To whom it may concern,

I am writing to you as a private citizen and geologist in Virginia who has not yet earned my official licensure. I will be taking the Fundamentals of Geology exam in October to earn my GIT. I am writing because I strongly believe in the licensure and regulation of licensure in Virginia and the process involved in licensing Geologists in the commonwealth. 

Most people are unaware of the work geologists do, and I wanted to familiarize you with the kind of work that I do specifically. Much like engineers, who are required to obtain licensure before being able to stamp an engineering report, geologists are required to do the same at the current time. The reason being is that our work directly affects the public safety, welfare of the public and the interests of the public on a daily basis. Much of the work I do personally has these broad effects because it pertains to the development and infrastructure that the citizens of Virginia and other states use daily. I am currently working on a roadway expansion project where my expertise is used to log the soils and rock beneath the roadway. It is essential to do this correctly because the engineered design of the roadway is directly impacted, which directly impacts public safety. 

Another essential component of my work is rock slope stability analysis. To complete these analyses, I undertake in geological mapping of a steep rock slope to map the discontinuities on the slope to determine the risk of failure. If failure occurs, human lives, infrastructure and buildings beneath the rock slope are at grave risk of irreparable damage. It is essential to have the expertise of a licensed professional examine these slopes and stamp the projects after completion to ensure that a regulated professional has done the work correctly and properly. 

The regulated licensure of geologists is essential to the public safety and welfare of the citizens of Virginia. It ensures the success of businesses by reducing liability as well as providing a legal certification for the employees to lean on when completing relevant work. It also ensures that geologists understand the fundamental methods and topics in our field which are absolutely crucial to complete our work correctly.

Overall, I strongly believe in the licensure program Virginia has for geologists. I believe firmly that it must remain in place to help ensure the public safety and welfare of our citizens, as well as the many businesses who hire geologists and the businesses whose welfare is affected by geological work on a daily basis.  

Thank you for considering my comment and I hope to see that the licensure program for geologists in Virginia remains in place. 

My sincere appreciation,

Noah Fleischer

My name is Christina Sullivan, and I have been a geologist for close to 15 years, and I currently do not hold a P.G. license in the state of Virginia. I do hold a Bachelor and Master's degree in Geology, as well as an MBA. My 15 years of experience includes experience in underground coal mining, coal mine permitting, underground gold mining, surface gold mining, and aggregates. I have lived in four different states across those 15 years and have held multiple positions from a Geologist I to Senior Geologist. In all my time as a geologist, I was never once mandated to obtain a P.G. license. The research that I have done on the Virginia licensing program has shown me that obtaining licensure not only requires a significant time commitment, but a financial commitment as well. I do not believe that every employed geologist would be able to make those time and financial commitments. Personally, I know several geologists that have tried to pass the exam numerous times and have failed; even after spending money on outside study resources. Those geologists are still gainfully employed and doing great work for the states, industries, and communities that they live and work in.

It is my opinion, that the geologist licensing in Virginia remain voluntary, and not mandated or repealed. There are certain industries that geologists work in, that do require licensures such as working as an engineering geologist, construction geologist, and environmental engineering geologist. Virginia already has very strict licensure requirements in other industries (i.e. mental health) that make employment difficult - I know this because my husband works in the Psychology field for the state. I do not want to see Geology thrust into that same strict licensure as it will cause companies to lose valuable employees, and employees to possibly lose their livelihoods.

Thank you for your time.

Christina Sullivan

I have my Virginia geology license, certificate #2475. I am licensed in ten states, and I am very familiarly with professional licensing for geologists. I was the first chairman of the Florida PG Board in 1987 and have more than 56 years of experience in many fields of geoscience.

We need professional geologists of high standing and regard to provide answers to questions that impact health, safety, and welfare of our citizens and neighbors. Professional licenses are part of the answer.

Licensing of our profession provides critical answers to questions posed by living on this planet. 

Do not move backward .... move forward with more integration of professional geology with engineering and other disciplines. 

                                                                                                                                                                July 31, 2023

To: Virginia Regulatory Town Hall

Regarding Amending the Certification requirements for Geologists in the Commonwealth of Virginia

Dear Sir/Madam:

                I am a retired professional Geologist, Certified in the Commonwealth of Virginia since 1984. (#2801000470)  I was employed by the Mitre Corp. (VA), PEPCO and the Maryland Department of the Environment.  All hired me after I received VA Certification. I also worked for Geotechnical Engineers and for a company as a hydrogeologist for development and remediation of contaminated public water wells.  Because of my field experience,   State review work and Certification in Virginia, I was registered also in Delaware.  The Mitre Corp. requires experienced Geologists for their government contracts, military and non- military.  A geologist, an earth scientist, typically has 4 or more years of college study and 7 to 10 years of experience prior to the VA examination.  Geologists work for State and Federal government, Geotechnical Engineering companies and are self- employed for specialized work.

                In my opinion, the purpose of certification is for two main reasons: to ensure a high level of expertise on projects affecting the public welfare and to disallow a conflict of interest. 

                We need experience and expertise, because in earth science, for example, land, surface water, ground water, underground foundation issues are not evident, visible, “black and white” and contain unknowns.   The analysis of test results is necessary.   Also, with more expertise, less funds are expended, and less time is wasted when working on new development, flood and slide, building foundation failures and remediation of contaminated soils and waters and other projects.

The existing rules and regulations do not allow a certified professional geologist from having a conflict of interest.  We work in behalf of the health and welfare of the public.  A Geologist might be pressured to provide approval or a recommendation favorable to his/her employer or other entity.  FThere is a code of ethics that a CPG must follow in order to remain certified.  (The Code of Regulations for Geologists, Outlines Standards of Practice/ Conduct and Competence)

I recommend that the regulations should be amended to make licensure of Geologists mandatory.

Thank you.

Phyllis V. Buff, CPG, Commonwealth of Virginia since 1984

I am writing this as a private citizen of the Commonwealth of Virginia and a 31-year practicing geologist.  I am in favor of amending the statutes that created the certification of Geologists in Virginia to make licensure mandatory and linking geologists’ services to the support of public welfare and the safeguarding of life, health, property, and the environment.  Furthermore, I am in favor of adding a continuing education requirement for continued licensure. 

Geologists in Virginia are commonly employed in the energy, water resources, infrastructure, and mineral resource sectors.  As such, some of the common tasks that we perform include.

