As an AOSE, I am fully aware that my existing license will expire on June 30 at midnight and this really bothers me.  Unlike the folks without an AOSE, I along with my fellow AOSEs do have something to lose.  We have been sold on the fact that our transition was supposed to occur on July 1, 2009 and some factions seem quite diligent to delay or potentially change that effect; hopefully that will not stop everyone else from moving forward. 

For over 30 years, VDH has provided home owners with a one stop&shop convenience for onsite permitting.  Yes, this includes soil evaluation and design purposes.  Only in extreme situations, was a home owner forced to seek the services of a "second" outside party.  During the past 9 of those 30 years, the AOSE program afforded the same services to our citizens, but did expand the type and number of systems that a home owner could have designed by the same professional.  AOSE was created as a "specialty" for a specific service-soil evaluations with a design to follow.  This privatized entity was only molded from the 30+ years of success that VDH achieved.  Financial and time resources should not be wasted on behalf of the tax payers to "fix" something that is working fine; a trained professional who has grown to specialize in the siting, evaluation of soils, and design of an onsite system.

Limiting an OSE to only evaluate soils for conventional only will further delay projects for home owners and cause additional financial burden.  If preliminary soil work determines secondary effluent is required, then another professional is needed complete the job.  If the OSE is marginally experienced, some AOSEs may not trust their work and insist at looking their existing work or doing it all over, again, more time and money.  SInce this "was" supposed to be a transition of the AOSE program from VDH to DPOR, it is discerning that we have people who are trying to sever soil evaluation from design.  I mean, it worked for 30+ years with VDH and 9 years under the AOSE program, what didn't work that would necessitate change? 

Standards:  Yes, we definitely need them.  For OSE/AOSE and VDH.  More so, we need definitive guidance on how local districts will be required to implement current GMP#126A.  As a soon to be licensed professional, I would hope that DPOR establishes conduct for how the "quality assurance" or our work is processed.  Quality assurance is intended to check the performance of a professionals work.  Under current policy and local differences, there are local counties that basically perform independent evaluations within a proposed site for "quality assurance".  The latter scenario tells VDH nothing about the professionals' work which was submitted, but is often used to force home owners to change their design type to a more complex and expensive system.  Once again, causing further financial burden and time delays to the tax payer.  We need standards for viewing existing pits, equipment required, and processes required if new pits are to be evaluated by VDH. 

Establish additional standardization of hydraulic conductivity or accepted percolation data for all soil evaluations.  It does not matter how "good" the soil evaluation is, for very few if any sites are consistently tested to determine "actual" field measured rates (may only be applicable to specific geologic provinces).  Adding more science will only give us more certainty of the final determined use, but will also help reduce failure rates.  Currently, unless required by VDH or a mass drainfield, perc rates are best guessed/estimated for design purposes. 

All current VDH AOSE should be grandfathered into an Alternative Onsite Soil Evaluator with the exception of those who have not completed the required designs.  Those who have not completed the designs shall be given a conditional AOSE license and must, within 3 years work directly with or under a licensed AOSE to gain their permitting experience of alternative systems and after which the 12 systems can be documented, gain rights to a full AOSE license.