Committee Summary for JLCAR Administrative Rules (12/18/2025)

Bill/Time	Type	Title	Sponsor
Unclear 00:05:49.280 - 8:00:26 AM	General Working Session	Unclear

Unclear: Senator Long Information Only00:05:49.280 - 8:00:26 AM; Led the pledge of allegiance at the start of the meeting.
Unclear: Chair (unnamed) Information Only00:05:49.280 - 8:00:26 AM; Opened the meeting, approved minutes, seated alternates, approved consent agenda, and introduced the first rule discussion.
Unclear: Attorney Ricard (Staff) Information Only00:07:00.479 - 8:01:37 AM; Provided staff comments on Department of Health and Human Services rule 25188, noting new rules implementing RSA 170-E:50, and issues with amended conditional approval request regarding deletions causing discrepancies between rule text and forms. Confirmed that proposed oral amendments resolve the issues.
Unclear: Nicole Valzola, Department of Health and Human Services Information Only00:10:01.839 - 8:04:38 AM; Explained amendments to rule 25188, adding definition of New Hampshire professional registry training transcript on page 15 and matching language to the form on page 17 for clarity and consistency.
Unclear: Representative (unnamed) Information Only00:11:06.640 - 8:05:43 AM; Questioned if fees on page 13 of rule 25188 are sufficient to cover program costs; agency confirmed they do, supported by federal funds.
Unclear: Senator Innis Information Only00:11:06.640 - 8:05:43 AM; Moved to approve rule 25188 as amended with oral edits.
Unclear: Attorney Ricard (Staff) Information Only00:12:18.320 - 8:06:55 AM; Provided staff comments on Department of Environmental Services rule 25206, noting conditional approval addressed most comments but raised legislative intent issue on expired fine schedule from 2008, and clarified provisions allowing replacement of smaller septic tanks via waivers and replacement in kind sections.
Unclear: Adam Crapo, Assistant Commissioner, Department of Environmental Services Information Only00:15:49.440 - 8:10:26 AM; Introduced team members Phil Trobridge and Courtney Lockwood; noted no fines assessed under expired rules for years, and this rule adds fine schedule to program rules.
Unclear: Chair (unnamed) Information Only00:16:50.880 - 8:11:27 AM; Confirmed discussions with agency addressed waiver process clarity, grandfathering for seasonal campgrounds and dispersed septic systems, ensuring replacements in kind without upgrades unless expanding use.
Unclear: Representative (unnamed) Information Only00:19:30.799 - 8:14:07 AM; Raised concern about form requiring 1,000-gallon minimum for permit by rule; agency clarified it's for single-family residences, not applicable to campgrounds, and general applications allow grandfathering and waivers.
Unclear: Christopher Albert, CSA Environmental Consultants Oppose00:22:04.720 - 8:16:41 AM; Testified against aspects of rule 25206 on daily flows and minimum bedroom size for water meter data. Argued that assuming two people per bedroom increases calculated flows excessively (e.g., from 5,398 to 8,640 gallons/day in example), overriding beneficial water meter data for disadvantaged manufactured home cooperatives. Cited census data showing average 2.5 people per home nationally, and examples from NH parks showing lower actual usage. Noted minimum 12-bedroom threshold discriminates against small parks with fewer units, leading to higher costs and financial impact on low-income residents. Provided handouts and letter to DES.
Unclear: Representative (unnamed) Information Only00:26:26.480 - 8:21:03 AM; Sought clarification that water meter data shows lower usage than two-people-per-bedroom assumption, emphasizing benefits for leach field sizing in manufactured home parks.
Unclear: Senator (unnamed) Information Only00:30:26.720 - 8:25:03 AM; Questioned conservative estimates, peaking factors, and potential overuse of safety factors leading to oversized systems; suggested lower peaking factor like 1.25 for various building types, noting lower usage in manufactured parks.
Unclear: Philip Trobridge, Department of Environmental Services Information Only00:33:01.840 - 8:27:38 AM; Responded to testimony, defending two-people-per-bedroom for individual on-site systems to prevent undersizing and costly failures, unlike averages for large systems. Explained grandfathering and waiver processes allow existing uses to continue without upgrades unless expanding. Clarified drinking water rule citation is for community system thresholds, not design flows. Defined metered flows as measured water inflow, useful for larger facilities (minimum 12 bedrooms for reliability); book values unchanged for new construction. Addressed housing crisis concerns, noting recent legislative changes reduce costs, and emphasized long-term replacement costs outweigh initial sizing expenses. Shared personal anecdote about septic replacement to illustrate planning for future occupancy changes.
Unclear: Senator Rein Information Only00:38:31.280 - 8:33:08 AM; Inquired about waiver process ease, frequency, and grant rates; agency described it as straightforward, common, with automatic options like grandfathering, and promised to provide numbers.
Unclear: Representative Maguire Information Only00:41:50.160 - 8:36:27 AM; Confirmed metering rarity in small facilities due to expense and variability; noted larger facilities (e.g., >50 units) benefit more; clarified metering measures inflow volume.
Unclear: Representative (unnamed) Information Only00:44:47.200 - 8:39:24 AM; Expressed concern that rules might disincentivize new developments amid housing crisis and high costs; agency affirmed book values unchanged, recent vertical separation reduction aids affordability, and proper sizing prevents future failures.
Unclear: Representative Lynn Information Only00:48:39.599 - 8:43:16 AM; Moved to approve rule 25206.
Unclear: Doug (Administrative Assistant) Information Only00:48:39.599 - 8:43:16 AM; Announced retirement of Cheryl Walsh after 20 years of service.