I support the new Continuing Education Requirements; however, think the criteria should include credit for being an officer in an engineering association and should not be as arbitrary with the documentation requirements.  Allowing credit for leadership in engineering associations would be consistent with other states such as NC.  It would not be inconsistent with the Code requirements in that they refer to "continuing education activities".  Leadership in professional engineering associations is probably one of the best professional development activities an engineer can participate in.  Also, in my opinion the board's proposed documentation requirements for acceptable continuing education are too narrow and arbitrary.  I have been providing PDH records to NC since 1995 and to NCEES since 2003 which included many self-interpreted PDH credits (i.e. without certificates or independent assessments).  I was audited by NC in 2005 with all credits claimed accepted.  The proposed VA criteria and documentation requirements appear to reflect distrust in professional engineers' integrity and ability to report acceptable continuing education activities.  My personal experience has been that engineers rarely lie and cheat.  It would save the board time and money to be more trusting and not require as much documentation.