§ 54.1-2301.D of the Code of Virginia states, in part, "The Board, in consultation with the Board of Health, shall adopt regulations for the licensure of onsite soil evaluators . . . [also requiring] the division of onsite soil evaluators into classes, one of which shall be restricted to the design of conventional onsite sewage systems."

Does anyone see a problem with the above language?  The Code says there shall be more than one class of SOIL EVALUATOR and that one of those classes shall be restricted to the DESIGN of conventional systems.  This does not state that the soils for an alternative site must be evaluated by a more 'qualified' individual.  It simply states that the less 'qualified' soil evaluator (whatever that may mean) can't DESIGN the alternative system.

Using the proposed terminology of COSE and AOSE, the above Code would allow COSEs and AOSEs to evaluate any site, conventional or alternative.  However, it would restrict COSEs to the DESIGN of conventional systems.  Was this the intent?

The GA needs to amend § 54.1-2301 and specify one class of evaluator and one class of designer.  The designer license should be placed under the board for waterworks, wastewater works, and onsite professionals.  The soil evaluator license should be placed under the Board for professional soil scientists.

Current AOSEs, certified by VDH, should be grandfathered as DPOR licensed onsite designers.  Regulators should be exempt from licensure requirements for conventional systems.

Current AOSEs, cerified by VDH, should be grandfathered as 'provisional' professional soil scientists with a stringent CPE requirement.  Bad apples can be weeded out through the complaint process.  All current CPSSs should be grandfathered as licensed professional soil scientists.  Regulators should be exempt from licensure requirements until such time that VDH gets out of the soil evaluation business.

Different topic:

Will VDH's Authorized Onsite Soil Evaluator Regulations be obsolete or null and void on July 1, 2009?  These regulations govern AUTHORIZED individuals not LICENSED individuals.  Will VDH be allowed to accept evaluations and designs from licensed individuals?  Are there time limits for designs submitted by licensed individuals?  Do the 'deemed approval' provisions end on July 1, 2009 since the regulations govern authorized, not licensed, individuals?

It's time to start over.  Next time around select committee members who have many years of recent field experience. Also, don't seek input from those who have been promoted to a level of incompetence.

Five years ago I was looking forward to retirement from VDH and starting a second career as a private sector onsite professional.  Today the program is so fouled up I am looking forward to retirement and starting a new career that has absolutely nothing to do with the onsite program.

Public Health has become Political Health.

Advice for the public: Boil your well water or get a chlorinator.