Remove the allowance for companies to maintain records out of state. There is no way that the current DCJS is going to be able to enforce compliance for "out of state record holding companies, while they can't currently enforce them in state.  The idea that records are electronic is far too simplistic.  The only companies that will benefit are large companies that don't always have the best interest of the Virginia consumer at heart.  Out of state records will make enforcement more of a nightmare and thus it won't happen. 

Minimum requalification has already been enhanced in the past.The students could be tasked with  bearing the burden of paying for additional retraining that is not necessary.Also, the fee for the firearms endorsement is probably going from $10 to $15.Students have many opportunities to enhance their qualifications with voluntary training where the student controls what they spend on their future.

A more concerted effort should be made to to communicate law and regulation changes to training schools.  I asked several times and never got answers to questions regarding the status of issues concerning private investigators, particularly the gps situation.  I found out after accidently checking another website. We need to know ahead of time since we are the ones teaching the subject.

It appears that the locksmith description has be rewritten to better include electronic locking devices.  This category should cross over with electronic security technician. 

For example, to install an access control system (electronic security), one must install either magnetic locks or electric strikes on the doors and provide card readers and key cards to the customer.  To perform this function, the electronic security business must already have a electronic security business license, a licensed compliance agent, a licensed electronic security salesperson, a licensed electronic security technician, and probably a licensed electronic security technician's assistant as well. Must this business now add a locksmith category to both the business license and the licenses of all of the business's personnel to perform the exact same functions as before?  This appears to be double regulating a specific sector of the industry.

Electronic security businesses and personnel should be able to perform tasks related to electronic locking mechanisms without having to gain the locksmith category as well.  An electronic security technician should know about card readers, proximity cards and magnetic locks, but should not be required to know anything about cutting and copying physical keys or how to pop a car door when someone locks their keys in the car. 

Suggestion: Allow those with electronic security licenses to perform functions related to electronic locking mechanisms without having to gain additional licenses for locksmithing.

Training needs a complete overhaul.  Current training for electronics may satisfy some arbitrary DCJS rule but it is definitely inadequate for the industry and the general public. Electronics is a dynamic industry.  If they even take the training, unethical companies are presenting the current training as making them "experts" while most of us realize it gives them close to nothing having to do with the real job of an ES salesperson or technician. 

If the industry itself is challenged to keep up with new products and services, it only makes the "required" programs more meaningless.  We are forced into supporting a cottage industry created by DCJS regulations that serves no real world purpose and does nothing to protect the general public. 

ES needs to have the ability to train from within and be specific to the type of business we, as individiual companies, do and the specific equipment and services we provide. 

These are costs that the business often incurs without any benefit other than satisfying a regulatory requirement.  ES is forced into supporting schools that for 17 years have not been able to provide meaningful, up to date education/training to our industry. 

It appears that if a non-compliance issue is exposed during a self-audit and DCJS is allowed to impose a fine or penalty on self-reporting of that violation, this then becomes self-incrimination and may be a Fifth Amendment issue. 

This raises many questions and doesn't solve anything obvious.  What if a mistake is made on the self-audit, does it automatically become an assumed fraud, and thereby subject to two violations, the original violation (which could have been human error) and a potentially fraudulent self-audit (again could have been human error)?  Does this shift all the audit responsibilities on the back of the company and what/where is the gain?  What is the purpose?   Without knowing what is included in this "self audit" there is nothing to base a determination of reasonableness.   For many companies this new process just creates yet another burden. 

I am under the impression we are charged with reducing and streamlining regulations, yet this just moves the paperwork and responsibility onto the back of company. 
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Currently a Compliance agent may represent only a single Private Security Business.  The Electronic Security Industry is made up by and large by very small companies, whose owners have difficulty managing all the different responsibilities required by the myriad of regulations with which they must comply.  In most other business areas responsible parties or registered agents may represent any number of businesses.  To allow a Compliance Agent to represent multiple businesses would raise the level of professionalism and help to insure that Private Security Businesses would receive knowledgeable advice.

                I currently operate several Private Security Businesses in Virginia, with my brother as my partner, and we must maintain different Compliance Agents for each.  This is a waste of my time and money and does nothing to improve the public safety.  Allowing a Compliance Agent to represent different companies, as long as notice is provided to each Business of that fact, is cost effective, eases the burden of DCJS to monitor Compliance Agent compliance with the regulations, and has no effect on public safety.  Many Private Security Businesses operate under different licenses for tax reasons, for management reasons, or simply for marketing reasons.  To require separate compliance agents makes the business climate in Virginia less conducive to growing and diversifying businesses.

