Provisions of section 25-9-108, C.R.S., provide the specific statutory authority for the adoption of these amendments to the established regulatory provisions of Regulation 100 (5 CCR 1003-2). The Board also adopted, in compliance with section 24-4-103(4), C.R.S., the following statement of basis and purpose.
BASIS AND PURPOSE
The Board determined that it was necessary to revise Regulation 100 to reflect a change in its testing policy which, before this hearing, consisted of requiring operators to take standard "multiple entry" exams to acquire certification for the various classes within the certification categories. The material on such exams covers the lower levels or classes within a certification category up to the certification level sought. The Board is now changing to a "sequential" testing scheme; each test focuses on the material for a particular class/level of certification within each certification category. Operators will now be required to hold a certification in the class immediately below the class for which the application is being made, and thus the operators will not be able to "skip" any classes of certification in progressing to the higher classes. The Board has determined that it is prudent to make this change in policy for the following reasons.
The Board agrees with recent findings by the Association of Boards of Certification (ABC) that there are certain deficiencies with the multiple entry exam approach. For example, operators who passed the Class 4 Distribution exam by doing very well with the lower level exam questions could actually do very poorly on the questions specific to Class 4. This indicates that the multiple entry approach may not provide an accurate indication of proficiency in the skills required of a Class 4 Distribution operator. For this reason, ABC is no longer developing standardized multiple entry exams for their clients.
Additionally, the Board was persuaded by the results of an analysis by a psychometrician hired by its Contractors to evaluate knowledge required of Colorado's operators for the various certification categories and the classes within each. Exam blue prints have been developed which support the use of sequential testing because some areas of knowledge are tested more thoroughly at a lower level than at an upper level. The Board also considered the issue of reciprocity, as there will be very few, if any, states using multiple entry exams by the end of 2011. The Contractors' reciprocity committees will benefit from a sequential testing scheme because it will allow an equal comparison of Colorado's testing requirements with those of other states.
Accordingly, the Board added new section 100.9.7 to include the new requirement that in order to qualify to sit for an exam, an applicant must hold a certification for the same category and in the class immediately below the class for which the application is being made. The Board also revised the corresponding "Prior Certification and Experience Requirements" table in section 100.9.8 to consolidate and simplify the explanation of the experience requirements for the various certification categories and classes within each. Minor revisions were also made to section 100.9.6 for consistency with the other changes.
The Board agrees with the Contractors' assessment that relatively few operators will be impacted by this change in testing policy, as most operators already gain the required experience and take examinations with the intent to advance sequentially through a particular certification category. For those few operators who currently have the requisite experience to bypass lower level exams and may wish to skip to higher class of certification, they should be able to obtain their desired level of certification in an expeditious manner. The Contactors have indicated to the Board that, beginning in 2012, they will be expanding from their current offering of two examination cycles per year to three cycles. This added exam cycle will allow operators who meet higher level experience requirements to go through the sequential testing process more quickly in order to obtain their desired level of certification.
5 CCR 1003-2-100.48