To Whom It May Concern,

I am writing to share my professional opinion regarding the licensure process for individuals applying for a Master Alternative Onsite Sewage System (AOSS) Operator license in the Commonwealth of Virginia under universal license recognition.

While I support making licensing more accessible and acknowledging equivalent experience from other states, I firmly believe that any applicant seeking a Master AOSS license in Virginia should be required to take and pass the Virginia-specific licensing exam. This requirement is critical because Virginia’s AOSS regulations, standards of practice, and system management requirements differ significantly from those of other states.

As you know, Virginia has established detailed and specific protocols for AOSS system design, monitoring, operation, and maintenance. These are outlined in the Virginia AOSS Regulations (12VAC5-613) and enforced through the Virginia Department of Health. A Master AOSS Operator in Virginia holds a position of great responsibility, often supervising other operators, managing compliance, and serving as the primary point of accountability for system performance. This role requires in-depth familiarity with Virginia’s unique regulatory framework, including local permitting requirements, reporting procedures, and ongoing public health protections.

The universal license recognition framework may be appropriate for issuing Journeyman or entry-level licenses, as those roles are typically performed under supervision. However, allowing out-of-state professionals to obtain a Master-level AOSS license without verifying their knowledge of Virginia’s rules poses risks to public health, environmental protection, and regulatory compliance.

For this reason, I respectfully urge the Virginia Department of Professional and Occupational Regulation (DPOR) and other relevant regulatory bodies to require all Master-level AOSS license applicants to pass the Virginia state exam, regardless of their licensure status in other jurisdictions. This step would protect the integrity of the profession, ensure regulatory consistency, and reinforce the public’s trust in the systems we design and operate.

Thank you for your time and consideration of this important matter.