While there is no data to suggest that a continuing education requirement will provide better engineering services to the Commonwealth of Virginia and I disagree with the actions of the legislature and the governor in approving this legislation, my comments are focused on the implementation presuming that implementation will proceed in any case.   I am a PE by personal choice not due to job requirements.

Since this is a "biennium" requirement, indviduals should reasonably have two years from the date of regulation enactment to comply.  "Date - 12 months" should be changed to read "Date -2 years".  To do otherwise is to change the "biennium" requirement to an initial annual requirement.   Additionally, allowing a biennium  transition to a "biennium" requirement may well reduce the number of licensees who choose not to renew.  

   Please note that the Department of Planning, 2006 Fiscal Impact Statement states under "Fiscal Implications", sub section " Cost to Regulants"

"No additional costs to licensees is expected as a result of this legislation for the next two biennium". 

Since legislative approval, and likely the governor's signature, was based on this financial analysis and the usual cost of a continuing education unit is $100, the continuing education requirement will likely cost each licensee $1600 in each biennium for which it is effective.   A one year implementation timeline is totally inconsistent with the planning departments analysis of the costs for implementing this legislation.  Please utilize an implementation (2 bienniums) which is consistent with the fiscal costs provided to the legislature when this law was considered, or at a minimum, allow at least 1 biennium (two years) for initial compliance.