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Soil chemistry data in Table 1 illustrates the soil characteristics correlated from the TIC project with the <br /> subject project,and was used to arrive at a reasonable denitrification factor. As noted,the denitrification <br /> factor of 60% is 33% lower than if I used 90%denitrification. A denitrification factor of 54%could have <br /> been used and still remained under the Nitrate Loading Standards. There are other projects that I have been <br /> involved with that illustrate similar denitrification percentages based upon the soil chemistry and texture <br /> analyses obtained. In addition,I did witness the installation of the septic tank that serves the existing <br /> modular home on the subject property and observed that the soil is of consistent characteristics to an <br /> approximate depth of eight ft. <br /> It should be noted that in the last five years, several arbitrary and capricious changes and misinterpretations <br /> were made to the nitrate loading equation factors and procedures by an outside consultant retained by the <br /> EHD and by the former Unit 1I Program Manager. These include arbitrarily changing the wastewater flow <br /> volumes emanating from single family residential structures, lack of understanding and misinterpretation of <br /> evapotranspiration/evaporation concepts,misunderstanding stormwater flow volume calculations, <br /> incorporating additional area into a well-defined subject property area, etc. <br /> Although an applicant's consultant is under no obligation to use the Hantzsche-Finnemore equation, it is <br /> used extensively for nitrate loading calculations. However, it must be understood that the equation has no <br /> less than a dozen variables and/or unknowns associated with it. <br /> Consequently, it is my opinion that a consulting civil engineer on a nitrate loading project should have the <br /> ability to make determinations such as denitrification factors, based upon their experience,knowledge, <br /> expertise and chemistry test results. It has been my observation after having reviewed several different <br /> nitrate loading studies,that other consultants are not conducting soil chemistry and texture analyses on <br /> specific projects. <br /> Respectfully submitted, �a4rofess;o.. <br /> CHESNEY CONSULTING `at�oo D. ChLIQ <br /> 04 No.7U79 <br /> Cb <br /> n <br /> s # <br /> fire Civil is <br /> Don Chesney,PE or Calif°� <br /> Registered Civil Engineer#C75479 <br /> Certified Crop Advisor/Manure Management Advisor/Nitrogen Management Plan Specialist#341829 <br /> Page 2 of 2 <br /> Cliesney Consulting <br />