Professional soil scientists, like the professional engineers, cover a wide variety of expertise. Our expertise is in the evaluation of soil characteristics, morphology, geomorphology and interpreting how these collectively impact any given use.

For the past 34 years I have worked as a soil scientist for Virginia Tech in each of the 5 physiographic provinces; in Loudoun as the interpretive soil scientist working along side civil, agricultural, geotechnical and solid waste and wastewater engineers and as the soil scientist that the Virginia Department of Health (Loudoun County Office) consults to evaluate complex and problem soil/sites. Finally, I have worked statewide as a private soil consultant under my own LLC conducting soil evaluations for septic systems, providing soil training, foundation evaluations, land development proposals and agricultural practices.

The Soil Scientist profession has historically assisted the Virginia Department of Health (VDH)in determining specific soil criteria/characteristics and landform analysis critical to a properly functioning “drainfield”. These lists of criteria and characteristics were intended to be minimums that should be evaluated but were never intended to be included into a “cook book” for evaluating soils for any use. Soils are natural bodies and the characteristics are so inter-related that establishing guidelines such as “clay textures will have a percolation rate of greater than 90 mpi” are misleading, misused and inappropriate.

The Health Department feels so strongly that the interpretation of soils for onsite wastewater disposal is so important that they have a long standing contract with VA Tech for soil scientists dedicated to the interpretation of soils specifically on difficult and problematic sites in the eyes of their employees, most of whom are AOSE’s. These VA Tech positions are required to be Certified Professional Soil Scientists. However in spite of the fact that these professionals are valued by the VDH in site and soil evaluation of both conventional and advanced “alternative” systems, they will no longer be qualified to be licensed onsite soil evaluators without taking a test that includes intricate design/engineering knowledge, beyond appropriate sizing, not required for soil/site evaluation.

DPOR already has a program in place that measures and tests the ability of individuals to become a professional soil scientist. The following are definitions from DPOR 18 VAC 145-20-10.

Definitions:

"Soil scientist" means a person having special knowledge of soil science and the methods and principles of soil evaluation as acquired by education and experience in the formation, description and mapping of soils. And

"Practice of soil evaluation" means the evaluation of soil by accepted principles and methods including, but not limited to, observation, investigation, and consultation on measured, observed and inferred soils and their properties; analysis of the effects of these properties on the use and management of various kinds of soil; and preparation of soil descriptions, maps, reports and interpretive drawings.

I am quite sure that the state legislature never intended to divide and diminish the profession of Soil Scientists by creating a separate Board which does very similar tasks and takes away much of what our profession makes a living at. It is also inconsistent with how other professions in the Commonwealth are handled. Professional Engineers are not separated into separate boards based on their professional education, training and experiences. A chemical engineer should not practice as a geotechnical engineer or as an aeronautical engineer yet there is no difference in the P.E. license they get from DPOR. In fact, any engineer that deems themselves educated and experienced in wastewater disposal can submit permits to the VDH for either conventional or alternative/advanced systems. DPOR was created to regulate professions and assure the health and safety of the commonwealth and its environment. As found in the Strategic plan for DPOR; “The mission of the Department of Professional and Occupational Regulation is to protect the health, safety and welfare of Virginians, while promoting a competent workforce, fair housing opportunities, and a productive economy.” and on the site for The Board of Professional Soil Scientists "The Board for Professional Soil Scientists was established in 1987 to implement a certification program for professional soil scientists for the preservation of health, safety and welfare of the citizens of Virginia." 

The professions of Soil Science and Engineering, although dependant upon each other for the adequate evaluation and design of a septic system, require very different education and training. This regulation, as proposed, requires the licensed on-site soil evaluator or engineer to be trained and efficient in both professions. I agree that cross training can be beneficial. However, although there are some individuals who are certainly versed in both soil evaluation and engineering design, I dare say that most of us are either very good soil scientists - soil/site evaluators or are very good engineers. Why try to force two of the oldest professions in the commonwealth to become something they are not? Why not just work together and provide the best product we collectively can?

Combining the on-site soil evaluators into the Professional Soil Scientist and Wetlands DPOR Board seems consistent and more in line with what is done in other professions. Furthermore, it does appear incorporating the on-site soil evaluators into the existing board would save tax dollars without impacting viable professions currently working in the commonwealth. If this were done all soil professionals, like their P.E. counterparts, would only conduct on-site soil evaluations for septic systems if they have the appropriate education and training. To assure smooth transition, education and experience requirements could easily be equated to those that have already been approved as an AOSE through the Health Department. After all, these individuals have already had to demonstrate adequate education and experience.

Finally, many others have suggested and I agree that:

1) Licensed soil scientists/on-site soil evaluators and professional engineers with the appropriate education and training, should be allowed to conduct soil/site evaluations for all types of septic systems. There is no difference in how you evaluate site and soil characteristics for either system!

2) Professional engineers are able to provide septic system design to the Health Department.

3) If a soil scientist/on-site soil evaluator wishes to provide septic system design, other than for conventional systems, then there certainly should be appropriate testing for that option.

4) All of these professional licenses should require continuing education and professional preparing inappropriate work should be reported to DPOR as designed.