Add the text shown in bold below to provide clarity. The table should be directly referred to in the text, so that all the other requirements of the table (besides those mentioned in this paragraph) are invoked. 

18VAC10-20-191 Requirements for an engineer-in-training designation

Applicants must apply directly with NCEES to take the Fundamentals of Engineering (FE) exam and meet the requirements in Table XX. An applicant qualified under subdivision 1, 2, or 3 of this section will receive the engineer-in training (EIT) designation upon passing the FE exam and verification of the applicant's degree by the board. All other applicants will receive the EIT designation upon passing the FE exam. The EIT designation will remain valid indefinitely.

Gender neutral terms are appreciated... change himself to themself as shown below.

18VAC10-20-730 Competency for assignments

A. The professional shall must undertake to perform professional assignments only when qualified by education or experience, or both, and licensed or certified in the profession involved. Licensed professionals may perform assignments related to interior design, provided they do not hold themselves out the professional does represent himself themself as certified in this the profession unless they are so the professional is certified by this the board. The professional may accept an assignment requiring education or experience outside of the field of the professional's competence, but only to the extent that services are restricted to those phases of the project in for which the professional is qualified. All other phases of such project shall must be the responsibility of licensed or certified associates, consultants, or employees.

I recommend that elimination of business entity registration- 18VAC 10-20-327.  With the licensing of individual professionals there is no enhancement to public safety provided by the registration of business entities.  Many businesses that provide design work are not required to register:  "pre-engineered" metal building systems building suppliers, wood and light gauge metal truss suppliers, precast concrete product suppliers, fiberglass framing suppliers all typically provide engineering services in the course of their work but are apparently not required to register as business entities.  Since these businesses are not required to register it makes little sense registering any businesses.

B. Applicants shall not have had a must report notify the board, in writing, of any disciplinary action related to the profession, including any suspended, revoked, or surrendered license, certificate, or registration to practice architecture, engineering, land surveying, landscape architecture, or interior design that was suspended, revoked, or surrendered in connection with a disciplinary action or have been the subject of a disciplinary action in any jurisdiction in accordance with 18VAC10-20-785.

Suggest modifying language to follow Section 18VAC10-20-785.

Delete: “report”   

Add: “…notify the board, in writing, of any…”

Add: “…in accordance with 18VAC10-20-785.”

Under Item B.7 Teaching, I recommend adding the following:

For teaching experience to be considered qualifying by the board, the applicant shall must have taught in an engineering program approved by the board and shall must have been employed in fulltime at the level of instructor or higher. 

Agree with 8/11/25 comment on 18VAC10-20-730

18VAC10-20-730 Competency for assignments

A. The professional shall must undertake to perform professional assignments only when qualified by education or experience, or both, and licensed or certified in the profession involved. Licensed professionals may perform assignments related to interior design, provided they do not hold themselves out the professional does represent himself  themself as certified in this the profession unless they are so the professional is certified by this the board. The professional may accept an assignment requiring education or experience outside of the field of the professional's competence, but only to the extent that services are restricted to those phases of the project in for which the professional is qualified. All other phases of such project shall must be the responsibility of licensed or certified associates, consultants, or employees.

Suggest modifying language to follow Section 18VAC10-20-730.  "He" has been removed from six (6) locations within the proposed regulations.  I agree with the previous comment to change "himself" to "themself".  Based on the Merriam-Webster Dictionary (online version), the use of "themself" in this situation appears appropriate.

Replace: “himself”   

With: “themself”

Under 18VAC10-20-160 Definitions:

"Related science program" means a four-year program in biology, chemistry, geology, geophysics, mathematics, physics, or other programs approved by the board. Programs must have a minimum of six semester hours of mathematics courses beyond algebra and trigonometry and a minimum of six semester hours of science courses in calculus-based physics in order to be considered a related science program.

I teach at a Virginia community college in the CET courses and they are not all calculus based so why would we require that of a “related science program”? This may preclude some highly qualified potential engineers already working in the field from achieving a PE license just based on the program they completed at the time many years prior.

I am in favor of the proposed changes to the EIT/PE licensure requirements, with one request for clarification:

In 18VAC10-20-160 Definitions, strike “calculus-based” from the definition of “related science program.” The vast majority of the “related science” programs mentioned in the definition require physics courses that are not calculus-based. For the qualification under the “related science program” to be a relevant avenue to PE licensure, the requirement should just be for six semester hours of physics. A lack of calculus-based physics classes should not disqualify someone with a related science program degree (with six semester hours of non-calculus-based physics) who can pass the FE exam and has the number of required years of qualifying engineering experience. Many CET degrees that qualify someone for PE licensure do not require calculus-based physics; it would be inconsistent to require calculus-based physics for one qualifying degree and not for another under the same number of required years of qualifying engineering experience under 18VAC10-20-210. 

Under 18VAC10-20-160 Definitions:

"Related science program" means a four-year program in biology, chemistry, geology, geophysics, mathematics, physics, or other programs approved by the board. Programs must have a minimum of six semester hours of mathematics courses beyond algebra and trigonometry and a minimum of six semester hours of science courses in calculus-based physics in order to be considered a related science program.

As a Virginia licensed Professional Engineer I fully support this change with one revision:

Under 18VAC10-20-160 Definitions:

"Related science program" means a four-year program in biology, chemistry, geology, geophysics, mathematics, physics, or other programs approved by the board. Programs must have a minimum of six semester hours of mathematics courses beyond algebra and trigonometry and a minimum of six semester hours of science courses in calculus-based physics in order to be considered a related science program.

Most of these related science programs do not include calculus based physics, so those classes would have to be taken separate from the "program", and it does not appear the language allows for that.  I do not see where the calculus based physics requirement makes the person more qualified if they can pass both exams and have the required on the job experience, which is far more valuable than a classroom environment as recognized by DPOR in the form of the work experience requirement.