I am opposed to increasing the hours required for inservice training.   The DCJS staff is not equipped to handle a massive in-service overhaul at this time.  What are the reasons for increasing the mandated hours?  What problems have occurred based on the current requirements?  I am opposed to imposing a "penalty" fee on persons submitting applications manually...it will create a tremendous hardship for people in the industry who are already struggling in a low waged industry during a recessed/depressed economy.  At the very least, make the penalty a small fee, maybe $5.00 until the older generation catches up with electronic operations.  The proposed reg that would have registrants be on the "honor" system, keeping track of their own renewal, is like taking many steps backwards for the industry that has come so far.  "Arrest Reporting" violates the right to be "innocent until proven guilty".  I am opposed this change in the regs.