This paragraph appears to require licensure for health department employees who perform soil evaluations (and design onsite systems?).

The proposed language will not put any currently working private sector AOSEs out of business (i.e. all they will have to do is apply for the interim license and continue business as usual).

The proposed language will put many VDH employees out of 'business' (i.e. they will no longer be allowed to perform soil evaluations -- and, presumably, no longer be allowed to design conventional systems).  Many do not qualify for the interim license and will be unable to apply for the conventional license for years.  Some will not qualify for the conventional license for at least 8 years -- and that's assuming their supervisor is a licensed evaluator.

This is a serious issue for many health districts.  One district, for example, covers 4 counties and has 12 onsite employees (excluding the manager) who are currently allowed to perform soil evaluations and design conventional onsite systems.  3 of these individuals currently meet the requirements for the interim license (i.e. they are certified by VDH as authorized onsite soil evaluators).  9 of the 12 employees will not be allowed to perform soil evaluations on the effective date of these regulations.  2 or 3 of those 9 might be able to secure VDH AOSE certification before June 30, 2009, and then qualify for the interim license.  At least 6 of the 12 individuals will not meet the experience requirements for the conventional onsite soil evaluator license for several years.  As a result. it appears the draft regulation will effectively cut this district's functioning staff by at least 50%.  Hello?

This may result in internal pressure to have licensed VDH employees signing off on the work of unlicensed employees -- not a good thing.

Recommendation: Allow a three year (minimum) licensure exemption for state government employees who are currently engaged in the practice of soil evaluation and onsite system design (see 54.1-402.1 for language recommendations).   The three year exemption will expire around the same time as the interim licenses.