... As the regulations have not undergone cumulative review since the inclusion of the onsite sewage program in 2009, a thorough review is necessary to ensure that the regulation complements the current Virginia law, provides minimal burdens on regulants while still protecting the public, and reflects current procedures and policies of the Department of Professional and Occupational Regulation (Department).

Given there's roughly 20 DPOR Boards and barely 150 professional licenses total, how did it ever come to pass that the onsite sewage system professional comprises almost 10 percent of all available DPOR license types? 

Between the potential for overlap of duties and the propensity for unlicensed individuals to operate with impunity statewide, how do the different competing regulant categories ever provide the intended level of public assurance?  Doesn't the Board have an obligation to prevent deceptive or misleading practices by practitioners?  The most recent inventory of regulated individuals/businesses listed by license type indicates there's currently eleven categories of "On-site" regulant.  This heterogeneous mixture of operators, designers, and installers serves to undermine the WWWOOSSP Board's authority and regulatory capacity.

How many different DPOR regulants does the WWWOOSSP Board require for a homeowner to install and operate a drainfield in their own backyard and which of those regulant choices represent the legitimate practitioner?  DPOR's webpage and license "look-up" appears to assume the public already knows how to successfully navigate their database, as well as, have a working knowledge of what all those on-site regulant categories represent.

How much less confusing would it have been for the public to work with just one responsible and licensed sewage system professional for all onsite matters?  Under § 54.1-2301.D of the Code of Virginia, only onsite soil evaluators and sewage system installers were to be divided into two classes (http://leg1.state.va.us/cgi-bin/legp504.exe?000+cod+54.1-2301):

(e) the division of onsite soil evaluators into classes, one of which shall be restricted to the design of conventional onsite sewage systems;

(f) the division of sewage system installers into classes, one of which shall be restricted to the installation of conventional onsite sewage systems.

Under § 54.1-2301 (Effective July 1, 2016) Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals; membership; terms; duties, what will become of installer classes after 2016?