(Date)
Thomas Starosta - Department of Environmental Protection
Bureau of Point and Non-Point Source Management
P.O. Box 8774
Harrisburg, PA 17105-8774
Re:
Document Number: 385-2208-001
Dear Mr. Starosta:
I am a land owner in ___________County, I write in opposition to the Department’s proposed guidance document, “Sewage Facilities
Planning Module Review for On-lot Sewage Systems Proposed in High Quality and Exceptional Value Watersheds.”

Northeast Pennsylvania is the land of lakes, ponds and streams. The water quality is mostly HQ and EV. Therefore, my first
question for PA DEP is why are you proposing this guidance? We should be rewarded for our efforts, not punished.

We have been good stewards of the land. The current onlot septic system practices that have been used in Northeastern
Pennsylvania have worked. The water quality is proof. Such practices currently used are; site-specific soils analysis,
inspection repair programs, replacement systems, proper siting and other site specific requirements.

On page 5 of the proposed policy, IV Onlot Sewage System and Water Quality, the policy states, “In the soil absorption field,
organic compounds are degraded and impurities are filtered out in the soil matrix. A septic system that is property designed,
located, installed and maintained through periodic pumping of the septic tank can treat sewage safely and effectively for
decades.” These are your words.

This policy is not based on any scientific studies. PA DEP should make decisions and policy based on proven scientific
facts. On page 7 of the proposed policy, it states, “Septic systems generally are not capable of affecting surface waters to the
degree where the 10 mg/L limit may be threatened, but for the purpose of this guidance, a more stringent standard applies.
Why? This is ten times more restrictive. This is not science but progressive policy.

If the State of Pennsylvania is to have economic growth and development, these kinds of arbitrary regulations must be
stopped. Projects that have substantial job creation will go to other states before incurring these additional costs and land use
restrictions. In fact this proposed policy could cause many of our current residents to leave Pennsylvania for a more friendly
state to live in. This will also cause many of our young people to leave Pennsylvania because they would not be able to
afford a home.

Under this guidance the most valuable land—that which is adjacent to lakes and streams—will become undevelopable and
restricted in use. This could result in land values being reduced because of the restrictions on the use of this land. The result
is likely to be a decreased tax base that will burden counties, municipalities and school districts as tax revenues decline.

For Pennsylvania’s economy to grow, it needs a housing market that provides housing to low and moderate income residents.
PA DEP, guided by sound science, should be focusing on addressing real water quality problems around the state in a way
that provides options to affected property owners that achieve the maximum environmental benefit. This needs to be done at
the lowest possible cost and stimulates critically needed jobs and economic growth.

When will PA DEP start paying the real estate taxes on all the land that we citizens have lost the use of?
Thank you for your consideration.
Respectively submitted,
Cc:
Governor Corbett