I support the continuing licensure of soil scientists in the commonwealth and emphatically oppose the proposed elimination/deregulation of Licensed Soil Scientists. The General Assembly voted unanimously in 2011 to require licensure for soil scientists because of the potential risks due to a lack of regulation. Following a 50+ year career as a certified and/or licensed soil scientist the need for professional description and interpretation of the soil profile is greater today than 2011.

Northern Virginia localities including Fairfax, Arlington. Loudoun, Fauquier, Prince William Counties and the Cities of Vienna and Alexandria require substantial investigations, interpretations and design for onsite storm-water management, onsite wastewater systems, drainage, seasonal high water table, expansive and other soil related issues. Many of these locations are presently either experiencing problems or are requiring costly design requirements due the lack of professional interpretations by licensed soil scientists. Many more rural counties lacking rigorous geotechnical requirements for site development rely on the NRCS website or published soil surveys for guidance. Review the geotechnical requirements for construction in any county of the commonwealth and it will indicate the need for either a soil map interpretation or a licensed soil scientist. I have attached a typical copies. Often the soil map is interpreted improperly or without knowledge of their limitations for specific onsite issues. A licensed soil scientist is the only professional that can provide the proper interpretations. With expanding development in these areas, the need will be increasing. The negative consequences of unqualified professionals practicing soil science include costly remediation and repairs.

In addition to the risks to the public, this deregulation will directly affect my ability to practice in Virginia and impacts my personal and company livelihood. Homeowners, builders, developers, and localities are dependent on my services. Without a license I would no longer be qualified to provide many of these services.

Virginia Soil scientists do critical work involving stormwater management, erosion and sediment control, Resource Protection Areas delineation, soil map interpretation, support for onsite wastewater systems, cooperative efforts with the geotechnical engineering and homeowner communities for soil and drainage interpretations, providing land planning services to local communities and nutrient management services to farmers and landowners

This work must be regulated otherwise potential damages both monetarily and environmentally will be costly to the commonwealth and its citizens.

Soil Scientist in VA Codes and Regulations, examples

STORMWATER MANUAL : A GUIDE TO STORMWATER REQUIREMENTS FOR LAND DISTURBING ACTIVITIES IN ARLINGTON COUNTY (March 2020)

Soil testing. Testing for infiltration rate and depth of seasonal high-water table is required according to testing procedure outlined in the Clearinghouse Design
Specification No. 8,

Appendix 8-A (Version 2.0, 2013). All soil evaluations, including test profile pits, soil borings, and permeability tests shall be conducted under the supervision of a licensed Soil Scientist. Per the testing procedure, the seasonally high-water table (SHWT) may be determined using soil morphology throughout the year by a certified professional with training and experience in soil morphology. SHWT determination by direct observation of the groundwater level should be performed during the months of November through May. Professional engineers registered in Virginia with experience in the field of geotechnical engineering with certified training in soil morphology may also be certified to determine the SHWT.

Design Specification No. 8: Infiltration Practices Infiltration-only systems installed to date under Chapter 60 have experienced high failure rates. These failures have placed burdens on builders and property owners, including inability to obtain certificates of occupancy, unanticipated added costs at the end of construction, and subsequent costs and disruption for property owners following construction.

Chesterfield County  (August 23, 2013)

"All new and single-single family residences in Chesterfield County and structures with habitable space located in the Triassic Area require the homeowner of contractor to acquire the services of a soils scientist, geotechnical or civil engineer who visits the site..."

City of Fredricksburg (April 1, 2017)

"On site soil and underlying parent material evaluations shall be performed by a Virginia licensed Soil Scientist, Engineer, or Geologist...."

Town of Vienna (August 9th, 2019)

Background: The town of Vienna and adjacent localities have been dealing with an increased number of complaints from residents regarding continuously running sump pumps and flooded basements. Effective immediately, the Town of Vienna will adhere to Fairfax Counties policy on establishing lowest floor elevations on on field evaluated seasonal high water table. (my comment: requires an analysis of redox soil color patterns in soil profile as evaluated only by a licensed soil scientist or trained professional)