The main issue that I see with these regulations as currently proposed is section 18VAC160-20-74.C.  This section states that “No licensee shall hold both a conventional and an alternative license simultaneously.”  This section in combination with the current definition of alternative installer, operator, and evaluator would not allow these individuals to also work with conventional systems.  I understand not allowing those individuals licensed as conventional installers, operators, and evaluators to work with alternative sewage disposal systems.  However, if someone is capable of designing, installing, or maintaining an alternative sewage disposal system, then they are certainly capable of designing, installing, or maintaining a conventional sewage disposal system.

In my discussions with local installers and AOSE, this is a main point of concern.  Most, if not all, installers and AOSE’s work with both conventional and alternative systems.  By allowing them to only work with one or the other you would effectively be cutting there work load in half.  The same goes for septic operators.  This would create a serious economic impact to their business.

These issues could be avoided by simply changing the definitions for each.  These are my suggestions:

“Alternative onsite sewage system installer” means an individual licensed by the board to construct, install, and repair conventional onsite sewage systems, alternative onsite sewage systems, and alternative discharging sewage treatment systems. (The definition on an alternative discharging sewage treatment system will also need to be added.)

“Alternative onsite sewage system operator” means an individual licensed by the board to (i) place into or take out of service a unit process or unit processes; or (ii) make or cause adjustments in the operation of a unit process at a conventional onsite sewage system and/or alternative onsite sewage system; and (iii) determine whether a component or device is functional.

“Alternative onsite soil evaluator” means an individual licensed by the board to evaluate soils and soil properties in relation to the effects of these properties on the use and management of these soils as the locations for conventional onsite sewage systems and/or alternative onsite sewage system.

By making these changes those individuals with conventional licensure would only be able to work with conventional systems, but those with alternative system licensure would be able to work with both conventional and alternative systems.  That is how the system works now, and if these individuals can meet all the requirements under DPOR they should be allowed to continue working as usual.

Lance Gregory

Environmental Health Supervisor

Chesterfield Health District