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Guam EPA board reviews SOP to standardize well‑driller licensing; staff to add rubric and equivalency matrix
Summary
The Guam Environmental Protection Agency board reviewed a draft SOP to standardize evaluation and testing for limited and unlimited well‑driller licenses, debated how to treat non‑local experience, and instructed staff to add a scoring rubric and an "equivalent experience" matrix for return within 60 days.
The Guam Environmental Protection Agency board on June 25 reviewed a draft standard operating procedure intended to put the agency—onsistent, documented processes for evaluating applicants for "limited" and "unlimited" well‑driller licenses.
Kristen, speaking for agency staff, said the hearing officerorder required the agency to "develop a written evaluation rubric and to define a passing threshold" and to identify the regulatory basis under "22 GAR section 7104," steps staff have incorporated into the draft SOP.
Pete of the Water Division described how the SOP would work in practice, saying the draft requires applicants to demonstrate documentation such as performance and payment bonds, insurance and familiarity with relevant regulations, and sets a competency framework for interviews and testing. "We require at least five years continuous work experience in well drilling," Pete said, summarizing the SOP's baseline for the unlimited license, and detailed that limited licenses are intended for above‑ground maintenance and pump work rather than drilling.
Staff also described an examination plan: four sample oral exams totaling about 80 questions, with an option to administer a randomized 20‑question test scored on a five‑point scale. "There's a 75% passing score" proposed to qualify an applicant for an unlimited license, with lower score bands tied to conditional or limited outcomes and opportunities to retest after roughly six months, staff said.
Board members focused their discussion on two issues: whether the SOP as drafted creates a clear, defensible pathway for applicants with non‑Guam experience and how the agency will measure "equivalent experience." Multiple members urged a clear, simple matrix or rubric so the agency can explain why one applicant was accepted and another denied. "I think there needs to be a little bit more specificity or grids," one board member said, noting due‑process and arbitrary/ capriciousness concerns.
Officials noted that the underlying regulations currently refer only generally to a well‑driller license and that any change to allow non‑local experience to substitute for Guam experience in the unlimited license would require regulatory revision and likely legislative action. Staff said the SOP is intended as a documented interim practice to allow the agency to continue to permit maintenance work while preserving strict standards for drilling until formal rule changes can be completed.
Next steps: staff committed to revise the draft SOP to include the scoring rubric, to build an "equivalent experience" matrix (examples discussed included education substitutions or contractor licensing board equivalencies), and to return with the revised SOP within the board's 60‑day timeframe; the board scheduled a continuation to further consider the SOP in July.
The board emphasized that unlimited drilling authority remains tightly constrained by the five‑year supervised‑experience baseline in the current regulations and that any broader change to the unlimited license would require a formal rulemaking and legislative approval.
