Gentlemen,

Mr.Richard Davenport, P.E. (Former Chairman APELSCIDLA Board & Engineering Sect *) mentioned in an earlier comment that he only had 8 instances of incompetence in 8 years on the APELSCIDLA board (that a problem ratio of about a 1 in 22,500) makes a compelling case for "lack of demonstrated need".   The GA requiring that we all get CE based on that kind of problem ratio appears to be a blatant insult on the intelligence our profession as a whole .

Other comments of my own:

 1.  There appears to be no PROVEN demonstrated need for this CE.  The thing actually demonstrated is that the GA listened to those who wish to capitalize on Arch/Engineers having to purchase CE.

2.  Our work, in the normal A&E business, already gets reviewed and judged with almost every set of plans submitted for permit and with every building constructed.

3.  During the normal design process we must keep up with the latest codes, equipment and design procedures just to remain in business. 

4.  There appears to be no provisions, at this time, for an individual to get the CEUs through self study without going to others and most probably having to pay some company for them.

5.  Maybe I am too dumb and need CE but, I have not found the actual math, science and physics involved in engineering calculations have changed much, if at all, in the over 40 years that I have been in this business.  The equipment has changed from slide rules to computers but that shouldn't require mandated CE.

6.  It has been mentioned in these comments that the time has passed for determining whether or not we will have a CE requirement since the GA has already passed the law, which they have - AND, that we should have contacted our legislators BEFORE it was passed.    I was aware that this law was being proposed and was against it then and still am but...  I talked to my representatives about CE and, if you ask them, they will not even remember the conversation - let alone place any value on an individual's opinion.  But they will listen to some organizations and listen mostly to the organizations that are in line to sell us the CEs we will need to maintain our licenses.   Also, Peter Bacque with the Richmond Timed Dispatch wrote a article about CE a couple of years age before the bill was passed but that was the only article that I was able to find that tried to explained it to the public at large. 

7.  I am not against CE however, most, if not all, practicing engineers get our own CE in our day to day engineering businesses. However, to mandate that we get CE that is "specifically approved" by anyone that is not intimately familiar with OUR own individual businesses, in reality, is an insult to every licensed Architect/Engineer, especially since there has been no demonstrated need for CE - oher than to promote the CE training industry.

8. Since the law has been passed requiring CE make the requirements such that:

a.  Allow manufacturer's seminar's and equipment demonstrations (physical attendance or web based) to count for CE.

b.  Allow trade show presentations to count for CE.

c.  Allow the individual Architect/Engineer to determine which courses are helpful to his/her own business.

d.  Allow CE approved in other states in which the regulant is registered to count for Virginia CE.

e.  Suspend the CE requirement in any year in which the State of Virginia implements new codes (USBC - 3 year cycle) or automatically give A/E's 8 hours credit when the new codes take effect.  Getting up to speed on the new code changes alone usually requires much more than 8 hours.

f.  Allow multiple hours for any college or community course credit.

9.  There have been comments that 8 hours is a minor disruption in a persons work year.  Whoever said that does not run a small engineering business.  Sure, if you work for someone else that pays you while you are taking the classes, it may not be significant.  But if you are paying the bills it is.  Also, to actually get 8 hours of CE will probably take a minimum of 16 hrs of time away from productive work.  Based on the +-25,000 reqistered professional required to get CE, the time loss is about 200 man years for the state as a whole.  A big loss for something that has no demonstrated need...

10.  As has been noted before, those of us that are already registered in other states that require CE to maintain registration may have to get additional hours because the different states may not accept the others requirements.  Any CE requirements implimented should be consistent with neighboring states.

Thanks for reading this.