Practitioner Comment:   Contracts should be required and minimum contractual requirements should be included in the regulation.

The Board licenses individuals, not business entities.  The Board for Contractors already governs contract requirements and it lists minimum contractual requirements in its regulations.--K.R. Davis

THE WWWOOSP BOARD HAS A RESPONSIBILITY TO REMOVE DECEPTIVE PRACTICES  IN THE INDUSTRY WHILE ADDRESSING THE PROPOSED REGULATIONS. 

Onsite professionals are routinely failing to disclose limits of service in both the operation and maintenance services and onsite design services.  Failure of the board to recognize and respond to the complaints has left the injured citizen with limited options for recovery. Virginia currently has a statute of limitations for breach of a written contract is five years, and for the breach of a non-written contract it is three years. Va. Code Ann. §8.01-246.

Is it the intention of the WWWOOSP board to deny  2 years of benefit during a professional breach to the consumer? 

SUGGESTION:  Create language for contractual agreements.  If the "entity" must be regulated, then incorporate that requirement into the proposed regulations.