What is driving this requirement--public safety or the education lobby?  Do we have documented instances of engineering or design-related failures that can be attributed to a lack of continuing education, or studies that support the theory that continuing education actually improves public safety?  I would argue that the end result of this proposal will be a net growth in VA state government to manage this program, however infectively; increased costs to practicing PEs and RAs, which will ultimately be passed on to government and private customers; and quite possibly the loss of some very talented engineers.