I’m not sure why I’m unable to edit and append to my earlier post. In the Federal Register that published the MMC rule we noted we did not intend and substantive changes apart from those associated with the TWIC and the new MMC. Had we intended to change the requirements for advanced fire fihting to require re-training, we would have been compelled to perform an economic impact analysis, none was done. So there was no intent to change the prevcous provision that on a raise in grade, advanced fire fighting was not required if met previously. And as I noted before, a plausible argument could be made that the apparently unintentional omission actually removed the requirement for cerain rqaises in grade,. but did not add any new requirement.