There are many issues with these new regulations:  Who will pay for this UNFUNDED MANDATE?  Who will bear the costs to the instructors to obtain the additional 12-hours of "Instructor Training?"  Who will provide the training?  How will you ensure that it is being provided in enough areas, frequently enough to allow everyone, both paid and volunteer, rural and urban to take these classes?  No other branch of Public Safety has regulations like this, why would OEMS choose times like these to place such a financial burden on jurisdicitons.  I am a member of both a career paid department as well as two volunteer departments and I don't belive that ANY of them have the money in their budgets right now to even begin to think about embracing costs such as these!  If there are problems with certain instructors, or certain programs, then THOSE PROGRAMS should be addressed, don't punish all of us for the shortcomings of a few areas/instructors/departments.  It is difficult enough to keep up with all of the current recertifications and CEUs, especially seeing as how we don't even rank high enough to have licenses, we simply get certifications that have to be renewed constantly, those of us that are blessed enough to be with career departments are being paid well below what our education supports, and now, we will be saddled with more training, requiring more traveling, more expensive classes and more time away from our families.  This is simply not acceptable.

UNFUNDED MANDATES such as these will destroy departments, both career and volunteer.  They will have to bow out due to lack of funding and available instructors.