As a member of the AIA, and being licensed in other states requiring CE, I already must comply with Continuing Educational requirements, so I have no objections to Virginia implementing MCE for Architects.   However, the state statute, if implemented, must not create another layer of inane, cryptic, obtuse, cumbersome, and/or expensive bureaucracy upon Architects (and the other design professional disciplines as well).  To insure this does not occur, any mandatory CE provisions should adhere, at a minimum, to the following criteria: (1) The regulations for the number of hours (Learning Units) should not exceed those established by the AIA, (2) The regulations must be crafted to seamlessly interface with, coordinate with, and compliment the established reporting/ recording procedure used by the AIA, (3) Pre-approved CE courses, as approved and accepted by the AIA (and therefore usually be default, other jurisdictions already imposing MCE) would be accepted by the State of Virginia, and (4) No other conditions or requirements that conflict, contradict, and/or exceed the already in-place AIA requirements be included in the state regulations, and (5) No provision of this regulation would be in conflict with any NCARB provision/ procedures, or with any other state jurisdictions, which may preclude or restrict licensure reciprosity.  Thank you for the opportunity for comment on this proposal.