Dale,
Good pick up. The Department and VBA have confused reg 801 (BP) and reg 1003 (OP) and assumed they refer to the same matter.
A Report and Consent will now be required for every application for a building permit where a new septic system is installed or alterations to the system are required.
Unless the septic system is installed prior to the issue of the Building Permit and a certificate to use the system is obtained.
This will require an amendment to the building regulations to address this anomaly.
You need to refer this matter to the VBA for rectification ASAP.
One fix from a Council perspective is to ask your Health Department to include a note on all septic permits to install that this permit is also Consent of Council under regulation 801.
We used to do this at Golden Plains when I was there prior to the reg change that allowed the BS to rely on the septic permit to install.
Marcus
Macedon