The OSE soil evaluation and design license already has a benefit of not being required to possess a full PE license. § 54.1-406. License required. 

A. Unless exempted by § 54.1-401, 54.1-402, or 54.1-402.1, a person shall hold a valid license prior to engaging in the practice of architecture or engineering which includes design, consultation, evaluation or analysis and involves proposed or existing improvements to real property.

Further REDUCING standards from the existing OSE requirement does not serve any interest to protect public health, safety, and welfare. 

I hope this Board soon wakes up and returns to it's purpose: promulgating regulations that protect the PUBLIC interest.  

As a matter of public concern, I find it discerning that the Director of Office of Drinking Water for the VIrginia Department of Health sat as WWWOOSP Board  Chairman and influenced the proposed regulations.  Will the fielding of journeyman benefit consumers or Virginia Department of Health?