I recommend that DPOR simplify the entry requirements in Section 96.  There are five basic KSAs (knowledge, skills, and abilities) that an OSE must have:

1.  Understanding of how to properly evaluate and describe site and soil features.

2. Understanding of how to properly design onsite sewage systems.

3. Understanding of how to read and follow regulations for onsite sewage systems and water supplies.

4.  Understanding of how to properly locate a water supply in accordance with applicable regulations.

5.  Understanding of how to properly inspect a water supply and sewage system.

First, the definition section needs to reflect these basic skills (and the differences in skill)  when defining an Onsite Soil Evaluator (both alternative and conventional).  The difference in KSAs between a Conventional and Alternative system revolves around additional skill and understanding with respect to low pressure distribution, drip dispersal,  treatment devices, nutrient removal, and treatment.  Hence, the definitions should explain this. 

Section 96 seems to explore that these basic understandings and these differences in skill can be found by having different years of experience and education.  For the conventional evaluator, DPOR proposes the following series:

1. CPSS with one year of experience.

2. 4-year science degree with two years of experience evaluating soil under the supervision of a COSE.

3.   2-year science degree with three years of experience evaluating soil under the supervision of a COSE.

4. No degree and eight years of experience evaluating soil under the supervision of a COSE

I will note the following problems with the above proposal.  First and most obvious, DPOR only asks for soil evaluation experience.  If that's all you need, then just be a CPSS.  Otherwise, change the experience requirement to the five basic skill sets noted above and ask for the experience that differentiates between alternative and conventional technology.  Next, most people do not enter this type of work by working for a COSE.  They work for engineering firms, state agencies, or go into practice for themselves.  Instead of asking for work under a COSE, DPOR should just ask for three references from persons with the Alternative or Conventional license, a CPSS, or a PE.  If a person cannot produce three references to show that they have had the required experience, then they probably do not have the required experience.  Next Section 98 of the proposed regulation seems to change the experience requirements than stated in Section 96.  In Section 98, it talks about having a GED and one year of experience without a GED.  I do not understand why Section 98 talks about needing a GED or 1-year of experience since you should have met this according to Section 96.

I recommend that you change Section 96 for the Conventional requirement by adding the requirements in a table format.  The headers of the table would have "Experience" , "References", and Education.

Under the experience category, the person have the following:

1.  CPSS with two years full time experience designing onsite sewage systems, siting water supplies, and inspecting treatment works and water supplies. 

2. Four year related science degree with four years full time experience performing site and soil evaluations using designing onsite sewage systems, siting water supplies, and inspecting treatment works and water supplies.  As I understand it, you must have 4 year degree and 4 years of experience to sit for the CPSS exam so this would make the CPSS equivalent to four years of site and soil evaluation experience.  I'm proposing an equivalent expectation for both the CPSS and a 4-year related degree.

3. Non-related four year degree or 2-year related science degree with six years full time experience performing site and soil evaluations using designing onsite sewage systems, siting water supplies, and inspecting treatment works and water supplies.

4.  No degree and 8 years full time experience performing site and soil evaluations using designing onsite sewage systems, siting water supplies, and inspecting treatment works and water supplies.

Now, require that everyone provide 3 references from a CPSS, PE, or OSE to demonstrate that they have this experience.  Do not ask people to submit confirmation of working under the direct supervision of someone else holding a COSE license.  They could just as reasonably gather the experience working under a CPSS, a PE, or an Alternative Onsite Soil Evaluator in an engineering firm.