Evidently this board has not been informed the Onsite Soil Evaluator is providing engineering services to support development of private real property. Engineering services include the preparation of feasibility studies and preliminary and final plans and designs; the provision of technical advice and assistance during the construction or installation phase; and the inspection and evaluation of engineering projects. In light of practice under exemption to engineering license (§ 54.1-402. Further exemptions from license requirements for architects, professional engineers, and land surveyors.) and offering professional services incidental to the scope such as surveying, this profession should be regulated in accordance with the wider expectations.

Please consider the means to integrate expectations of reliable professional services into the next draft of these regulations.

In the absence of a clear articulated policy to displace competition, I trust these measures would include: standards of practice, canons of ethics including written disclosures of scope and conflicts of interest and other factors, and consideration of policies to either regulate or assess and prohibit the effects of misleading practices which affect the consumer. 

As others have suggested this board may not be adequate to the task, as an interim solution the PE/OSE Workgroup may be able to advise staff and board members prior to consideration of future regulatory language.