I am currently licensed in 6 states and several currently require CE.  I have been complying with this requirement for years, and I find it useless and quite insulting to require me to document that which any engineer must already be doing in order to maintain competence in their field.   

This requirement does indeed breed "pay for credits" courses that are not even applicable to the work specialty a particular engineer is involved with, but only serve to satisfy the CE requirement (how can that possibly be construed as proving competence in my practice?).

I would urge you to discard this proposal as unnecessary and bbecause it will only be a burden for your license holders and for your office to keep up with and instead focus your efforts at stopping the practice of unlicensed engineers, which is much more dangerous to the general population that we serve.