As a class 1 operator, I am concerned about the reduction in Continuing Professional Education hours required for license renewal. I understand the Board's concern about a declining workforce and difficulty of maintaining and training new operators, but I feel reduction of CPE hours does little to remedy these issues and only reduces the quality of current operators.

I also understand there has been some concern over learning hours not fitting nicely into an 8 hour work day. Often complained that an 8 hour day does not equal 8 contact hours, given breaks, lunch, and other time off. I would counter that claim that breaks ARE included in 8 contact hours, as explained in: 18VAC160-30-10 part B "Contact hour" means 50 minutes of participation in a structured training activity.

With this understand, an 8 hour day would already include 80 minutes of break time while still counting as 8 contact hours for CPEs. Forgoing breaks to gain additional CPE hours in the same time is also not recommendable. And seeing as many professions already exclude  1/2 or 1 hour lunch break as part of their 8 hour day, a course whose start and end time are 9 hours apart is not unreasonable for only 8 contact hours of CPE.

And neither 20 nor 18 are easily divisible by 8, so a reduction to 18 wouldn't make a comprehensive CPE course doable in fewer days.

My point being that a reduction in CPE hours will only be to the detriment of the operator's education, without providing much benefit.

With other changes to the regulations, such as:

• reduction in time required to sit for licensure exams
• additional time to renew expired licenses
• ability to request additional time to earn CPEs

I believe it sufficient to ease the burden on the operator. However, CPE reduction to me seems an idea that only hurts Waterworks Operations as a whole in order to appease operators.

The Board must not only consider the quantity of operators, but also the quality.

I also would like clarification on the proposed change to Training Credits. The proposed changes state: Up to one training credit will be awarded for each 10 hours of classroom contact time or for each 20 hours of laboratory exercises and field trip contact time. Training credit will not be earned for breaks, meals, or receptions. A training credit awarded is equivalent to one month of experience. However, contact hours are defined as 50 minutes of teaching. This implies that for every 60 minutes, you may use 10 minutes as break time and still qualify for 1 contact hour. Does "break" mean breaks outside those 10 minutes/60 minutes?

Would a training course that covers 20 hours with the corresponding 200 minutes of "breaks" built into contact hours not count for 2 complete training credits?