This regulation should be retained in its current form. I have no issues with how the regulations are written or applied. 

Please retain these regualtions as written. They are functional and necessary to preserve the high quality standards for soils work in the Commonwealth. 

I am writing in support of retaining the LPSS in its current form. 

As a member of the Virginia Association of Professional Soil Scientists, I recognize that the Professional Soil Scientist license protects the public welfare and encourages all qualified soil scientists to participate in licensure.   Our goals are to:

1. Advance the professional interests of soil science.
2. Promote the liaison and exchange of information between soil scientists and other disciplines.
3. Promote high standards of education and training in soil science
4. Enhance public awareness and appreciation of the profession.
5. Establish and maintain high standards of ethical conduct in all professional matters.

As such we encourage and request the Board recommend maintaining the license for professional soil scientists. 

Soil Scientists characterize and interpret soils for many various land uses.  USDA-NRCS published soil survey reports prepared by soil scientists, among others, form the basis of many investigations and designs for all types of projects important to the Commonwealth.  Building foundation integrity depends upon identification of stable soil, agricultural productivity depends upon identifying soil types that can grow food and fiber.   Soil scientists are also trained in many aspects of surveying, engineering, agronomy, building construction, chemistry, physics, microbiology and geology because they all relate to the use and management of our soil resources and the protection of human health and our soil and water resources within the Commonwealth of Virginia.   Professional soil scientists continue their training in soils and the application of various lands uses to soils as a way to garner a livelihood and to better guide sound management of this important natural resource.  

Professional soil scientists recognize that soils are natural bodies on the earth's surface, and that the environmentally responsible utilization of this natural non-renewable resource is of utmost importance to the Commonwealth.  They are also trained to recognize the strengths and weaknesses of published soil surveys- a trait not shared by many other disciplines. 

As licensees, our clients- including state and federal agencies know the persons being hired for a project are fully trained and tested in the field of soil science with expectations that the product of our work will meet the standards of other licensed professionals and protect the health of the Commonwealth of Virginia. 

Thank you for your consideration of these comments. 

Emily Salkind, LPSS, PWD

Environmental Project Manager

Associate

Balzer & Associates

15871 City View Drive, Suite 200, Midlothian, VA 23113 / p 804.794.0571