Having been a Professional Engineeer for some 45 years I comment only with regard to the practice of engineering. As a professional I feel it is my responsibility to maintain a current awareness of engineering tools and techniques and I have endeavored to do so. However, I realize there are those who speak of "finishing my education" when they get a bachelors degree in engineering. Thus a mandatory program is necessary. Such a program is likely to be resisted by engineers who have been in practice for many years, but we are the ones who need it most. With regard to the cost, 16 hours of continuing education every two years is only one day a year. That is a minimum effort to stay abreast of changes and advances in engineering. Even a small practice should be able to make such an investment in order to stay competitive. My biggest concern about the proposed regulation is who offers the training, is the content relevant and timely and who certifies the value of the training to the practicing engineer. Some groups see a business opportunity to offer "continuing education" that is of limited value. I do not believe that faculty of engineering colleges are necessarily the best to offer continuing education. 

I have been a licensed professional engineer in the Commonwealth of Virginia for 11 years.  Obtaining my license was the high point of my engineering career, especially since PEs are relatively uncommon in my field (chemical engineering).  However, I am also an active duty military officer (Coast Guard) and my employer neither funds nor provides professional engineering education.  Since the Coast Guard does not generally require its engineers to hold PE licenses, this situation is very unlikely to change.  Many of the courses approved for continuing engineering education in states such as New York and Texas are relatively expensive and could easily cost $1,100 - $1,500 per year.  This is especially true for chemical and mechanical engineers, where the course offerings are much less varied and more expensive than for the civils.  I do not believe that I could afford these costs on a military salary.   The Coast Guard does not allow its members to use Tuition Assistance funds for courses that provide CEUs or PDHs either.

 

A military career requires frequent moves, often to sites remote from universities or professional training centers.  While I am in Virginia currently, I expect to receive orders to another state in June.  I may be able to become active in the professional engineering society in my new state, but there is no guarantee of that.

 

Prior to coming on active duty, I worked as a chemical engineer for a major defense contractor in Northern Virginia.  That firm also did not fund or facilitate professional engineering training, since Federal Government contracts are tightly managed and this type of training is not considered an allowable charge or normal overhead.  I suspect that most Government contractor employees in Northern Virginia would report the same situation.

 

Given the large number of military, Federal, and Federal contractor engineers working and registered in Virginia, the Board should carefully consider all of its options and select a system that will minimize the out-of-pocket costs to registrants and afford them the maximum flexibility in time and location.

As an EIT and soon to be PE, I am concerned with the lack of opportunities for continuing education that are available in my area.  I am also concerned with the way "continuing education" could be interpreted.  The legal mandate for this policy is far too vague to figure out what will be considered to be continuing education and whether or not it will be readily accessible to all individuals seeking recertification.  Many professionals in Virgina do not live close to universities and technical schools which would provide the classic forms of continuing education.  The "professional development" that many other professional organizations require is satisfied by local chapters of the organizations which offer regular lectures meetings in their local areas that qualify for their mandated professional development hours.  Again, many professionals in Virginia do not live near strong NSPE chapters who hold regular professional development opportunities.

I do not oppose this new regulation, I in fact feel it is important for all professionals to remain current with latest developments, I just caution the way this mandate is implemented to ensure that it is not too difficult for professionals in Virginia to satisfy these requirements.  I also feel that it is important to broaden the traditional scope of "continuing education" to something beyond classical university courses.

The Notice Summary of Significant Changes in Virginia Board for Architects, Professional Engineers, Land Surveyors, Certified Interior Designers and Landscape Architects Regulations clearly states it is the responsibility of the regulant of the board to be up to date with the latest changes to DPOR regulations.  It appears by the amount of responses nearing the end of the comment period this is not the case.  Certainly more than four professional engineers, including myself, in the state of Virginia have a vested interest of the continued educational mandate.  The lack of response is probably the result of the DPOR’s latest policy enacted February 1, 2007 not to mail regulation changes.  If the Board were sincere in obtaining honest feedback for this mandate all board regulants would have been notified by mail.

 

I am not an advocate for or against without knowing the arguments that lead to this mandate.  My first impression was the General Assembly of Virginia is seeking a way to increase revenue to state colleges and universities.  Be that as it may, as a practicing mechanical engineer I can offer the Board how this mandate will affect me.  Working for a government contractor, my position does not require a professional engineer license nor does the company encourage or reimburse the expenditures of individuals obtaining and maintaining such a license.  I expect the “continuing education mandate” to be an out of pocket expenditure since my company only provides reimbursement for company approved class courses.  My busy family lifestyle with my very young children does not afford me time away to attend class courses.  If I could manage time away for class and travel I’d have to endure the burden of child care expenses.  I foresee a drop in license renewals for those individuals in similar positions as myself.  If the Board were at all interested a survey of regulants with job positions requiring a professional license can provide an estimated drop in license renewals.  For my sake and disappointment, it does not make monetary sense to maintain a professional license as a result of this mandate.

With respect to Virginia’s exemptions to the requirements, I urge the board to allow local, state and federal governments to lead the way by not exempting regulants employed by these agencies.  Any regulation that furthers a perception that governments are above the law is flawed.  Exemptions or time extensions are appropriate for regulants who are service members deployed overseas and perhaps for those stationed outside the Commonwealth. These exemptions or extensions may even be obligatory under the “Soldiers and Sailors Relief Act”.  Exemptions for others, including government employees, who elect to spend extended periods outside Virginia or the United States, are not appropriate.

Jan Harris, PE
Virginia Beach, VA

It is a given that the board must adopt some continuing education regulations.  I have been meeting continuing education requirements in several states and have found only one of these states to have requirements that are difficult to meet: New York.  New York’s requirement that providers of Continuing Education Units or Professional Development Hours be members of one of several registries makes it difficult for nonresident regulants to meet the requirements, forcing them to attend seminars provided by national trade associations or national professional societies. Many excellent professional development opportunities are provided within Virginia by organizations such as the local branches of the American Society of Civil Engineers and the Virginia Structural Engineers Council.  The Virginia Engineers Conference, an annual event of late, by the Virginia Society or Professional Engineers and the American Council of Engineering Companies (Virginia) is another example.  These seminars often do not qualify for continuing education credit in New York as the providers are not registered with that jurisdiction. I understand other states have similar requirements but New York is the one I know.  North Carolina and West Virginia’s requirements are relatively simple and leave the screening of providers and course content primarily to the regulant.

Jan Harris, PE
Virginia Beach, VA

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