Agencies | Governor
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
[REPEALED] Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals Regulations [18 VAC 160 ‑ 20]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 Final
Comment Period Ends 9/9/2015
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Back to List of Comments
8/11/15  1:47 pm
Commenter: Jeff Walker, BRSS

Undermining Authority
 

We observe the Board has ratified these changes to the requirements for entrance and certification of installers. Objections delivered during initial public comment, appropriately resulted in the abandonment of the Fast Track initiative. Over 25 commenters objected to the term "VDH authorized employee" emphasized the need for licensed supervision under authority of a DPOR Board.

Notice that none of the recommendations provided to the WWWOOSSP Board in the initial NOIRA or further public comment have been considered or ratified. Specifically the suggestion offered 2/14/214, supporting (1 year) warranty of installer's approved work which deserved incorporation in the Regulations. The Board should consider placing the Installer license under the Contractor's board with other licensed tradesmen.

This is fundamental to the DPOR duty to establish minimal standards to protect the public and assure a reliable service by licensed Installers. This illustrates the disconnect between the Board and the Installers, Operators and Evaluators who actually serve the public.

It is my understanding that Mr. Thomas did not have a valid license when he resigned his seat on this board as a subject matter expert. And alert the public to calls for Mr. Davis’ resignation due to prejudicial comments exchanged with the Executive Director. And calls for Mr. Aulbach to attend to ethical matters in his capacity as chairman. The Code allows for convening a panel of experts to advise the Governor on controversial regulations, it is unfortunate this board failed to recognize these concerns. Soliciting regulations creating additional continuing professional education (CPE) requirements should not conflict with the interests of the board members particularlily when undisclosed affiliations to organizations which profit by the sale of CPE.

The undermining of the authorities of this board is a concern to the Commonwealth, likewise undisclosed conflict of interests. I believe that we are united in calling for greater transparency to the regulatory processes, and look forward to further opportunity to comment on regulatory review currently underway.

Jeff T. Walker, AOSE, AOSSI, LPSS

CommentID: 42110