Thanks to the Board for providing a forum to address the onsite wastewater program, which pays the bills for a lot of people in Virginia, including this writer. 

I don't know how we have ventured so far in scope and content regarding the proposed "Amend Regulations to License Onsite Sewage System Professionals."   For the uninformed or slightly informed observer of these proposed regulations, he/she could only surmise that prior to July 1, 2009 Virginia has had a fairly inept and incompetent group of people working in all aspects (evaluators, designers, installers, pumpers, VDH staff, etc) in the onsite wastewater program.  This perceived ineptness and incompetence has cried out for the complete overhaul and gutting of a system that I thought had been operating quite well for the past few years.  I keep trying to figure out why we need such a drastic overhaul of the onsite program?  Still figuring. 

Virginia already has a strong core group of professionals working in all aspects of the onsite program.  Now we are getting proposed outlandish legislation that includes such gems as: there should be separate licenses/categories for evaluating conventional vs. alternative soil and drainfield sites.  It should register strongly and without equivocation to the Board that nearly all the people who have addressed this particular issue of conventional vs. alternative have immediately recognized that it is illogical and counterproductive for the onsite program.  The bottom line: there have been many, many, similar, common sense suggestions and comments submitted in this forum.  The Board should seriously listen to these common sense submittals and write mandates and laws accordingly.  I don't think the Board should sink the current onsite ship merely because it can.   

I have been a practising soil scientist in Virginia for the past 36 years.  For the past 22 years, I have reviewed hundreds and hundreds of drainfield sites submitted by public and private sector soil consultants.  The logic never changes, if a person wants to do a good job in the onsite program, they will do a good job.  Advanced educational degrees and/or extensive experience nearly always play second fiddle to the desire to want to do a good job and calling like it is.  Mucky, complicated, overreaching legislation as represented in some of the proposed amendments will not ensure a job well done.   

Thank you again for this forum and good luck.