There are many operators employed by the DOC that are licensed in both water & wastewater. This is the case with many municipalities and private utility companies as well. As written, an operator would now be required to have 20 training hours for each license held during the bi-annual renewal cycle (assuming they hold a class 3 or higher license in both categories). I think a provision that addresses dual certification should be included in the final regulation. The subject matter covered in many water training classes applies to wastewater as well. SUGGESTION: ALLOW A SPECIFIED AMOUNT OF THE APPROVED TRAINING  A WATERWORKS OPERATOR OBTAINS TO BE USED FOR WASTEWATER RECERTIFICATION ALSO.