While the concept of the continuing education requirement is sound in theory, rarely does the practical application meet the needs and serve both the professional and the public when mandates are involved.  I'd like to raise a few points for consideration:

1.  History has shown that rarely does more government regulation equate to more benefit, rather it tends to drive the mean of any sample population to mediocrity at the same time that it constrains those willing to put up with it.  It definitley increases cost and bureaucracy to manage the new regulations.

2.  The proposed guidelines imply that continuing education must be provided by someone else. I have already earned my PhD, so more college courses don't make sense.  I teach engineering course and have to remain current in my field to do so.  I attend conferences and publish papers from my research.  Research and publishing is self-directed continuing education.  Reading trade journals and trade publications is also self-directed continuing education.

3.  The marketplace tends to be a better arbiter of best practices in cases such as this.  For those of us who fail to stay current in our profession, we won't be employed for very long.  Employers understand the need to have current, educated individuals to remain relevant to the public.  They also understand the liability they face if they employ someone to do work they are not prepared to do.  Successful licensees will continue to do what is necessary within their niche to learn through formal, or informal, directed or self-directed programs.

I would submit that perhaps a better course of action would be to drop the requirement as a mandate and focus on using the Board to encourage continuing education (much of which is already taking place).  Spend a few years gathering data from licensees when they renew their licenses about what continuing education activities they feel they accomplished during the previous license period.  You may well find that you are trying to fix a problem that doesn't exist.  As several have pointed out, adding a mandate may well drive away many otherwise well-qualified engineers at a time when we have a major shortage in the nation. 

Thank you.