Section 74.D says "No person shall act as an alternative onsite sewage system operator of an alternative onsite sewage system which exceeds 10,000 gallons per day design flow without possessing the appropriate class of wastewater works operator license in addition to an alternative onsite sewage system operator license.

As this is written and read in plain language, to operate an alternative onsite sewage system greater than 10,000 gallons per day design, the person must possess a wastewater works license and an alternative onsite sewage system operator license. It seems counter-productive to make persons possess two licenses.  I recommend that the Board consider just having one license.  If a wastewater works operator is needed, then that should be sufficient.  It seems unnecessarily expensive to require licensees to possess two licenses to operate one system.  I recommend that the Board re-examine the economic impact of requiring owners to hire persons that must hold two licenses rather than one for a given task.  As I understand the rules, installers will need two (and perhaps three) licenses to install sewage systems, one from the Board of Contractors and another one or two from this Board.  Again, it seems like there is an unnecessary regulatory redundancy with the proposed regulations.  Maybe the board can consider adding alternative onsite sewage system operator as part of the classes for the wastewater works license to avoid such redundancy.  Presumably, owners will have to pay more for these services since the professional will need to go through the effort and time of getting and maintaining two separate licenses.  In its economic impact analysis, the Dept. of Planning and Budget indicated that there was insufficient information to determine the benefits of these regulations.  I recommend that the costs be better defined before proceeding with this regulation.