Electronic Security Technicians install, maintain, and repair access control systems as a normal part of their work.  They do not repin locks, repair locks, install locks, or cut keys.  To require an electronic security technician to maintain a second registration does nothing to protect the public safety and substantially increases the costs for a security technician to maintain their registration.

                There has been no resistance by the locksmith industry to this exemption, the requirement does not protect the public safety, and only increases regulation and the costs to the electronic security technician.

Have us sit through the same training multiple times for categories is not a good use of our time. I have been to multiple training in the same day and seen the same material twice and most of which was anything but relitive to my job in the real world. I feel there is more training being given that we should get credit for which is more productive to the jobs we perform on a daily basis. Thanks for your time Rick Heinig.

Electronic Security Technicians install, maintain, and repair access control systems as a normal part of their work.  They do not repin locks, repair locks, install locks, or cut keys.  To require an electronic security technician to maintain a second registration does nothing to protect the public safety and substantially increases the costs for a security technician to maintain their registration.

            There has been no resistance by the locksmith industry to this exemption, the requirement does not protect the public safety, and only increases regulation and the costs to the electronic security technician.

ype over this text and enter your comments here. You are limited to approximately 3000 words.

Currently any Electronic Security employee who carries multiple registration categories must attend different training classes for each category.  The fact is that most training classes are registered to satisfy multiple category requirements.  This has led to individuals sitting in the same class multiple times simply to satisfy the written requirements. 

            The Electronic Security industry is changing dramatically every day and any company or any individual who hopes to stay in business or keep his or her job must continually learn new technologies.  The marketplace takes care of keeping individuals and businesses trained.  DCJS cannot regulate to such a degree as to guarantee competence in registrants.  The training standards are defined as minimum training standards, but they should at least allow for useful training.  The current regulatory environment and the current administration by DCJS effectively prevents businesses from conducting useful training.  To reduce the requirement to a single 4 hour class for every registrant each year or registration renewal period, regardless of the number of categories carried, would be sufficient to maintain a knowledge of the regulations and compliance and assure the public that the registrants had a basic knowledge of the requirements to operate in the industry.

While, generally, I would applaud increased training hours, range time and additional rounds fired at the range, I think we must remind ourselves that our country is in a severe economic situation with an unemployment rate above 8%.  As a result, many people are struggling to find jobs and many unemployed persons are turning to the security industry.

When the Commonwealth of Virginia, DCJS, mandates additional classroom & range time plus increased rounds to be fired, it increases the cost to the training schools which have to pass on the added expense to the students; many of whom are unemployed and struggle to pay for the current mandated training and registration fees, etc.

I would recommend that this hard fact of economic life be considered before putting these new requirements into effect.  While I am almost always in favor of increased training, there comes a point of diminishing returns and in our effort to improve the security industry we must not lose sight of the human side of the equation.

Thank you.

Adds another burden to a trainer unnecessarily, increasing continuing education and fees without any benefits.  Being a certified trainer in Virginia has nothing to do with subject matter proficiency.  It is an excessively long and expensive process that again forces industry into supporting a third party business. 

If regulations were clearly written, you wouldn't need a class.  They should be clearly written for anyone in the industry to understand if the goal is compliance.  When you need classes to "understand" what's written, a re-write of the regulation is in order.

In the past, DCJS has issued exemptions to SOs convicted of asault, firearms convictions, etc on a case by case basis.  The sad fact remains that people WILL file false criminal charges against SOs who did their job as revenge.  In cases where it is one person's word against another's, the officer may well file nolo contendre even though he was in the right.  Also, the way the new provision is written, there are NO exemptions allowed.  A person who was convicted of an offense 40 years earlier would find himself stripped of his Registration, even though he has had no convictions since.

Of course, we don't want to hire violent or criminally minded people.  However, do we also want to eliminate good employees whose only fault was arresting a vindictive person, or whose offense was a youthfull indescretion from decades ago?  DCJS should be allowed to issue exmeptions on a case by case basis.

