The draft language creates a requirement of licensure for full time employees of installation contractors, which exempts firms that hire day labor. Employees working less than 1760/yr are exempt from the expense of licensing, continuing education and renewal. Under this proposal firms are liable for acts of malfeasance or negligence by "journeymen" with no requirements for education training or supervision except the minimal guidance of these revised regulations.

Will the journeyman be entitled to sign a completion statement? If so does he bind his company, or his person?

How will amending definitions of direct supervision affect contractors? The only viable business model is a responsible supervisor onsite at all times, with unquestioned excercise of his professional judgement under contract to his client.

Small business deserve greater consideration, who is the AG fooling in his regulatory review?
These regulations are not in the best interest of the public, who's interest are they in?

I recommend DPOR's Contractors Board be brought into the discussion of requirement for written contract, including definition of minimum standard of service & warranty.

This board deserves investigation for undisclosed confict of interest and collusion by the Attorney General's Office. Perhaps the self dealing board should be under greater scrutiny for Waste, Fraud and Abuse by the Inspector General. This board seems to be under influence by VOWRA (selling training and manufacturer's lobbying) and VDH (providing design, training & oversight), and water authorities under oversight of VDH.