This board has heard well supported condemnation of it's conduct. This board has manifested a culture of contempt. It's response to the periodic review was "retain as is"  this is unacceptable for a public body.

However, please recall this board was sternly lectured regarding it's duty to the citizens and the professions under regulation. The clearest message we've ever heard was delivered by Jay DeBoer, "the governor likes to be liked." His message of concern toward an ill considered and unpopular set of standards was ignored. A board which embraces dual standards, and refused to consider documented complaint cannot be trusted to be a fair and impartial arbiter. The initial drafts of these regulations were inexplicably corrupted by internal processes, as the process continued we became more alarmed and the board became more hostile. When the minutes cannot be trusted to report the people's business we have a serious problem. When FOIA reports the true business we learn to suspect the worst.

This board would do well to listen to the people's voices, do away with the self dealing practices of the past, learn to listen to the concern expressed, and consider those portions of the historical roots of the AOSE program (12VAC5-615) which served the public well for over 20 years. Support our call for enforceable standards of practice, a regulated professional seal, and an understanding that development of natural resources must contend with limits which require professional training & judgment. 

It would also be wise to police this board, we have asked for fair treatment, and have witnessed vindictive and inappropriate behavior by the very people chosen to represent the Governor's interest in serving to protect the public's health, welfare and safety.

Sunshine is the best disinfectant, rather than hiding in the shadows we expect you to conduct your business in a manner beyond reproach. There should no longer be secret meetings with VDH, VOWRA or others wishing to privately influence the regulatory functions. This board should reconvene the OSE/PE Work Group, and find the means to elevate this profession for the simple reason that a limited exemption to engineering license should support the construction of real property improvements as defined under 54.1 of the APELS Board. The licensed professionals relying upon this board have invested their time, treasure and talents to serve the public's interest in reliable site evaluation and design, we deserve better representation. You must incorporate the natural order into these regulations: universities and community colleges have the reward and responsability of developing our successors, and we await the young men & women who will join us in the field to learn our skills and serve the public into the future.

Consider these words:
No regulation of a profession or occupation shall conflict with the Constitution of the United States, the Constitution of Virginia, the laws of the United States, or the laws of the Commonwealth of Virginia. Periodically and at least annually, all agencies regulating a profession or occupation shall review such regulations to ensure that no conflict exists.

We stand prepared to guide this board, or work to block the next stage- the choice is in the hands of DPOR's staff and board.