Nearly 14 years ago, the
Institute for Environmental Negotiation (IEN), University of Virginia, prepared a final report of recommended goals for the AOSE Regulatory Program. The recommendations and conceptual framework were based upon a series of meetings held by the AOSE Program Ad Hoc Advisory Committee. While much has transpired through the years, several topics of concern date back to 2000 which bear a striking resemblance to recent Safety and Health in Facilitating a Transition (SHIFT) discussions currently underway by the Virginia Department of Health and facilitated by
IEN. Selected excerpts
were added below from AOSE_FINREPORT (2000) with various
highlights.
View 3Dflipbook version of AOSE_FINREPORT.pdf (click here)
AD HOC ADVISORY COMMITTEE
FOR THE AUTHORIZED ONSITE SOIL EVALUATOR
(AOSE) PROGRAM
FINAL REPORT AND
RECOMMENDATIONS
TO THE VIRGINIA DEPARTMENT OF HEALTH
AUGUST 18, 2000
PREPARED BY THE
INSTITUTE FOR ENVIRONMENTAL NEGOTIATION
SCHOOL OF ARCHITECTURE UNIVERSITY OF VIRGINIA
EXECUTIVE SUMMARY
(page 3)
[...]
"The Ad Hoc Advisory Committee for the Authorized Onsite Soil Evaluator (AOSE)
Program, comprised of 22 members representing a range of stakeholder interests, was convened by the Virginia Department of Health and facilitated by the Institute for Environmental Negotiation, University of Virginia. The Committee was charged with developing recommendations for permanent regulations for the AOSE program. It met for six all-day meetings, which were held from April through July 2000, and during these meetings the Committee operated by consensus.
At the outset of its work, the Committee adopted criteria that would serve both as its desired outcomes for the new AOSE program and as its criteria for judging the merit of proposed recommendations. These criteria, which were not prioritized, should be considered of equal importance."
[...]
AD HOC ADVISORY COMMITTEE BACKGROUND
Purpose
(page 11)
[...]
"Advisory Committee members were selected to represent a broad range of interests in the AOSE program, reflecting both geographic and substantive diversity. (See page 42 for a list of Committee members.) Some of these Committee members had participated in the 1998 AOSE Advisory Group, which had developed recommendations for the AOSE regulatory program based on the provisions of Senate Bill 415 (1994)."
[...]
Goals and Decision Criteria
(page 11-12)
[...]
"Later discussions surfaced an additional issue concerning the need in the new AOSE program to harmonize the requirements and practice between public and private AOSEs. Together, these form the recommended goals and conceptual framework for the new AOSE program.
Goals for the AOSE Regulatory Program
• Protect public health and thereby minimize poor designs and the number of permits revoked.
• Foster responsible conduct by the private professionals who are implementing the program.
• Provide VDH consulting guidance to the private professionals who are implementing the program so long as this does not add to backlogs and supports a responsible
private sector.
• Minimize the need for remedial action, which can be costly in terms of both dollars and time delays.
• Strive for establishing the same requirements for VDH and Private AOSEs.
The Committee adopted criteria that would serve both as its desired outcomes for the new AOSE program and as its criteria for judging the merit of proposed recommendations. These criteria, which were not prioritized, should be considered of equal importance.
Advisory Committee Criteria for Success
The Committee’s recommendations should:
• Establish consistency throughout state.
• Reduce delays.
• Improve responsiveness.
• Provide no less protection of public health and of the environment (water supply and quality).
• Provide clarity of the division of responsibilities.
• Reflect "Best Uses" of the public and private sectors.
• Provide certification that is effective and efficient.
• Comply with Virginia Code, Regulations, and policy, including other agencies.
• Provide the least burdensome alternatives."
[...]
RECOMMENDATIONS CONCERNING ADMINISTRATIVE ISSUES
Content of Application Forms
RECOMMENDATION #15
(page 35-36)
[...]
"The Committee also addressed the discrepancies between application packages filed by public and private AOSEs. Most members agreed that the application requirements for private sector AOSEs were more stringent than those for the public sector, specifically with regard to the paperwork that must be submitted. Two suggestions were made to remedy this situation. The first was to require that the VDH AOSEs should fulfill the same requirements as the private sector. The second suggestion was that the VDH should aim to "meet in the middle" with regard to the different requirements of the two sectors; that is, it would lessen some of the requirements on private sector AOSEs and increase the requirements for public sector AOSEs.
In addition to the difference in fees, the Committee identified the following examples of paperwork that is required of private but not of public sector AOSEs:
• Pump Calculations
• Pump Curve
• Topographic Features
• Abbreviated Design Form
• Permit Sanitary Survey
• Utility Lines Noted On Sketch
• Minimum Setback Distances
• Statement On The Permit About The Regulations
Many members felt that the higher standards for private sector AOSEs were justified for the following reasons, and felt that the VDH AOSEs should be required to meet those same standards.
• At present, anyone can install a septic system. As a result, all AOSEs should be
required to provide adequate information in the documentation until such time
that only certified contractors can install systems.
• The VDH should follow the guidelines set by GMP 100, which stipulate what
paperwork is necessary, and which are currently being followed by the private
sector AOSEs.
• In the future, all work will be done only by AOSEs, whether public or private,
and so standards for all AOSEs should be the same.
• There should be a higher standard of information provided, generally, to reflect a higher level of professionalism and to protect public health and community
groundwater. This issue is particularly important when it pertains to having the
drainfield sited on a survey plat.
Other members felt that the higher standards for private sector AOSEs were not justified, for the following reasons.
• The VDH has little experience in some areas in which the private sector AOSEs do have experience, such as mineralogy and shrink/swell soils. More training will be required if public sector AOSEs are to required to fill out information on such matters.
• A higher standard creates superfluous paperwork; perhaps the unnecessary
paperwork for all AOSEs should be identified and eliminated.
• The work of private AOSEs is not supervised, and therefore a greater degree of
paperwork is needed. In contrast, supervisors of public AOSEs are able to
identify when a particular AOSE needs to do more or less paperwork.
The Committee generally agreed that that it would be desirable to achieve a common “middle ground” with a high standard that could apply to both sectors."
[...]
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