENNVEST::::: Financing onsite w Financing onsite w Financing onsite w Financing onsite w Financing onsite wasteasteasteasteastewwwwwater systems in the Kater systems in the Kater systems in the Kater systems in the Kater systems in the Keeeeeystone Stateystone Stateystone Stateystone Stateystone State

The Pennsylvania Infrastructure Investment Authority (PENNVEST) provides low-cost financing for systems onindividual lots or within entire communities. Teaming with the Pennsylvania Housing Finance Agency and thestate’s Department of Environmental Protection, PENNVEST created a low-interest onsite system loan programfor low- to moderate-income (150 percent of the statewide median household income) homeowners. The $65application fee is refundable if the project is approved. The program can save system owners $3,000 to $6,000in interest payments on a 15-year loan of $10,000. As of 1999 PENNVEST had approved 230 loans totaling $3.5million. Funds for the program come from state revenue bonds, special statewide referenda, the state generalfund, and the State Revolving Fund.

Source: PADEP, 1998.



Funding systems and management inMassachusetts

The Commonwealth of Massachusetts has developedthree programs that help finance onsite systems andmanagement programs. The loan program providesloans at below-market rates. A tax credit programprovides a tax credit of up to $4,500 over 3 years todefray the cost of system repairs for a primaryresidence. Finally, the Comprehensive CommunitySeptic Management Program provides funding for long-term community, regional, or watershed-basedsolutions to system failures in sensitive environmentalareas. Low-interest management program loans of upto $100,000 are available.

Source: Massachusetts DEP, 2000.

certificates of participation, notes, and propertyassessments. Nearly 20 states offer some form offinancial assistance for installation of OWTSs,through direct grants, loans, or special project cost-share funding. Capital reserve or savings funds areoften used to pay for expenses that might not beeligible for grants or loans, such as excess capacityfor future growth. Capital reserve funds can also beused to assist low- and moderate-income house-holds with property assessment or connection fees.

Bonds usually finance long-term capital projectssuch as the construction of OWTSs. States, munici-palities, towns, townships, counties, and specialdistricts issue bonds. The two most common typesof bonds are general obligation bonds, which arebacked by the faith and credit of the issuinggovernment, and revenue bonds, which are sup-ported by the revenues raised from the beneficiariesof a service or facility. General obligation bondsare rarely issued for wastewater treatment facilitiesbecause communities are often limited in theamount of debt they might incur. These bonds aregenerally issued only for construction of schools,libraries, municipal buildings, and police or firestations.

Revenue bonds are usually not subject to debtlimits and are secured by repayment through userfees. Issuing revenue bonds for onsite projectsallows a community to preserve the general obliga-

tion borrowing capacity for projects that do notgenerate significant revenues. A third and lesscommonly used bond is the special assessmentbond, which is payable only from the collection ofspecial property assessments. Some states adminis-ter state bond banks, which act as intermediariesbetween municipalities and the national bondmarket to help small towns that otherwise wouldhave to pay high interest rates to attract investors orwould be unable to issue bonds. State bond banks,backed by the fiscal security of the state, can issueone large, low-interest bond that funds projects in anumber of small communities

Communities issue Certificates of Participation(COPs) to lenders to spread out costs and risks ofloans to specific projects. If authorized under statelaw, COPs can be issued when bonds would exceeddebt limitations. Notes, which are written promisesto repay a debt at an established interest rate, aresimilar to COPs and other loan programs. Notes areused mostly as a short-term mechanism to financeconstruction costs while grant or loan applicationsare processed. Grant anticipation notes are securedby a community’s expectation that it will receive agrant. Bond anticipation notes are secured by thecommunity’s ability to sell bonds.

Finally, property assessments might be used torecover capital costs for wastewater facilities thatbenefit property owners within a defined area. Forexample, property owners in a specific neighbor-


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hood could be assessed for the cost of installingsewers or a cluster treatment system. Depending onthe amount of the assessment, property ownersmight pay it all at once or pay in installments at aset interest rate. Similar assessments are oftencharged to developers of new residential or com-mercial facilities if the developers are not requiredto install wastewater treatment systems approved bythe local regulatory agency. Funding for ongoingmanagement of onsite systems in newly developedareas should be considered when these assessmentsare calculated.

Although funds from grants, special projects, andother one-time sources can help initiate specialprojects or develop new functions, support foronsite management over the long term should comefrom sources that can provide continuous funding(table 2-7). Monthly service fees, property assess-ments, regular general fund allocations, and permit/licensing fees can be difficult to initiate but providethe most assurance that management programactivities can be supported over the long term.Securing public acceptance of these financingmechanisms requires stakeholder involvement intheir development, outreach programs that providea clear picture of current problems and expectedbenefits, and an appropriate matching of commu-nity resources with management program need.

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