Fwd: Comments for the PE Board  
Tuesday, October 12, 2021 3:57:44 PM  
Comments to PE Board.doc  
From: James McLaughlin <>  
Sent: Tuesday, October 12, 2021 3:40 PM  
To: BPL-BoardSupport  
Subject: Comments for the PE Board  
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Dear Board Support: Please provide the Professional Engineering Board with the  
accompanying letter.  
Thank you, James C. Mc Laughlin  
James C. Mc Laughlin  
Associate University Counsel  
Emeritus Professor of Electrical Engineering  
Kettering University  
Department of Licensing and Regulatory Affairs  
Bureau of Professional Licensing - Boards & Committees Section  
P.O. Box 30670  
Lansing, MI 48909-8170  
Attention: Policy Analyst  
In regards to: Proposed revisions to the Professional Engineering rules - MOAHR 2021-020LR  
1. Background: The undersigned and other Professional Engineers who practice in academia  
(ABET accredited universities); or perform engineering research; or practice professional  
engineering in fields such as electrical, chemical, or air/nautical engineering, have found the  
current CE rules not to be alined with the way CE is actually performed. Augmented CE rules  
have been advocated to correspond to how such Professional Engineers effect CE..  
2. Proposed new Rule 41(1)(j): The PE Board is commended for proposing this new rule as the  
new rule reflects a part of what many Professional Engineers routinely do as part of their CE.  
However, truncating credit at four hours per renewal period is woefully inadequate to effect the  
goal of CE found in Rule 1(1)(c)  
3. Proposed Rule 41(1)(k) and Rule 41(1)(e): Receiving a Patent from the PTO requires  
significant expense, long periods of time/effort; and satisfying a novelty and obviousness  
requirement far in excess of that required by Rule 41(1)(e). Ten hours seems quite an inadequate  
credit for overcoming such barriers. Mindful of the CE aspects of a utility patent application, the  
Board should include publication of a utility patent application by the PTO in the list of  
publications in Rule 41(1)(e).  
4. Provision should be made within Rule 41 for CE credit for engineering faculty at ABET  
universities who work with engineering students in research involved in crafting a thesis as part  
of an ABET engineering program. Inherently, this sort of mentoring accrues CE to the faculty  
member and has nothing to do with job description.  
The Board is thanked for their continuing consideration of the expensive CE requirement, and  
having the requirement be inclusive of engineers across all areas of professional practice, and to  
promote and support continuing education and professional competence to include how many  
Professional Engineers perform CE.  
James C. MCLaughlin; P.E., J.D.  
Associate University Counsel  
Kettering University  
October 12, 2021