As someone who has held a PE license for 34 years, and a VA PE license for 23 years, overall I am in favor of the proposed changes. I am "grandfathered" from many of the new provisions; however, I am commenting as a member of the PE profession with a view to the long-term health of the PE practice.

The fact that some fees are going up, while not pleasant, is to be expected and is in line with what other jurisdictions have been doing. VA increases are quite modest in comparison with other jurisdictions.

As I read the specific changes, it looks to me that the intent to clarify and simplify the language while maintaining the basic intent has been met.

However, if the intent of DPOR is to be more in line with other jurisdictions and model laws (e.g., NCEES CPC) as it relates to continuous education requirements, then there is still a lot of work to do. For example, VA's requirement for 16 PDH for PE's is low compared to most jurisdictions that have imposed the requirement (I think it is ~34 so far) - 16 compared to 24 to 32. Also, VA does not allow any carryover PDH's from one license period to the next. The PE regulant requires a minimum of 16 PDH in the prescribed categories for each two year license term. Other nearby jurisdictions (e.g., PA and MD) require 24 PDH, but up to 12 PDH can be carried over from the previous year. This approach is much more in line with the concept of "continuous" education.

I also believe that part of PDH should include training on the specific VA regulations as they apply to PE's. I think  the citizens of VA should have better assurance that a VA regulant is fully familiar with VA requirements.

I hope that DPOR intends this as a "first step" and will continue to review and further conform its PDH requirements to be leaders, rather than followers.

I believe that increasing the requirements for references, and instituting a time frame places an unreasonable requirement on applicants.

Civil engineers make up a large majority of both examinees and licensees.  From my experience and what I've seen on message boards, engineers, who are anything other than Civil Engineers, have a hard time finding any PE references to begin with. 

With the new Computer Engineering examination and licence, it will be nearly impossible for Computer Engineers to find any references. 

Do references have any legal liability of the referred person's failures?  No, they don't. I propose to eliminate requirements of PE references completely, and optionally, replace them with a background check. 

-130 and -220 do not specify any legal reason for providing references other than to "demonstrate the applicants competence and integrity".  Competence requirements should be met by the degree, passing of the FE, passing the PE, and integrity by a background check.

At a miniumum, I believe that Engineers and Architects should be able to be references for each other, in particular since the work often overlaps, and legally, each one can do a portion of the others work.

1.  I am not sure why the board doesn't allow one of the references to validate experience.  It appears rather unseemly to have to trawl for references if one has to use your supervisor to verify experienec in order to sit for the exam, versus using the supervisor as one of the references.

2.  It is appreciated that the Board does not invent Virginia specific classes so popular in other states.  Requiring classes such as a hypothetical "Ethics for Virginia Engineers" are self serving to local training vendors only.  The regulations drafted are very clear and need nothing to further explain their meaning.

Comments:  Within this section “in writing” should be included in all notification requirements because the issues are too important not to document.   “Entity and Entities” should be added to this section because a regulant may construe that a person did not pay them for the same services because the additional compensation was from a business entity.

A. The regulant shall promptly and fully inform an employer or client of any business association, interest, or circumstance which may influence the professional's regulant's judgment or the quality of service.

Recommendation – add “in writing”.  The regulant, in writing, shall promptly and fully inform an employer or client of any business association, interest, or circumstance which may influence the professional's regulant's judgment or the quality of service.

B. The regulant shall not accept compensation, financial or otherwise, from more than one party person for services on or pertaining to the same project, unless the circumstances are fully disclosed to, and agreed to in writing by, all interested parties in writing persons.

Recommendation – add “or entity” and “and entities”.  B. The regulant shall not accept compensation, financial or otherwise, from more than one party person or entity for services on or pertaining to the same project, unless the circumstances are fully disclosed to, and agreed to in writing by, all interested parties in writing persons and entities.

D. The regulant shall not solicit or accept gratuities, directly or indirectly, from contractors, their agents, or other parties persons dealing with a client or employer in connection with work for which the regulant is responsible.

Recommendation –  add “or entities”.  D. The regulant shall not solicit or accept gratuities, directly or indirectly, from contractors, their agents, or other parties persons or entities dealing with a client or employer in connection with work for which the regulant is responsible.

