PSS Reg Review I

      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 some instances they are overly burdensome;

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

~  the regulations are not simplified - they would become more complex.

Issues which must be considered in this analysis include:

~  reasons for change - under the current Regs, is someone being harmed?  - and how do these changes 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,  and

~  are resources for enforcement of new requirements realistically available to the Department under current conditions?  

               Please see continuation.  Thank You.