Delete the concepts outlined in Section 84 of the proposed regulations.  All persons who hold an Authorized Onsite Soil Evaluator (AOSE) certificate from the Board of Health passed a written and field test and had to have at least 4 years of experience.  The Board of Health also required that all regulants pass approved VDH training courses or be registered as a CPSS.  This Board of Health standard is much tougher than the standard proposed by DPOR, which will only requires a written test and experience with as little as two-years.

I do not understand why DPOR plans to make all people who were tested and validated through a previous regulatory process to re-validate.  The licensing aspects are simply changing from one state agency to another one.  The VDH regulations were more stringent than proposed by DPOR and the VDH regulations passed public scrutiny, the Board of Health's evaluation, and the Governor of Virginia.  If there are bad actors in the VDH program, then DPOR should weed them after they enter the program instead of trying to weed them out at the expense of making the vast majority of us who are doing good work to revalidate through a testing mechanism.

Open the door to grandfather those who have already tested and deemed qualified to design both conventional and alterantive systems.  Otherwise, these persons have to endure two testing procedures from two different state agencies.  It is more reasonalble to grandfather people and weed out the bad actors than to force everybody with the AOSE certificate to test two times.

I recommend that Section 84 say the following:

Any person who held a valid AOSE certificate by the Board of Health on June 30, 2009 shall be deemed qualified for the OSE license for conventional, alternative, and alternative discharging systems.  Upon application for the license by any person who held a valid AOSE certificate from the Board of Health, the board shall grant the license for the AOSE certificate.