Comment on DOD_FRDOC_0001-3048

The regulation inclusion of unlicensed behavior analysts is unfortunate. It represents a big government take over of how businesses are protected and regulated in Arizona. State like Arizona license behavior analysts and they define them and regulate them as they see fit. To include unlicensed people, who may be certified by the BACB, infringes upon states rights to define and regulate trade in the state. It interferes with a state’s ability to protect its people. Behavior analysis has a long a shady history with the use of punishment and other questionable technologies. To allow unlicensed people to engage in such activities with military children is a grave error.