As noted a several times in previous comments, Continuing Education (CE) is required and the details associated with implementing CE are now being developed. My comments on the proposed text for CE are as follows:

1. The allowable content and subject matter needs to be as broad as possible. Allowable CE content should not be limited to the professional's primary discipline.  Other CE areas should be allowed such as training related to safety, value engineering, public speaking, contracting procedures, etc...Also in-house training by other professionals on project lessons learned, etc...should be allowed for those that attend the training and the professionals that prepare/conduct the training. Allowing somewhat less structured training would be quite helpful and reduce some of the bureaucracy associated with the CE requirement. In the text more examples of allowable training would be helpful.

2. It is not clear what the criteria are for determining what training will or will not be allowed. The criteria that will be used should be included in the text. Professionals should not have to guess what training will or will not be allowed.

3. It is also not clear who decides if the CE training is allowable. This should be described in the text. An appeals process should be included and described in the text if CE training is somehow determined to be "not allowable".

4. Either do away with the possible CE audit or include a process to get advance approval for CE training in a timely manner. Professionals should not have to guess what training will be allowed.

5. Carry-over credit should be allowed for any excess credits. The excess credits should count for future renewals beyond the current renewal period.

6. If a professional is teaching a course it is not clear how to document this activity to get CE credit. 

7. It is recommended that one semester credit hour of approved college credit equal 16 (not 15 as proposed) CE credit hours.

8.  A waiver process is needed to consider special circumstances, retirees, etc...

9. The proposed text states "Course instructors must be competent in the subject being taught, either by education or experience". Who makes this determination of competency? What is the criteria/standard that must be met to be considered competent?

10. When the CE requirement is first enforced, everyone should have at least two years (typical renewal cycle) to complete the required 16 CE credits. The way the text is currently worded, some professionals requiring renewal may only have 12 months to achieve the required 16 credits. If some people are in the middle of the renewal cycle when the CE requirement is first in place, either reduce the requirement to 8 credits for those that must renew within the first 12 months of the CE requirement or give them extra time (the full two years) to get the full 16 credits. 

Thank you.