As a Soil Scientist & an AOSE, and a charter member of VAPSS, I have concerns about the regulations as proposed.  The regulations do not recognize the impact that soils have on the site suitability, design and performance of onsite wastewater treatment systems.  A proper site and soil evaluation and interpretation for any proposed parcel to be used as a site for a wastewater treatment system is the primary and most important "piece of the puzzle" in the successful functioning of a septic system.  Without a correct site and soil evaluation, system design will most likely be flawed and function of the system impaired to the point of possible failure of the system.

The Board for Waterworks and Wastwater Works Operators Regulations [18 VAC 160-20] seems to "re-invent the wheel".  The Board for Professional Soil Scientists has existed since 1987 and has been qualifying soil scientists through an examination, experience requirements and an examination for many years.  The Board for Professional Soil Scientists should be the governing board for those in soil science, including the current AOSEs certified by the Virginia Hepartment of Health.  Licensure of soil evaluators and system designers should be under the Board for Professional Soil Scientists, not under the Board for Waterworks and Wastewater Works Operators.

As a practicing Soil Scientist and AOSE with 36+ years of experience and education in soil science, I am very disappointed that on July 1, 2009, I will become an "Interim Licensee" that will again have to prove by examination, this time, to the Board of Waterworks and Wastewater Works Operators, my abilities to work in the Commonwealth of Virginia as a soil professional.  This is surely a duplication of efforts and procedures now currently residing with the Board of Professional Soil Scientists.

Separate licenses for conventional vs. alternate system evaluators cannot be supported technically or logically.  In order to determine that an alternate system is needed, the soil professional must be adept in making an evaluation and interpretation of the soil.  Only then will the correct design be applied.  As a CPSS and AOSE, I have proven my qualifications to DPOR and VDH my abilities to investigate soils and to design systems.  As CPSS and AOSEs, we should be able to continue designing conventional systems and pre-engineered systems as currently allowed by VDH without involving an engineer. 

I request an amendment stating that current dual Certified Professional Soil Scientists (CPSS) and Authorized Onsite Soil Evaluators (AOSE) be grandfathered as a Licensed Professional Soil Scientist (LPSS) which would emcompass drainfield evaluation & design (conventional and alternative drainfields with pre-engineered components), shrink/swell soil investigations, wet land delineation, soil mapping for mutiple land uses, etc.  Those currently certified as only AOSEs should be given an interim license for three years and be eligible to sit for the LPSS exam, regardless of current education and experience.  If AOSEs do not wish to become a LPSS, offer an alternate licensure for septic evaluation and design professionals ( such as LOSE - Licensed Onsite Soil Evaluator, LSED - Licensed Site Evaluator and Designer, etc.)  Having separate licensures for LPSS and LOSE will protect those soil scientists (still licensed as a LPSS) that work in fields of soil science other than septic evaluation and design.  Soil Scientists (CPSS) throughout the state are involved in numerous professions not related to septic evaluation, interpretation, and design, therefore AOSEs without CPSS should not be grandfathered  as Professional Soil Scientists.  All current CPSS and AOSEs should be able to continue to work without having to take another exam to prove their expertise because the only change with this legislation is the governing board.

New applicants for LPSS, or a new classification of Site Evaluators/Designers should take an exam specifically for the category in which they are requesting licensure along with education requirements, and experience requirements that are attainable in a respectable amount of time.  There could possibly be a requirement for LPSS applicants to have successfully completed the Site Evaluator/Designer examination.  There should definitely be separate licenses for Professional Soil Scientists and Soil Evaluators/Designers. 

All LPSS and Site Evaluators/Designers should be required to maintain professional continuing education.

I further request an amendment to the proposed regulations requiring any soils and site evaluation be performed in accordance with specific standards.  The standards used by USDA NRCS for soil evaluation, descriptions, nomenclature, etc. are used by soil scientists throughout the country.  Professional standards of evaluation and conduct are already set forth in the Board for Professional Soil Scientists.

Thank you for the opportunity to voice my concerns.