Having read the provisions, I saw nothing about Inhouse Security.  For instance, current provisions allow for armed Inhouse Security providing the officers have a valid Firearms Endorsement with their State Registration card.  With the new provisions, will people be able to work armed Inhouse security without any certificiation?  If I recall correctly, in the past the definition of Armed Security included armed Inhouse officers.  Perhaps the new definition should as well?  Or are inhouse now exempt?

The Security Trainers have enough to go over, do we really need them to cover lead exposure?  Unless the Officer is working at a Firing Range, he won't be exposed to enough lead in the course of his duties from discharging his firearm that it would be a worry.  If the officer IS firing his gun that often while on duty, then there are more important considerations.  Frankly, as an armed officer of 25 years the only times I've had to worry about lead exposure was when people were shooting at me. 

6 VAC 20-171-20 – Fees

"There is also a new manual processing service fee for applications not submitted by available electronic methods. "

Eliminate this clause entirely as the current system does not function reliably to accept electronic payments. Manual processing is imperative and should not be penalized.

1. Not only mailing address but all addresses,both  walk-in locations or offices associated with registered business must be listed with DCJS. Some businesses have multiple locations, corperate office other than coorespondence location This ensures any other location claimed by such business cannot be fictional.

2. All paid adversing must have DCJS number listed including web and search engine directory ad placement and Payf or clicks I. E. Google

3.Increase fine to $10,000 After warnings to comply

Currently Electronic Security has three registration categories, Security Sales, Security Technician, and Central Station Operator.  Each category has its own training requirements.  In fact, in this business, all these individuals need to know similar information.  In addition, many individuals, particularly in smaller companies, carry multiple categories.  I have several employees who carry all three, including myself.  This means that we must attend three different training sessions during each renewal period.

Since the categories need similar training and many classes can be applied to all categories, it would be simpler and more feasible to have a single training session satisfy the requirements for all three categories for any individual.  It makes no sense to have a single individual attend three classes just to maintain three categories of registration, when the information provided is in many cases the same.

Currently all training must be conducted by a licensed training school, using DCJS registered instructors.  Since the electronic security industry is highly technical and that technology is constantly changing, it is impossible for training schools to provide training classes that keep current with technology.  Current DCJS policy requires training schools to allow 60 days for lesson plans to be approved.  The cost of lesson plan design and documentation and the time delay between submission and training precludes training schools from conducting training that addresses current technology and processes.  Most manufacturers update their equipment line at least twice a year, and offer regular training to their clients.  This training is not acceptible to DCJS since the documentation is not submissible in strict cirriculum lesson plan format.  These classes must change regularly in order to maintain currency, and to constantly update such plans is economically unfeasible.

Most electronic security firms depend on manufacturer provided training to keep their salespeople and technicians up to date, but under the current system cannot apply this regular training to their registration requirements.  This requires them to spend additional time with a licensed training school receiving training that satisfies regulatory requirements but not real world business requirements.

The only answer is to allow employers to do their own training on subjects of their choosing with instructors of their choosing and have a system in place to allow them to submit training information easily and quickly.  Ideally training should be provided by qualified company employees or factory representives, without requiring DCJS instructors.

The current waiver program is now working for electronic security since DCJS does not readily approve such training, and requires far more documentation than is generally available.  

Since the Compliance Agent is responsible for the proper compliance with regulations, the Compliance agent should have the authority to monitor compliance with training requirements.  Allow the business to conduct training to its own standards and simply maintain records documenting that training satisfactory to the business in sufficient amount to comply with regulatory requirements was received by each registrant.  

At renewal require the registrant to provide simple documentation of the dates and amounts of training required to comply with the regulations.  More detailed documentation including a copy of the program, notes regarding the subject matter discussed and sign up sheets would be maintained in the Company files for access by DCJS upon request.

Granted this would reduce the revenue of the training schools by reducing the number of classes required, but I am unaware of any statutory or regulatory requirement to protect the revenue of licensed training schools.  If there is such a code or regulation, I would like to have my electronic security business added to that section so that my revenue need not be linked to the needs of the marketplace.

It was brought to my attention that other licensed private security companies may use staff hired through temporary agencies to do office work, bookkeeping, or customer service tasks.  It seems that Electronic Security is the only Private Security licensee that may not use the services of temporary employees to perform such duties.  This seems unreasonable and unfair. 

