The regulations do not need to require contractors to provide completion statements of past work to verify experience.  Deleting 18 VAC 160-20-97.C.2 is a good idea.  In addition, the Board should eliminate 18 VAC 160-20-97 in its entirety.  The Board could replace 18 VAC 160-20-97 with a much simpler application to verify experience with three references.  The Board does not need to see completion statements and make people go searching for a bunch of old work to confirm  experience. Take the man's word for it, get three references to confirm the man is likely telling the truth, and then let the guy pass a good test to show his experience has developed the right knowledge. 

Why do we need all of this regulation gobbledy-gook in 18 VAC 160-97?   

If the applicant is not listed on the completion statement but did perform the installation, then the individual named on the contractor's completion statement and associated operation permit issued by the VDH may certify the applicant's work performed on an alternative onsite sewage system that was installed prior to June 30, 2009, provided that the application is received by the department no later than June 30, 2010.

References shouldn't mean that a person will do good work, only that they are capable of doing good work.  Contractors already possess a license (Class A, B, or C) and should not have to hold a second license to install a sewage system.  The other license used to have a sub-speciality category.  The regulations and law should only require one contractor license, not two.   The regulations should be changed to allow contractors to hold just one license to install a sewage system.  We don't need two licenses. 

If experience installing, operating, or performing soil evaluations must be verified, then have applicants provide three references from other licensed folks.  If they have been doing the work, then at least three people with a license can verify their experience.  If the person gets the license under false pretense, then it can be taken away.  If the person does bad work, then the Board can take away the license.  We don't need to eat up tax dollars looking at completion statements and paperwork that people have done in the past.  Take references to confirm experience and allow for a test.  If they pass the test, then they should be good to go.  Get them out if they do bad work.  Easy enough, and a lot less regulation.