Many of the comments so far are about the overlap and redundant regulation changes occuring as we are moved into the world of DPOR.  I have not seen any comment or concern about existing systems.  More so than the changes needed in site evaluation, system types and who will jockey into contention to do the complicated evaluations are the guidelines for the evaluation of existing systems and existing stressed or failing systems.  In recent months we have undertaken the repair of existing systems in locations of Northern Virginia and have come into some overwhelmingly different opinions on how to remedy the situations.  The current regulations state nothing on the requirements of the repair situation.  It has always been a gray area in my experience with the Health Department as an Employee and as a Consultant.  With out some sort of guidline or agreement on how to proceed with many of these systems which will be greater and greater numbers in the years to come the home owners in Virginia will have been done a great disservice by VDH and the private sector. 

After reading many of the previous coments I am disapointed in the tone of many  "professionals".  Those in VDH who have not seen the writing on the wall in regards to being phased out must have had their eyes closed for the past few years.  Everyone who is just now crying about the deficient regulation proposals and the disoriented change of ownership of the onsite program from VDH to DPOR did not go to any of the meetings in Richmond headed up by Don Alexander.  Many HD offices had Polycom on with no one in site of the camera to watch what was being discussed.  I personally have no remorse for those in VDH who may fall off tha map due to the  changes.  I may be in need of more requalification to become eligable but I will take the CPSS exam if required and do what it takes to become LICENSED.  As a foot note to all those who are CPSS CERTIFIED.  How is it that CPSS stands for CERTIFIED Professional Soil Scientist and is still some how construed as a LICENSE?  Being Certified in something is not the same as a License.  This was a discussion the DPOR representative had with others at one of the meetings in Richmond concerning the AOSE classification.  There was a clear distinction between the two as he pointed out.  That would mean that AOSE and CPSS holders will have to be LICENSED regardless of which title you hold.  Is not the CPSS title a VOLUNTARY title to obtain? 

At present the new House Bills and Senate Bills approved last year and the new ones for this year are taking more involvement away from VDH and placing it more with the Engineer, CPSS and AOSE (soon to be elimiated).  Even with this it is taking longer and longer to have anything approved in the Health Department.  This is appearant in almost every county I have completed work in in the past few months.  Again if VDH has less involvement in the permit process (taking less responsibility) why is it taking longer for VDH employees to review and issue a letter of approval?  The great tradgedy of this entire rearrangement of power is that VDH will still be in the middle holding on with no real direction to turn to and head.  In essence there will still be that alligator in the road that everyone wants to move but no one wants to get out and help out of the way.  So they all go around into the muddy median and get stuck in the layers of muck that have become the State and County regulations.

There is my gripe with this entire process.  Many out there may be headed to a new profession due to the current economic situation yet we are still pushing for harder and more costly requirements for all involved. (Home owner, Installer, Builder, Realtor, Banker, VDH employee, ASOE,CPSS, P.E. ect.)

Sincerely 

John Sawdy