• Prepare water supply studies for public and private water supplies.
• Complete highway rock slope stability evaluations for roadway safety.
• Perform geologic and geophysical surveys to locate and mitigate active karst conditions beneath the Commonwealth’s infrastructure.
• Prepare mine safety studies to extract mineral resources safely and effectively.
• Prepare dam and bridge foundation studies to support engineering design.
• Evaluate mineral and aggregate resources to construct the Commonwealth’s infrastructure.
• Assess and reclaim abandoned mine lands to revitalize Virginia’s natural resources.
• Position and monitor landfills to manage Virginia’s solid waste the to protect groundwater resources.
• Assess and clean-up contaminated groundwater and soil to protect human health and the environment.
• Assess, clean-up, and redevelop brownfields to spur economic growth.
• Respond to natural hazards and provide consultation aimed at mitigating the hazards identified.

It is important that the individuals that serve in these roles are properly trained and have demonstrated minimum competency.  Verifying minimum competency through examination is one key role of the Board for Professional Soil Scientists, Wetlands Specialists, and Geologists.  Ensuring that geologic services are provided by competent geologists protects the environment and safeguards the life, health, and property of all Virginians.

It is critical to the protection of the citizens of Virginia that a rigorous program be maintained to assure the quality of the services that geologists provide to the public.  The current voluntary program should be strengthened to be required and allow the grandfathering of the participants in good standing in that program.  The protection that upholding the minimum standards of professional conduct in the execution of geological investigations and projects insure that the individuals who are conducting the work are qualified and meet the standards of the profession.

As a registered geologist in 4 Canadian Provinces and 5 US States, including VA,  I would like to express support for 18VAC145-40, particularly Part III Sections 90-150 Standards of Practice and Conduct.    It appears relatively consistent with similar statutes in other states and provinces that have recognized, given the current state of climate, the professions importance in collaboration with registered civil engineers in competently mitigating the impact of natural geologic hazards to our life, health, property and built environment.  However, geologic licensure is currently voluntary if I understand correctly?   The can say that the wording of Chapter 40, particularly Part III (Sections 90-150), appears inconsistent with that of a "voluntary" program.

As a licensed geologist in Virginia since 1997, I support the continuation of the licensure program in the voluntary form.  Having licensed geologist is important in maintaining a higher degree of qualified individuals who work in areas of public importance.  Having been in the environmental consulting practice for over 30 years, it is important to have qualified individuals in charge of projects involving such important tasks as site assessments and contaminant fate and transport modeling.  

I hope that the Department will continue the program to insure the public is well served.

I am writing this comment as a private citizen with more than 40 years' experience as a practicing geologist. I have had my Virginia geology license, certificate #2801000222 since 1984, my first license as a Professional Geologist. I am licensed in four states which I work in regularly. I also have offered expert witness testimony in multiple states dealing with various aspects of geosciences from landslides to ground water impacts.

It is imperative that we have Professional Geologists of high standing held to professional and ethical standards to provide answers to questions from clients and the public that impact the health, safety, and welfare of our clients and the public at large. Professional licenses are a crucial part of the answer. I further suggest that continuing education requirements be made part of the continuing licensure.

When looking for new hires at the 8+ years' experience level, if they are not registered as a Professional Geologist, frankly I have a challenging time taking them seriously as a consultant in the geological sciences. I actively encourage and mentor my younger staff into obtaining their license as soon as they are able in the states they currently work in. Within the past 2 years, I have had 3 young geologists who have obtained their registration as a Professional Geologist in Missouri, Indiana, and Kentucky. I have a fourth geologist who will sit for his exam in October of this year.

It is important that we have geologists that are properly trained and demonstrate a minimum level of competency. I implore the politicians of Virginia to not move backward by eliminating this licensing program, but to move forward and require all geologists offering services to the public in Virginia be licensed. Only then can we protect the environment and safeguard the health and property of the citizens of Virginia.

I am writing to express my support for continued licensure of geologists in the Commonwealth of Virginia.  While our society depends on the ability of our elected officials to make prudent decisions regarding what laws are needed for protection of society and which are unnecessarily burdensome, I am writing this in hopes that my professional and personal knowledge gained over the course of my 25 year career may be helpful in this process.  

I am a Virginia PG (exam-certified in 2005) and have focused much of my work on contaminant hydrogeology, the study of how toxic chemicals move through the subsurface, where they will migrate, and how to treat them to eliminate human and ecological health risks.  In recent years, I have spent a significant amount of time supporting drinking water sites impacted by Per- and Polyfluoroalkyl Substances (PFAS). In cases where there are releases of PFAS in fire fighting foam or other chemicals that may impact surrounding drinking water supplies, it is the role of the hydrogeologist/PG to assess what wells/reservoirs may be impacted by contaminated groundwater and how to address the  contaminated media and exposure.  Poor or uniformed decision making may result in prolonged exposure to toxins.  While the licensing process does not wholly prevent poor decision-making, it is a deterrent.  To date, PFAS investigations have been focused on manufacturing facilities for these chemicals and Department of Defense sites.  However, EPA has issued draft maximum contaminant levels for some PFAS and a draft CERCLA hazardous substances designation.  If these are finalized, addressing PFAS in many Virginia communities will be a high-profile issue and our Virginia citizens deserve highly qualified professionals to help them. I believe it would be very unfortunate timing to eliminate a safeguard intended to ensure professional qualifications right now.  

On a related note, I would like to share a personal story of an even that occurred in Berlin, NJ, a town adjacent to the town in which my parents live.  New Jersey does not license geologists, though there is a site remediation professional license there for geologists remediating contaminated properties. A number of years ago, the Town of Berlin, NJ drilled and operated a drinking water supply well with the help of a consulting/engineering firm.  The well was properly permitted.  It is my understanding the well was screened in an unconfined aquifer (the surficial aquifer is very thick and has high hydraulic conductivity in this part of NJ due to coarse clean sands). The well was pumped at ~500 gpm.  Within a short time after the well became operational, private wells in adjacent neighborhoods went dry and needed to be redrilled deeper due to drawdown from this municipal well.  Nearby streams and a wetland where a federally listed threatened species (Helonias bullata, swamp pink) grows also dried up. Because the well was pulling water from the wetland, the water quality was terrible.  There were high metals and sulfide resulting in taste and odor complaints from Berlin residents.  The New Jersey Department of Environmental Protection got involved.  Residents from the town and those with private wells in adjacent communities were outraged.  Environmentalists were outraged.  Eventually, the well was turned off, but the story was a lose-lose-lose for everyone. The town spent money that didn’t benefit residents, the residents were all angry, the state was burdened, and the environment was damaged.  Every licensed geologist I know in Virginia would have performed appropriate aquifer testing including drawdown assessment/radius of influence assessment prior to operating such a well or would at least know to find someone else who could do those things. Perhaps I just keep good company. Perhaps there are mistakes like this being made by PGs in Virginia I don’t see, and maybe licensure doesn’t prevent such egregious errors, but I personally think licensing here in Virginia does improve quality of work.  It is an added layer of accountability to protect our citizens.  Virginians deserve to be protected by their government on issues which are not common knowledge to most people.  I hope my elected officials will afford Virginians those protections.  

