Most of the issues that I have with these proposed regulations have been addressed by others already, but I feel that I need to echo them to some extent.  Some of the problems I have need to be addressed as often and as loudly as possible.

First, any non-AOSE individual who is not currently working under a certified AOSE is essentially out of a job on July 1 (assuming this ends up being the effective date of this chapter).  This statement includes current VDH EHS, Seniors.  While we may not be laid off after July 1, we will have no authority when a bare application is submitted for review.  This is especially true if an LHD does not have an AOSE on staff, as is the case in some districts (mine).  I have my four years in...now I can't become an OSE (C or A) because I'm not already.  That makes no sense.

Second, clarification is required regarding COSE vs. AOSE.  It states in section 74.C that issuance of an alternative license voids all previously issued conventional licenses.  Does this mean that an AOSE can do everything that a COSE can? 

Thirdly, and this is after talking with VOWRA members, AOSE committee members, and existing AOSE's, but I have no issue with taking a written test for actual license to be an AOSE.  While I do agree that the VDH standards to become an AOSE now are very stringent in relation to what is proposed by DPOR, I do not have a problem with actually satisfying DPOR when they take over the program.  This complacency is finite, however.  The addition of a provision for existing VDH personnel who have passed the required VDH training modules and exams MUST be added.  This provision should NOT take into account the experience level of that EHS.  I say this because these proposed regulations are innately unfair to "new" hires into the soils program, especially if their district does not have an AOSE on staff.  If they have passed the multiple written exams and the final field exam with VDH, and are able to pass the written exam for DPOR, then why not grant them, at a minimum, an IOSE?

Next, I do agree with a previous comment that condemns the requirement that 36 examples of previous work for OSE's needs to be submitted to prove experience.  If twelve of these 36 examples need to be approved alternative system designs (I'm assuming that means anything more advances than a primary system) and your geographic work area does not reequire a third of their systems to be anything other than primary, how can you possible satisfy this requirement?  Additionally, the previous comment that identified other licenses that are not required to show proof of experience hit the nail on the head.  A P.E. candidate doesn't need to show 36 approved designs but an AOSE needs to?  That makes no sense.  Most of the systems that AOSE's are designing now are PRE-engineered anyway, and others already have worksheets available online that already have the engineering built in.  It seems to me that the requirement would almost need to be reversed.

Literally, I could go on for a very long time about this proposed chapter of regulations.  DPOR and VDH need to reconvene and address ALL of the comments made in this forum.  I believe that discussion has to happen between the two agencies involved and more of the actual field personnel who are pounding the ground.  I don't know off-hand how many EHS's, AOSE's, and CPSS's were on the committee for these regulations, but it doesn't seem like enough. 

P.S.  I will not comment on the requirements for operators/installers.  I am neither, and thus have no practical input.  I do encourage everyone to talk to their local installers/operators and give them the chance to comment on these regulations.