Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals
 
chapter
Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals Regulations [18 VAC 160 ‑ 20]
Action Amend regulations to license onsite sewage system professionals.
Stage Proposed
Comment Period Ended on 3/6/2009
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1/22/09  8:01 pm
Commenter: Leon Campbell

Change Regulation Style
 

As a private citizen trying to read and understand these regulations, I found it difficult to understand where requirements for one licensee begins and another ends.  For example, in Section 74, the header says "License required."  Natually, I figured this section must apply to all of the licenses.  But the paragraph starts with operator of waterworks and wastewater works.  The second sentence just refers to classification of licenses; the third sentence starts with "no licensee".  Going to paragraph B, it starts talking about provisional licenses; paragraph C discusses "no person", "no licensee" and "individual".  Paragraph D then reverts back to "no person".   It looks like Section 74 applies to some of the licenses, but not all.

I suggest the board consider dividing the regulations into parts, such that each part deals with a specific license.  That way, as a citizen, if I'm interested in understanding the requirements for alternative onsite installer, I simply go to that Part of the regulations and read all about it.  It would save me a lot of time in trying to read the entire regulation and then trying to figure out which pieces and parts apply to installers and which applies to waterworks operators.

Thank you for considering this idea.

CommentID: 6748