I support the APELSCIDLA Board’s proposed regulations for continuing professional education.  However, the proposed rules do not provide credit for publication of books, papers or articles; for active participating in a technical or professional society; or for patents.  The National Council of Examiners for Engineering and Surveying Model Rules for Continuing Professional Competency provide credit for each of these activities.  (See http://www.ncees.org/introduction/about_ncees/cpc_guidelines.pdf.)  I would propose revising the proposed regulations to permit credit for publication of books, papers or articles; for active participating in a technical or professional society; or for patents.