Your economic analysis documentation states there is insufficient data provided to show any benefit to proposed action.  The vast majority of comments provided to date demonstrate overwhelming resistance to the proposed action.  The regulations already in force require licensees to remain current in their respective fields of expertise as is the case with every employer or customer of our professional service.  It is difficult therefore for me to understand why the proposal was offered and what the desired improvement to the existing process might be.  What problem or issue are we trying to solve?

It is very easy to be emotional about being blindsided in this manner, but more productive to simply question the rationale and expected benefits-apparently there are none or they should be promulgated right up front .

I have to date practiced my trade as a PE for over thirty years, and necessity dictated my continuing participation in formal as well as practical, hands on learning in my field. is all that work to be grandfathered as "approved" CE?  If so, then why should I be required to pursue additional CE?  If not, how do you explain my ability to remain a competent and trusted engineer over all this time without your oversight?  I ask again, what is the problem we wish to solve?

My bottom line is that you have rushed into something without sufficient study and rationale.  Perhaps it would be prudent at this juncture to undertake further study as to (1) what you expect the proposed action to produce by way of results, and (2) the costs associated with managing the effort to both the individual licensee and the government.  If as a result of that study you find it difficult to better quantify the existing problem and/or the benefits of the "solution" than you have currently done, then set aside the proposal and move on to more productive business.  If on the other hand you are successful in communicating a need and associated benefits of the proposal, proceed with a more detailed and clear implementation plan.