I believe that most people in the wastewater industry would agree that the Engineering Board is currently a host to a major flaw, GMP 146, where Engineers can design ANY wastewater treatment system regardless of the soil or site composition.  However, that is not the subject matter of the proposed regulations.

It is important to note that CPSS is a part of DPOR, like any other license (i.e. PE, Land Surveyors, PWD) whether it is required to perform a particular line of duty or not.  For example, there is the licensing of Professional Wetlands Delineators...however it is not a requirement for any line of work.  Just like, CPSS, our certification is not required for any line of work, but is used in many instances for qualification (like to become an AOSE, its an avenue to get licensed).  However, as a CPSS, I will stand stongly behind it stating that all CPSS's believe that it SHOULD be a requirement for onsite soil evaluations, NOT just ONE avenue to get your license.  Just because CPSS is mentioned in the regulations doesn't mean that everyone who is an AOSE is well versed and knowledgeable in the field of soil science.  How many AOSE's who are not CPSS's or who do not have a soil science background or degree truly understand the soil characteristics (structure, rupture resistance, textures, etc.), morphology, geomorphology and interpretion...my guess...not many...and isn't it the soil that established the guidelines for determining the appropriate system.  Why is CPSS only 1 way in which you can become an AOSE...isn't the soil the most IMPORTNAT PART?  It should be the NUMBER1 requirment..."YOU MUST HOLD A VALID CPSS LICENSE", if not you are just a designed.  However, I feel that it would be very important to INDEER grandfather ALL AOSE's with adequate experience into a program like this.   In addition, why are the currently proposed regulations concerned with the soils portion..when we ALREADY have a Board of Professional Soil Scientists that governs that portion of the onsite industry.  Why not save some taxpayer dollars (which i think is a splendid idea in these great economic times) and utilize an existing board for the soils component and use the currently proposed regulations for the system design. The Board of Professional Soil Scientists alreadt has existing requirements, standards, exam procedures, specifications...developed by qualified individuals...EVERYTHING...it is A DPOR BOARD too!  So my suggestion it to require CPSS for the soil components AND an AOSE for the design components. 

And please note that a major steakholder...THE BOARD OF PROFESSIONAL SOIL SCIENTISTS was NEVER involved in the development of these regs...and they are affiliated with DPOR and represent the soils industry.  Nor where any representatives from the Virginia Association of Professional Soil Scientists, which represents a large number of pulic and private soil scientists.  We are not going down without a FIGHT!