I recieved my original PE license in Virginia in 1984.  Since that time I have also become licensed in 7 other states.  I am certain that many Virginia PEs are licensed in multiple jurisdictions and many of those PEs are already conforming to continuing professional development requirements.  I have no problem meeting the requirements in those states currently requiring continuing education.  However, Virginia's proposed requirements seem to vary from other states' requirements.  One paragraph in particular causes me some concern.  This paragraph (18 VAC 10-20-683 C.5.b) provides that in order to receive credit for continuing education, the sponsor must predetermine the amount on continuing education credits:  "The sponsor of the continuing education activity must have predetermined the number of continuing education credit hours that an activity shall take to complete."  This is not a requirement in other states' programs.

I feel certain that the courses offered in Virginia to help engineers meet these requirements will have predetermined continuing education credit hours.  Courses or programs offered in other states may not.  There are many Virginia PEs who live out of state.  An engineer may wish to take a course or seminar in his state and meet the requirements for both his home state and Virginia.  However, this language may nullify an otherwise perfectly good continuing education opportunities.

There is another negative aspect to this language.  Each year many, many engineers sit on standards development boards and committees.  The information and knowledge exchanged through these activities is invaluable and often much more educational than attending a seminar put on by a product vendor.  There usually are no predetermined continuing education credit hours associated with the standards boards, but quite often there are predetermined credits for vendor seminars.

I would encourage the Board to eliminate the need for predetermined credits and recognized that other activities can be valuable educational experiences.

Thank you for your consideration of my comments.

John N. Dalton, PE