As an engineer licensed in thirty two states, I view continuing education as a fact of life.

However, the timing of the required continuing education activities is extremely burdensome. I have a specific recommendation that I would like to see in ALL states. It would ensure that engineers obtain the requisite continuing education without the burden of overlapping licenses renewal periods forcing us to take many more credits than is required by any one state due to the credits "expiring" simply due to the timing of multiple license periods.

When an Engineer is licensed in more than one state, all states should use the license renewal date (month and day) in the engineer's home state for the determination of when continuing education activities "expire", weather the engineers home state has continuing education requirements or not.

Using the engineer's home state resolves conflicts that would arise between the states that do have continuing education requirements each wanting to be ‘preeminent’.

Also, other states allow carryover of excess continuing education units of up to half of the required credits. In your case, you should allow a carryover of 8 hours of ce credits.

I propose the following change:

D. 1. Only continuing education activities completed during the license period immediately prior to the expiration date of the license plus up to eight carryover hours from the previous renewal period shall be acceptable in order to renew the license. Continuing education activities utilized to satisfy the continuing education requirements to renew a license shall be valid only for that renewal and shall not up to eight hours of continuing education activities may be carried over for the next accepted for any subsequent renewal cycles or reinstatement of that license.

Exception: Engineers residing in a US state or territory other than Virginia shall use the renewal cycle (month and day) emediately preceeding the renewal cycle (month and day) of Virginia (if different from Virginia) of their home state or territory for the determination of continuing education activity expiration.

Even if you decide not to allow carryover of excess activities, I strongly urge you to accept the exception. It would make life much easier for all of us licensed in multiple states. The current burden is considerable.