Virginia Regulatory Town Hall
Department of Professional and Occupational Regulation
Board for Professional Soil Scientists, Wetland Professionals, and Geologists
Regulations for the Geology Certification Program [18 VAC 145 ‑ 40]
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7/31/23  10:08 pm
Commenter: Laura J Cook

Virginia Professional Geologist Licensure

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

CommentID: 218249