Agencies | Governor
Virginia Regulatory Town Hall
Department of Professional and Occupational Regulation
Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals
Onsite Sewage System Professionals Licensing Regulations [18 VAC 160 ‑ 40]
Action General Review 2014
Stage Final
Comment Period Ends 2/22/2017
Previous Comment     Next Comment     Back to List of Comments
2/22/17  11:01 pm
Commenter: bob marshall / cloverleaf env. cnslt., inc.

Accomodating the market participation of ancillary agencies

When did the current procedures and policies of the Department of Professional and Occupational Regulation (Department) include accomodating the market participation of ancillary agencies involved in the oversight of waterworks, wastewater works, and onsite sewage systems?  The new chapter 18VAC160-40 for onsite professionals failed to incorporate the Board's original definition of Owner

"Owner" means the Commonwealth of Virginia, or any political subdivision thereof, any public or private institution, corporation, association, or any other entity organized or existing under the laws of this Commonwealth or of any other state or nation, or any person or group of persons acting individually or as a group, who own, propose to own, manage, or maintain waterworks, wastewater works, or onsite sewage systems.

"Owner" in 18VAC160-40 for onsite professionals was glaringly absent:




Part I

18VAC160-40-10. Definitions.

A. Section 54.1-2300 of the Code of Virginia provides definitions of the following terms and phrases as used in this chapter:


"Onsite sewage system"


"Wastewater works"

One might surmise, the necessity for repealing 18VAC160-20 might have been altogether avoided had a comprehensive white paper been prepared to inventory and assess the full extent of VDH's participation in the marketplace as an Owner.

Also, the Board might have thought more rationally about its recent modifications to "direct supervision" which apparently were in conflict with the current procedures and policies of the Department of Health (Sept 27, 2011, request from Mr. Allen Knapp (VDH official) and Mr. Dan Richardson (VDH official).

CommentID: 57619