The resolution to some portions of these comments are not under the control of DPOR and the proposed regulations, but impact how effective the proposed DPOR regulations will be.  These portions of the comments are made for thought.

 18VAC 160-20-10 Definitions:  Have only one soil evaluator designation for onsite sewage disposal systems of all types.  Place this designation in whatever DPOR board you want.  Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals makes sense.  Call this designation whatever you want.  Eliminate interim and conventional onsite soil evaluator designations.

Have soil evaluators qualify under current training regime provided or over seen by VDH with on going improvements.  Virginia Center for Onsite Training (VCOT) at Southside Community College is a developing onsite training center for onsite sewage disposal in Virginia.

18VAC160-20-82 & 96.  You want Environmental Health Specialists (EHS) with Virginia Department of Health to possess the equivalent level of qualifications as private sector individuals, but not a requirement of employment with VDH.  If an EHS leaves VDH employment, they should be financially liable for repaying VDH for their training if they are employed in the private sector onsite program in Virginia within 2 years of leaving.  If an EHS plans on leaving VDH, the EHS could set up with VDH a payment schedule while employed with VDH to pay back training VDH provided.

Allow all current VDH licensed AOSE's (private and VDH) to become licensed under new DPOR regulations.  Allow all current EHS's with VDH and appropriate amount of time to qualify for the soil evaluator designation.  Time limit should consider econonic situation.  Require all new applicants for onsite soil evaluator designation to pass training regime, testing and education/experience  set up by DPOR with guidance from VDH.

Minimum requirements for an AOSE applicant would be (A) College level degree, completion of VDH onsite training program and 5 years supervised technical work experience in onsite sewage disposal industry, or (B) a high school degree or GED, completion of VDH onsite training program and 10 years supervised technical work experience in onsite sewage disposal industry.  Appropriate testing should be able to more accurately identify the qualified applicants.  A small percentage of unqualified will get by.  The system can identify the licensed but unqualified evaluator, contracator, or designer by the licensed and concerned evaluator, contractors and designers reporting poor quality work  or behavior to DPOR.   In order for the system to achieve the objective of a reliable onsite program with major implementation of field work by the private sector and monitoring by the Health Dept., the private sector has to take a much greater role to identify the bad apples.

Residential onsite designer clasification:  Licensed soil evaluators are not necessarily qualified  to design onsite systems.  Create an onsite system designer classification.  Create a test that can identify these individual.  Allow these individual to design all types of residential onsite systems less than 1000 gpd.  Create (incorporate) some standards similar to AOSE regulations for Soil Evaluators and the new designer classification.

Onsite system installers:  Keep the proposed conventional onsite system installer license for current, and below average drainfield contractors working now.  The proposed alternative onsite sewage disposal system contractor licensee should show knowledge (testing) of the important installatin considerations and necessary cooperation and interaction required with the system designer and Health Dept.