I appreciate your consideration of my thoughts on this important issue.  

Very Respectfully

Laura Cook, PG 

705 Achilles Ct

Virginia Beach, VA, 23464

I apologize, my comments submitted this morning were no meant to be listed as anonymous.

Thanks

Dan Centofanti

1 August 2023

Via Electronic Mail

Kathleen R. Nosbisch, Executive Director 

DPOR, 9960 Mayland Drive, Suite 400, Richmond, Virginia 23233 

Telephone: (804) 367-8514  

FAX: (866) 465-6206 

BPSSandWP@dpor.virginia.gov

Dean Ms. Nosbisch:

I am writing this as a citizen of the Commonwealth of Virginia and a 25+-year practicing Certified Professional Geologist.  I am in favor of amending the statutes that created the certification of Geologists in Virginia to make licensure mandatory and linking geologists’ services to the support of public welfare and the safeguarding of life, health, property, and the environment.  Furthermore, I am in favor of adding a continuing education requirement for continued licensure. 

Geologists in Virginia are commonly employed in the energy, water resources, infrastructure, and mineral resource sectors.  As such, some of the common tasks that we perform include:

• Prepare water supply studies for public and private water supplies.
• Assess, clean-up, and redevelop brownfields to spur economic growth.
• Complete highway rock slope stability evaluations for roadway safety.
• Prepare dam and bridge foundation studies to support engineering design.
• Prepare mine safety studies to extract mineral resources safely and effectively.
• Position and monitor landfills to manage Virginia’s solid waste the to protect groundwater resources.
• Perform geologic and geophysical surveys to locate and mitigate active karst conditions beneath the Commonwealth’s infrastructure.
• Evaluate mineral and aggregate resources to construct the Commonwealth’s infrastructure.
• Assess and reclaim abandoned mine lands to revitalize Virginia’s natural resources.
• Assess and clean-up contaminated groundwater and soil to protect human health and the environment.
• Respond to natural hazards and provide consultation aimed at mitigating the hazards identified.

It is important that the individuals that serve in these roles are properly trained and have demonstrated minimum competency.  Just like engineers, verifying minimum competency through examination is one key role of the Board for Professional Soil Scientists, Wetlands Specialists, and Geologists.  Ensuring that geologic services are provided by competent geologists protects the environment and safeguards the life, health, and property of all Virginians.

Sincerely,

Montgomery S. Bennett, P.G., RSM

Principal Consultant

Haley & Aldrich, Inc.

13872 Coalfield Commons Place | Suite 200

Midlothian, VA 23114

O: 804-419-0010

C: (804) 467.8572

mbennett@haleyaldrich.com

I write this not because I enjoy paying fees to be a Professional Geologist or that I enjoy having to do additional training and study to enhance my education/knowledge of geological and hydrogeological subject matters, but because it is a technical and moral responsibility of the profession we practice. This applies to all facets of the professional geologist (whether it be geotechnical, mining, environmental, or water related).  For example, in my world as a hydrogeologist, I/we need to stay current on the various emerging contaminants (e.g., PFAS compounds, arsenic, lead, 1,4 dioxane etc.) that adversely impair our drinking water supplies or environment. What we do and the decisions we make impacts the safety of the public who most often have no idea what can harm them or improve their lives. Becoming a certified professional Geologist sets the bar high for being qualified to do our work. This is very similar to a lawyer's certification passing the bar exam, or a doctor passing his medical exams and getting medical training (through residency) before becoming a certified doctor. In some way the impacts that a professional geologist can have on society exceed that of a doctor and /or lawyer who often practice their crafts/skills on only single individuals. The PG's (and PE's) most often practice their skills in ways that impact entire communities, towns, and cities. One decision that a PG makes can impact 100,000's of people's lives. This is not something that should ever be accomplished by a non-certified individual. I believe that the state of Virginia would be making a grave mistake if they lowered the qualification of individuals practicing in these professional and critically important fields.

I am writing this as a private citizen of the Commonwealth of Virginia and a 13-year practicing geologist (VA 2801002355).  I strongly support amending the statutes that created the certification of Geologists in Virginia to make licensure mandatory and linking geologists’ services to the support of public welfare and the safeguarding of life, health, property, and the environment.  Additionally, I support adding a continuing education requirement for continued licensure. 

Geologists in Virginia are commonly employed in the energy, water resources, infrastructure, and mineral resource sectors.  As such, some of the common tasks that we perform include:

• Prepare water supply studies for public and private water supplies.
• Complete highway rock slope stability evaluations for roadway safety.
• Perform geologic and geophysical surveys to locate and mitigate active karst conditions beneath the Commonwealth’s infrastructure.
• Prepare mine safety studies to extract mineral resources safely and effectively.
• Prepare dam and bridge foundation studies to support engineering design.
• Evaluate mineral and aggregate resources to construct the Commonwealth’s infrastructure.
• Assess and reclaim abandoned mine lands to revitalize Virginia’s natural resources.
• Position and monitor landfills to manage Virginia’s solid waste the to protect groundwater resources.
• Assess and clean-up contaminated groundwater and soil to protect human health and the environment.
• Assess, clean-up, and redevelop brownfields to spur economic growth.
• Respond to natural hazards and provide consultation aimed at mitigating the hazards identified.

It is important that the individuals that serve in these roles are properly trained and have demonstrated minimum competency.  Verifying minimum competency through examination is one key role of the Board for Professional Soil Scientists, Wetlands Specialists, and Geologists.  Ensuring that geologic services are provided by competent geologists protects the environment and safeguards the life, health, and property of all Virginians.

I support the continuation of a mandatory licensure program for geologists practicing in the Commonwealth.

It is imperative to have qualified licensed geologists performing work on complex projects along side professional engineers, soil scientists, and surveyors to safeguard life, health, property, and the environment. 

The regulation should make licensure of geologists a mandatory program and that the statutory language doing so should link our profession to public welfare and the safeguarding of life, health, property, and the environment.

Dear Board, 

I would strongly recommend keeping licensed geologist in the state of Virginia. First and foremost, I believe Virginia has unique and vastly varying landmass types and rock types, making for a state in need of people who can differentiate them for public safety and use. Second of all, the public, and private businesses, or developers are able to search the DPOR database for licensed individuals for any reason pertaining to anything commercial, industrial, to residential consultation where they need an experts opinion. You get rid of that, and I'm afraid that people could be douped or scammed by people who have no business offering geologic advice. I do request that geologists remain licensed professionals in the state of Virginia. 

