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2. If the imported soil material to increase the leachline trenches/disposal area elevation does not match the existing native soil characteristics, problems with continuity of permeability between the two strata could result, including surfacing of effluent at the line of demarcation. 3. On August 29, 2019, the former Director of EHD, Ms. Linda Turkatte, issued a permit for a septic system repair (See Attached). This project is approximately 2.5 miles southwest of the subject site. I know for a fact that perc rates in this locale can range from 20-30 min/in, and I also know for a fact that the water table can be within five feet below grade during the irrigation season. Ms. Turkatte didn't seem to have much concern regarding an eight -foot separation distance for this project, so why should my client be held to a different standard? 4. The LAMP Policy Number Section 9.4.8., Relevant Lamp Section 8, Page 33, Legal Authority Code Section: OWTS Policy Approved LAMP SJC Ord. Code, Title 9, Sewage Standards: "Encroachment Above Groundwater" states that "Bottom of OWTS dispersal systems cannot be less than 2 ft above groundwater, or bottom of seepage pits, less than 10 feet above groundwater." Page 33 of the LAMP states that "fast percolation rates are addressed when the initial soil suitability and nitrate loading study is conducted and mitigations are required as part of the design parameters. Mitigation can range from engineered fill in the dispersal area to the installation of a supplemental treatment system. "Sewage Standards Section 10. 3.11 requires a minimum five-foot separation from the bottom of the leach trench to groundwater." As the civil engineer -of -record for this project, the referenced natural mitigations outlined in Item 1 above were used in the design parameters, as outlined in my report. 5. Mr. Ahmed Hussein, retired Command Sergeant Major US Army, who has served our Country with the upmost distinction, has already spent in excess of $500,000 (soil and equipment costs) raising the building pad 14 feet above surrounding flood plain elevation. The 1997 flood, which some consider to be a 500 year flood, only discharged approximately two inches of water depth to the area surrounding the subject property, and this was primarily due to a levee break. If Mr. Hussein purchased flood insurance at the quoted price of $2k/month, it would take 21 years to be an approximate equivalent cost to soil importation. Mr. Hussein projects an additional $85,000 cost in soil importation to increase leachline trenches/disposal area elevation. This is a cost he should not have to bear. Comments from Questa Engineering also include the following: "Normally several percolation tests (3 to 6) are conducted to provide a representative characterization of soil conditions in the planned leachfield area." It is not "normal" to conduct 3 to 6 perc tests in a leachfield area unless the engineer has reason to believe, or proof, that there has been changes to the soil characteristics due to plowing (particularly ripping), there was a very poor water quality source applied to the area, or the disposal area is unusually large (>0.25 ac). Soils characteristics very rarely change dramatically in a relatively short distance. Page 2 of 3 Chesney Consulting