Comment:  The issue of self-determination of competency as the regulations have been written and are currently proposed places an undue burden on a review authority.  It seems regulants sometimes use a review authority to determine whether he or she is competent to practice a profession.  In other cases, it has been observed regulants use a review authority’s comments as a learning process to help educate him- or her-self on the requirements because he or she is not readily competent in the work submitted for review. 

As a result and all too often a regulant assumes because his or her plan was reviewed, commented on and/or approved by a review authority that it absolves him or her from any responsibility associated with the work not meeting the applicable technical regulations and standard of care.  Many time the phrase used by a regulant is “You (or you all) approved it.”   This mentality by regulants only serves to undermine the importance of licensure and perpetuate inappropriate perceptions of our professions by the public and review agencies.

It should be clear within the regulations that the review authority is not obligated or expected to determine whether a regulant is competent to practice a profession, a discipline within a profession, or work incidental to another profession.

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

Recommendation – add “sentence that compliments section 18VAC10-20-760”.  A. The professional regulant shall undertake to perform professional assignments only when qualified by education or, experience, or both, and licensed or certified in the profession involved.  Regardless of acceptance, reviews, comments, recordations or approvals from a review authority, the regulant continues to assume full responsibilities for the work on which his or her seal and signature are affixed and possessing the competency required for such work.   Licensed professionals Regulants may perform assignments related to interior design provided they do not hold themselves out as certified in this profession unless they are so certified by this board. The professional regulant may accept an assignment requiring education or experience outside of the field of the professional's regulant's competence, but only to the extent that services are restricted to those phases of the project in which the professional regulant is qualified. All other phases of such project shall be the responsibility of licensed or certified associates, consultants or employees.

18VAC10-20-10. Definitions.

Comments:  I recommend adding a definition for “work” such that it includes design, drawing, specifications, technical reports and documents, and other professional services.  This would help reduce confusion and uncertainty with certain sections of the regulations.   For example, section 18VAC10-20-740 uses “designs, drawings, specifications, or work”; whereas, section 18VAC10-20-760 uses final documents and includes an impromptu definition of documents to include plans, plats, documents, sketches, technical reports, and specifications.  Also, section 18VAC10-20-760 E. only references “work”, but in other sections “work” is distinguished as being separate from design, drawing, specifications, etc….

Recommendation – add a term “work” and update other sections to replace multiple terms with "work".  “Work” means any design, drawing, specification, technical report, document, plan, plat, survey, sketch, or other product that represent the practice of a profession.

Comments:  It seems there is duplication in terms “professional” and “regulant”, but also defined differences that may lead to confusion.    For example, a “professional” hold a license or certificate pursuant to the provisions of this chapter and in good standing; whereas, a regulant need only hold a valid license.   Is it the Board’s intention to have two similar terms, but with specific differences?  I recommend updating “regulant” and  removing “professional” from the definitions and sections because it adds confusion to have in some circumstances “professional” used as a standalone term and then in other sections to use the term “professional engineer”.

"Professional" means an architect, professional engineer, land surveyor, landscape architect, or interior designer who is licensed or certified, as appropriate, holds a valid license or certificate issued by the board pursuant to the provisions of this chapter and is in good standing with the board to practice his profession in this Commonwealth.

"Regulant" means a licensee, certificate holder or registrant an architect, professional engineer, land surveyor, or landscape architect holding a valid license issued by the board; an interior designer holding a valid certification issued by the board; or a registrant.

Recommendation – modify “Regulant” to include all the components of “Professional” and update sections within this chapter to only use “regulant”  Use the term “good standing” because it is defined as “a current or active license, certificate, or registration issued by a regulatory body that is not revoked, suspended, or surrendered.”

"Regulant" means an architect, professional engineer, land surveyor, landscape architect, or interior designer who is in good standing with the board to practice his profession in this Commonwealth.

Comments:  Move item 18VAC10-20-740 G.2 to 18VAC10-20-740 F.

D. A F. Except as authorized by 18VAC10-20-760 A 2, a regulant shall not utilize the design, drawings, specifications, or work of another regulant to complete the design, drawings, specifications, or work, or to replicate like design, drawings, specifications, or any work without the knowledge and written consent of the person or organization that owns the design, drawings, specifications, or work.

Recommendation – modify 18VAC10-20-740 F. to have two items by moving an item from G.

