As someone who has held a PE license for 34 years, and a VA PE license for 23 years, overall I am in favor of the proposed changes. I am "grandfathered" from many of the new provisions; however, I am commenting as a member of the PE profession with a view to the long-term health of the PE practice.

The fact that some fees are going up, while not pleasant, is to be expected and is in line with what other jurisdictions have been doing. VA increases are quite modest in comparison with other jurisdictions.

As I read the specific changes, it looks to me that the intent to clarify and simplify the language while maintaining the basic intent has been met.

However, if the intent of DPOR is to be more in line with other jurisdictions and model laws (e.g., NCEES CPC) as it relates to continuous education requirements, then there is still a lot of work to do. For example, VA's requirement for 16 PDH for PE's is low compared to most jurisdictions that have imposed the requirement (I think it is ~34 so far) - 16 compared to 24 to 32. Also, VA does not allow any carryover PDH's from one license period to the next. The PE regulant requires a minimum of 16 PDH in the prescribed categories for each two year license term. Other nearby jurisdictions (e.g., PA and MD) require 24 PDH, but up to 12 PDH can be carried over from the previous year. This approach is much more in line with the concept of "continuous" education.

I also believe that part of PDH should include training on the specific VA regulations as they apply to PE's. I think  the citizens of VA should have better assurance that a VA regulant is fully familiar with VA requirements.

I hope that DPOR intends this as a "first step" and will continue to review and further conform its PDH requirements to be leaders, rather than followers.