Thank you, 
Nick Bass

As a registered Geologist and small business owner.  The review of this profession is critical to those who deal in earth science.  We provide a service to the public in areas that the federal and state regulates.  The professional qualifications of this field are worthy of regulation.

As a last comment I wonder if the DPOR personnel are subject to review as to qualifications and ability to discern issues dealing with so many professional regulations?

In my twenty years of experience,  I have found that professional licensed geologists in the Commonwealth of Virginia provide critical assurance to the public in terms of human health and environmental protection.    It is my opinion that the statute that created the voluntary Geologist certification program in Virginia should be amened to make licensure of Geologists a mandatory program and that the statutory language doing so should link our profession to public welfare and the safeguarding of life, health, property, and the environment. 

I have been a PG in Virginia and other states for over 30 years and wanted to express my opinion that Professional Geologist licensure is an important aspect to doing work safely and professionally in the earth sciences, both in Virginia and elsewhere.  I work for the world's leading engineering firm and we employ 1,000's of geologists to perform our geotechnical, geological engineering, and hydrogeological work.  In hiring, promotions, proposals, and project assignments, we look to state professional licensure as an indicator of a candidate attaining a certain level of expertise in the field of geology.  Not having VA geologist get licensure would handicap their ability to get jobs and perform rewarding and valuable work. In some (but not all) aspects of our work, state PG stamps are required, and also send a signal to our clients that we are using qualified staff. And even though I'm no longer living in Virginia, I maintain my PG certification because that state is where I took the PG test and achieved my first licensure.  I have subsequently used that VA PG licensure to get PGs/LGs/RGs in a dozen other states that accepted the VA PG test results through comity/reciprocity.  If VA abandoned the program, it is highly likely other states, who deem a PG important and valuable, would no longer accept my VA PG, requiring me to retake the PG exam. 

Overall, PG certification provides the public, facility owners and state and federal regulators an assurance that the work is being done properly and professionally, to safeguard property and both human and environmental health.  Please do not do away with this important program.

I obtained certification as a professional geologist in Virginia in 1993 (2801000943). When I was in the private sector I performed a variety of geology related services including groundwater monitoring at landfills and other regulated properties, groundwater supply studies, and groundwater withdrawal permit applications. The regulated community relies on certification as a means to ensure that the professionals they hire are in fact capable and qualified to provide services for which geologic knowledge is necessary. Further, certification provides employers with the means to evaluate the qualifications and skills of geologists being interviewed for positions which include the practice of geology.

Since 2017 I have worked in the Office of Environmental Health Services at the Virginia Department of Health, specifically in the private well and onsite sewage system arena. I, along with geologists working at DEQ and other agencies, have been called upon by the General Assembly and the Governor's office to provide expertiste regarding "hot-button" issues pertaining to private wells, state waters, public health, and the environment. Recent issues include:

• Potential uranium mining
• Potential gold mining
• Coal ash pond closure
• Pipelines
• Wastewater infrastructure
• Groundwater injection
• PFAS and other emerging contaminants

In such cases, knowledge and understanding of geology is a necessary asset for efforts to determine whether an issue should be regulated, to draft regulations, and to represent the interests of the Commonwealth in public outreach and other communication.

I believe that 18VAC145-40 is critical to ensure that the practice of geology in Virginia is protective of public health, safety, and welfare and a strong factor in the economical performance of important governmental functions. Therefore, these regulations be retained.

Geologists provide an essential service to human health and the environment.  Their role includes determining appropriate levels of clean up of contaminated sites for redevelopment, as well as risk management to users to obtain a comfort level for contaminated site reuse.  This is a safe way to keep contaminated sites profitable/economical.  The current voluntary program should change to making licensure of geologists mandatory.  

I am a native resident Virginian and a Virginia certified practicing geologist.  It is with concern for citizens of the Old Dominion and the future practice of the geological profession within her boundaries that I submit to you the following:

• The Commonwealth bears the responsibility for any reduction in regulatory requirements pursuant to Executive Order No. 19 signed into law by governor Youngkin on June 30, 2022.  There are many great elements to the Order, and while the intent of the Order is certainly welcomed and needed, any reduction in regulatory requirements specifically related to the practice of geology within the Commonwealth would be a disservice her citizens and those geologists currently certified by her.

• There is, and has existed, the need to instead strengthen those regulatory requirements related to the practice of geology within the Commonwealth.  This need is primarily predicated on the highly specialized and technical nature of the work geologists do related to public health, safety and welfare.  Virginia is the 12^th most populous state in the US yet 35^th in land size.  In my 31 years of practicing geology within the Commonwealth well over 2 million new residents have arrived, and with that more needs related to housing, infrastructure, support facilities, natural resources, water supply, power, waste disposal and the like.  All of these geologists perform services for and are critical to the success of.  This trend shows no sign of slowing down in the foreseeable future.  The Commonwealth’s landscape is one of reducing resources and open land space, and increasing dense urban and suburban hardscapes which collectively increase technical complexities and challenges to the practice while balancing impacts to the environment.  As a result, the nature of the work geologists do is becoming even more important, driving the need for increased talent. 

• The majority of the Commonwealth’s citizens, legislators included, do not understand exactly what geologists do on a daily basis, nor do they understand the important role geologists play in ensuring public health, safety and welfare.  For this reason, there exists the explicit need for increasing education and awareness concerning the profession.  It is not hard to understand why deregulation of practice of geology could be viewed by some as an acceptable contributor to the governor’s EO-19 mandate of a 25% reduction in regulatory requirements.

• The Commonwealth’s use of the National Association of State Boards of Geology (ASBOG) testing for certification of geologists is an appropriate standard to demonstrate a minimum level of competency and should be maintained within Virginia Administrative Code (VAC).  It is important to note that the similar American Institute of Professional Geologists (AIPG) professional geologist certification does not require testing to demonstrate minimum competency of geologists certified by that Institute.  AIPG certification does not equal the Commonwealth’s certification of geologists, and is often mistaken to.  Also, the Commonwealth’s use of ASBOG testing affords particular ease of reciprocity for practicing certified, licensed and registered geologists among the 32 ASBOG member states.  Deregulation of the practice would most certainly cause undue hardships for geologists once certified by the Commonwealth seeking reciprocity elsewhere.

