On March 19, 2025, the Governor's Office received the appeal you filed in response to the Department of Labor and Industries' (L&I) decision to deny your petition to amend WAC 296-200A-030, -040, -050, -060, -070, and -080. These regulations provide requirements for contractor registration. Under RCW 34.05.330(3), an agency's denial of a petition to repeal or amend a rule may be appealed to the Governor. However, the Governor lacks jurisdiction under this statute to consider an appeal of other matters, such as an agency's denial of a petition to adopt a new rule. See RCW 34.05.330(3).

On January 17, 2025, you petitioned L&I to amend WAC 296-200A-060. You proposed amendments that would: 1) "Establish specific measures and penalties to enforce compliance with the notification requirements," 2) "Implement oversight mechanisms to monitor compliance with the notification requirements," and 3) "Ensure that the regulations are aligned with statutory requirements to prevent gaps that can lead to consumer harm."


1.	WAC 296-200A-030: "Require contractors to consistently use their registered business names in all official correspondence, with penalties for violations."
2.	WAC 296-200A-040: "Require L&I to cross-reference and validate insurance information directly with insurance companies before accepting contractors' registrations."
3.	WAC 296-200A-050: "Mandate L&I to verify compliance with anti-flipping laws when registering contractors. Additionally, ensure that electrical, plumbing, and structural work are verified and documented by licensed professionals, especially in cases of property flips."
4.	WAC 296-200A-060: "Enforce SHB 1843 more stringently with clear guidelines on regulating sales of properties by contractors."
5.	WAC 296-200A-070: "Create stricter penalties and follow-up mechanisms for non-compliance with timely notifications of policy cancellations"; "Include specific timelines and mandatory reporting for insurance companies, with fines for late notifications"; "Insurance policies cannot be considered cancelled until L&I has been notified and a grace period for the notification process"; "Clarify the statutory requirement for notification in general liability insurance policies and ensure insurance companies are informed of this requirement."
6.	WAC 296-200A-080: "Require contractors to follow safety regulations and obtain permits and city inspections for plumbing, electrical work, and structural work. There should be no exemptions wrongfully made under the guise that they are homeowners renovating their primary residence. Furthermore, all plumbing work must be properly permitted, inspected, and documented by licensed professionals."

WAC 296-200A-030: "Require contractors to consistently use their registered business names in all official correspondence, with penalties for violations."

WAC 296-200A-040: "Require L&I to cross-reference and validate insurance information directly with insurance companies before accepting contractors' registrations."

WAC 296-200A-050: "Mandate L&I to verify compliance with anti-flipping laws when registering contractors. Additionally, ensure that electrical, plumbing, and structural work are verified and documented by licensed professionals, especially in cases of property flips."

WAC 296-200A-060: "Enforce SHB 1843 more stringently with clear guidelines on regulating sales of properties by contractors."

WAC 296-200A-070: "Create stricter penalties and follow-up mechanisms for non-compliance with timely notifications of policy cancellations"; "Include specific timelines and mandatory reporting for insurance companies, with fines for late notifications"; "Insurance policies cannot be considered cancelled until L&I has been notified and a grace period for the notification process"; "Clarify the statutory requirement for notification in general liability insurance policies and ensure insurance companies are informed of this requirement."

WAC 296-200A-080: "Require contractors to follow safety regulations and obtain permits and city inspections for plumbing, electrical work, and structural work. There should be no exemptions wrongfully made under the guise that they are homeowners renovating their primary residence. Furthermore, all plumbing work must be properly permitted, inspected, and documented by licensed professionals."


o	To prevent deviations from the intent of House Bill 1843 and other protective laws and regulations, L&I employees should be held to a higher standard of law interpretation. This includes ensuring they fully understand and accurately apply the law as intended, so as not to deviate from its protective measures for consumers.
o	Implement rigorous oversight and clear guidelines for law interpretation.
o	Utilize detailed compliance checklist and enforce strict penalties for any violations.
o	Conduct regular audits and reviews of enforcement practices.
o	If those entrusted to enforce the law do not interpret it correctly:

To prevent deviations from the intent of House Bill 1843 and other protective laws and regulations, L&I employees should be held to a higher standard of law interpretation. This includes ensuring they fully understand and accurately apply the law as intended, so as not to deviate from its protective measures for consumers.

Implement rigorous oversight and clear guidelines for law interpretation.

Utilize detailed compliance checklist and enforce strict penalties for any violations.

Conduct regular audits and reviews of enforcement practices.

If those entrusted to enforce the law do not interpret it correctly:


•	Penalties should apply.
•	If repeated, as in my case, someone else should immediately take over and perform the job efficiently.
•	Otherwise, they compromise consumer safety and security, which cannot be permitted.

•

Penalties should apply.

•

If repeated, as in my case, someone else should immediately take over and perform the job efficiently.

•

Otherwise, they compromise consumer safety and security, which cannot be permitted.

In sum, your petition and follow-up communications contain multiple requests seeking to expand L&I's enforcement authority or add penalties and other provisions beyond what is provided by the agency's authorizing legislation. L&I correctly responded that it cannot adopt rules that exceed the authority the Legislature has granted to the agency by statute. Relatedly, while framed as requests to amend existing rules, your requests that the agency adopt rules that exceed its statutory authority are effectively requests for new legislation, and the adoption of new rules on new subjects under an expanded scope of statutory authority. Such requests are not subject to the Governor's jurisdiction through this appeal. See RCW 34.05.330(3).

L&I denied your petition on March 18, 2025. The next day, you wrote to the Governor's office seeking reconsideration of your petition. While you refer to your submission as an "appeal," your submission does not specify any amendments that you are asking L&I to make to existing regulations as requested in the petition. Instead—consistent with L&I's explanation that it cannot regulate beyond its legislatively delegated authority—your submission asks the Governor to: 1) "introduce legislation to close critical enforcement gaps and strengthen consumer protections" and 2) "foster transparency and collaboration with affected individuals, like myself, to ensure that our voices are central to the reform process."

As noted above, RCW 34.05.330(3) provides that the Governor can review agency denials of a petition to repeal or amend a rule; however, requests for new legislation and advocacy efforts are outside of the scope of this rule appeal process. Accordingly, the Governor does not have statutory authority to take action pursuant to RCW 34.05.330 in response to your request.