I object to the changes to the Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals Regulations, as proposed.  These changes could create a total of 12 licensing classifications for individuals working in the onsite industry, By my count. The problem continues to be that "Onsite Sewage System Professionals" encompass three distinctively different skill sets - site evaluation/design, installation, and operation.  It seems we keep trying to fit a square peg in a round hole by regulating these three professions with the same blanket expectations.  Many of these licensing classifications would be unnecessary, if the following recommendations were to occur:

I recommend moving Conventional and Alternative Onsite Soil Evaluators to the APELSCIDLA Board, where their exemption to practice resides, and combining the two licenses into one "Onsite Soil Evaluator" license.

I recommend moving Conventional and Alternative Onsite Sewage System Installers to the Board for Contractors, which "licenses businesses engaged in the construction, removal, repair, or improvement of facilities on property owned by others. Contractor licenses consist of two parts: the class of license (A, B, or C), which determines the monetary value of contracts/projects that may be performed, and the classification/specialty, which determines what type of work is allowed" and "regulates individual tradesmen".  The differentiation between Conventional and Alternative Classifications should be worked out under the class of license and/or the SDS classification/specialty, and "journeyman" should be worked out under the Tradesman program.

I recommend keeping Conventional and Alternative Onsite Sewage System Operators under the Waterworks and Wastewater Works Operators board and keeping licensing requirements and expectations consistent with those of other Wastewater Works classifications, which don't appear to have any need for journeymen.

Thank you for the opportunity to comment on these proposed changes.

Respectfully,

Rob Charnley