Thank  you and your staff for all the diligence and obvious hard work evidenced in the development  of the proposed Regulations.  We all very much appreciate your consideration of previous suggestions that were made and incorporated in this proposal.  Thank you too for the restraint that you have made and incorporated in setting the fees.  As always, there are additional recommendations and comments listed below.  Thank you in advance for your consideration, and especially for coming to Northern Virginia for the Reg Review meeting.

  To begin, some general comments that arise from a basic review and discussion with many others affected by the proposed Regs:

    >  the changes to the Regs are overwhelming in many areas - at this time, in this economy, they are often too demanding, in many instances they are overly burdensome;

    >  at a time when state government, including DCJS, has diminishing resources - these Regs require increasing increasing demands of the regulator;

    >  the regulations are not simplified - they are more complex;  and,

    >  there appear to be changes in priorities that will reduce effectiveness of the regulatory program rather than strengthen it.

  Issues which must be considered in this analysis include:

    >  reasons for change - who is being harmed and how does this strengthen the regulatory purpose - to protect the public safety and welfare

    >  the risk of becoming overly-regulated

    >  current economic challenges - both to businesses and individuals - many of our community are low-paid workers - proposed training will have large cost increases and time commitments attached

    >  Department is proposing additional tasks for staff at a time when positions are being lost.