My comment is in regards to language in Regulations - 18VAC50-30 published in the Virginia Register, which states "This proposed regulatory package would address the licensing of RBEAs by requiring applicants for licensure to: (2) Complete a minimum of five residential building analyses under the supervision of a licensed RBEA." Does this requirement apply to those applying for their license for the first time or does it apply to those renewing their license as well. My assumption is that it would apply only to those trying to obtain their license for the first time because requiring a licensed individual to complete five audits under the supervision of another licensed individual is problematic at best. It might be helpful to list those requirements for first ime applicant vs. those requirements for renewals if there are differences. Thank you.