Now therefor, in consideration of the above existing conditions, I urge you to properly discharge the duty of your position and the responsibility entrusted to you by the Commonwealth by seeing to it that those statues within the VAC under your influence or authority are, at minimum, kept intact as current, or arguably strengthened in the near future to include provisions related to continuing education requirements and mandatory licensure (not voluntary certification) related to the practice of geology within the Old Dominion.  This would be consistent with the precedent set by similar existing statutes pertaining to other regulated professions within the Commonwealth where highly specialized professional technical expertise is being applied to work, and the products of work, that so directly impact the public health, safety and welfare our citizens are entitled to under law.

Respectfully submitted,

Steven P. Pond, P.G.

I strongly support the current regulation within the VAC to require certification of those who apply the principles of Geology to the daily lives of Virginians! This regulatory requirement has been long-standing and key to protect the public health, safety, and welfare to those that depend on the judgement and experience of Professional Geologists who work every day to support the design and construction of our built environment.  Other professionals in the design, construction and mining industries rely on the judgement, experience, and recommendations of Professional Geologists to develop the facilities, structures, and water systems that Virginians depend on daily.  As a Certified Professional Geologist and registered Professional Engineer in the Commonwealth of Virginia, I strongly support maintaining the current regulation requiring certification of Professional Geologists to practice within the Commonwealth.

Eric B. Rehwoldt, P.E., C.P.G. 

If any changes are to be made to the current regulations, they should be to mandate licensure for practicing geologists in Virginia.  Geologists routinely make decisions critical to the health and safety of the population, including work on public water supply systems, assessment and remediation of hazardous sites, and natural hazards such as flooding and landslides.  Geologists frequently work alongside engineers (who have mandatory licensure) on these types of projects, who rely on information provided by the geologists.  

To the Virginia Regulatory Town Hall, and to Kathleen R. Nosbisch, Executive Director, DPOR:

Although retired, I am and have been a Certified Professional Geologist with the Commonwealth of Virginia since the CPG designation was enacted.  Please consider my opinion about the importance of the professional services Geologists provide in support of public welfare and the safeguarding of life, health, property and natural resources, and the environment.  I feel the statue that created the voluntary Geologist certification should be amended to make licensure of Geologists a mandatory program and that the statutory language doing so should link our profession to public welfare and the safeguarding of life, health, property and natural resources, and the environment.

Thank you for your consideration.

John T. Popp

CPG No. 2801000190

To whom it may concern,

I am writing to express my support for the licensure of Professional Geologists in Virginia.  As a licensed professional geologist, I can assure you that the process to gain licensure is not easy.

Currently regulations state that an individual applying for professional geologist licensure must work under a licensed PG for at least seven years. In addition to the work and PG oversight requirement, applicants must pass not one, but two tests.  The first tests the applicant's fundamental knowledge of geology, ie, what we were taught in the classroom. The second tests the applicant's professional knowledge, ie, what we have learned on the job.  These tests do not focus on a specific area of geology, but rather a broad range of knowledge is needed to pass.  

There is a reason applicants are recommended to begin studying months before the exams. The wide variety of topics potentially covered requires a significant time investment to successfully review the knowledge base gained in school and in the workplace. And most applicants complete this extensive study on their personal time.  As a geologist, this is a major career achievement.  

All of this means that there is a level of competence and professionalism assumed with an individual whom has earned their PG. Cheapening our profession is not only personally offensive, it would open the door for the potential of less competent work in our industry, with the potential to create situations dangerous to the public.

Sincerely,

Krista J. Tetrick, PG, PWS  

Professional Geologists serve the public and society by applying their knowledge toward the responsible use and management of the earth’s resources.  This is true whether they are employed by a government agency or a private firm.  

To have qualified individuals whose work and knowledge involves the practice in the field of Geology is important, in many ways, to the wellbeing of the general public in the Commonwealth of Virginia.  I will cite several examples of where this is true: in the field of mineral exploration and management  Virginia Energy - Geology and Mineral Resources - Mineral Resources; consultation related to earth events such as the 5.8 earthquake in Mineral, Virginia on August 23, 2011; the prevention and/or remediation of rock slides, which are periodic and reoccurring throughout the Piedmont and mountainous regions in Virginia; contributions to environmental studies of groundwater resources and pollution.  All of these examples involve areas of critical importance to the wellbeing and safety of the citizens of the Commonwealth.  We must have QUALIFIED individuals who know how to investigate the aforementioned, and who will study and provide answers to questions and solutions to problems that are earth related.  We must have qualified individuals in whom we can have confidence.

In numerous ways, the certification/registration/licensing of geologists is a means of contributing to the economy of Virginia.  A number of Virginia universities have excellent geology programs that educate in-state and out-of-state students who aspire to gain certification/registration/license as a Professional Geologist.  Additionally, according to the U.S. Bureau of Labor Statistics, individuals who have professional registration are more engaged in the work force and achieve higher earnings (thus providing more tax contribution) than those not having professional registration Professional certifications and occupational licenses: evidence from the Current Population Survey : Monthly Labor Review: U.S. Bureau of Labor Statistics (bls.gov).

Professional Geologist certification/registration/licensing adds to the status of the Commonwealth in that it shows that we have high standards in our expectations of those who are practicing in this discipline.  I believe the National Society of Professional Engineers puts it well when they say, in part, “Licensed engineers also achieve an enhanced status in the eyes of the public, which equates the engineer with professionals licensed in other fields.

Licensure is an indicator of dedication to integrity, hard work, and creativity, and an assurance that the individual engineer has passed at least a minimum screen of competence. Of course, licensure is just a starting point for professional growth and development, and participation in professional activities is part of the ongoing activities of a true professional.”  Advantages of Licensure | National Society of Professional Engineers (nspe.org).  These statements apply to Professional Geologists, as well.

As a former state employee, I have seen that the government in our Commonwealth has made many efforts to keep Virginia high on the list of states that provide for the safety, prosperity, and advancement of its citizens.  Let us move forward with maintaining high standards for those who practice in the field of geology.

I am writing this as a private citizen of Virginia and a 37-year practicing geologist certified in Virginia since 1991.  I am in favor of requiring licensure in Virginia based on the need for geologic services to be provided by credentialed professionals whose role it is to protect public welfare and safeguard life, health, property and the environment.  

Many of the most significant issues facing society today require the input of qualified geologists including reliable energy supplies, locating and extracting mineral resources, assessing and cleaning up environmental contamination, and maintaining potable water supplies.   

I am fully in support of DPOR continuing to certify professional geologists.  

