ENV TASK FORCE FINAL REPORT TO BOS_11.3.25.PDF
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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