VDH employees are not allowed to design alternative onsite sewage systems by agency policy.  It is a conflict of interest to approve proprietary devices and then design their use.  DPOR proposes a rule that requires applicants for the Alternative Onsite Soil Evaluator license to submit 36 onsite sewage system designs (12 of which must be for alternative system permits approved by VDH).

As a previous writer noted, VDH does a Level 2 review on 10 percent of applications.  It is possible for VDH to approve work from the private sector without ever looking at it.  Why ask for the submission of approved plans when they may not have been reviewed by a third party or VDH?

I read through the requirements for a lot of the other professions that DPOR licenses.  I did not see a requirement that engineers must submit 36 designs to sit for the P.E. exam.  I did not see that architects or surveyors had to submit 36 designs or plats that they produced, which were approved by a state agency.  Why is DPOR trying to chart new ground?  Follow the routine expectations for all other professions that DPOR licenses.  Do not create new expectations.  Who is trying to keep VDH employees from obtaining a license?

The proposed regulation unfairly penalizes people who work for VDH.  Why ask VDH employees to produce something that they cannot produce?  Is it DPOR's intent to keep VDH employees from getting the AOSE license?  If not, then DPOR needs to get rid of the expectation that a person asking for the Alternative OSE license must submit designs approved by VDH.