My original CPSS license # was 13 before the numbering system changed.  Other than the subject matter experts, I am one of the first group to take and pass the exam and be licensed.  When the concept of AOSE came along I was on the committee that drafted interim guidance in which you were required to be a CPSS and provide copies of soil evaluations and designs that you had prepared to obtain an interim license.  When it came time for permanent regulations, I must admit that I personally let all of my fellow certified professionals down and gave in to Don Alexanders idea that an AOSE was more about being a well rounded designer and inspector than it was about doing soils work even though the original bill was specifically related to soil evaluations for subdivision approvals without designs.  Those of us on the committee should have held our ground  that the first requirement for being an AOSE was to hold a CPSS.  

Since that time, the profession of soil science has been lost to VDH and at one time budget cutters thought it was best to keep Engineers on staff and cut the State soil scientist positions from the VDH roster.  Sad.  We fought like hell to get those positions back because now you had experienced  licensed soil scientists arguing over depths to water table and restrictions with VDH AOSEs with a 2 week soil training course and two years of experience with no third party to consult with.   

The effect of this, at least in my region of Virginia, is that some health department reviewers doing level II field reviews always lean towards a more conservative call on depths to restrictive  features and estimated infiltration rates as what I interpret as a well intentioned effort to protect the citizens and the environment when in fact at times it often has the opposite affect.  God forbid they agree with a consultant, they wouldn't be doing their job. Lets take a class II  70 rate soil with restrictions of one form or another at 24'. Simple system, you need TL-2 treatment with 12" deep trenches and some cover dirt, or TL-3 and trenches a little deeper depending on your preference and mounding calculations.   Any AOSE can design that every day and its a simple effective solution.  Now, on a level II review the VDH reviewer calls restrictions at 23". Suddenly the choices have changed.  Its either TL-2 drip or another engineer designed TL-3 trench system at 1 - 11" , maybe now UV is needed and an AOSE is likely not designing the system a PE is required.  Repeat the same scenario with restrictions identified by the AOSE @ 12" vs VDH @ 10".  A more conservative call now results in a more complicated, expensive system with a higher risk of issues related to clearing, installation and long term performance.  What we need here is the correct call on restrictive features and not the most conservative call.  In a lot of ways, the practice of soil science has been watered down to submitting what you know can be approved on the first submission because  no one in the building industry has time for the drawn out appeals process created by VDH.   So, more complicated  systems get designed and installed in lieu of arguing a few inches via an appeal.  

Just as their are classes of OSE's, Operators and installers under one DPOR board, instead of eliminating the LPSS, I would suggest that the regs be revised to attract more professionals and different classes be developed specifically related to soil evaluations for the treatment and dispersal of human and other wastes regulated by VDH and DEQ.   There are others more familiar with other public needs for LPSSs relating to nutrient management, storm water and where we all came from, Agronomy now know as CSES I think.  So lets not get rid of the one professional license that was the original requirement to be an AOSE, lets create a new class and train more AOSEs to be LPSS.