The proposed continuing education requirements for licensed professional engineers is fatally flawed. Not enough clarity or guidance is provided on what will count as continuing educational activities. Additionally, if VPOR is to adopt some continuing education requirement program they will need to provide license holders with an on-line tool for submitting their credits that feeds into a VPOR database. The standard should be on VPOR to identify any problems with submitted credits at the time the credits are submitted, not at some random audit. As the VPOR program is currently constructed, the license holder is under some vague standard and may find themselves on the wrong end of an audit due to this lack of clarity. VPOR should provide a listing of credits that will automatically be granted credit and should work with these educational programs to have credits automatically posted to a VPOR database without the need for a license holder to submit data. VPOR should go back to the drawing board and consult with license holders before taking any further steps. As it stands, the current proposal lacks clarity, efficiency, and certainty for license holders.