The regulation, as written, is too restrictive on what constitutes a qualifying continuing education experience.  The proposed Virginia regulation would do harm to innovation, research, discovery, teaching, and participation in professional activities in Virginia.  It must not be approved in its present form or it will harm our profession and the state.  Perhaps the proposed regulations are overly influenced by the lobbying efforts of commercial training organizations, as it appears a licensee would essentially be forced to purchase the credits.   

Other states are not this restrictive, as shown in the example below from Georgia where I hold a license. The State of Georgia PE Regulations state:

"180-11-.03 Requirements. (1) Professional Engineers. Every professional engineer is required to obtain thirty (30) PDH's each twenty-four (24) month (Biennial) renewal period. If a professional engineer exceeds the requirements in any biennial renewal period, a maximum of fifteen (15) PDH's may be carried forward into the subsequent renewal period.

(2) Land Surveyors. Every land surveyor is required to obtain fifteen (15) PDH's each twenty-four (24) month biennial renewal period. In addition, every land surveyor must ensure that, once every five (5) years, at least six (6) PDH's in "Minimum Technical Standards" be included in their PDH's acquired. If a land surveyor exceeds the requirements in any biennial period, a maximum of seven and one-half (7.5) PDH's may be carried forward into the subsequent renewal period.

(3) Dual Registrants. The person with a dual license is required to obtain thirty (30) PDH units for a twenty-four (24) month (Biennial) renewal period. If a dual registrant exceeds the requirement in any Biennial renewal period, a maximum of fifteen (15) PDH's may be carried forward into the subsequent renewal period. At least one-third (1/3) of the PDH's in a renewal period must be obtained in engineering, and one-third (1/3) in surveying. The remaining units may be in either field, at the discretion of the registrant.

(4) PDH's may be earned as follows:

(a) Successful completion of college courses.
(b) Successful completion of continuing education courses.
(c) Successful completion of correspondence, televised, videotaped, audiotaped, and other short courses/tutorials taken for the purpose of maintaining, improving, or expanding the skills and knowledge relevant to the land surveyor's or professional engineer's practice.
(d) Presenting or attending seminars, in-house courses, workshops, or professional or technical presentations made at meetings, conventions or conferences which are relevant to the land surveyor's or professional engineer's practice.
(e) Teaching or instructing in any area relevant to the land surveyor's or professional engineer's practice.
(f) Authoring published papers, articles, or books in any area relevant to the land surveyor's or professional engineer's practice.
(g) Active participation in professional or technical societies. (For professional engineers only)
(h) Receiving patents in any area relevant to the land surveyor's or professional engineer's practice.

(5) Sponsor Forms. Organizations or individuals that provide continuing education must complete the "Sponsor Form" available from the Board."

While they are very specific on what constitutes a professional development activity, they include a broader range of valid, and important, activities than the proposed regulations.  The Georgia regulations promote research, discovery and innovation in that state, as other states likely do.  The proposed Virginia regulation would send these activities that are vital to economic and social well being to other states.  It fails to make engineers in Virginia active participants in their growth.

It is absolutely essential that the proposed regulations not be approved until these broader issues are resolved.  Failure to do so will harm our profession, our engineering professionals, and our state.

Dr. Joseph Dove, PE

Blacksburg, VA