ENV TASK FORCE FINAL REPORT TO BOS_11.3.25.PDF

Maricopa County — Informal (2025-11-03)

View PDF Item 1 Meeting page

Extracted text (via pymupdf) 12016 characters
Environmental Services Department 
301 W. Jefferson St., Suite 170  
Phoenix, Arizona 85003 
P: 602.506.6616 
Maricopa.gov/Enviro 
 
 
 
 
 
 
ENVIRONMENTAL SERVICES DEPARTMENT AD HOC STAKEHOLDER TASK FORCE FINAL REPORT 
 
With the direction of the Board, an ad hoc task force committee was formed to review the service level and processes of the 
Environmental Services Department (ESD). At the invitation of Chairman Galvin, key stakeholders, comprised of a diverse 
group of professionals who are interested and involved in the services provided by ESD's Onsite Program, participated in a 
kickoff meeting on July 31, 2025. There was an active, open discussion of the department’s strengths and identification of 
areas for review and improvement. 
 
Based on the discussion items from the initial meeting, the committee members met biweekly starting on August 14, 2025. 
During the first meeting, a chairperson was selected to lead and focus the group’s efforts. As the stakeholders worked through 
the areas of interest, key staff provided support by preparing notes and providing information on current processes, reference 
material, and organizational history. 
 
The task force held its last meeting on October 10, 2025, to reach a consensus on the final recommendations from all 
members. As a result of their commitment to the process and intense efforts, 27 recommendations were developed. 
 
Due to the nature and scope of the recommendations, staff have been proactive in working to implement many of the 
recommendations. For those recommendations that require additional time, resources, and further stakeholder input, a phased 
implementation schedule has been proposed. 
 
Below is a high-level summary of those recommended actions being submitted to the Maricopa County Board of Supervisors 
for review and consideration.

Environmental Services Department 
301 W. Jefferson St., Suite 170  
Phoenix, Arizona 85003 
 
P: 602.506.6616 
Maricopa.gov/Enviro 
 
 
Onsite Recommendations 
Issues Reviewed: 
Recommendation(s) & Supporting Information: 
Status: 
 
1.   Interpretation of requirements needs 
to be communicated more 
effectively.  
 
A) Develop a procedure for customers to escalate 
concerns or disagreements regarding rule 
requirements to the Business & Community Liaison 
and the Engineering Manager. 
 
 
 
B) Provide direction in the staff training review 
manual for resolving conflicts with general permits 
related to proprietary products, such as engineered 
pads. The guidance will direct staff to give greater 
weight to the ADEQ-approved installation manual. 
 
C) Develop and provide customers with guidance on 
deviations from the proprietary products 
installation manual and the reasoning behind the 
deviation. 
 
D) Advertise on the department's website the current 
procedure for accepting Certificates of Completion 
from the installer, express agent, or implied agent 
(when the original designer or engineer is 
unavailable). 
 
E) Share new rule interpretations and enforcement 
process with stakeholders prior to implementation 
via the Waterworks Bulletin. Share final rule 
interpretations via the Waterworks Bulletin. 
A)   In Progress – Creation of the 
WaterWorks Bulletin template has 
been completed. Release of a 
procedure for stakeholders to 
escalate concerns will be released in 
a bulletin by 11/30/25. 
 
B)   In Progress – To be released in a 
WaterWorks Bulletin prior to 
12/31/2025. 
 
 
 
C)   In Progress – Guidance will be 
developed and updated as code 
deviations and conflicts are identified 
by 12/31/2025.  
 
D)   In Progress – Guidance documents 
will be created and released prior to 
1/31/2026 regarding acceptance of 
Certificates of Completion.  
 
 
E)   In Progress – To be released in an 
ongoing manner via the WaterWorks 
Bulletin when new rule interpretations 
are created by 12/31/2025.

Environmental Services Department 
301 W. Jefferson St., Suite 170  
Phoenix, Arizona 85003 
 
P: 602.506.6616 
Maricopa.gov/Enviro 
 
 
 
F) Schedule quarterly check-in meeting between 
Environmental Services and Planning & 
Development to ensure consistency with septic 
system reviews. 
 
F)   Completed – An initial meeting with 
PND is scheduled for 11/19/2025, and 
the agenda includes items meant to 
assist ENV and PND with consistent 
reviews among organizations.  
 
 
2.   Requirements related to alluvial 
basins are unclear due to 
inconsistencies with publicly 
available maps.  
A)   Provide a directive in the staff training review 
manual that staff utilize the Arizona 
       Department of Environmental Quality's online 
alluvial map to make compliance 
       determinations. 
 
A)   In Progress – The staff training 
manual will be updated with this 
information prior to 11/30/2025. 
 
 
3.    Lack of clarity and current practices 
regarding subdivision soil testing 
requirements cause delays and 
unnecessary expense. 
A) Create a procedure that allows a health certificate 
to be issued based on the submittal of a geological 
report signed by a registered engineer (or 
geologist), submittal of geological data, and a 
statement from the engineer attesting that the soil 
conditions are such that individual disposal 
systems can reasonably be expected to function 
properly on each lot in the proposed subdivision. 
 
A)    Complete – The procedure for 
allowing greater reliance on 
subdivision health certificate reviews 
has been developed and 
communicated to staff.  
 
4.   Sometimes designers get a second 
hold letter with new items that were 
not addressed on the first hold letter. 
A)   The On-site Program will develop written guidance 
for staff to: 
 
Ensure the same plan reviewer reviews plans 
for contiguous lots. Investigate Permit Center 
applications fields for the applicant to specify 
when there are contiguous lots. 
 
Ensure plan reviewers include all deficiencies 
on the initial hold letter. 
 
