The members of VBCOA Region 8, representing the Hampton Roads area, wish to commend the Board and DPOR staff for moving forward with this long-anticipated regulatory amendment.  We find the proposed language to be reflective of the statutory intent with the exception of provisions which allow Residential Building Contractors and Home Improvement Contractors to perform an unlimited scope of work within existing multi-family buildings.  These types of buildings involve construction and components which are not typical of small-scale residences such as extensive use of fire-resistance rated assemblies and fire protection systems.  Unlimited interior alteration and reconfiguration by contractors who are not required to demonstrate technical knowledge or practical experience related to these types of  structures is contrary to the overall intent.  If there are concerns regarding unintended restrictions to residential contractors for minor work within multi-family buildings, there are an extensive number of specialty designations which may be added to those licenses none of which are specific to commercial or residential..