Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Professional and Occupational Regulation
 
Previous Comment     Next Comment     Back to List of Comments
9/24/20  5:35 pm
Commenter: Gregory Monnett, Ph.D.

Protect the public with licensed Soil Scientists
 

I am writing to oppose the elimination of Licensed Professional Soil Scientists (LPSS).    The Certification of Soil Scientists has a long history in Virginia.  Soil Scientists have been certified by the State for decades before being upgraded to Licensure.   Many localities have relied our profession to provide expert advice and evaluations of soils and site conditions and as such they have  incorporated the use of Professional Soil Scientists in a number of their local codes.    One example is the requirement in Fairfax County to use a LPSS, or an engineer that has soils trainings, when designing stormwater infiltration basins.   As an added note to the Fairfax County regulations, the engineers are trained by LPSS individuals.  Many localities have also incorporated into their code the option of using LPSS in determining soil conditions for structure foundations.

Additionally, LPSS are recognized by a number of localities as licensed professionals that can conduct Water Quality Impact Assessments (WQIA) and Resource Protection Area (RPA) determinations.    WQIAs are used when there is a need to encroach into an RPA.   Many homeowners along the Chesapeake Bay watershed need WQIAs to build homes and other structures and to protect the bay.

LPSS is also cited in the Erosion and Sediment Control and Stormwater Management Certification Regulations.  (9VAC25-850-10) as a profession that can review Erosion and Sediment Plans. 

The elimination of the LPSS program will not help the general public since the options for the public to hire professionals other than engineers will be reduced.   Soil Scientists have proven their contribution to the public with their expertise over the decades.  Since many of the local codes name certified or licensed Soil Scientist as a qualified professional that option to the public will be taken away.   This proposal to eliminate LPSS will not create more competition or employment to the public.  In fact, is will have the opposite affect and hurt the livelihood of numerous professionals and drive up the costs to homeowners needing environmental services by reducing the availability of professionals that are required by local and other state codes.  

CommentID: 85926