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.