Larry Stearns is a VA PE (plus 6 other states) and PMP with 28 years practice in remediation and heavy construction; currently an independent consultant.  Comment 1 - The VA proposed requirement for 16 PDU's is more than Ohio or West Virginia (15 PDU's) - what is the justification for 16 rather than 15 PDU's in Virginia?  Comment 2 - Although I generally support the requirement for continuing education for professional engineers, please be aware that it absolutely does impose a significant financial burden. Corporate employers typically do not fully reimburse the employee for such training, and when coupled with continuing education requirements for other widely held professional certifications (such as the PMI PMP requirement of 20 PDU's annually or annual 8-hour OSHA refresher training 29 CFR 1910.120), the financial burden on the individual becomes substantial. For example, on-line engineering training courses typically cost $38 to $45/PDU (reference www.redvector.com) on the low end, while professional seminars or university courses cost substantially more particularly when travel and lost-work time costs are considered. It is typical for me to expend about $2,500 per year in direct out-of-pocket costs maintaining my various continuing education requirements. Comment 3 - usually the documentation for continuing education is not submitted with the license renewal. Rather a statement attesting to the satisfaction of the PDU's is provided, sometimes with the applicant's PE seal. What exactly will VA require in terms of demonstrating completion of the required continuing education on renewal applications?