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.