From: Roadcap, Dwayne (VDH) Sent: Monday, September 19, 2011 7:45 PM To: Knapp, Allen (VDH); Bowles, James (VDH); Bolling, Patrick (VDH) Cc: Hicks, Robert (VDH) Subject: FW: HB 2185 FYI From: Gregory, Lance (VDH) Sent: Monday, September 19, 2011 4:31 PM To: Roadcap, Dwayne (VDH) Subject: HB 2185 Dwayne, I have a tendency to speak out of turn or talk too much so I try to hold back on my two cents on this issue today. I thought I’d just put it in a email and let everyone else speak. I think we should privatize the onsite evaluations and designs for all paid applications (new construction, expansion, modification, subdivision, etc.). I don’t think this would have much of an impact on the cost of services from onsite professionals, at least not in our area. They will still be competing for services in a down economy, and 50% to 60% of these services are already completed by OSE’s/PE’s in our area. I think VDH staff should still be responsible for reviewing and approving these designs. County officials perform and in-house review of every building permit, plan review, zoning case that comes through the door. I think we should do the same, 100% Level I review. As for Level II reviews I think 100% is excessive (unless stipulated by county ordinance). OSE’s and PE’s are licensed, and we do need to respect that licensure. However, there should be some level of field review to keep them honest and because soil evaluation and design is so subjective. I believe that OEHS should put together a OSE/PE review policy and provide training on that policy to all EHS’s. Because of the subjective nature of what we do you will never get complete uniformity throughout the state, but if the review is based on a set standard it should at least be close district to district. I think all repairs….. is an issue above my pay grade. I’d like to see them taken over by the private sector, but I fear that if people have to pay for that service they will either let the issue persist until we take enforcement action or they will repair the system illegally. I really think the OSE’s and PE’s need to step up here. If we are willing to back this proposal and give them a 50% increase or so in work, the least they can do is come up with some alternative ideas for cost effective repair permitting. My last thought on this issue is VDH should complete an internal audit of how these changes will effect staffing needs. If we eliminate a large portion of direct services it stands to reason that some portion of staffing may be eliminated. Chesterfield has keep a detailed timesheet over the last 3 years to determine the amount of time spent on the services we provide. The average bare combination permit takes approximately 5 hours to complete, not including paperwork which is about another hour, so approximately 6 hours total. The average OSE permit receiving only a level I review takes 1.5 hours, and the average OSE permit receiving a level II review takes 2.5 hours. Using 2010 numbers for Chesterfield, if every application (repairs not included) were completed by an OSE/PE and only 10% level II’s were completed, it would free up approximately 550 man hours from our EH staff. I had calculated that 97.49% of our EHS time was accounted for in 2010, so with this reduction in direct services that number would fall to 91.81%. I think our staff could make up for that time by increasing the amount of time spent on Legacy documentation, our proposed GIS mapping program, public education, and the additional duties necessary in Operation and Maintenance of AOSS. The point being I believe a reduction in Chesterfield Health District staff would be detrimental to our goals as a department. That being said I think all districts should provide some data to show how these changes would affect the demands on their staffing. We may find that some districts would be understaffed. would be overstaffed, while others are and To put it bluntly, if some EHS positions are eliminated then maybe those staff would move to underserved areas to provide OSE services, or not. Anyway, that’s my 2 cent. Sincerely, Lance Thanks again for coming out.