I oppose the repeal of these regulations. I understand that the responsibility for licensing OSE's has moved over to DPOR. However these regulations contin the standards of practice that DPOR used to establish its testing for the OSE Licenses.  None of that information, which is not directly licensing, is being retained anywhere.  Virginia must have a basis for Standards of Practice.  It can be by a state department such as VDH, or DPOR, or by a independent group such as VAPS or VOWRA.  In any case the Standards of practice should be vetted before those groups/organizations who are part of the Onsite Wastewater practice.  Until that happens those standards contained in this regulation should stand.  The conflict with licensing can be removed,but it is not utilized and should not be a problem until the standards are documented sufficiently elsewhere.