While I am sympathetic to the Board, and the VDH for their interest in cleaning up loose ends within the regulatory environment, I oppose this effort to fast track a change to the Installer’s Regulations. If there shall be changes within the Regulation they should be consistent with the intent of the legislature and VDH in establishing a licensure which delivers a professional service to the public.

The installers and the public benefit if there is less ambiguity regarding who is licensed to evaluate, design, permit or approve installations. Please clearly define who is authorized to take the responsibility for adjustments which may be required for a particular installation to comply with the Regulation, and the intent of the Licensed Onsite Evaluator or Professional Engineer responsible for the permit. Certifying an installers work requires a clear and consistent authorization.

About 2/3 of the OSE in the Commonwealth are currently employees of the VDH. However the Agency has not required staff to utilize their OSE designation while permitting or certifying design and inspection documents. I am not aware of any guidelines or Regulations authorizing an “EHS” to certify onsite sewage installations.

The public deserves a consistent means of assigning responsibility for the design and construction of improvements to their real property. And while the transition will be complicated I believe the public interest is best served by following the lead of Counties wherein all site evaluations, designs, installations and certifications are performed by the private sector with the VDH maintaining a regulatory and records keeping function. Clearly the old model of EHS providing field support for home construction is out-dated and the regulations should reflect a phasing out and/or clarification of responsibilities.

Thank you for soliciting our comments; Jeff T. Walker; AOSE