HomeMy WebLinkAboutLetter from David Moench DRil.l_iNC1 COMPANY
P.O. BOX 1029
OROVILLE, CA 95965
(530) 589-3914
License 425609
Cathy Raevsky 24 August 2016
Butte County Director of Public Health
202 Mira Loma Drive
Oroville, CA 95965
Dear Cathy;
On August 15, 2016, 1 was told there is a rea'uirement to install a 50' seal even
where a consolidated formation such as solid rock was found at 18'. The
California State Standards (guidelines) clearly state that only a 20' seal is
required for private water well. Butte County Code 2313-913: Well Sealing
adopted 4/22/14 and effective 5/22/14, states "the sea/shall be extended (5)
feet into the first consolidated formation encountered below fifteen (15) feet to
a maximum required sealing depth of fifty (1510) feet."
The Butte County Board of Supervisors adopted a standard allowing a setback
of 50' from the leach lines if the lot was created prior to 1976 and even before
well ordinances were created. This standard has been used for over 30 years
and now Ms. Morgado is changing it--she has instructed Brad Banner (a
R.E.H.S/Environmental Health Director) to require a 100' setback.
On August 16, 2016, Ms. Morgado stated there must be a 100' setback from
septic tanks. This is a new requirement, which the qualified, registered inspectors
(R.E.H.S.) are not aware of. A non-registered staff member should not be able to
change practices that have been used for years without going through the
proper channels and following the proper protocol. Ms. Morgado is trying to
implement Bulletin 74-90, which is NOT law. In fact, it is still in draft form and has
not been fully adopted by Butte County.
What are the qualifications of the senior Environmental Health staff members? It
appears they have no institutional knowledge or experience with water wells.
They only know what they read from books, unlike the REHS inspectors and the
EH Director that have to get re-certified every two years and receive on-going
education and training. It seems your two Public Health Assistant Directors are
far less qualified in your department than your inspectors. The minimum
education requirements for their positions is a bachelor's degree in Business
Administration, Public Administration, Public Health, Health Sciences, Behavioral
Health, Social Sciences, or any closely related field. I will admit Mr. Quin does
have a BS in Business Administration, but it and the majority of his prior work
experience has been in Human Resources. How does that fit into Public Health?
Ms. Morgado has a BA in French Language and Literature and one in Political
Science and Government. How does this satisfy the education requirement?
How are either of these a "closely related field"? Or do you consider her
certificates in plant-based nutrition and whole foods nutrition "health sciences"?
Lastly, what are Kristen McKillop's qualifications? I see by her job description
that it is preferable that she has a master's degree, but is required to have a
bachelors degree in administration or management. Again, how do any of
those degrees transfer to her having the ability make decisions or try to
implement laws, regulations or guidelines concerning water wells?
Please help me understand how unregistered people have authority over the
registered ones. Why do they have the power to make technical decisions
when they do not have the technical knowledge to do so? Why are they trying
to implement these changes? Butte County has does not have a history of
problematic wells.
I look forward to your written reply.
Sincerely,
David R. Moench
I
Cc: Board of Supervisors
3 TV f,�,