F. Permission to use another regulant’s work.

1. Except as authorized by 18VAC10-20-760 A 2, a regulant shall not utilize the design, drawings, specifications, or work of another regulant to complete the design, drawings, specifications, or work, or to replicate like design, drawings, specifications, or any work without the knowledge and written consent of the person or organization that owns the design, drawings, specifications, or work.

2. The information contained in recorded plats or surveys may be utilized by another regulant without permission.

Comment: Replace “discipline” with “profession”.

2. 3. The regulant has been found guilty by the board, or by a court of competent legal jurisdiction, of any material misrepresentation in the course of professional practice, or has been convicted, pleaded guilty or has been found guilty, regardless of adjudication or deferred adjudication, of any felony or misdemeanor which that, in the judgment of the board, adversely affects the regulant's ability to perform satisfactorily within the regulated discipline. Any plea of nolo contendere shall be considered a conviction for the purposes of this chapter. The board shall review the conviction pursuant to the provisions of § 54.1-204 of the Code of Virginia;

Recommendation – drop “regulated” because a profession by default is regulated.  Replace “discipline” with “profession” because disciplines are not defined as being regulated; instead, professions are regulated.

2. 3. The regulant has been found guilty by the board, or by a court of competent legal jurisdiction, of any material misrepresentation in the course of professional practice, or has been convicted, pleaded guilty or has been found guilty, regardless of adjudication or deferred adjudication, of any felony or misdemeanor which that, in the judgment of the board, adversely affects the regulant's ability to perform satisfactorily within the regulated profession. Any plea of nolo contendere shall be considered a conviction for the purposes of this chapter. The board shall review the conviction pursuant to the provisions of § 54.1-204 of the Code of Virginia;

Comment:  Include competency in the definition of “responsible person”.
"Responsible person" means the individual professional named by the entity registrant to be responsible and have control of the registrant's regulated services offered, or rendered, or both, by the entity. A professional can only be the responsible person for the professions indicated on his license or certification.

Recommendation – modify the definition of “Responsible person” by referencing competency.

"Responsible person" means the individual professional named by the entity registrant to be responsible and have control of the registrant's regulated services offered, or rendered, or both, by the entity. A professional can only be the responsible person for the professions indicated on his license or certification and the field or discipline within the profession for which he is competent.

 [“Field” is used in 18VAC10-20-730 and I have proposed using “discipline” in the additional comments submitted.  Consequently, I have proposed to include the terms “field” and “discipline” in the definitions.  See following comment.]

Comment:  Add terms “field” and “discipline” in the definitions.  Architecture, Engineering, Land Surveying, and Landscape Architecture are broad areas of practice that contain specialty areas.  In order to provide the minimal protection of public health, safety, and welfare, I feel it is important to require regulants to be competent in the overall profession and possess competency within the sub-areas in which they practice.   I think this concept is implied within the regulations, but it is not explicitly stated.  Therefore, I believe the regulations should include language that indicates to regulants that they must be competent in the work they perform – not just the profession.  For example, the discipline of engineering is extremely broad, and encompasses a range of more specialized fields of engineering, each with a more specific emphasis on particular areas of technology and types of application.  I do NOT think the Board needs to seek certification or licensure for areas, sub-areas, or disciplines because I think this should be left up to the professional – self-policing.   My intention to modify the regulations is to allow the Board to have a means to better regulate our profession in the event a regulant practices an area, sub-area, or discipline in which the regulant was clearly not competent to practice and by doing so jeopardize the public health, safety, and welfare.  In addition, if unaddressed then a regulant would perpetuate a perception to the public that professionals are neither trustworthy nor are they interested in looking out for the public.

Recommendation – add two terms to the definition..

"Field" means an area or sub-area within a profession that typically requires additional, specific knowledge and experience beyond the experience and education required to become licensed as a profession.

"Discipline" means an area or sub-area within a profession that typically requires additional, specific knowledge and experience beyond the experience and education required to become licensed as a profession.

Comment:    Recommend using another term other than “firm” or defining “firm”.  Who designates the resident, responsible person?  Paragraph A states that it is the regulant who maintains a place of business is responsible to name at least one responsible person; however, paragraph B states that a resident, responsible person is to be designated by the firm. 

