I do not support the Onsite Soil Evaluators (OSE) being regulated by the Board of Waterworks and Wastewater Works. 

The proposed OSE regulations as exclusively pertaining to the design components of an onsite wastewater disposal system and do not adequately address the requirements for soil evaluations.  I respectfully request that the proposed OSE be limited to the design, inspection and certification of onsite wastewater disposal systems - removing the ability to perform soil evaluations.  I propose that all soil and site evaluations for the purpose of onsite wastewater disposal systems be conducted by a Certified Professional Soil Scientist (CPSS) who is governed under the existing Board of Professional Soil Scientists (PSS).  The Board of PSS already defines qualifications for certification, examination and experience as well as standards for the practice of soil evaluation, we recommend an amendment that DPOR defer to PSS Board and accept these standards and qualifications already established for any professional conducting soil and site evaluations.

I respectfully request an amendment that any CPSS currently certified under either DPOR or VDH, may continue to prepare site and soil evaluations for onsite wastewater disposal systems and submit reports to VDH as licensed professionals as long as the system design has been prepared by an OSE or PE.

All soil evaluations for onsite wastewater disposal require specific skills, knowledge, and abilities regardless of the type of wastewater treatment design.  In many circumstances, it is the soil conditions which dictate the type of wastewater treatment design.  If an individual does not possess the necessary skills, knowledge, and abilities to properly evaluate soils on all sites an error in design and subsequent system failure may occur. 

I recommend leaving the soil evaluation component to the certified professional soil scientists.