We originally wished to be able to use such agencies to recruit for central station operators or technicians, but simply for office personnel who would be certified as electronic security employee would be satisfactory and reasonable.

171-240-A9  Allow compliance agents to work for multiple companies provided that the agent has notified all entities that he represents.  This helps large and small companies.  Large companies often have multiple entities with multiple license numbers  but one person actually is responsible to be the compliance agent for all.  Therefore there are many compliance agents in "name only".  Small companies can have emergencies that leave them without an agent for more than 90 days.  Small companies often don't have the manpower to spend on regulatory oversight and a part-time agent would give them relief and ensure that compliance issues are met.

171-350   Make electronic security (ES) training standards the same for all ES categories.  The training for ES sales, tech, tech assistant and central station dispatcher overlap.  One training course can be approved for all ES categories.  With the current regulations a registrant that holds a registration in sales and tech take the same class twice, sometimes in the same day, just to meet DCJS in-service training requirements.

171-60 C7  Do not require businessess to perform a self audit to renew their business license.  The regulations are very clear on standards for businesses and registrants.  It is clear that the compliance agent is responsible for ensuring that the business and employees comply withthe code and regulations.  There are sanctions in place for those that have violations.  It is not necessary to mandate how the compliance agent ensures the compliance.  The self audit is redundant, time consuming, expensive, and creates unnecessary paperwork. 

In addition to the concerns over time and energy expended in performing a self audit on a DCJS provided form or format, such audits are a standard part of professional business practice.  A State mandated audit is therefore redundant.  If DCJS wants to provide a guideline for conducting a self audit and chooses to recommend such an audit that's fine.  To require one is not.

There are two additional concerns with requiring a self audit.  To do so requires a Compliance Agent to report corrected or correctable errors in compliance with code or regulations, which may not, in fact probably do not, affect public safety, and in doing so place himself or herself in jeopardy of sanction.  Though DCJS may suggest that serious sanctions would not generally result in identified and corrected violations, such sanctions are called for in the Code, primarily when identified as part of an audit or action conducted by DCJS itself.  I believe it is improper to ask a Compliance Agent to self incriminate.

At the same time, the US Constitution provides protections against such self incrimination, so it is not incumbent upon a Compliance Agent to voluntarily provide such information.

If the role of DCJS is to preserve public safety, why is it that none of the proposed changes have any impact  or only very remotely relate to public safety.  In fact, if anything some of the proposed changes could actually make enforcement more difficult. 

If the Governor's objective is reducing red tape and unnecessary regulatory burdens on small business, why are there so many efforts being placed on increasing regulations or just changing who carries the burden and exposure. 

No response required. 

Course instructors for electronic security in-service training should not be required to obtain DCJS instructor certification.  The current requirement severely limits our opportunity to obtain training from manufacturers' reps, distributors' experts, and even our own in-house experts.  The current in-service training for ES sales and techs is virtually meaningless and a waste of our time and money.  Our industry is constantly innovating and changing, and it would be in the best interest of the customer for us to be current on new, emerging technology and "best practices" for configuring and servicing products and integrated systems.  Competition in the marketplace drives the need for training, not DCJS requirements.  Let that training be effective and meaningful by removing the requirement for instructor certification from qualified instructors.

In our industry, product and systems and configuration knowledge is required of both ES Sales people and ES Technicians in order to provide the best value to the customer and protect them from shoddy installations that do not deliver services they seek.  Current DCJS approved training courses for sales and tech already have some overlap; in my 20+ years in the industry, I have observed that effective sales people need to understand product capacity and installation practices, and techs need to be cognizant of the sales perspective.  I recommend you combine the sales and technician in-service training course curriculums and only require one in-service training course completion during the registration renewal period, regardless of how many different categories a person is registered under.  This will streamline the compliance process for both DCJS and licensees, and reduce frustration and loss of productivity among our workforce.

171-60-C7 Do not require businesses to self audit when renewing a business license.  This is an added government task, on government forms that adds an unnecessary burden to businesses.  The code and regs clearly state businesses must be in compliance at all times.  How a business manages that task should not be a government mandate.  I believe Wayne Boggs' comments express the views of many.

171-240A9  Allow compliance agents to work for multiple companies.  This will benefit large and small companies.  It is common to have professionals offer their  expert services to multiple businesses such as, accountants, lawyers, etc. Once again Wayne Boggs' comments are the views of many. 

