"Continuing Professional Education" means participation in a structured training activity that enables a licensee to maintain and increase the competence required to assure the public's protection. 

Does public protection include protection of public health?  Does it include protecting groundwater and surface water?  Does it include public safety?

Why is there a difference in contact hours between conventional and alternative?  My thought is that regardless of the amount of difficulty, everybody should have the same amount of training within their level of understanding.  An analagy if you will, is that first graders must experience the same amount of schooling that second graders have.  Just because the second grade material is more difficult and second graders are more "experienced" than first graders, both first and second graders must acquire the same amount of training within their area of expertise.

Section 109, #5, says COSEs must obtain 10 contact hours.  Since a contact hour is defined as 50 minutes, then that equates to 500 minutes or 8.3333333 hours.  It is very difficult to find training sessions that offer 8.3333333 hours per event.  If the board thinks the person should participate in at least  one day, eight hours of training every two years, then change the definition of contact hour to 60 minutes and require 8 hours of CPE.  That change would make it much easier to acquire the training.

I noticed that the board expects that licensees with the alternative designation and waterworks operators to receive 20 contact hours.  Again, that equates to 16.6666666 hours.  Just as before, it is difficult for regulants to find training that gives you 0.66666666 hours of training.  I recommend that you keep the requirements simple by just asking for 16 hours of training since most training will be eight hours.  You could eliminate the term CPE and just define contact hour as "60 minutes of ...... to protect....."

The board only seeks documentation of training from certain professionals at renewal and a dispute could arise about acceptable training, especially with the vague CPE definition.  As CPE is defined, suitable training would be in the eye of the beholder and the board and the professional could easily disagree.  How are these disputes handled?  The proposed regulations should outline a procedure for dispute resolution since not renewing a license because of acceptable documentation could greatly impact the regulant's ability to earn a living.  The regulations should allow regulants to keep their license (i.e., renew it temporarily until the dispute is resolved).  Keep in mind that in our time of war, some people are reservists and may be called oversees to keep America safe.  The board should include in its regulations a process or variance from the renewal requirements for extreme cases, such as someone spending 18-months to 2-years on a tour of duty protecting America. 

The board could spell out in the regulations that training from community colleges, VDH, VOWRA, NOWRA, VEHA, NEHA, etc would be deemed to comply with the requirement.  Regardless, I think all training that the Board accepts should be reviewed and endorsed by a university.  Otherwise, disputes about acceptable training will arise between the board and its regulants without more clear guidance as to what is acceptable.