CPSS are certified by a similar process as the PE, also pertaining to Architects, Geologists, Surveyors and others; with defined requirements of experience and education, with written standards of conduct, subject to investigation and censure, and governed by a Board of our peers, under a branch of DPOR.
Whether "voluntary," or as a requirement to practice as for the PE, the licenses, certifications, registrations or other authorizations are issued by DPOR. Any movement to deprecate these professional registrations diminishes the rights of stakeholders practicing under the Code of Virginia. While it is desirable for onsite designers, installers and maintenance to enter licensure there are problems with the current proposal, and it is unfortunate that the drafters of this document have not solicited comments or concerns from soil scientists in the field. Perhaps the correct remedy would be to introduce legislation changing the Certification to a Licensure; however I understand that this may create other complications.
It is true that there were 2 AOSE (one of which is a CPSS), out of the 11 Licensure Committee members at the Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals. There are also seated representatives to the VDH, as well as DEQ, and at least one of the appointees has served on the Board of VOWRA a Virginia chapter of NOWRA. All the members were appointed by the Governor, and to my knowledge none are affiliated with VAPSS (VA Association of Professional Soil Scientists), nor the CPSS Board at DPOR.
The draft proposal was not released until Fall of 2008, it was made available prior to review by the Attorney General's Office, via a members bulletin board at the VOWRA web site. Frankly many of us were surprised by the approach the Committee has taken, for the expectation had been that licensure of onsite design would build upon work completed by the existing DPOR Board for Soil Science which was established over 20 years ago.
I believe that as the comment period continues we may expect other PE's and interested people to weigh in with their concerns. Indeed during the Spring of 2008 there were over 600 comments concerning a change in the requirements for continuing education for PE's. Most of the Engineers that I associate with are satisfied with the limited role that AOSE's play in the onsite waste water design field. We do not seek to expand our role beyond that of offering economical design services for limited domestic and small commercial wastewater issues. A PE is usually not interested performing this work, and is not able to provide the rapid turnover and economical services that an integrated soil and design practice (AOSE) can produce. Normally a CPSS or a AOSE provides site information to a PE for larger or more complex installations or those exceeding the narrow mandate of design that we are qualified to perform.
The Commonwealth only has about 230 AOSE currently, however as the roles of governmental services change due to budget restrictions and pressure toward privatization we can expect the field of onsite wastewater design to become more important. Indeed though my own practice is established I look forward to working with younger soil scientists to solve some of the economic and environmental dilemmas that we now see emerging in public discussions. These are topics which are best addressed by scientific analysis, interpretation and the creation of solutions in cooperation with other professions.
I am a member of VAPSS, and have been a member of VOWRA as well, but I do not speak for either association.
