I would like to address the new proposed EMS Educator requirements which I feel are going to be very excessive for our educators and the agencies they work for and with. To require EMS Educators to obtain an additional 12 hours of educator specific education EVERY recert period, in addition to the 50 hours already required to teach in a 2 year period. That is a BRAND NEW UNFUNDED MANDATE, the cost of such classes is a financial burden to already budget-poor EMS systems/governments & EMS educators who will likely have to pay for many of these classes on their own, out of pocket, taking time off from work, especially in the volunteer sector of EMS. These will be difficult classes to find, as they are very RARE currently. The second portion of this specific section of the regulations which I am gravely concerned for is the REQUIREMENT that EMS educators MUST TEST every recert time in order to keep serving as such. NO OTHER HEALTH OR ALLIIED HEALTH PROFESSION REQUIRES THEIR EDUCATORS TO TEST aka "sing for their supper" every 2 to 4 years. This is also not a requirement for any of the other public safety sector (fire, law enforcement, etc) Instructors to do this so why is it now becoming a regulatory requirement for EMS Educators? UNFUNDED MANDATE, HUGE EXPENSE, TRAVEL EXPENSE TO TEST TO RECERTIFY, TIME OFF FROM WORK TO DO SO, AN EXCESSIVE MANDATE THAT HAS NO RHYME OR REASON BEHIND IT. Where is the data to show this is essential? If educators are not educating correctly now, there is a regulatory process available to OEMS/VDH to take proper enforcement actions against that specific instructor. Don't punish all of our Educators for a few who are unable to perform to expectations. What happened to the policy of "If it's not broke, don't fix it". Take swift action against the bad ones & keep the good instructors. You're setting this up to be career-only instructor certification, forcing our dedicated volunteer educators out of this field. Please reconsider this section as an UNFUNDED MANDATE which is an UNACCEPTABLE, OVER THE TOP REQUIREMENT that is NOT NEEDED or APPROPRIATE in these financially difficult times.