Prohibit the addition of hold items based on 
phone conversations or email exchanges. 
 
Provide red line annotations when they are 
required by a municipality. 
 
 
 
 
A)    In Progress – The requested 
information has been communicated 
to staff and will be memorialized in 
training documents prior to 
11/30/2025.

Environmental Services Department 
301 W. Jefferson St., Suite 170  
Phoenix, Arizona 85003 
 
P: 602.506.6616 
Maricopa.gov/Enviro 
 
 
B) Develop a list of top hold letter items/deficiencies 
and other common mistakes and best practices 
when submitting applications. Publish this 
information on the department's website, with a 
link to the information in Permit Center and the 
Waterworks bulletin. 
 
B)    In Progress – A document with top 
hold letter items has been created 
and will be released via the 
WaterWorks Bulletin before 
11/30/2025. 
 
 
 
5.   Wait times tend to average 3-5 days 
for inspections. Ideal wait times 
should be 1-2 business days to align 
with building inspections. 
 
A)   Maintain 1-2 day response time to inspection 
requests by developing a procedure that prescribes 
virtual re-inspections and/or photographs for re-
inspections that do not require major 
modifications. 
 
B)   Provide direction in the staff training review manual 
that approval from the engineer or registered 
sanitarian is sufficient to issue Construction 
Authorizations for alternative systems. The 
direction will outline that the purpose of a staff site 
visit is to obtain as-built drawings for the records 
and identify any critical components that may be 
missing. 
 
C)   Develop procedures to better train Onsite 
Wastewater Program inspectors on alternative 
systems and network with the industry for in-
person training. 
 
A)    In Progress – Inspection training 
documents are in the process of 
being updated with a procedure for 
virtual re-inspections. The procedure 
will be finalized before 12/31/2025. 
 
B)    In Progress – Inspection training 
documents are being updated 
accordingly. The procedure will be 
finalized before 12/31/2025. 
 
 
 
 
C)    In Progress – Inspection training 
documents are being updated 
accordingly. The procedure will be 
finalized before 12/31/2025. The 
Onsite Program will advertise 
quarterly staff meetings via the 
WaterWorks Bulletin to help facilitate 
presentations and training with 
stakeholders.  
 
 
6.   If a significant change is needed on a 
conventional system after a 
Construction Authorization is issued, 
the original designer should be 
involved in approving it. 
 
A)   Develop guidance in the staff training manual to 
ensure revisions submitted after the Construction 
Authorization are completed by the original 
designer or their designee. Where revisions from 
the original designer are not possible, the record 
will be updated to reflect who prepared the 
revisions. 
A)    In Progress – A procedure to ensure 
the original septic system designer is 
involved when revisions are required 
or when the original designer is no 
longer available. The new designer’s 
information will appear on the record 
for consistency by 11/30/2025.

Environmental Services Department 
301 W. Jefferson St., Suite 170  
Phoenix, Arizona 85003 
 
P: 602.506.6616 
Maricopa.gov/Enviro 
 
 
 
 
7.    Arizona Department of 
Environmental Quality’s (ADEQ) 
onsite wastewater rules cause 
delays and unnecessary expense 
because they are outdated, unclear, 
and do not adequately consider 
current practices. 
A) Send a formal letter from the MCESD director 
to the ADEQ director identifying outdated rules 
and associated regulatory issues and 
concerns. The letter will also be signed by 
members of the Ad Hoc Task Force: 
 
There is no process for new owners of 
properties with alternative systems to be 
made aware of the O&M requirements for 
their septic systems. 
 
Clarification is needed on where seepage 
pit performance test (SPPT) locations 
should be in relation to the proposed 
disposal area. 
 
Greater consideration should be given to 
not requiring a reserve area in septic 
subdivisions. Space constraints make it 
difficult to place a reserve area in some 
subdivisions. 
 
Subdivision soil testing requirements are 
not clear for health certification approval. 
 
The interpretation of a "contiguous site" is 
inconsistent. 
o 
Recommend to ADEQ that 
consideration be given to mobile 
home parks and aging 
infrastructure. Currently, mobile 
home parks are operating with 
septic systems in failure. The 
current rule prohibits new permits 
for many of these parks due to 
R18-9-E323 (e.g., seepage pits, 
nitrogen). An exemption should be 
given to allow for a one-time 
replacement of failing systems 
that pollute to a greater degree 
than a properly functioning system 
would in mobile home parks. 
A)    In Progress – MCESD will draft and 
send the letter as described before 
11/30/2025.

Environmental Services Department 
301 W. Jefferson St., Suite 170  
Phoenix, Arizona 85003 
 
P: 602.506.6616 
Maricopa.gov/Enviro 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Clarity and clear parameters are needed 
for determinations of sewer availability. 
 
There is no way to extend or renew a septic 
permit construction authorization. 
Consideration should be given to renew 
septic construction authorizations without 
a reapplication.

Environmental Services Department 
301 W. Jefferson St., Suite 170  
Phoenix, Arizona 85003 
 
P: 602.506.6616 
Maricopa.gov/Enviro 
 
 
 
 
 
 ACTION REQUESTED 
 
The requested action is to consider the recommendations, accept the report, whole or in part, as submitted by the Ad Hoc 
Task Force, and provide guidance and direction to staff. 
 
 
 
 
 
 
 
 
 
 
 
Special thank you to staff and stakeholders for their time and commitment to this process:  
 
Onsite Task Force Committee: David Pounders (Committee Chair), Brian Mings, Dan Caparros, David Bartholomew, Jaimee 
Griffin, Kathy Mills, Mark Basic, Tabitha Zapata 
  
Staff: Ryan Hall, Brian Knisley, Logan Peiman, and Andy Linton