I have been recently informed that DPOR is wanting to require CPE training for to maintain a Waste Water license. I do not agree that CPE training should be required for this field, unless it is made convient for all municipalities, such as online training or free onsite training. I feel that travel expenses and the cost of training would strain small municipalities. I think if the State is going to shove rules and regulations down the throat of Operators, the least the the State can do is make the necessary training convient and fair for everyone! In my few years of Operating I don't think that has been done!

Thanks for the opportunity to express my comment

There are many operators employed by the DOC that are licensed in both water & wastewater. This is the case with many municipalities and private utility companies as well. As written, an operator would now be required to have 20 training hours for each license held during the bi-annual renewal cycle (assuming they hold a class 3 or higher license in both categories). I think a provision that addresses dual certification should be included in the final regulation. The subject matter covered in many water training classes applies to wastewater as well. SUGGESTION: ALLOW A SPECIFIED AMOUNT OF THE APPROVED TRAINING  A WATERWORKS OPERATOR OBTAINS TO BE USED FOR WASTEWATER RECERTIFICATION ALSO.                                                  

The Board has recognized the appropriate time for an operator with a degree in environmental science or engineering, to become familiar with the workings of the plant by setting minimum work experience requirements under the supervision of a licensed operator. This allows time for individuals to become familiar with the mechanics and intricacies of the plant and how it reacts to adverse conditions.

Mechanics that have spent considerable time at the plant have a good portion of this knowledge.  To become a licensed operator, they must learn the operator skills then apply them to their existing knowledge.

For the purposes of gaining the necessary experience for obtaining a waterworks operators license, a percentage of the time spent as a mechanic at the water treatment plant should be given.  This credit should apply only to work on the plant operating equipment and not to tasks such as painting or housekeeping.  This could be documented and verified via a work order system. 

Fairfax Water has had very good experience with mechanics that transitioned to the operator position. They have proven that a good working knowledge of the plant gives them a head start towards learning the operator’s duties and responsibilities.  This change would allow a pool of dediacated and talented employees who can react quickly to plant upsets and/or diagnose problems, to be recognized by the Commonwealth through the licensing process and use their talents to protect public health. 

At 18VAC160-20-109, paragraphs H and I, the proposed regulations indicate that a "CPE instructor" may himself obtain CPE credit for developing, instructing and/or updating a continuing education course. While this proposal is laudable to the degree it encourages and motivates speakers, presenters, and other actual and would-be CPE instructors, some definition of "CPE instructor" may be in order. A definition should differentiate between instructors who develop and present such classes in a public forum, or instructors who come in to make a presentation from outside an organization, and those who arrange and conduct private classes "in-house."  I do not agree with the view that CPE instruction can be or should be met  in-house by the organization that benefits from it, which I regard as a conflict of interest, and so must take issue with language that would give further impetus to that trend. As another state puts it in their regulations, "For in-house training, an instructor from outside of the organization shall provide the instruction."

Dennis R. Wanless

After having read DPOR's Regulations and statutes, and all current comments on the proposed regulation changes I would like to suggest any Bachelors degree count as experience time.  I understand that a biology degree is preferred, and classes in the "sciences" will be taken into consideration but as the current regs. state a person with a college degree is no more qulified than a High school graduate right out of school if they went through the Apprenticeship program.

Most businesses recognize a College degree even if it is unrelated to the job in question as very valuable.  It shows commitment and reliability to finish a program of study and a confidence in the holder's commitment.  Throughout the proposed regulation Form TH-02 Competency is a driving desire for DPOR.  Allowing increased degree programs to satisfy the licensing requirements will bring that competency and also help get more operators into the business. I Propose for any Bachelors degree  Class III should need 1yr experience w/o substitutions and a class IV license, Class II 2yrs experience w/o substitutions and a class III license, and Class 1 3yrs experience w/o substitutions and a class II license. 

Thank you for your consideration,

Jonathan Newcomb Class IV operator BCVPI Water Authority

B.B.A. Radford Univ. 

M.Div. Southwestern

I believe you do an injustice to those individuals interested in the field of waterworks and wastewater works operations by excluding experience gained in the lab, water distribution systems, wastewater collection systems, plant maintenance, and other nonoperating duties (18VAC160-20-90B.4).  All experience gained in those areas comes in to play as an operator.  Operators as well as operators-in-training perform some aspect of those duties in their day to day job tasks, especially smaller systems where an operator is required to be a jack of all trades.  I began my career in water as a distribution operator/lab tech and transitioned into operations when the licensing requirements were less stringent and am glad for it.  That's not to say the regs should revert back to allowing individuals without operating experience become licensed but allowing experience in the aforementioned areas to count as experience as an operator or operator-in-training.  The license application provides adequate documentation that an individual has obtained the appropriate hands on operating of a water facility.  I think there is room to allow these types of experiences to be counted in the Class IV and III license categories along with the Class V or VI.  With the impending shortage of operators everywhere I believe it is imperative that every opportunity be afforded to those interested in joining the ranks of operator.

Has DPOR considered that hundreds of licensed wastewater operators in Virginia will retire within the next five years and that replacements will be hard to find?  There are not many up-and-coming operators standing-by waiting for opportunities.  Localities will be foprced  to compete with one another in salaries just to find qualified people.  With a new CPE requirement on top of that, the costs of employing licensed operators will be driven upward even further.  With the current state of the economy, how can private and public utilities afford to hire and maintain qualified operators?  More thought and brainstorming are needed here.

The Virginia Water Environment Association (VWEA) provides educational opportunities to wastewater treatment operators and other industry professionals. VWEA has been providing continuous educational opportunities and support to our membership for many years via conferences, workshops, training events, etc. and welcomes the opportunity to continue supporting the objective of providing Continuing Professional Educations for licensed wastewater operators in the State. VWEA requests for “subject content” to be defined and to be confined to “meeting the seven topics identified in the PSI Examination Content Outline (page 3) documentation” which is available from DPOR.  VWEA desires a procedure to allow the Association to determine CPE credit worthiness without undue burden or time constraints.  Prior to implementation of these regulations, VWEA would appreciate the opportunity to discuss collaboratively the methods and procedures DPOR will be using for mutual benefit.

VWEA Board of Directors