1.  In Preamble Sect. B, is the 16 hrs of CE intended per 2-yr renewal period or per year?  This needs clarification up front.

2.  What instructor & instruction institution qualifications are required?  There are dozens of different people , organizations, course sponsors, and on-line entities willing to teach or offer CE courses, but some may not be qualified or certified by some institution like a university, college, ASCE, NSPE, CPESC, etc.  I think that minimum instruction/course standards and instructor qualifications should be specified.  Maybe even list examples that are not acceptable.

3.  In re Section 5e: As a retired university civil engineering faculty, and current instructor in Tennessee's Erosion Prevention & Sediment Control Program, we are constantly updating and modifying our three courses (see www.tnepsc.org) to be consistent with current state & federal regulations and with new technologies.  Tennessee engineers, inspectors, regulators, etc. engaged in erosion and sediment control are required to renew their EPSC certifications every 3 years for this reason.  Therefore, it seems reasonable to allow engineers to use the specified PDH credit hours that each of these different courses provide, at least every 2 years, even though the title of the course remains the same.   Also, it seems reasonable to allow the course instructors, who are university faculty or other experts commissioned by the sponsoring university program, to use these courses for credit every 2 years, because the cumulation of incremental changes can be "significant."

Thanks.