I object to the Rescission of these Regulations under an Emergency Action, and understand that an indication of opposition will require the Agency to consider the means to amend or transfer these statutes which document the expectations of our work and the procedures by which our client’s interests are considered. We realize that the change from “Authorized” to “Licensed” in 2009 might have created some administrative confusion, however the work an AOSE performs in the interpretation of a client’s objectives, in conjunction with site restrictions and the Regulation have held steady. There are technical, procedural and ethical standards which are lost by the repeal of this section of the Administrative Code of Virginia.

Some of these expectations are captured and refer back to 12VAC5-615 in GMP126B- Standards for Applications with Supporting Documentation from the Private Sector; however there are many issues under the regulation and the policy which deserve clarification and support to standardize the practice of site evaluation and design. Furthermore standards for the handling of documents and the expectation that a professional’s work be reviewed and approved by a qualified code official is an essential component of a citizen’s right to improve his real property..

I recommend that the VDH work with the DPOR Waste Water Board, and consult the Professional Soil Scientist's and Engineering Boards to capture those standards essential to the practice of onsite sewage system evaluation and design. Only with full disclosure may the citizen may be assured that his interests are being considered with  allegiance to our duty to the client, other professionals, the regulation, and the environment.