I have two fundamental comments concerning the proposed legislation. 

First the method by which you derived economic impact to firms and affected indivuduals is incorrect.  While  the mean salary paid to an individual may be $34.32, the cost of the individual to the firm he/she belongs to is much higher.  The cost must include the overheads, statutory fringes, general and administrative expenses, etc.  So a $34.32 person may cost the firm in lost revenue well over a $100/hour in lost revenue (or more- and likely more).  So firms employing engineers (especially senior ones will lose thousands of dollars of revenue per year due to this regulation.  This is revenue that has tax implication to the commonwealth.  Given the cited 32,672 people that this will affect, at a Revenue rate of $125/hour (a more reasonable number based on my professional experience) for 16 hours each - the revenue lost to the firms is now in excess of $65 million dollars!!  This is revenue that the commonwealth now loses tax income on.  Bottom line - you economic impact analysis is flawed.

Second and an opinion shared by many - 16 hours of seminars and the like are not necessarily 16 hours of improvement.  I have been to many, many professional development programs that qualify for professional development hours and frankly I cannot think of a single one that actually made me a better engineer, who is more likely to be protective of the citizens of Virginia.  I do everything to the best of my ability and conservatively as protecting people's health and welfare is my job.

May I ask the question before this uneeded change is codified - How many injuries have resulted in Virginia due to the lack of PHD for engineers?  Is there really a need/basis for this action or is it just the in vogue thing to do?

I do not support this proposed change.