I estimate the direct annual cost of a business providing continuing education to Virginia professional engineers under the West Virginia and North Carolina rules at $1,300 per engineer per year.  My estimate for a Virginia professional engineer complying with the New York rules is $2,500 per engineer per year.  Both estimates include an estimate of the engineer’s pay but do not include any associated overhead costs or the opportunity cost to a business losing two engineer-days of billable effort.  Including that cost would increase each estimate by at least $1,500 per engineer per year.  Obviously we must expect that the overhead rates of Virginia engineering companies and other agencies employing regulants will increase as a result of these requirements. 

I urge the board to adopt regulations along the lines of North Carolina or West Virginia: http://reports.oah.state.nc.us/ncac/title%2021%20-%20occupational%20licensing%20boards%20and%20commissions/chapter%2056%20-%20professional%20engineers%20and%20land%20surveyors/21%20ncac%2056%20.1703.html and http://www.wvpebd.org/continuing_ed.htm

The New York rules are summarized at  http://www.op.nysed.gov/peceques.htm; while I find them somewhat burdensome due to my living in Virginia rather than New York, they are not without merit.  New York did “phase in” the requirement nicely. New York emphasizes that continuing education is more for the purposes of improving technical skills and protecting the public than the purpose of enhancing profits.  

North Carolina allows regulants not resident in North Carolina to meet their home state continuing education requirements, if any exist.  If the home state has no continuing education requirements, the regulant must meet the North Carolina requirements. The board should adopt similar language.

Jan Harris, PE

Virginea Beach, VA