By Reed Johnson

Virginia’s decentralized wastewater infrastructure is facing a quiet but growing crisis: we lack enough skilled, licensed operators to manage the advanced systems needed in rural communities and developing areas. At the center of this problem lies a bureaucratic choke point—one that artificially caps the authority of Master Alternative Onsite Operators at 10,000 gallons per day (GPD), while also placing Class IV licensure out of reach for most small business operators.

Worse still, this regulatory structure blocks practical solutions for systems that are already being deployed successfully across the state—systems that work identically whether they discharge to surface or subsurface environments. We need to fix this, and the fix isn’t complicated.

The 10,000 GPD Cap Is Arbitrary and Counterproductive

The current limit on Master Alternative Onsite Operators—restricting them to systems under 10,000 GPD—isn’t based on any scientific treatment threshold. Rather, it’s a bureaucratic relic. Advanced treatment systems (such as MBBRs, recirculating media filters, and ATUs with UV disinfection) perform the same core functions at 7,500 GPD as they do at 15,000 or 25,000 GPD. The physics of flow, nutrient reduction, disinfection, and dispersal don’t magically change at five digits.

This outdated cap isn’t protecting public health. Instead, it’s creating bottlenecks in system operation, project approvals, and sustainable growth, especially in areas not served by central sewer. In many cases, the cap prevents the very operators trained to manage these technologies from doing so legally.

The Class IV Barrier: A Logjam for Rural Projects

To make matters worse, Virginia’s Department of Environmental Quality (DEQ) requires Class IV Wastewater Works Operators for systems discharging directly to surface waters—even for flows as low as 1,000 GPD, and all the way up to 40,000 GPD. The problem? In many parts of Virginia, Class IV operators are scarce or nonexistent, especially in rural localities where alternative systems are most needed.

Let’s be honest: the same exact process—settling, aeration, clarification, disinfection—is used in a 1,000 GPD plant and in a 40,000 GPD plant. What changes is not the treatment method, but the footprint. Yet our licensing structure imposes the same Class IV requirement on both, despite the fact that many Master Alternative Onsite Operators are more than qualified to manage these systems in the 10,000–40,000 GPD range, especially those serving clustered developments, schools, or private communities.

These operators already manage advanced treatment systems for subsurface dispersal, some with real-time telemetry, time-dosing, and nutrient removal technology. They just aren’t allowed to manage the same system if it has a direct discharge, because of the rigid license boundary.

A Reasonable Path Forward: Bridging the Licensing Gap

If Virginia is serious about solving this growing rural wastewater problem, then we must create a clear, achievable path from Master Alternative Operator to Class IV licensure—without compromising public safety or treatment standards.

Here’s a practical solution:

1. 1. Create a “Bridging Test” for Class IV Eligibility

Develop an open-book, treatment-focused exam specifically tailored for Master Alternative Operators seeking to operate small-scale direct discharge or large-flow decentralized systems. This bridging test would focus on:
- Surface water discharge monitoring
- Permitting knowledge
- Sludge management basics
- Reporting and sampling protocols

2. 2. Mandate Training Access via VDH and Virginia Tech

Virginia Tech and the Virginia Department of Health (VDH) should jointly offer a bridging course with built-in test preparation, including digital and in-person formats. Successful completion of the course and test would qualify the operator for a provisional or full Class IV license based on system type and experience.

3. 3. System-Specific Training from Manufacturers

Just as electricians are trained on specific products and brands, wastewater operators should receive manufacturer-supported training for any advanced system they maintain. Whether it’s Orenco, BioMicrobics, Norweco, or Advantex, a minimum manufacturer-endorsed class should be required to operate systems beyond 10,000 GPD or those with direct discharge.

The Root of the Problem: A Regulation Out of Step with Reality

Many Master Operators in Virginia are skilled business owners who balance installations, service contracts, permitting, and design support. They are not full-time students or lab techs. The current path to Class IV licensure was designed for large municipal plant workers—not small business professionals supporting rural infrastructure.

This mismatch explains why so few onsite professionals make the jump to Class IV, despite the need. The system we’ve built unintentionally punishes the very people most capable of solving our wastewater challenges.

The Cost of Doing Nothing

Without reform, we can expect:
- Continued project cancellations due to lack of eligible operators
- Increased environmental risk from mismanaged or orphaned systems
- Higher costs for small communities due to third-party oversight requirements
- Overreliance on centralized sewer in places where decentralized alternatives make more sense

This isn’t just bad planning—it’s an equity issue. Rural and underserved communities are being denied the wastewater infrastructure they need because our licensing system hasn’t caught up to modern technology or workforce realities.

A Win-Win Opportunity

Creating a bridging path doesn’t weaken the system. It strengthens it—by increasing the operator pool, improving system oversight, and encouraging professional development. At the same time, we empower small businesses and remove a major obstacle to infrastructure progress in areas that need it most.

We don’t need to reinvent the wheel. We just need to make it turn for more people.

Conclusion: From Cap to Catalyst

The 10,000 GPD cap and the Class IV barrier are symptoms of a broader regulatory problem—one where innovation, practicality, and environmental stewardship are being stifled by well-meaning but outdated rules.

Virginia has the chance to lead here. By introducing a practical, test-based path from Master Alternative Operator to Class IV, and by requiring system-specific training, we can solve our operator shortage and unlock new potential for sustainable development across the state.

Let’s stop treating decentralized wastewater as a fringe solution and start recognizing it as the future. The operators are ready. Now the system needs to catch up.