DCJS must understand that the electronic security industry is faced with a constantly changing technological environment and any class we devise will be out of date in a few months.  To meet the requirements of DCJS regarding lesson plans and detailed program documentation, equivalent to academic instruction, is not possible for the electronic security company and not economically feasible for the training school.  Training schools must operate revenue and profit driven programs, and they simply cannot rewrite every class for electronic security twice or more times a year just to maintain relevancy, and if they are not relevant, students will not come. 

We must be allowed flexibility in training and in documentation if DCJS approved training is ever to be pertinent, realistic, and valuable.

Mr. St. John notes that "instructors are required to be certified by DCJS to ensure that a minimum standard is met by those who provide training on regulated activities".  My experience has been that the DCJS certification does not and cannot guarantee that the individual who passes the DCJS class is any more qualified to teach an electronic security subject than someone who has spent years in the industry.  In my own case I hold a BS degree in Physics and Mathematics and an MBA degree in Business, both from Universities in the Commonwealth.  I also hold instructor certification by the national trade association representing the electronic security industry, and have taught numerous classes on a national level, as well as having over 30 years of experience in all levels of operations and management, but I am not considered qualified to teach a class on any subject.  I can however become qualified by attending a 5 day training session conducted by DCJS.

I also disagree on the matter of training content.  Security system design and installation techniques are constantly evolving.  We rarely spend hours running wires in walls in homes or businesses with the current technology in wireless systems.  National companies like Verizon, Comcast, Vivant, and ADT, no longer lead their sales presentation or marketing efforts with security systems.  Today everything is home automation, temperature control, lighting, locks and video.  None of these services were even available one year ago.  Comcast and Vivant have both stated that they expect electronic security to be a decreasing part of their offerings over time.  We still expect centrally monitored security systems to be a large part of the business on a local level for many years, but we are adding many more centrally monitored or managed services as well.  To provide entry level training for salespeople and technicians on even two year old security technology does not prepare them to provide current technological services to prospects, nor in any way assure the safety of the public.

I also operate a U. L. listed monitoring center, and we send our operators to basic entry level training classes from licensed training schools simply to meet the requirements of the law.  We then spend the next two weeks training them on false alarm prevention, customer service, and technology.  These subjects have not changed much in recent years, but the additional tasks of managing video and access control systems and answering the myriad of technical questions they are asked at all hours by concerned clients whose security and fire alarm systems are malfunctioning, takes months more.  Ask a central station operator if they need technical training on security systems in order to competently perform their duties.  They will certainly laugh at the idea that they are not providing technical services.

Regarding salespeople and technical training, just in the area of video equipment, within two years the conventional analog camera systems that have been in use for the past 20 years will not longer be available.  Digital technology, particularly IP technology is sweeping the industry.  We don't even attempt to maintain printed catalogs or price lists any more; the products, their applications, pricing and features are changing so rapidly.  Basic sales techniques remain the same, but the technical application of the available products simply outstrips the ability of any for-profit school to adapt.

Finally, the marketplace is the final arbitor of who is qualified to provide a product or service.  Any business who does not regularly train their employees on the latest technology will find ever vanishing prospects.  Prospects will ask questions they cannot answer and demand products and services they don't understand.  DCJS and the licensed training school simply cannot react with the speed of the marketplace.  Certainly members of the public will be offered lower quality services by unqualified providers, but not likely on a widespread basis.  The proliferation of comparison and evaluation sites such as Angie's List and the Better Business Bureau, and the power of social media provide ample opportunity for the public to find appropriate information prior to making a purchase.  If a firm misleads the public, DCJS should investigate and sanction.  In recent years the vast majority of problems have been with unethical operators whose personnel meet the basic training requirements.  It is simply not possible to mandate a level of ethics and proficiency that assures the public will always receive the service they expect.  Rather than waste money on training that satisfies no one but DCJS, let businesses spend that money on training that is useful and productive.

The gold standard for central station operations is U. L. Listing.  By Code all commercial fire alarm systems must be monitored in an Underwriters Laboratories Listed monitoring center.  U. L. is the largest standards and testing laboratory in the world, and the accepted standard for central station operations.  Each U. L. listed monitoring center undergoes an annual, on-site inspection by a U. L. engineer who inspects training records, operational procedures, and documentation, and queries operators and supervisors on their knowledge of those operations and procedures.  The inspector also verifies that all equipment used, including the facility itself, meets the published standard for the listing carried.

