John,

What do existing systems, site evaluations, etc. have to do with DPOR's regulations governing licensure?  These matters currently fall under the purview of VDH and will remain under their purview until some crazy interest group decides to take it away.  DPOR will have nothing to do with this.  The role of the local health department will not change as a result of the DPOR regulations.  The role of OEHS will change - i.e. they will no longer issue AOSE certificates.

I think VDH employees saw the writing on the wall at least 10 years ago when VDH was mandated to accept AOSE work without field review.  Our role has changed considerably.  Who knows what the EHS role will be in 5 years from now.

You indicated that VDH employees never attended Mr. Alexander's videoconference meetings.  Perhaps it's because most of us were either not informed of the meetings or we were not invited.  In the past my primary information source about new GMPs was the private sector.  It's pretty embarrassing when an EHS receives a phone call asking for clarification on a GMP that he/she did not know existed.  In OEHS's defense, the communication problem has improved.

You appear to be very dissatisfied with the VDH permit approval process.  This may be due in part to the fact that we have conflicting regulations, 146 GMPs, House Bills, Senate Bills, etc. and the EHS doesn't know what his/her role is anymore.  Have you ever received any training on a GMP?  Me neither.  We just fumble along until we reach a common ground if possible.

Perhaps you should find a delegate or senator who will push some legislation through the 2010 GA.  Heaven knows we could use some more Bills.  How about this?  A Bill that will require VDH to issue an "Express Construction Permit" when the work is certified by a licensed individual?  Maybe it could be limited to residential applications with flows no greater than 750 gpd.  The health department would be required to issue the permit within 24 hours, the licensed individual assumes all responsibility, etc.  This would prevent VDH from having any time to review it which would result in an immediate permit approval.

Sorry to ramble on about a topic that has nothing to do with the DPOR regulations.  I think most of your arguement was that VDH is broken and I would agree whole-heartedly.  Let's save our comments for the public comment forum for future VDH regulations.