Location and place of business are used interchangeably.  I recommend using “location” instead of “place of business”.

Also, the proposed regulations place the burden of signing and sealing ALL documents on the resident, responsible person.  Instead allow multiple regulants within this location to sign and seal documents so long as they are in direct control and personal supervision in accordance with 18VAC10-20-760. This would force a business (firm) to designate every PE, Architect, LS, LSA that is in direct control and personal supervision of the work produced in a given location.  This could be 1, 10, 50, 100, etc… regulants who need to be designated to the Board.

A. Any legal entity or professional regulant maintaining a place of business from which the entity or professional that offers or provides practices architectural, engineering, land surveying, landscape architectural, or certified interior design services in Virginia, shall name at least one responsible person for each profession offered or practiced at each place of business a resident, responsible person. The named resident, responsible person must hold a current valid Virginia license or certificate in the profession being offered or practiced.

Each named professional B. A resident responsible person designated by the firm shall exercise direct control and personal supervision of the work being offered or practiced at the each place of business for which he is named. Each named professional shall be responsible for only one location at a time. A named professional A resident responsible person may be responsible for more than one location provided that he is resident at the each place of business during a majority of the its operating hours of operation at each location.

Recommendation – Modify A and B to remove “services”.  Change B to reduce the burden of having the designated person responsible for ALL work produced at a given location.

A. Any legal entity or professional regulant maintaining a place of business from which the entity or professional that offers or provides practices architecture, engineering, land surveying, landscape architecture, or certified interior design in Virginia, shall name at least one resident, responsible person for each profession offered or practiced at each location a resident, responsible person. The named resident, responsible person must hold a current valid Virginia license or certificate in the profession being offered or practiced.   

Each named professional B. A resident, responsible person designated by the firm shall ensure the work being offered or practiced at each location place is being performed under the direct control and personal supervision of a regulant who is minimally competent in the profession practiced. A resident responsible person may be responsible for more than one location provided that he is resident at the each location during a majority of the its operating hours of operation at each location.

18VAC10-20-780. Professional required at each place of business.  (Option 2, preferred)

Comment:    Option 2 is preferred over Option 1.  Recommend using another term other than “firm” or defining “firm”.  Who designates the resident, responsible person?  Paragraph A states that it is the regulant who maintains a place of business is responsible to name at least one responsible person; however, paragraph B states that a resident, responsible person is to be designated by the firm.  Requiring the “regulant” to name a responsible person is ambiguous because which regulant is required to designate another regulant.   Make this a senior officer in the firm/entity or the title used on the business registration.  Another option would be to clarify that “regulant maintaining a place of business” shall mean the person who signs the DPOR business registration form.

I feel it needs to be clear that a regulant needs to be minimal competent in the profession and discipline being offered or practiced.  Virginia does not distinguish disciplines within a profession.  I am supportive of this concept because there are numerous disciplines within a profession, and there is overlap within these disciplines.  For example, a civil engineer may also be a water resources engineer, a structural engineer, an electrical engineer etc…  The reason for adding a discipline is to better ensure  to the public that not only is the appropriate profession resident at the location, but the specific discipline also has a competent person.  For example, if a business is offering mechanical engineering services, then the CEO must designate a professional engineer who is competent in mechanical engineering.  I do NOT think this area or discipline needs to be listed on a form or website, but it allows the Board to better regulate professions in the event someone is not minimally competent within the area/discipline.]

Physical Address, location, and place of business are used interchangeably.  I recommend using a single term to improve the meaning.  I recommend using “location” so that you don’t have someone working remotely without supervision.

The proposed wording states the designated person shall exercise direct control and personal supervision of the work being offered or practiced at that location.  This requires the person listed to be the regulant who signs and seals the work as indicated in section 18VAC10-20-760.  Many firms would be required to send documentation to the Board weekly if each and every person who is signing and sealing work is required to be listed.  The proposed regulations place the burden of signing and sealing ALL documents on the resident, responsible person.  This would force a business (firm) to designate every PE, Architect, LS, LSA that is in direct control and personal supervision of the work produced in a given location.  This could be 1, 10, 50, 100, etc… regulants who need to be designated. 

