As a licensed acupunturist, I oppose the proposed rules allowing Physical Therapists to do "Dry Needling" with only 54 hours of training.  To become a board certified, licensed acupuncturist, each practitioner must complete clinical training hours roughly 20 times that required for physical therapists to perform "Dry Needling". The definition of acupuncture according to Webster's dictionary is: "an originally Chinese practice of inserting fine needles through the skin at specific points especially to cure disease or relieve pain (as in surgery)". 

"Dry Needling" is acupuncture. Passing these proposed rules would be irresponsible.