1.4 License Renewal, Training Units (TUs) & Mandatory Regulatory Training

The three-year certification lifecycle

Colorado certificates are not permanent. Under Regulation 100, sections 100.15.3 and 100.16, a new certificate is valid for three years from its effective date, and a renewed certificate is valid for three years from the expiration date of the prior certificate — not from the date the renewal is issued (section 100.16.1). Renewing late therefore does not buy you extra time; it simply costs more.

To renew, section 100.16.2 requires the operator to apply through the CCWP Portal and demonstrate:

1. Verification of regulatory training course completion as described in section 100.14.5(b), and
2. The training unit requirements of section 100.16.6.

The $85 renewal application and administration fee (section 100.17.1(c)(iii)) is collected when the application is submitted and is non-refundable.

Training unit quotas by class

A training unit (TU) is defined by contact hours. Section 100.14.6(b)(iii)(A) sets 10 contact hours = 1.0 training unit, and section 100.16.9(d) sets the minimum course duration for any credit at 30 minutes: 1 to 29 minutes earns 0 TUs, 30 to 45 minutes earns 0.05 TUs, and 46 to 60 minutes earns 0.1 TUs.

The section 100.16.7 table is short and heavily tested:

Note carefully that Class S sits with Class C and Class 2 at 1.8 TUs, not with Class T and Class D at 1.2. Class S is a hybrid certificate covering both treatment and distribution or both treatment and collection, so the Board assigned it the higher quota. Candidates who mentally group "all the small-system certificates" together get this item wrong.

Category, carry-over, and multiple certificates

• Category rule (100.16.6(b) and (c)): at least 50 percent of the TUs used for a renewal must be for courses approved for credit in the specific certificate category being renewed — water treatment, domestic wastewater treatment, industrial wastewater treatment, distribution system, or collection system. Up to 50 percent may come from another category, including supplemental training.
• Multiple certificates (100.16.6(e) and (f)): each certificate carries its own TU requirement, but the training units from one course may be applied toward the renewal of more than one certificate. Units may only be used once in each category. An operator holding a Class A water treatment certificate and a Class 4 distribution certificate must satisfy 3.0 TUs for each, and a single qualifying course can count toward both — but the operator must still meet the 50 percent same-category rule for each renewal.
• No carry-over (100.16.6(g)): training units are earned during the three-year period the certificate is valid and do not carry over into the next period.
• Pre-exam training (100.16.6(i)): a course taken before an upgrade examination that you then pass does not count toward renewing the new, higher certificate. If you take the course and do not pass, it may still be applied to your current certificate.
• Teaching credit (100.16.10): an operator who teaches an approved classroom course earns double the approved TUs, once per course approval number per year.
• Out-of-state courses (100.16.9(e)): a course not already approved — for example, one taken in another state — can be submitted with the $25 operator-initiated approval fee, and if approved applies only to the operator who requested it.

Core versus supplemental training

Section 100.16.9 divides approved training into two kinds, and the distinction is not "technical versus safety" — it is "directly related to facility operations versus not."

• Core training (100.16.9(a) and (b)): courses on topics directly applicable to operations that may affect public health or the environment, or that maintain regulatory compliance. Eligible subjects listed in the rule are: operation and maintenance of facility mechanical systems, electrical equipment, or hydraulics; physical, chemical, or biological treatment; physical, chemical, or biological testing, or disinfection; regulatory compliance; and other relevant topics the Board or its contractor approves.
• Supplemental training (100.16.9(c)): courses the Board finds provide useful operator knowledge but are not directly related to water or wastewater facility operation. Supplemental training units may still be used toward renewal, subject to the 50 percent category rule.

The Board or its contractor determines all subject matter relevance, and the searchable catalog of approved courses lives in the CCWP Portal.

Mandatory regulatory training (MRT)

Section 100.14.5(b) requires an approved regulatory training course to be completed before an application is submitted — for initial certification, for an upgrade, and for renewal alike — and each completion is valid for three years.

CDPHE provides the MRT free and on demand through Indigo Water Group. There are separate Drinking Water and Wastewater MRT courses, and the format is a mix of videos, interactive slides, and quizzes. You register with your operator ID number from your CCWP Portal profile so the completion posts to your record. Section 100.16.8 makes an important point about accounting: the training units from the MRT are included in the total TUs required in section 100.16.7, not added on top of them.

Typical MRT subject matter tracks Colorado's regulatory landscape — operator duties under Title 25, Article 9; ORC designation and written operating plans under Regulation 100; drinking water monitoring, assessments, and public notification under Regulation 11; and discharge permit compliance and reporting for wastewater facilities.

Expiration, restoration, and automatic revocation

  Certificate active (3 years)
       |
       v  [expiration date]
  INVALID IMMEDIATELY -- there is NO grace period (100.16.3(a))
       |   * May not represent that you hold the certificate
       |   * May not serve as ORC or operate on the expired certificate
       v
  Restoration window (up to 2 years after expiration, 100.16.4)
       |   * Apply for renewal, pay $85 renewal + $100 late fee
       |   * Meet MRT and all training unit requirements
       |   * Restored certificate still runs 3 years from the PRIOR expiration date
       v  [more than 2 years expired]
  AUTOMATIC REVOCATION (100.16.5)
           * Treated as a NEW applicant
           * Must meet all initial requirements and pass the sequential exams again

Three consequences of section 100.16.3 are worth memorizing because they are commonly misstated:

1. A certificate becomes invalid on its expiration date. Regulation 100 contains no 60-day grace period. The day after expiration you are an uncertified person.
2. You must not represent that you hold the certificate in the category or level of the expired certificate, and no ORC may operate a facility on an expired certificate.
3. The restoration window is two years, measured from the expiration date. Section 100.16.4(b) confirms a certificate renewed after expiration is still valid only for three years from the prior expiration date, so late renewal shortens your usable cycle.

Section 100.16.6(j) provides one practical accommodation: training taken after the expiration date but before the automatic revocation date may be used to renew the expired certificate, and if those units are not used for that renewal they may be applied to the subsequent one. It is the operator's responsibility to track which units have been used, and using the same credits twice is grounds for disciplinary action, including revocation.

Military service (100.16.2(b)). For an operator in uniformed service as defined by USERRA, certificates are tolled for the duration of service, plus an additional 90-day grace period on return, with discretion for the Board to extend further. No late fees apply to a renewal application filed in conformance with that provision.