You may want to consider including the steakholders directly linked to and involved in the proposed regulations...looks as though the Virginia Association of Professional Soil Scientists, DPOR's Board of Professional Soil Scientists, Virginia Association of Authorized Onsite Soil Evaluators, Virginia Health Department, etc. were NOT included in on the development of these proposed regulations.  Don't you think it might be good to include those WHO ARE EDUCATED and WORK in the area on a daily basis in which new regulation is proposed.  What a thought?!...including people to whom it affects and creating regulations that help the professionals AND protect human health!