In section 6VAC20-171-110-B-2 & B-3:   What constitutes Instructor Development? How will we document it and how much will it cost? Who will decide if a course or class meets the yet unknown and unwritten criteria? What is the defination of Professional Development? How will the Categories be comprised? Will there be any enforcement and how.

What are the current problems that are causing the Department to request this change. It will cost the Instructors more time away from the classroom and more money for the training. These costs will be directly passed down to the students.

If there is a problem, address the problem, don't put more regulation on those who are doing it correctly.