I believe you do an injustice to those individuals interested in the field of waterworks and wastewater works operations by excluding experience gained in the lab, water distribution systems, wastewater collection systems, plant maintenance, and other nonoperating duties (18VAC160-20-90B.4).  All experience gained in those areas comes in to play as an operator.  Operators as well as operators-in-training perform some aspect of those duties in their day to day job tasks, especially smaller systems where an operator is required to be a jack of all trades.  I began my career in water as a distribution operator/lab tech and transitioned into operations when the licensing requirements were less stringent and am glad for it.  That's not to say the regs should revert back to allowing individuals without operating experience become licensed but allowing experience in the aforementioned areas to count as experience as an operator or operator-in-training.  The license application provides adequate documentation that an individual has obtained the appropriate hands on operating of a water facility.  I think there is room to allow these types of experiences to be counted in the Class IV and III license categories along with the Class V or VI.  With the impending shortage of operators everywhere I believe it is imperative that every opportunity be afforded to those interested in joining the ranks of operator.