This paragraph provides one of three options for qualifiying for the alternative onsite soil evaluator license.  It states, "Three years of full-time experience as an authorized onsite soil evaluator certified by the Virginia Department of Health (VDH) and evidence of completing the soil evaluation and system design work on a total of at least 36 onsite sewage systems (12 of which must be alternative system permits approved by VDH)".

1.  Is the last parenthesis appropriately placed (i.e. is it the intention that only 12 of the systems have to be approved by VDH and the other 24 need no approval)?  Or, was it the intention that all 36 need VDH approval?  If the latter is the case, recommend inserting the last parenthesis immediately after the word "permits".

2. What is the significance of having these 12 (or 36) systems "approved by VDH"?  It is VDH policy to field review 10% of private sector work.  Consequently, VDH may only field review 1 or 2 of the 12 systems.  Under state policy all 12 will be reviewed 'on paper'.  However, who has been reviewing these 'alternative' systems?  Typically they are reviewed by unlicensed, uncertified health department employees that have a minimum of one year of 'experience'.  One might recommend that all 12 (or 36) systems must be field reviewed and approved by a licensed VDH employee.  However, that's unrealistic and quite possibly more ridiculous than the language proposed.  Perhaps a survey of malfunctioning systems designed by authorized onsite evaluators would be more meaningful (and VERY controversial).

3. What are the significant differences between a 'conventional' system and an 'alternative' system when the design is completed by someone who is not an licensed professional engineer?  When the practice of engineering is not involved, what makes an alternative system 'alternative'?  A pre-engineered treatment unit?  An archaic pad/bed?  VDH policies and manufacturer cut sheets can guide any idiot through the design process of all non-engineered alternative systems.  The real difference between a conventional system and a non-P.E. alternative system is the inspection and operation of the alternative system which has nothing to do with the site and soil evaluation or the design.

Recommendation: Delete paragraphs a, b, and c and simply require the applicant to pass an exam and have 2 years experience as a conventional onsite soil evaluator.  Keep it simple.