I am writing in support of maintaining the regulation of the practice of geology in the Commonwealth of Virginia.  While I appreciate taking opportunities to reduce regulation when it will not cause public harm, the practice of geology, including developing dam strategies, blasting plans, remediation of contaminated soil and groundwater, as well as many more infrastructure concerns, is exactly the wrong area to deregulate.

Below, I will briefly provide information regarding why licensure of geology is important to protect the public including health, safety, environment, and fiscal considerations and why it is important for Geology to be licensed as a unique profession. 

Public Protection through Licensure

The ASBOG® Fundamentals of Geology Examination is a requirement for a person to become a Certified Professional Geologist in the Commonwealth of Virginia and to offer geologic services to the public in the other 30 States that register geologists by examination. Pass-fail analyses of the Fundamentals of Geology Examination indicate that nearly 50 percent of the applicants who take the examination lack the knowledge and experience to practice geology at a minimum competency level.

Much of today’s geological practice affects the health, safety and welfare of the public, the environment, and the economy and feasibility of engineered works. Thus, the public deserves to be protected.

Unqualified geologists, who are employed in jobs that affect the public, place an undue risk on the health, safety and welfare of that public. The risks include:

• The possibility of an error that will cause a loss of life or property
• The higher costs of supervision
• The costs of repeating incorrect and incomplete work
• Lower cost/benefit ratios brought about by an inability to do efficient work

The registration examinations used by State Boards of Geology (including Virginia) to complete an applicant’s registration are carefully developed and designed by ASBOG® and routinely updated to reflect changes in the profession. The initial step in developing an examination is to carry out a task analysis. The task analysis is based on a survey of registered geologists to determine:

• The amount of time spent on a specific task;
• The importance of the task in protecting the public; and
• The extent of competence required for an entry level geologist at the time of initial licensure.

The results of these three independent responses are used to determine the relative significance of each content area on the Geology Examinations as a requirement for a person to become a Licensed Professional Geologist. Pass-fail analyses of the Fundamentals of Geology and Practice of Geology Examinations indicate that nearly 50 percent of the applicants who take the examination are unqualified to practice geology. Further evaluation of the results from decades of testing results indicates that those not passing the ASBOG® examination(s) lack the required knowledge and/or experience to offer geologic services to the public in a manner that would protect the health, safety, and welfare of the public, the environment and/or the economy.

Additionally, the results of the task analysis are used to determine the relative significance of the tasks that are performed by geologists and used to set the blueprint for each of the ASBOG® examinations - one for the Fundamentals of Geology and one for the Practice of Geology. If constructing geologic maps is the most significant task, then the examination will have more questions on constructing geologic maps. If, on the other hand, a task is determined to be the least significant task, it may be dropped from the examination all together. The blueprint developed based on the task analysis is the template for the examination and ensures that it represents the current practice of the profession.

Subject Matter Experts who represent the full spectrum of the profession are brought together to write and review questions for the examination. These experts prepare questions in their field that other experts will review and approve. The criteria for a question include:

• Does it have only one answer?
• Is it related to a blueprint task?
• Is it related to public protection (health, safety, environment, and fiscal)?
• Is the question clear and direct?
• Is it written at the entry level?
• Is it free of trickery?
• Does it avoid assessing trivia?

If the question passes each of these criteria it will be approved for the examination database. Prior to and after a question has been used on an examination it is reviewed and evaluated by the subject matter experts from each of the States where registration by examination is required. The first step in the evaluation of each examination is to require these experts to take the examination. The experts, working as a committee, review each examination question to determine:

• The correct answer,
• That there is only one correct answer, and
• That the question meets the criteria listed above.

If the question passes review, the experts assign a difficulty score to the question. The score for each question is combined to determine the degree of difficulty of the examination, which is then compared with the minimum level of competence required for a person to practice geology before the public to ensure that every administration of an ASBOG® examination meets this requirement.

Importance of the Licensure of Geology as a Profession

Geologists make use of their special knowledge for the benefit of the public: from the obvious, e.g., exploration and development of mineral resources plus development of water resources to the less obvious, e.g., evaluating the stability of foundations for buildings, dams, bridges and roadways, plus many others. Few other professions affect the public more than geology, especially through collaboration with the construction and engineering professions. "Civilization exists by geological consent, subject to change without notice," a popular saying with much merit.

Why register geologists?

The application of geologic knowledge and experience are integral to many actions involving public health, safety, and welfare (including financial). Professional geologists working with others can determine and apply sound geologic knowledge and procedures that will serve to avoid endangerment of the public or the environment.

How will the public be protected?

First, no one may be represented as a Professional/Registered Geologist unless registered by the State in which they practice. Second, State registration boards are typically granted the authority to monitor and enforce the registration laws, thus ensuring the practice of geology in a competent manner by Professional Geologists within that State.

Who can become registered as a geologist?

Currently, in Virginia, individuals who have a college degree in geology and five years of geological work experience can initially qualify for registration. In addition, the successful completion of two four-hour long examinations to demonstrate minimum competence in both the fundamentals and the practice of geology.

Registration assures that qualified and reputable individuals provide accurate geologic information to the public. Examples of the practice areas covered by registration include the following:

• geologic mapping
• groundwater resource and development protection
• mineral-resource evaluation
• oil and gas development
• safe oil, gas, water, or mineral drilling
• accurate and reliable information to government agencies for public use
• environmental geology issues
• land surface stability
• solid waste siting
• toxic, nuclear, and hazardous waste disposal siting
• contaminated soil investigations and remediation
• groundwater investigations
• mined-land reclamation
• acid mine drainage suppression and remediation
• dam and impoundment construction
• highway, roadway, and bridge construction

Some people note that geology sounds a lot like engineering. So, what's the difference?

Geologists are trained to consider the entire physical environment, the materials that compose it (rocks, soils, and water) and the dynamic physical and geochemical processes that drive it. Engineers are more concerned with facility design including material and structural properties along with construction and constructability considerations.

Geologists and engineers generally work together making sure that all natural and man-made influences are considered in a project or setting.

Why don't geologists register as engineers?

Geologists have education and professional experience that is specifically directed toward investigating and using the earthen materials that affect the public or natural spaces. No other profession has comparable education and professional experience.

Why not hire engineers to certify geologists' work?

For public protection, persons can only certify geological work for which they were trained in the fundamental geologic principles and have the necessary experience. Geologists are trained and have experience in geologic interpretation of earthen materials; engineers are trained and have experience in designing and building. These are two distinctly different professions. However, because of the close relations between those who interpret and those who design and build, geologists and engineers must work together in a collaborative fashion.

How do they work together?

Geologists interpret, engineers design and build. Geologists investigate earth materials and processes and advise how to compensate for those conditions to assure safety. Engineers take this information, and working with geologists and others, determine how to design and build safe structures in a cost-effective manner.

