1.  The last paragraph under this section lists post-secondary courses that may be substituted for experience.  It's hard to believe that Geology courses are not included.  It appears to be a bit arbitrary to include Biology and Soil Science but exclude Geology.  This is either an oversight or the paragraph was written by an uninformed individual/group.

2.  When these regulations become effective there will be an enormous number of VDH employees who will not qualify for the interim license or the conventional license (and may not qualify for years).  Is it DPOR's intention to take VDH out of the evaluation and design business?  If so, fine.  If not, has anyone considered the consequences (e.g. 1. pressure placed upon VDH employees who are licensed to sign off on the work of unlicensed individuals, 2. land owners being forced to hire private sector evaluators in localities that don't have licensed public sector employees, etc.).  Maybe DPOR should consider something similar to 54.1-402.1 which allows license exemptions (engineers, architects, surveyors) for state employees for a limited time.  In other words (for example) if a VDH employee was hired on or before July 1, 2008, and is authorized by the VDH to issue permits on the effective date of these regulations then that individual is exempt from licensure requirements until some future date (say July 1, 2013).  Otherwise, chaos is on the horizon.