The recommended language places a responsibility on the resident, responsible person to ensure he or she has minimally competent regulants working in that location.  If someone then wants to see more information about who signed/sealed the document, then the person can check the regulant’s individual license information.  This would allow multiple regulants within this location to sign and seal documents so long as they are in direct control and personal supervision in accordance with 18VAC10-20-760.

A. Any legal entity or professional regulant maintaining a place of business from which the entity or professional that offers or provides practices architectural, engineering, land surveying, landscape architectural, or certified interior design services in Virginia, shall name at least one responsible person for each profession offered or practiced at each place of business a resident, responsible person. The named resident, responsible person must hold a current valid Virginia license or certificate in the profession being offered or practiced.

Each named professional B. A resident responsible person designated by the firm shall exercise direct control and personal supervision of the work being offered or practiced at the each place of business for which he is named. Each named professional shall be responsible for only one location at a time. A named professional A resident responsible person may be responsible for more than one location provided that he is resident at the each place of business during a majority of the its operating hours of operation at each location.

Recommendation – replace A and B with the following and add C.

1. For each physical address or location and for every discipline offered or practiced there shall be at least one designated resident, responsible person who is also competent in the discipline offered.  It shall be the chief executive officer’s or similar position’s responsibility to designate to the board at least one resident, responsible person for each profession and discipline offered or practiced at this physical address or location. 

2. A resident, responsible person, as designated by the chief executive officer or similar position, shall ensure the work being offered or practiced at each location is being performed under the direct control and personal supervision of a regulant who is minimally competent in the profession and discipline practiced.

3. A resident responsible person may be responsible for more than one location provided that he is resident at the each place of business during a majority of the its operating hours of operation at each location.

Comments:  Within this section, it would appear that a cover sheet may not need to be signed and sealed if no professional had assumed responsibility for the entire project.  It appears a statement needs to be included.  Also, should professional and professionals be changed to regulant and regulants, respectively?

B.2. For projects involving multiple sets of plans from multiple professionals involved in the same project, each professional shall seal, sign, and date the final documents for the work component that he completed or that was completed under his direct control and personal supervision. Any professional responsible for the entire project shall seal, sign, and date the cover sheet of the aggregate collection of final documents for the project.

Recommendation – add “a sentence that at least one professional shall be responsible for the entire project”.   Change "professional(s)" to "regulant(s)".

B.2. For projects involving multiple sets of plans from multiple professionals regulants involved in the same project, each professional regulant shall seal, sign, and date the final documents for the work component that he completed or that was completed under his direct control and personal supervision. The professional regulant responsible for the entire project shall seal, sign, and date the cover sheet of the aggregate collection of final documents for the project.  All projects shall have a minimum of one regulant responsible for the entire project.  This regulant(s) shall also be responsible for assembling the final documents (work) and ensuring compliance with the regulations.  When a regulant affixes his seal, pursuant to 18VAC10-20-760 A, to the cover sheet of the final documents (work), he shall assume responsibility for all work shown in the final documents (work) for which no other seal has been affixed.

Comments: I agree the regulant should assume full responsibility for any changes or modifications to the work.  The proposed language adds clarity; however, there is still some ambiguity in the language that should be clarified.  I am now unsure if the regulant is responsible for the “existing” work or ONLY responsible for any changes or modifications? 

Assuming the changes are made to 18VAC10-20-740 F to add proposed G.2 as a F.2., I feel there are two situations involving section 18VAC10-20-740 G.: (i) utilization of work that has not been signed and sealed and (ii) utilization of work that has been signed and sealed

Situation (i): Utilization of unsealed work created under the direction of another regulant.

Situation (i) represents a case in which the original regulant may be unavailable to complete the work; therefore, a “second” regulant utilizes the designs, drawings, specifications, or work of another regulant to complete the project.  In this case, the “second” regulant shall assume full responsibility for all work to which his or her seal is affixed. 

Situation (ii): Utilization of sealed work created by another regulant.   