In closing, I think you will agree that the continued regulation of the practice of geology is vital to the protection of public health for all citizens of  the Commonwealth of Virginia.

Sincerely,

Andrew Owens, PG

I am writing this as a private citizen of the Commonwealth of Virginia and a 30-year practicing Geologist in good standing within the Commonwealth of Virginia, Florida, Georgia, Kentucky, Alabama and Louisiana and a Certified Environmnetal Manager (CEM) for the Commonwealth of Nevada. I am highly in favor of requiring licensure in the Commonwealth of Virginia (state of my birth) based on the need for geologic services to be provided by credentialed professionals whose role it is to protect human public health, welfare, property and the environment. 

Many of the most signifigant issues facing our society and state today require the input of qualified Certified Geologists including reliable engergy supplies, assessing environmnetal intergrity, contamination remediation and potable water supplies. 

I am fulling in support of the DPOR continuing to certify Professional Geologists in the Commonwealth of Virginia.

Ron A James, CPG, CEM

I support the change of the current certification process into a mandatory licensure process for the practice of geology in Virginia.  The work reviewed and performed on a daily basis by geologists is many times directly related to the public health and welfare of Virginia citizens.  Work involving drinking water quality, pollution control, protection for vital groundwater and surface water resources effects all Virginia residents and should be controlled to ensure properly qualified professionals are completing these evaluations.  

Brent Johnson P.G., P.E.

Koontz Bryant Johnson Williams Inc.

I have been both consulting geologist and state regulator, so have witnessed first hand the importance of staying abreast of the latest developments in the environmental geology, hydrogeology, and engineering geology fields of practice to best serve the Commonwealth of Virginia and humanity in general. As with any specialized field of practice, passing certain tests for licensure, e.g. doctors, lawyers, engineers, geologists, soil scientists, or wetlands specialists, the level of service is assured and the confidence in that individual can be relied upon. 

It is my opinion that the statute that created the voluntary Geologist certification program in Virginia should be amended to make licensure of Geologists a mandatory program and that the statutory language doing so should link our profession to public welfare and the safeguarding of life, health, property, and the environment.  The decisions made for finding potable water sources, free of contaminants or the remediation of that groundwater and surface waters should be made a professional geologist. 

Virginia has had this licensure program at least since the 1990s and thus Virginians have benefitted from having PGs review and sign documents characterizing the varied rock and soil types unique to Virginia, and understanding the fracturing and structure of bedrock through which most of our groundwater flows. 

Keep Geology Licensure in Virginia; do not abolish or eradicate this beneficial program. 

I support the continuation of the licensure program for geologists.

Having licensed geologists is important in maintaining a high degree of qualified individuals who work in areas of public importance. This is the same as licensing for professional engineers, soil scientists, and surveyors and serves to support public welfare and the safeguarding of life, health, property, and the environment. 

I support amending the regulation to make licensure of geologists a mandatory program and that the statutory language doing so should link our profession to public welfare and the safeguarding of life, health, property, and the environment.

I hope that the Department will continue and/or amend the geologist license program to insure the public is well served.

I appreciate your consideration and support.

As a Professional Geologist in Virginia (PG # 887) and other surrounding States, I believe that the public benefit of licensing Geologists practicing geologic work in Virginia is protective of the Citizens of the State of Virginia.   

Geologist licensure is overseen by a Regulatory Board which is protective of the public and maintains regulations to keep practicioners responsible for work in the State of Virginia.  The Rgulatory Board oversees the testing and licensure and maintains a process for citizens who have a legitimate complaint against a practitioner to seek resolution within the rules.    Geologist Licensing and supervision by the Board over the practitioners is a protection for the Citizens of  Virginia, and it would be a disservice to disrupt the PG Licensure Program. 

I have been a Professional Geologist doing projects in Virginia for over 30 years, and take the obligation to protect the citizens of Virginia very seriously.  The Public Benefit of Virigina Geologist Licensure is greater than the cost for the licensure program, and the Virginia Professional Licensure Program should be maintained. 

                       Michael G. Jones, PG # 887

It is with respect that I urge your careful consideration of and support for continuing the licensing of geologists in VA.

Daily, we provide services of critical importance not only to the public but also to local, municipal, and state government officials and leaders in multiple industries, including, but not limited to, water and wastewater, commercial and residential real estate, hard and soft-rock mining, forestry, environmental and energy, agriculture/viticulture, ground/air/rail transportation, construction, and recreation/tourism. Questionable work by unprepared, unlicensed, ill-trained, and uneducated practitioners could jeopardize public welfare and the safeguarding of life, health, property, and the environment. In addition, the outcomes of shoddy work could have significant financial impacts on Virginia's residents, tourists, employers, and employees.

Kindly amend the regulation to make VA geologist licensure a mandatory requirement.

Dan Jackson (#918)

I strongly support licensing geologists. I have worked in both private and public sectors and thing\k that having licensed geologists is important for protecting public, private, and environmental issues.

As a registered professional geologist in Virgina (and 3 other states) with more than 30 years of professional experience, I strongly support the mandatory registration of geologists providing services in the public or private sectors.  The strict education, experience, and ethical requirements that accompany professional registration are a safeguard for the citizens, businesses, and local governments of Virgina who rely on geologists for a variety of services and professional advice.  Professional registration of geologists helps protect the health and safety of people and the environment. 

Below are my comments submitted as part of the public comment period:

Consider renaming the board to "the Board for Professional Geologists, Soil Scientists, and Wetlands Professionals" which lists geologists first. Geologists should be listed first because we are, by far, the majority profession within the board. 

Review the Regulations for the Geology Certification Program Chapter: [18 VAC 145 ? 40].

Consider updating the definition of the "Practice of Geology" to contain more modern language more in line with the current standard language.

Update rules/regs to include "geoscientists" in addition to geologists. Updating the rule to include geoscientists broadens access to the profession while maintaining the competency requirements needed to protect the public. Compare to model law published for the practice of geology, and regulations from states that have recently implemented a professional geologist/geoscientist licensure program, such as Tennessee, Texas, and Louisiana. 

Educational and experience must include be an adequate knowledge of understanding the subsurface. Must be able to past the Fundamentals and Practice of Geology examinations published by the National Association of State Boards of Geology (ASBOG) as a requirement for certification/licensure, which is consistent among the 32 states with certification/licensure programs for geologists. 

Virginia Certified Professional Geologists (PGs) serve a vital function in many fields, including in my field of groundwater contamination investigation/remediation. 

