The Board cannot expect balanced comments without providing details as to how this regulation will be executed. 

I have been taking continuing education courses for most of my post grad career.  I have been a degreed civil engineer since 1980, and a professional engineer since 1987.  I have licenses in the Commonwealth (by exam) and Maryland (by reciprocity).  On the average I have attended continuing ed courses at the rate of one per year, some years not at all, some years (2) per year, depending on my financial situation, and time constraints, since becoming a PE. 

How can the Board intelligently expect a 'one size fits all' solution to the myriad career paths that a design professional can undertake?   

Who on the Board is qualified enough to decide what my career path should be, and which courses will aid me in following my path?  How will the Board evaluate any course I desire to take?  What if I desire to take a writing course to improve my report writing skills?

Engineers follow many career paths, not necessarily design oriented, at any given point in their professional careers. 

I myself have worked in design (site development, structural design), inspection, construction management, contract administration, quality control/quality assurance, forensic investigations, and project management, in both private (i.e. residential, commercial), and government arenas.  At any point in my life, certain continuing ed courses held more interest, and relevance, than others. How will the Board address this aspect? 

The expense of taking coninuing education courses is not insignificant, when one includes travel, lodging, meals, and the fees, typically, in the high hundreds, and low thousands, of dollars.  Will 8 hours of attendance at a cont ed course count for 8 hours of completion, in the eyes of the Board?  does the Board expect additional fees from this regulation?  Is it appropriate for the Board to expect compensation? 

The Board is remiss in not providing quasi-definitive details regarding the implementation of this regulation.  The Board should remember that they are dealing with very intelligent people, whose stock in trade is to make informed decisions based on details, which are woefully inadequate in this instance. 

Go back to the drawing board, revise, and resubmit.