"operating staff" means individuals employed or appointed by an owner to work at a waterworks or wastewater works.

By definition, if a homeowner appointed himself to work as his own wastewater works operator, then he would be considered the "operating staff". 

The proposed regulations define the term, "operating staff," but never use it elsewhere.  What value does this definition serve if it is not used anywhere else in the regulations? 

I could perhaps see value with this definition if owners were allowed to appoint themselves to operate their own alternative sewage system, to become an "operator-in-training" if a licensed operator allowed the owner to work under their license to service their own treatment unit.  

As such, I recommend that the regulations expand the concepts of "operating staff" and "operator-in-training" so owners can "operate" their own alternative sewage system.  Allow "operating staff" or "operator-in-training" to have an interim or provisional license to operate their own alternative sewage system.  Owners of Virginia would have the option to save themselves a lot of money by operating their own alternative sewage system instead of having to pay someone else $50 to $150 per month.  This would be a huge benefit for owners who want to operate their own system.

In the proposed regulations, "operate" means any act of an individual that may impact on the finished water quality at a waterworks or the plant effluent at a wastewwater works. 

This definition would mean that every homeowner in Virginia with an alternative onsite sewage system would need to have a valid operator license since any act of the owner may impact the finished water quality of the plant effluent at a wastewater works. Owners of alternative sewage systems should be allowed to operate their own alternative system as the rules seem to contemplate.

§ 54.1-2302 requires everyone to have license who perform the duties of an onsite soil evaluator, or install or operate an alternative onsite sewage system, without a valid license.

This code section says unlicensed people cannot perform any of the above work.  Why do the proposed regulations say unlicensed people can do this work as long as they are directly supervised by someone with a license?  If this is possible, then homeowners should be included in the group so they can operate their own alternative sewage system.