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PA-1800185 (SA), S00011909 Page 2 of 2 11075 W. Larch Road, Tracy September 2, 2018 3. The 2002 OWTS repair permit was for a 4 bedroom dwelling. Current information indicates the dwelling contains 6 bedrooms. Based on this information, the existing OWTS serving the dwelling may be undersized. 4. The proposed OWTS for the project and the 100% future repair area represented on the plot plan is not drawn to scale and does not fit in the area shown on the plot plan, as proposed. All items on the parcel must be represented and drawn to scale on the plot plan. Information Relating to the Provision of Water As of January 2017, State law requires any small public water system to consolidate to a nearby public water system. This development project meets the definition of a small public water system and would likely be required to consolidate to the City of Tracy water system. Health and Safety Code Section 116527 requires an a preliminary technical report to be submitted to the State Water Resources Control Board, Division of Drinking Water(DDW) at least six months before an application to operate a new small public water system can be submitted. The current location and distance of the existing water well, as denoted on the plot plan, to the existing OWTS may not meet the required setbacks, including those specific to protect a small public water system well source. Information Relating to the Disposal of Sewage Any future OWTS for this project must be evaluated based on the fully defined project scope. The EHD has received conflicting information in Soil Suitability and Nitrate Loading Studies (SSNLS) and other documentation submitted for the expired proposal. To be accurate and to avoid confusion and inconsistencies, the SSNLS must be based on a specifically defined project scope. As noted above, the project lacks sufficient detail on the scope of development and activities and a SSNLS cannot be appropriately compiled or evaluated without this information. It is important to note that a SSNLS that shows an impact to groundwater from the OWTS requires an engineered OWTS designed to mitigate that impact to protect the beneficial uses of the groundwater resource. The project location must have sufficient area available to support the existing and proposed development and the utilization of an onsite well and OWTS. All items on the parcel must be fully represented and drawn to scale to allow an evaluation to make this determination. Based on the information provided to date, it has not been established that the parcel can support the proposed development project.