DPOR should take the proposed regulation back to the board and get input on the minimum standards to evaluate the soil permeability.  DPOR and board need to include in the regulation any minimum standards of practice for operators, installers, and OSEs.

Right now, DPOR rules just look at entry requirements and do nothing else.  The citizens of the Commonwealth need more protection than entry requirements to the license.  Look at what other DPOR boards do, especially the APSCELIDLIA Board.  That board includes minimum standards of practice.

Building on what a previous person wrote, I think the board's rules should include the minimum standards for doing a percolation test or using a device to measure the soil permeability.

Without minimum standards of conduct and practice, the board will have very, very limited ability to deal with bad actors.  DPOR should not depend on other state agencies to regulate the practice of its regulants.