DPOR should get rid of the interim license concept and replace it.  It is a well established principle in licensing that an applicant holding a valid license or certificate in another jurisdiction can have reciprocity.  It happens with medical doctors, engineers, nurses, and other professions.  DPOR should allow all persons holding an AOSE certificate from VDH to be licensed as an OSE (Authorized Onsite Soil Evaluator) without retesting.  Why torture the 250+ persons who tested and complied with the prior regulations to make them re-test again?

If a law passed to move engineers from the APSCELIDLIA Board to go to another board, would DPOR give them an "interim" license, change the entry requirements, and then make them re-test?  I don't think so.  I agree with the person who wrote before that DPOR should get rid of this concept and simply let those who have already passed tests and been certified to be given the OSE license.  If there are bad actors in the program, then DPOR can remove them following complaints.

What benefit is served by making 250+ licensed people retest?  They have already been tested and the experience and licensing requirements included a written test, passing a field test, completing a 12-week course of study at VDH, and having more stringent experience and degree requirements.  Why lower the bar and then say everybody that meant the higher bar must re-confirm that they can now meet the lower standard?

I think the Joint Commission on Administrative Rules would be interested in understanding why DPOR believes a tested and confirmed group of people must re-test!