I believe there is an overwhelming flow of concern here for the safety and preservation of public health by the creation of a journeymans license for the OSE license.  What I don't see is any commentary from the installer community and little from the operators; have they not been informed of such an important change to their license?  This lack of response by contractors concerns me greatly and I feel as though stake holders have not been included in this process that should be transparent and inclusive.

The program for private OSE licensure works well as is and is successful.  The output of work in the State would not be possible without the private sector licensed PE & OSE community.  VDH has historically been incapable of handling the workload without the private sector, hence the 2009 creation of the OSE license.  The controversy of private and public subsidized permitting and the struggle between the private and public sector for the market share is well known need not be addressed here however, I don't believe the creation of a license holder with a lesser standard of knowledge and or experience is of any benefit to public heatlh. 

An OSE individuals ability to access, evaluate and determine soil suitability as well as to practice engineering for systems under 1000 gallons has been provided by the Engineering Board via an exemption to the state code; so I don't believe this change in the license can be legal without consulting the entity who has granted the exemption to practice engineering.

The majority of private and public OSE's have extensive education and experience in the wastewater, geological, engineering and soils science fields; this knowledge continues to grow with recent graduates looking for opportunities within the state and private sector.  While the pool of knowledge is great, the experience is critical in a multi-disiplinary field such as this.  As a license holder I take full responsibility for the entire body of my work, I don't see a journeymans license providing me with any benefit.  If a PE has an EIT provide poor or false information for a project that PE will be held accountable.  So once again there is little to no benefit here to the public or the OSE. 

I see no reason to encourage the unwanted growth of government, please strike OSE langauge from these changes and consult all stakeholders specifically installers, wastewater operators and PE's before consideration of any other changes to the regulations that concern current license holders.