On behalf of the Associated General Contractors of Virginia (AGCVA), we appreciate the opportunity to provide comment on the current NOIRA to reduce regulations for licensed contractors specifically the journeyman examination exemption.

As the trade association that represents both general contractors and specialty contractors, AGCVA prides itself on representing the broader constituency of industry among its members. AGCVA has concerns about the consequences of such large changes to the requirements to be an experienced trades person in construction. Specifically, we have the following concerns about the proposed changes.

The requirement for a journeyman to sit for an examination is an important step in preparing trades persons for achieving the journeyman status. The examination serves as the crucial step for individuals to show knowledge retention and comprehension to qualify as a journeyman. In construction, the journeyman often serves as an on-site trainer for less experienced trades people. The examination requirement helps to ensure journeyman have sufficient knowledge that can be utilized to safely and properly train upcoming trades people.

For these reasons, AGCVA has serious concerns about these proposed regulations.