There are many impediments to the integration of the AOSE into the onsite permitting process, notable is the lack of a statewide policy regarding the part time employment of VDH personnel as consultants for AOSE or PE's.

It is common practice for EHS in some districts to solicit AOSE's for "part time work" in conjunction with their review of applications. It is also common for VDH staff to offer informal recommendations to the public for consulting firms. And it has been common for the public to be told that there are no lists of AOSE active in a District, but that firm XYZ is preferable to all the others. The specter of a public employee recommending one consultant over another is damaging to the reputation of all, and policy should address this conflict.

Until the VDH establishes a uniform policy for conflict of interest the public will be right to assume it is business as usual for insiders. The public also seems skeptical of the subsidized services provided by the VDH for speculators on property for sale, or properties for sub-division also for private profit. Is there an EHS who has not been leaned on by a realtor or speculator demanding rapid service for their property? The VDH does not have policy which distinguishes between residential or repair property or commercial or speculative property, nor is their universal acceptance of requirements to identify commercial property, or property which is disposing of process waters rather than domestic wastewaters.

Since DPOR took on the AOSE administration it is very difficult for the public to select a consultant from the DPOR website listing registrants, since no differentiation is made between EHS staff which seem to have been "deemed approved" in the wake of the change-over from VDH, and AOSE's who offer consulting services for the public on a fee for service basis. The intent of Regulations concerning the OSE being separated into two fields, one of “Conventional Evaluators” and another of “Advanced Evaluators” has been twisted beyond recognition by this deceptive designation by the VDH.

A solution would be to identify private versus public licensees, however this would be left to DPOR. The VDH has the power to establish a policy of listing AOSE’s available for service in Districts based on an open enrollment list available to the public identifying consultants in good standing who are active in that District, and restricting enrollment to those firms not employing moonlighting public employees.

I apologize for not signing my name, however it is safe to assume that there is a penalty for open discussion of these issues, and it is not worth the risk of calling attention to myself by commenting on these issues of common knowledge.