Creation of an unrestricted "journeyman" class of licensure open to any applicant does not have established benefit for the public. This new class expands upon the statutory construct which implied two classes of licensed Onsite Soil Evaluators “one of which shall be restricted to design of conventional" systems.

In Virginia  journeyman and apprentice are defined under the Contractor’s Board, and the Department of Labor and Industry Generally considered an individual who has completed an apprenticeship and is fully educated in a trade or craft, but not yet a master. To become a master, a journeyman has to submit a master work piece to a guild for evaluation and be admitted to the guild as a master. A "journeyman class" may be applicable to trades guilds with an established training program but not to the onsite soil evaluator’s duties, Indeed this seems poorly considered as applied to licensed operators or installers. Waterworks have Operators in Training, professional engineering established Engineer in Training, neither were created in such a haphazard fashion as this proposal.

This does not apply to professional licensure based upon the practice of principals of both environmental science and engineering. This new class further confuses the requirements for direct supervision and responsibility. OMB's Small Business Impact Statement is inadequate to the task of reporting judgments about the impact of the regulation on the behavior of individuals and firms in the economy and about the value that people place on those changes. There are over 350 licensed OSE distributed across Virginia, the majority are employed by small businesses (<$5M in gross revenue/yr) or sole proprietorships, surely the economic impact of amendments affecting delivery of services to over 6,000 new homes per year deserves greater consideration.

We read in the supporting documentation that complaints were delivered to this board showing examples of unlicensed or non-compliant design provided by individuals lacking direct supervision. Rather than acting on violations of existing regulations DPOR seems to advocate licensure for everyone holding a shovel, this is a barrier to employment, and raises the cost of labor without apparent benefit to the public. This action does not address potential damage to the valuation of property which may be caused by unsupervised or incompetent employees.