May 2, 2008

Mark:

             I’m a near-70 year old electrical engineer who has held his PE license from the Commonwealth of Virginia for nearly 45 years or thereabouts, having passed all 3 parts of the examination at Natural Bridge during one weekend back in approximately 1965.  I’ve taken pride in holding that license even though I don’t use “PE” behind my name anymore, and seldom ever did.  But in talking, for example, with high school kids during Career Day, I mention it as a mark of professionalism in the field of engineering.  It sounds as if those days might be coming to an end. 

             A proposed “mandatory continuing education program” is what the postcard noted.  Hmmm. . . I wondered if the hundreds of hours of reading books, newspapers, magazines, and journals (the IEEE in my case (I’m now a Life Member having passed my 65^th birthday several years ago)) will qualify for continuing education.

             I also wondered how many of us oldsters, who had careers in corporate America (mine was half technical and half management with GE and GTE) will drop or be dropped from the PE roster) because we scoffed at the notion that the continuing education that we obtain every day may not qualify for the requirements imposed by the new rules.

             I also wondered how much revenue Virginia will lose because of our deletion from the roster.

             I also wondered what sorts of continuing education you’ll require to cover the thousands of different fields and specialties that architecture and engineering cover.

             However, before jumping to foregone conclusions, I did download and have read the proposed regulations in search of answers.  My suspicions have been upheld.  The Proposed Text comprises one of the most obtuse documents I’ve ever been in need of understanding.

For example, what are the objectives of the new regulations?  Do you think that we’re delinquent in “keeping up” such that you need to impose continuing education on us?  Has something gone wrong with the system that requires this action?  Do you have measurements to the effect that your 16 continuing education credit hours of “board-approved” study will trump our own “self-approved” study? 

I also find that the document is full of wording that leaves one wondering as to whether or not we comply.  The following are examples: 

• shall be deemed . . .

• areas related to . . .

• which have demonstrated relevance . . .

• must be consistent with . . .

• must have sufficient resources . . .

• instructors must be competent in . . .

• has achieved the purpose and objective of the continuing education activity

 . . . and others.  They all lack specificity as to what constitutes compliance.  Who passes judgment on these ambiguities?  Perhaps a Philadelphia lawyer can understand the proposed rules, but I, for one, cannot.  Overall, it bothers me that we complicate life all the more with bureaucratic gobbledegook like this in pursuit of unspecified objectives employing non-understandable methodologies leading towards non-quantifiable results. 

I do believe in continuing education.  I was told in 1960 when I graduated from college for the first time that the half-life of our then-current knowledge base was four years.  I’m sure that it’s even less today.  Can any engineer or architect remain in his or her chosen profession without the need for an effective continuous-learning program?  Does not the phrase “continuous learning” apply to virtually every field of learning?

Is the program that you are proposing going to accomplish something that those of us in the professions are delinquent in accomplishing for ourselves?  This reminds me of a long-ago situation in which an employee in our business of a thousand employees was taking advantage of his ‘exempt’ status by regularly coming in late and leaving early.  Why should he be so lax in his attendance while the rest of us were working so hard including a lot of casual overtime?  One solution was to force everyone to punch a clock.  Wisely, however, we chose to deal with that one employee rather than to apply a punitive measure on the 999 who were working so hard to accomplish our business objectives. 

Am I missing something so fundamental that I cannot see it even while looking at it?

 Sincerely,

Dick Larson