I have several comments on the proposed Regs. Due to cuts in staffing and funds, DCJS needs to be careful in changes that could put new and continued straing on resources. With the conversion to a new computer system there will be a steep curve learning for the Department as well as those under the regulation.

I do not believe this is the right time to "overhaul" the inservice training program. Completly changing the current reporting system for inservice training and then changing the hours required and the course content is totally ill advised at this time.

As I understand from the Department, Students will be responsible for their own training records and will simply check a box to verify compliance with the inservice training for that registration period. With the current level of enforcement, there will become a "catch me if you can attitude". I compare this to trying to reduce speeding by adding more speed limit signs. Without a police cruser and traffic stops, no one respects the sign. That is not in the best interests of the public.

Please reconsider and look for another way.