DPOR does not seem to recognize errors or omissions in qualifications for operator license eligibility.

Much of the Commonwealth is under-served by competitive firms, making inspection and reporting on status of "alternative" (more properly referenced advanced treatment) onsite systems. While VDH regulations under review seem focused on incorporating additional layers of oversight, the Agency has not provided examples of real world threats to public health or safety. For example, malfunctions in design, installation and operation of advanced treatment works attributable to lack of regulation. FOIA of Indemnification fund hearings, or enforcement actions would seem to show there is little threat within the existing regulatory environment to justify additional expense to the landowner. Similarly DPOR has not compiled a record of violations related to non-compliance. Hence the public may infer the industry is over-regulated, and justified in speculating that barriers to entry are unfounded, or even anti-competitive.

As others have noted, there is little difference between operation of small, vs. large treatment works. Also noted that onsite (e.g. soil) receiving areas have redundant safety and far reduced risk of environmental impact as compared to discharging systems.

Incorporating additional prerequisite paths to licensure seems to be in the public's interest.

Specifically, consider eligibility for examination professionals who have earned experience in design, or installation and commissioning of advanced treatment works are deemed qualified to operate that equipment. The Board may choose to standardize the field; incorporating a short course and exam would seem sufficient to assure consistent assessment and reporting.  

Since theory and practice of wastewater works operation includes education components, it is peculiar that provisions have not been made for academic paths to license. Upon founding of these license classes the industry recognized a STEM path bachelors or masters degree could provide mechanism for abbreviated term of experience. This is also the case for professional engineers, who are capable of self selecting qualifications to assess, design, install or operate onsite systems.

It seems warranted to incorporate additional pathways to licensing into future regulations; unless it is the Board's intent to restrict availability of service technicians, and sustain barriers to entry.