I am unaware of the problem this is intended to solve.  Do we in Virginia have an unacceptable level of technical or ethical violations?  Is the public safety or trust in jeopardy?  If so I am -- in principle -- not opposed to continuing education, but having read the new draft regulation a major new bureaucracy seems to be in the making with major enforcement investments (and if minimal enforcement, why the complicated requirements?)

Not being aware of a major problem -- I oppose this on common sense basis.

If the state decides to pursue, then there needs to (1) be courses available and approved by the state BEFORE any regulation becomes effective, and (2) there needs to be provision to “credit” the many hours spent in counseling/educating our staff and younger professionals within businesses on the practice of professional engineering.  In addition, there should be credit allowed for teaching relevant courses without having to attend the course you are already qualified to teach.