Water & Wastewater works operators are licensed to understand and manage the public systems. In an era wherein political expediency rather than likely consequences drive decisions with catastrophic results, Virginia's Waterworks Board proposes to dilute the standards for licensure and supervision at water and wastewater works.

Disaster capitalism feeds on regulatory capture; vast public resources are at stake, and failure to adhere to known scientific principals of responsible operation and maintenance result in public funds being released; while maintenance and development of decentralized systems are boring and cheap... diluting qualifications, standards and responsibility bring higher risk of events such as Flint, Danville or Charleston.

While dilution of standards is intended to reduce costs, and we understand PSA operators claim qualified employees are scarce. The use of prison labor (paid pennies on the dollar) with promise of granting license after release is cause for concern, as it is very hard for a captive employee to provide oversight or resist political will. These policies inevitably result in the depression of wages for qualified operators in competition with persons trained at public expense.

There are abundant examples within the proposed regulation resulting in reduced protection of public resources, entrance of unqualified personell under "journeyman" or provisional license, and dilution of the expectations of supervision by licensed professionals.

I urge the Board to reconsider the proposal to reduce expectations. For example the following language permitting absentee management by licensed operators:

"Direct supervision" means being immediately available and fully responsible for the provision of waterworks and wastewater works operation regulated pursuant to Chapter 23 (§ 54.1-2300 et seq.) of Title 54.1 of the Code of Virginia and this chapter.

"Direct supervisor" means a licensed waterworks or wastewater works operator who assumes the responsibility of direct supervision.

Which does not carry the same weight as existing regulation:

"Direct supervision" means being responsible for the compliance with this chapter by any unlicensed individual who is engaged in activities requiring an operator, installer, or evaluator license.

"Direct supervisor" means a licensed operator, installer, or evaluator who undertakes the supervision of an unlicensed individual engaged in activities requiring a license. The direct supervisor shall be responsible for the unlicensed individual's full compliance with this chapter.