Richard, no debate with regards to your testimony, but read the next sentence…”Any combination of education and experience that would confer equivalent knowledge and ability shall be deemed to satisfy this requirement.” Therefore, if the Permit Technician can demonstrate understanding in terms of facts, information, and conceptual process acquired through experience / education or the theoretical understanding of a subject (knowledge) in a similar field; as well as skill sets necessary to carry out the practical application (ability) of similar duties, then they have met the equivalency requirement and therefore can and should be considered Technical Assistants in accordance with 105.2.1.; which is in tune with the definition. In my opinion, one must draw intent here, and my reading of the intent is demonstrated competence in the field or something equivalent. If you feel the language needs some adjustment, I am Chairing the Administrative Ad-Hoc Committee and we can work with the Permit Tech Committee to propose the necessary adjustments to satisfy your concerns. Let me know.
Sean P. Farrell