I am writing to express my professional opinion and recommendation that individuals seeking to obtain a Master Alternative Onsite Sewage System (AOSS) license in the Commonwealth of Virginia be required to pass the Virginia-specific licensing exam, regardless of licensure status in other states.

As someone actively involved in the onsite sewage industry, I understand the importance of maintaining high standards for public health, environmental protection, and system performance. Virginia has developed its own regulations, technical standards, and design requirements that are often significantly different from those in neighboring or other states. Allowing individuals to bypass the Virginia exam by obtaining licensure in another state and transferring it back into Virginia undermines the integrity of our regulatory system and puts both the environment and public welfare at risk.

While universal license recognition may be appropriate for entry-level positions such as journeyman licensing, the specialized nature and complexity of AOSS systems in Virginia demand that Master license holders be well-versed in Virginia-specific codes, laws, and system design criteria. Master licensees often take the lead on projects, interface directly with local health departments, and bear significant responsibility for compliance and performance. Without proper evaluation through the Virginia exam process, there’s no assurance that these individuals have the knowledge and competency required to meet the state’s unique requirements.

Requiring passage of the Virginia Master AOSS exam ensures that all professionals operating at this level are equally qualified and prepared to uphold the standards expected by the Department, the citizens of Virginia, and the broader industry. I respectfully urge DPOR to consider implementing or maintaining this requirement as a safeguard for the integrity of our profession.

Thank you for your attention to this matter and for your ongoing efforts to protect the health and safety of all Virginians.