In the field of Civil/Structural Engineering, I have observed and experienced of unsafe trend of self certification and claims within Federal Government which I had been with for past 8 years.  Due to incompetancy of those who do not have experience and/or non-engineering degreed but Branch-wide or self-claimed engineers, I have found many failures that were covered up and patched only thru monetary solution which equates into gross waste and fraud.  Problem when you report those gross negligence and omissions are even though the law clearly regulates and supposedly make the person be accountable is that the law is not regulated or applied by Federal Government. 

I am opposed to this proposal for following reasons:  1. For the public safety, review process is not applied and rather reliance to computer result over-rides engineer's decision.  2.  Engineering is performed and decisions are made by non-engineers or engineers who are not qualified.  3.  Experience is more important than certification process.  4.  There are numerous number of Federal Employees who goes thru the motion of getting those extra certification process without having the necessary knowledge.  This results in those incompetant people to claim to have met regulatory requirement.  This further results in experienced and conscientious engineers to waste time.  5.  Same updating knowledge in each professional's discipline can be achieved by sending relevant information on professional web-site.

I hope this helps someways to Virginia regulatory proposed.