PGs with a working knowledge of Virginia geology are critical to public safety because PGs have the unique skill set to evaluate geologic conditions conducive (or conversely dangerous) for road cuts, tunnels, excavations, dams, etc) and can mitigate property damage/injury related to karst features such as sinkholes. 

With our recent understanding of the high toxicity of per- and poly-fluorinated alkyl substances (PFAS) and their high mobility in groundwater, the need is clear for Virginia Certified PGs to be involved in environmental assessments to protect groundwater sources used for drinking water supplied to Virginia residents and businesses. The fact is, most Professional Engineers do not have the background and experience to technically evaluate the complexities of contaminant fate and transport to be protective of groundwater aquifers. 

The Virginia Department of Environmental Quality employs many Virginia Certified PGs. And Virginia stands out as an early leader in the formation of the well-regarded Association of State Boards of Geology who now administers the national PG exam through states like Virginia.  

While Virginia unfortunately is among some states that have a voluntary PG program (voluntary meaning persons practicing geology in Virginia are NOT required to hold a Virginia Certified PG license), state licensure of PGs provides individuals, businesses and regulators assurances that the person practicing in the many fields of geology (hydrogeology, mining geology, engineering geology, geochemistry, geophysics, etc.) have a baseline of necessary training and experience. 

And having served on the Virginia Board for Geology for 8 years, I know the program is self-funded such that it represents no additional cost to Virginia taxpayers. And being a voluntary program, it represents zero negative impact on commerce, except perhaps to entities who would selfishly benefit (financially or politically) from elimination of the program.

For these reasons, there exists no reasonable rationale to eliminate the self-funded, voluntary Virginia Certified PG program. 

Dear Executive Director Nosbisch,

I am writing to you to express my strong support for the the Commonwealth's Certified Professional Geologist program. I serve as Regional Partner for St. John Properties where I oversee our portfolio of more than 1,500,000 square feet of commercial real estate in Virginia and a development pipeline of another 1,500,000 square feet to be built in the next few years. I am also on the Executive Committee for Loudoun County, VA's Economic Development Advisory Commission. St. John Properties is one of the largest and most respected privately-held commercial real estate firms in the Mid-Atlantic. Several years ago we were recognized as the National Developer of the Year by our premier industry organization, NAIOP, and the U.S. Green Building Association holds us as one of the Nation's Top 5 developers/owners of LEED-certified buildings, LEED being the main U.S.  designation for environmentally sustainable buildings.  Upon completion of our buildings, we lease them to a wide variety of businesses that provide the Commonwealth with substantial new tax base, jobs, economic diversity, and small business opportunities.  We hold Virginia's Certified Professional Geologist (CPG) certification in high regard and it is widely recognized as a respected industry credential similar to being a Certified Public Accountant or Professional Engineer.  The CPG designation can only be obtained through accomplishment in study, relevant experience, and a rigorous board examination.  It is a mark of expertise and credibility that is respected by fellow developers, lenders, investors, and insurers.  Their confidence in the CPG designation encourages confidence in more investment into Virginia which promotes statewide economic development. As we develop our projects, we rely heavily on professionals with Virginia's CPG certification including all geotechnical and environmental matters. The certification tells us that these professionals understand Virginia's unique geology and environment, and that they have the expertise to guide us toward delivering projects that are high-quality, safe, and environmentally sustainable.

I understand the value of this certification better than most because I am Virginia CPG. After obtaining a university degree in Geology and several years of relevant work experience, I obtained my CPG certification more than 20 years ago. Although my career has evolved into leading a commercial real estate company, I attribute my success and that of my firm to the teams of professionals including Certified Professional Geologists. I respect and appreciate efforts to streamline government and eliminate unnecessary/unfair bureaucracy that limits business. I encourage close evaluation of other licensure/certification programs in Virginia that have limited impacts on public health, life, property, or the environment. But the CPG certification is not one of those and its place in protecting our health, safety, property, and environment cannot be overstated. For these reasons, I implore you to protect Virginia's  CPG certification as a valuable contributor to what make the Commonwealth great.   

Sincerely,

Matthew F. Holbrook, CPG

Regional Partner

St. John Properties, Inc. 

CPG No. 2801001511

As a professional geologist with 30+ years of experience in Virginia, I can say from experience that unlicensed and unqualified people practicing geology can have significant negative consequences.  Maintaining and even expanding a professional geologist certification will be a benefit to the citizens of the Commonwealth.  

I've been a Virginia PG for over 20 years and have been responsible for environmental investigation and remediation projects throughout Virginia and the Mid-Atlantic region during my career. Many of these projects have required a comprehensive understanding of a site's subsurface geology in order to characterize the impacts posed by a contaminant release, the associated risks to human health and the environment, and the appropriate remedies to mitigate risks and restore a site to productive use.  Pursuit/maintenance of a PG license is a demonstration that an individual is committed to the study of geology, the application of scientific principles to societal challenges, being accountable to the public, and to the betterment of outcomes for those served.  While my experience has been focused primarily on environmental impacts, the need to understand site geology is also paramount when evaluating geologic conditions for infrastructure development.  Contributions from Certified Professional Geologists ensure that our infrastructure and environment are safe, protected, and preserved for the benefit of all.  The potential impact and cost of unqualified professionals practicing geology far outweighs any perceived benefit associated with elimination/minimization of the PG licensure program.  I therefore support Virginia's current voluntary Certified Professional Geologist licensure program and would support an expanded requirement for a PG license with demonstrated continuing education to practice Geology in Virginia.  

As a practicing Certified Professional Geologist in Virginia, I strongly support continuing the certification process in Virginia. I also recommend making licensure mandatory for providing professional geological services. Geologists provide an essential service in both private and public sectors. The work we do protects public safety, supports infrastructure, and ensures the sustainably of our natural resources. These are essential services that require a complex skill set and knowledge base to execute properly.

Maintaining the rigorous standards associated with certification in Virginia ensures that only those with the necessary qualifications can perform these essential services. Allowing certifications to lapse would reduce the standard of care being paid to the important aspects of public safety, infrastructure, and sustainability that professional geologists are responsible for.

As a practicing professional geologist in the Commonwealth of Virginia I strongly support maintaining the Geologist certification program and amending the statutes to make licensure mandatory. Virginia geologists play a role that is vital to the safeguarding of life, health, property, and the environment, providing essential services to the public that require specific expertise. As such, I believe it is important to continue verification of minimum competency through examination. This “minimum competency” is not trivial, especially when viewed in the context of infrastructure design and the protection of natural resources. The decisions of a licensed professional geologist can have wide ranging impacts, and I feel it would be irresponsible to lessen the standard we are currently held to.