Reminder to Submit Complete Septic Applications, Comply with Septic Standards, and Maintain Professional Communications

Dear Septic Professionals,

This message is intended as a reminder to please submit complete septic applications in accordance with county standards including the OWTS Manual v7.0, policies and procedures, and published guidance documents as well as to encourage and promote professional communications.

While the OWTS Manual established some minimum information for what constitutes a complete application and what should be included in septic documents, we must also have a more nimble mechanism to detail and update what should be included as part of a complete application and within the application documents.  Guidance documents that address the administrative permit application and processing information are much easier to manage and update than revising regulations and codes.  This is why we use guidance documents for complete application submittals throughout Permit Sonoma.  Guidance for what constitutes a complete septic application is available on our website: WLS-008 Septic System Application Requirements. 

Septic applications must be submitted through our Permits Online website.  Please use our published guidance document (form WLS-008) to assist you in determining what constitutes a complete application for your specific project and to ensure the information contained within your application documents comply with our requirements.  The exception to the application contents from our guidance document is that we do not require multiple sets of the same documents to be submitted now that we only accept electronic applications.  Please ensure all required application documents are submitted with your electronic application so that we can better and more quickly process and review septic applications.

Some specific noteworthy items related to septic applications include:

• We now offer two separate and distinct types of septic applications; Septic Construction Applications and Septic Design Applications.  Septic Construction Applications should be submitted for projects intended to be constructed or vested while Septic Design Applications should be submitted for projects not intended to be constructed or vested.  Please visit our Septic Application Types webpage to learn more about Septic Construction Applications and Septic Design Applications and please ensure you apply for the correct type of application.
• All septic applications for new and replacement systems must include both a site plan and a design report with all applicable information described in our guidance document within the respective documents.  Site plans are generally considered the construction document to demonstrate compliance with septic standards and to be used install the septic system while design reports are considered the supporting documentation (including narrative information, calculations, site/soil evaluation information, and any other relevant information to support the septic system design) to construction document that is the site plan.

In addition to the information provided in the guidance document, septic applications must comply with all applicable OWTS Manual v7.0 standards.  We have encountered many instances where the septic application (plans and/or design reports) do not comply with the OWTS Manual v7.0 standards which leads to delays in permit issuance or prolonged disagreements between consultants and staff.  Please ensure septic applications comply with all applicable standards.  Doing so will assist Permit Sonoma staff to review and approve septic applications in much more timely manner.

Some examples of the discrepancies we’re experiencing include but are not limited to the following:

• OWTS Manual Section 7.4.D is not being met.  Designers are not showing at least one soil profile hole in the primary area and one soil profile hole in the reserve replacement area as the OWTS Manual requires.  Too often designers are placing either areas within an assumed acceptable distance to a soil profile hole.  The standard states a minimum of two soil profiles are required; one in the primary area and one in the reserve replacement area. There is no reference to an acceptable distance to a soil profile hole.  Please ensure that all septic applications for new or replacement systems meet this standard.
• The OWTS Manual does not provide any effective area or radius for a soil profile hole for which soil conditions may be assumed to be the same as the location of the soil profile hole.  Currently, designers are making various assumptions for the effective area or radius of soil profile holes.  This approach enables inconsistency and invites discretion into the review process.  When the OWTS Manual is updated we will address this omission but in the meantime staff and consultants need some better guidance.  Our most common past practice has been to apply a 50’ effective radius to soil profile holes.  In an effort to offer more clarity and consistency, we will continue using a 50’ effective radius for soil profile holes and are hereby notifying septic design professional of this direction.  Please take note of this and ensure all septic applications for new and replacement systems comply with this determination.
• Similarly, the OWTS Manual does not provide any effective area or radius for a percolation test hole for which percolation rates may be assumed to be the same as the location of the percolation test hole.  When the OWTS Manual is updated we will also address this omission but in the meantime staff and consultants need some better guidance.  Our most common past practice has been to apply a 25’ effective radius to percolation test holes.  In an effort to offer more clarity and consistency, we will continue using a 25’ effective radius for percolation test holes and are hereby notifying septic design professional of this direction.  Please take note of this and ensure all septic applications for new and replacement systems comply with this determination.
• Multiple septic systems require demonstrating permeable soil at least 24 inches below trench bottom at least 25 feet down gradient from the edge of the last proposed trench, drip line, or sand perimeter. This standard applies to bottom primary and reserve replacement areas.  Please ensure that all septic applications for new or replacement systems meet this standard.

Permit Sonoma staff have been directed to ensure septic applications comply with the OWTS Manual v7.0 standards, septic policies and procedures, and published guidance documents.  This is to better ensure consistent reviews are being performed by the section as a whole and to reduce as much discretion as possible in the application review process.  Staff should and will comment when standards are not being met. That’s their job and the direction they’ve been provided.  Please try to understand and respect their role as regulators in the partnership we have with our customers.

Professionalism During COVID-19

We also want to take this opportunity to acknowledge the current pandemic situation that has challenged both Permit Sonoma staff, our customers, and our community.  Many of us are working from home, tending to child care or distant learning demands, experiencing difficulties with technology, have been impacted by multiple emergencies including public health orders, fires, extreme heat waves, and power outages, and dealing with a variety of personal and professional issues.  In spite of all this, we are a community of professionals that can come together and, for the most part, has been able to work amicably through permitting issues, differences in code interpretations, and challenges with virtual inspections.

However, not all have maintained civil or professional interactions.  We’d like to remind all to please be professional when communicating with Permit Sonoma staff and refrain from interjecting personal innuendoes or disparaging comments about staff in any form of communication with the department.  We realize we are not working in the most ideal situation and there are delays in services and responses but our staff are working hard and diligently to provide a variety of services to our community with limited resources.  We expect staff to be professionals in the work they perform and in their communication efforts.  We do not think it unreasonable to expect the same from private consultants.  If anyone does experience any unprofessional behavior from staff please notify their supervisor and we’ll investigate the situation.  Conversely, we ask that private consultants also maintain a civil and professional demeanor.