seems like a very amateurish situation by the council..... if the council official was going to recommend refusal, what could possible be achieved by further information requesting you to contact him... do they think you can change his mind??? if he is an executive engineer that does not bode well for his job prospects.... is this the same guy who admitted to you that hes not really qualified to say what is required for a site to be acceptable for percolation.... but maybe they are just trying to give you every opportunity to resolve the issues... personally i think you need to engage a suitabily qualified professional (a hydrogeologist or someone who has FAS qualification to carry out EPA testings) and get them to write up a report based in the EPA guidelines... they would be best to advise you of the next steps...... raised bed percolation definately seems necessary, they may also recommend a sand polishing filter bed or reed bed as tertiary treatment. but at the end of the day the council have the last say, and in this day and age of groundwater pollution and health hazards, they make the easy decision of refual in the vast majority of cases....