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