The U. L. standard for central station operations, UL Standards 681 and 1981 set forth in some detail the training required for all operators.  The annual inspection verifies that the training is ongoing and satisfies the standard.  

It only makes sense that an operator hired to work in a U.L. listed central station will be required to meet a far higher standard of experience than anything DCJS could require and U.L. will inspect each year to assure compliance.  Therefore it seems reasonable to request that individuals employed in U.L. listed central stations be exempted from the minimum entry level and in-service training requirements.

I am speaking from the point of training.  The current training method may provide some value regarding state regulations and codes, but it does not prepare my employe to do their job at all.  After the training, which my company pay for, I spend addiional time and money getting my employee ready to do the job they have been hire for. 

It is best for the hiring company and the public if the training is provided by the company.  The employee will be given the tools, policies, procedures, and standards to perform their job at the highest level of expectation.

Proper training of the employees that will be providing service to the public should be done by the company/agents that are conracted to provide the service. 

I think the following should apply to electronic security and locksmiths.  These are the only two catagories represented on the PSSAB that have a service and a product.  The products are constantly changing and are becoming increasingly hi tech.  These changes are not something that can be learned through DCJS in a two hour course. 

1.  Entry level apprenticeships are badly needed carry on our career fields.

2.  Compliance agents should be allowed to serve as agents for more than one entity.

3.  Grant an exemption to companies to utilize a temporary agency's services as long as the temporary employee is fingerprinted and trained according to DCJS requirements.

4.  Make training standards the same for all electronic security and locksmith catagories.

5.  Allow businesses to train their own employees without being a certified training school nor a certified training instructor.  Records of training should be kept up to date by the compliance agent and forwarded to DCJS.

I agree with the comment previously posted by Lynn Comer regarding the changes to Out of State records.

The comment voiced by Lynn Comer under the Subject line Training captures exactly my feelings regarding training.  Please ditto those remarks as my remarks too.  

I agree with the multiple previous comments that my company should be able to provide training to new and current employees that better pertains to the individual's job at hand.  It would be much more efficient and precise to handle all training in-house rather than it coming from different sources.  Renewing a registration would also be much easier.  Personally, I had to renew recently and spent hours on the phone trying to get information on the steps to take.  I was given incorrect instructions multiple times and therefore had to complete an initial registration again when I didn't really need it.  This cost my company time and money where it did not need to be spent.

Once again, I find myself having the exact same thought process as that expressed by Lynn Comer as it relates to Self Audit.  There is no reason to try to restate what she has already communicated so well.  I concur and support her comments and concerns as it relates to the self auditing process

I support and share in the comments made by Wayne Boggs as it relates to the subject line Combine and simplify Training Requirements.  No need to restate since he captured how my thoughts very well.

I am a Compliance Agent. I also am the part owner of 4 Electronic Security businesses. Because they are all separate Legal businesses, we must have a separate compliance agent for each. This creates a problem and extra expenses that are a total waste. Allowing a Compliance Agent to represent more that one company certainly does not affect the safety and welfare of the public. Change the rule. Enforcement will be easier with fewer Compliance Agents.

Mr. Boggs has done an excellent job of communicating my position as it relates to his comments under "All Companies to Conduct their own training".   There is no need to elaborate any more on this subject because his summary clearly communicates my position on the changes to training that need to be addressed.

I personally feel like training should held at the establishment you work for by in house trainers. Sometimes when outside parties come in to train they are goin off of a check list which 85% of the information has nothing to do with the job we were hired to do. Its easier to learn from a individual who has been in the same position you are currently in at the same company. They can teach you the basics of what you have to know, but they also can give you tips and help on certain siuations that go on at the job site the a outsider would not know about. It makes it more interesting and easier to learn.

  A single compliance agent should be able to work for multiple companies when those companies are owned and operated by the same “person”  I do believe that the number of years in the industry should not be a factor for compliance agent eligibility.   It should be up to the owner of the business to determine who within his/her company should hold the title of Compliance Agent.  I, further believe, that a Compliance Agent must be employed by the company. 

6VAC 20-171-100-5 This is a good idea to make it easier for us to train instructors. This allows someone who is a good technician and a good communicator to now become an Instructor