Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals
 
chapter
Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals Regulations [18 VAC 160 ‑ 20]
Action Amend Definitions of Supervision, SDS Experience and Document Requirements for Installers
Stage Fast-Track
Comment Period Ended on 11/7/2012
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10/26/12  9:42 am
Commenter: Bob Willoughby, AOSE, LRH Soil Consultants, Inc.

Fast Tracking Objection
 

I object to the Fast Tracking o the proposed amendments to the definitions of supervision, SDS experience, and document requirements for installers for the following reasons:

1. It appears that this includes soil evaluators and designers.

2. I see no reason why the fast tracking process should be used for changes to regulations in this instance.

3. I feel all changes to the regualtions should be handled through the normal process and go to the state legislators. I'm sure there are some exceptions where fast tracking could be used but I see no reason for it in this case.

This appears to be a "back door" way to get changes without the approval from State Legislation.

CommentID: 24388