As I understand it these regulations are up for review as to whether these regulations should be repealed, amended, or retained.  These regulations are necessary to help protect public health, safety, and welfare. As such these regulations should not be repealed.  I have no specific recommendations for amending the regulations at this time.

The current requirements under this section for taking the PE examination state that a potential candidate needs to have some educational background, generally in the form of a college degree.  Even without a degree, the board may judge that academic coursework meets the equivalent requirement.  The results of this regulation is that an individual with either limited or no academic background has no chance of ever becoming a Professional Engineer, regardless of the years of qualifying engineering experience.  I believe this requirement creates a needless barrier to entry for the engineering field in Virginia by discouraging otherwise talented individuals from entering the field if there is a fixed ceiling on professional advancement.  I believe this also creates an economic burden in the state by restricting both the supply of our native engineering talent pool and the earnings potential of Virginia citizens. 

I suggest the current regulations should be amended to allow 20 years of qualifying engineering experience to be an acceptable means of satisfying the requirements of 18 VAC 10-20-210 without having any college level education. 

Personally and professionally, I would respect any individual, with 20 years of qualifying engineering experience and having passed the PE exam, as a colleague and peer as a professional engineer.

I respectfully suggest that the current regulations should be amended to allow 20 years of qualifying engineering experience to be an acceptable means of satisfying the requirements of 18 VAC 10-20-210 without having any college level education. If a person has this amount of qualifying experience, it should demonstrate a level of competence, determination, and an ability to learn and apply oneself to the profession. More importantly, the EIT and PE exams serve as excellent, rigorous and thorough filters to determine a person's depth and breadth of engineering knowledge.

The Board is considering whether or not to modify the regulations to permit 20+ years of experience in engineering to be equivalent to a Bachelors of Science degree for purposes of qualification for sitting for the PE examination.

The regulations currently permit such experience to qualify in lieu of the FE examination. 

It is respectfully requested that the Board consider permitting 20+ years of experience EITHER to apply in lieu of the FE exam OR in lieu of the Bachelors of Science degree, but not both.

The skills required to pass both the FE and PE exams demonstrate a grasp of the knowledge and skills taught in a Bachelors curriculum.  Neither examination is easily passed without such skills and knowledge.