I am opposed to the Licensure Regulations for School Personnel [8 VAC 20 -22}  proposed Engineering Endorsement and the Regulations Governing the Review and Approval of Education Program [8 VAC 20 -542] proposed Engineering program.  The proposed engineering endorsement duplicates content that has long-been covered and continues to be a part of technology education.   Virginia is a national leader in secondary engineering education since the Technology Education Service created the first high school engineering courses in 1988.  If the goal of the proposed engineering endorsement is to get more students to enter engineering, then, by definition that is Career and Technical Education.  Such a program already exist in technology education and duplication of endorsements are not needed.  Engineers already have an avenue to Virginia licensure thorough technology education (reference 8VAC20-23-270 Career and Technical Education--technology education], as well as, through the Career Switcher program, or through a provisional licensure program.  Engineering is an integral part of Virginia's technology education program.  This statewide program is improved thorough existing channels such as the curriculum revision schedule and the DACUM panels used annually by the Department of Education's Office of Career and Technical Education.  To have a separate engineering endorsement and an engineering program, are clearly a duplication of services.  During a time of continued budget constraints at the local school division, funding a separate engineering program is a waste of valuable resources, when engineering concepts are already in place within the technology education curriculum.  Senate Resolution 308 passed in 2011 specified engineering education within Virginia is the shared responsibilities of science, technology, and mathematics and not the silo approach to STEM as  proposed by the separate engineering endorsement.  An engineering endorsement is already in place through technology education and engineer programs and concepts are already in place through the technology education curriculum.