Action | Update regulations to reflect changes in the Code of VA |
Stage | NOIRA |
Comment Period | Ended on 5/25/2011 |
Ya'll really should widen the fee gap between AOSE and bare applications. You charge way way way too much for AOSE supported permit preparation and these fees should be slashed drastically. It can't cost that much to check 10% of a licenced professional work.
Fees attributable to site evaluation, permit preparation, and inspection charged for bare applications should reflect the private market not determine it. It is an invalid comparison for the state health department to say 'since it takes X time to perform such and such a task and we pay employee so and so this amount an hour the cost of doing a permit is Y' . This kind of analysis negates the supply of and demand for a service as a factor in determining a fair market price. The only factor is how much (or little) does the state pay to to have an employee available to provide the service regardless of how many times the service is provided. That state employee is going to have a job whether he does 10 permits a year or 100 as long as the state is in the business.
You can juggle the numbers but the fact is that the state health dept competes for work ( site evaluation, permit preparation, and inspections) for which there are private sector state licenced people -at a taxpayer subsidized rate. It also, in my opinion, employs arcane policies, such as double evaluations and inspections of AOSE documented sites, to maintain the employee base and revenue stream generated by the on site evaluation program.
Virginia set up this AOSE business but still is in direct competition with the private sector it created and all the while driving permit prices through the roof. Either the AOSE program is a gigantic failure and should be eliminated to decrease the overall cost of the service and ya'll can just hire everybody back or it should be left to the market to determine its value unburdened by unfair competition and an unfair fee structure.