Specific comments on proposed regulations:

1. On page 27, section H. Standing, delete the words "as a" after the word "standing" in the first line.

2. Page 58, Item 12   This action against an "ostensible licensee", if I am interpreting it correctly, does not appear to make good legal or business sense. After all, you don't have to be a barber to own a barber shop. If I own an environmental company I am responsible for it's operation.  What concern is it of the Board's if I hire competent "undisclosed persons" to manage it for me?  If my business conscientously follows all the regulations and is profitable I am a happy owner and the Board should have no issues with me.  Can the Board legally define who I can and can't hire?  What kind of an "undisclosed person" could cause the licensee to be disciplined?  How difficult would enforcement of this be?

3.  Page 62, 18VAC15-20-456 Section A   Recommend deleting "when the project monitor is present".  Obviously inspections can't be done unless the monitor is present.

4.  Page 62 18 VAC 15-20-456 Section B  Recommend adding "for the entire time" to the first line following the word "day"