You don't have to read far to figure out that most of the commenters are against the proposed regulations for a continuing education program (CEP) for architects, PEs and land surveyors in Virginia.  Unfortunately, I think most of the commenters focused their attention on the words "proposed regulation" rather than the words "mandatory continuing education program".  It appears the time has passed to oppose this change.  We now need to try to make the CEP work for all of us.  While I too am opposed to the new CEP, I offer the following comments for your consideration:

• Grandfathering - There is no provision for the exclusion from the CEP of those professionals who received their licenses many years ago.  It may be extremely difficult for many of us to be reintroduced to the classroom after so many years.  It is common practice to provide grandfathering provisions when new regulations are introduced.  This would prevent the new regulation from being a hardship on those who graduated from school many years ago.
• Economic Impacts - Many continuing education courses are quite expensive.  For those that do not work for major corporations or large consulting firms that are willing to pay for the courses, the financial burden for these required courses falls on the individual.  Before making this a requirement, the APELSCIDLA Board should provide assurance that these courses will not create an undue hardship on any individual.  There should be an adequate number of inexpensive or no-cost courses provided throughout the Commonwealth to prevent this new requirement from becoming a burden to anyone.  I would hate to be faced with the decision of giving up my PE simply because I couldn't afford to take the required classes each year.  These classes are essentially an additional tax on those professionals that are not fortunate enough to work for a large corporation.
• Additional License Categories - I work for a State Agency, and my PE is not a requirement for my present position, but I am very proud of the fact that I took the PE exam and was successful in becoming a  PE.  While my PE is not required at present, there is always the possibility that I may need it in the future.  Perhaps the regulations could be amended to include additional license categories (e.g. grandfathered, non-practicing, practicing, etc.) with corresponding levels of CE requirements.  In other words, make the CE requirements match the level that the license is used.
• Exclusions and Waivers - In the section on exclusions and waivers, you refer to "illness or undue hardship".  The term "undue hardship" is a very subjective term.  Can you please define it better in the regulation?

Thank you for the opportunity to comment.