Alternative system installers will be required to have 20 hours of continuing professional education during the 24 month license period.  The currently advertised A-Z Onsite Waste Water Course will cost $255 for non-VOWRA members and give 0.8 CEUs for attendance.  How does that translate to continuing professional education hours?  If everybody spoke the same language, professional hours versus educational hours, we might understand better just how much this will cost us. 

If one CEU equals one CPE hour and we use VOWRA’s A to Z class as an example, at that rate each year’s CEUs or CPE hours will cost approximately $3,200 and require ten or more days of missed work (since the A to Z class is an all-day class.)  Even with VOWRA membership, the class at $155 would mean an additional $2,000 per year of expense plus the lost time.  That is a significant increase in the cost of doing business.  Add in possible travel expenses to participate in the classes, the State Board of Contractors License and recovery fund contributions, the new DPOR license application fee of $100, and the exam cost which is estimated to be $84, and you’ve made a big difference in the economic condition of all businesses affected by these new regulations.  At this stage, we have no idea what courses will be available, where they will be held, or at what cost. 

These regulations will require a part of the industry that has previously been essentially unregulated to spend considerable money and time to be able to continue in work that many of them have been performing in a very professional manner for decades.  If VDH has approved their work for all these years, then why is this drastic a change necessary?  If their work is substandard, then there are ways currently available that can help them either be brought into compliance or persuaded to find some other area of work.  Operating permits can (and should) be denied for systems that are not installed properly and the expense of correcting the error will fall on the installer, an expense he is not likely to want to incur often.  A little gentle persuasion by the EHS who approves or disapproves the system can go a long way to helping an installer clean up his act.  As a last resort, the State Board of Contractors has “teeth” in their ability to fine poorly performing contractors and require that they take classes to improve their business practices or, if all else fails, to pull their license.  And in the case of systems designed by AOSEs or PEs, the designer has a responsibility to not allow poor workmanship to go uncorrected when they inspect their systems.  And again, the installer will incur extra expense if his work is not up to standard.  If these procedures are followed, then the problem of sloppy work by a handful of installers would be essentially eliminated.  And the industry will be better for it.

The General Assembly has mandated that licensing of installers and operators of alternative systems be implemented but not for conventional systems.  The currently proposed regulations go far beyond what is now the situation for these businesses and will create a period of confusion and difficulty for the entire industry.  If the regulations as currently stated are the ultimate goal of whoever instigated these changes, then why not create an intermediate step so the industry can catch its collective breath while coming into compliance.  Even the so-called interim licensing process will be difficult and expensive, especially for installers and operators who have not been regulated prior to this time. 

Here are a few suggestions:

1. Eliminate at least half of the hours of education required for both conventional and alternative installers and operators.
 
2. For an interim installers license, require only certification from two or three EHS, AOSE, or PE license holders that prior work by the installer on some specified number of systems has been of good quality instead of the current proposal’s extensive details about the number of systems installed and Completion Statements and Operation Permits.  For a full license, require the exam and the same certification from the designers or VDH. 

3. Manufacturers of the various units for alternative systems are already required to hold classes to certify installers.  Somewhat stiffer requirements for these classes may be advisable, and these classes by manufacturers should be at their expense, not out of the pocket of the business desiring to install their products.  Every inspector of these systems should require proof of installer certification for the specific product.  Allow these classes to be counted toward the continuing education requirement. 

4. At the end of four or five years from implementation of the new regulations, revisit the issues and see if changes need to be made.  By then everyone who desires to continue in this work will be more nearly in compliance with others in the building trades and the transition to tighter requirements will be easier.