Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals
 
chapter
Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals Regulations [18 VAC 160 ‑ 20]
Action Amend regulations to license onsite sewage system professionals.
Stage Proposed
Comment Period Ended on 3/6/2009
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3/6/09  3:52 pm
Commenter: Ron Fellenz / Action Tank & Drain Service

Lack of Timely Notification of Proposed Regulations
 

TThe website for public comment opened on 1/5/09. The public hearing for the proposed regulations was 2/5/09. The deadline for submission of comments is today 3/6/09. We received notification of the proposed regulations on 2/25/09 in a letter sent by the Prince William Health District dated 2/18/09. We cannot meaningfully respond to the proposed changes when we were notified after the public hearing and given only seven working days to respond.

We also notice from the website comments on the proposed regulations that very few of the comments are from existing companies or individuals that install and maintains system - the vast majority of the comments are from government employees, Certified Professional Soil Scientists or Authorized Onsite Soil Evaluators. We suspect that the lack of timely notification has contributed to the lack of comments from the installer and maintainers.

We request the following:

1. Extending the deadline of 3/6/09 an additional 60 days to allow enough time for meaningful comments to be made by the installers and maintainers directly impacted by the proposed changes; and

2. Request that a second comment period be provided after the current proposed changes have been revised. Given the confusion in the current proposed regulations and major concerns expressed by those who have commented on the proposed changes, and  in anticipation of significant revisions to the current proposed regulations, a second public review seems warranted. We also request timely advance notice of the revised regulation comment period.

CommentID: 6908