Situation (ii) represents a case in which the original regulant has completed a work.  The client or others have decided to build on the work of the previous professional.  If a client wants to add a deck to a structure, then “new” regulant should not need to redo all the calculations.  In this case the “new” regulant should be responsible for his/her work, any “previous” work relied on which his/her work relied, and the impacts and effects his/her work will have on the work of the previous regulant.   Requiring the “new” regulant to redo everything does not protect the public welfare; instead, it adds an unnecessary expense.  The “existing” information if shown on the plan should be represented in a manner that is readily visible to a reviewer or client.  For example, this representation may be gray scale line work, cloud, or some other method.  Sometimes an existing design has been constructed and the most efficient and effective means for renovating the structure is to utilize existing drawings.  For example, a business owner wishes to install a new heating system in an existing building.   As opposed to generating a new survey of the interior of the building space.  The professional would secure written permission, pursuant to 18VAC10-20-740 F, and add his or her ductwork, heat exchangers, etc…  Instead of being responsible for the informational items shown on the plan, I feel the mechanical engineer should only be responsible for his/her work and those components of the existing design utilized by his/her work.  The mechanical engineer would only need to review and be responsible for the structural components and electrical components impacted by the HVAC system.  The mechanical engineer would then be able to show other existing features on his or her drawing for the construction documents so as to facilitate constructing the new HVAC system.   Another example would be adding a pump to pump-house.  The civil or mechanical engineer may show the building, roof, and other components of the structure to assist in the installation of the pump; however, I don’t believe the engineer should be expected or responsible for portions shown on his/her plans that were not relied on for the current work.  The civil or mechanical engineer should not be responsible for this other work shown on the plan unless the pump relies on some component of these existing conditions.  If the civil or mechanical engineer were to install a pump that will be hung from the roof, then the civil or mechanical engineer should verify that the roof structure is designed to carry the additional loading.

G. Utilization and modification of work.

1. A regulant who utilizes the designs, drawings, specifications, or work of another regulant pursuant to 18VAC10-20-740 F.1 or 18VAC10-20-760 A.2, or who modifies any plats or surveys, shall conduct a thorough review of the work to verify that it has been accomplished to the same extent that would have been done under the direct control and personal supervision of the regulant affixing the professional seal, signature, and date. The regulant shall assume full responsibility for any changes or modifications to the work.

Recommendation - create two items under Section G as discussed above and listed below.  This is the preferred method of establishing 18VAC10-20-740 G. 

G. Utilization and modification of work.

1. A regulant who utilizes unsealed designs, drawings, specifications, or incomplete work of another regulant pursuant to 18VAC10-20-740 F.1 or 18VAC10-20-760 A.2, shall conduct a thorough review of the work to verify that it has been accomplished to the same extent that would have been done under the direct control and personal supervision of the regulant affixing the professional seal, signature, and date. Pursuant to 18VAC10-20-760 A, the application of the seal, signature, and date shall indicate the regulant’s acceptance of responsibility for all the work, including any changes or modifications to the work, shown thereon.  [Drop professional from in front of seal.]

2. A regulant who utilizes the sealed, signed, and dated work of another regulant pursuant to 18VAC10-20-740 F.1 shall conduct a thorough review of the work impacted or affected by the regulant’s proposed work and any work upon which his design shall rely.  The review shall be conducted in a manner to verify that impacted and affected work of the other regulant has been accomplished to the same extent that would have been done under the direct control and personal supervision of the regulant affixing the professional seal, signature, and date.   An exception to 18VAC10-20-760 A, shall apply in this situation such that the application of the seal, signature, and date shall indicate the regulant’s acceptance of responsibility for the changes and modifications to the work, those portions of the previous work relied on to design the changes and modifications, and those portions of the previous work affected and impacted by the changes or modifications.  A note shall be placed on the work and near the seal that states, “Per 18VAC10-20-740 G.2, the regulant’s seal shown on this work is responsible for the changes and modifications, those portions of the previous work on which the proposed design relied, and those portions affected or impacted by the changes and modifications.”  Work shown, but not affected, impacted, or relied on shall be represented in a manner that is evident to the reviewer and client.

I agree with the comments submitted by Mr. Craig Moore, P.E. regarding various sections of the APELSCIDLA Regulations and the proposed changes thereto. The sections are listed below. The changes proposed by Mr. Moore will improve the clarity and content of the Regulations and render the Regulations more usable by regulants and the public alike. I applaud Mr. Moore for the significant effort and time he has obviously expended, based on the breadth and depth of his comments, reviewing the proposed changes to the APELSIDLA Regulations.   

18VAC10-20-10

18VAC10-20-710

18VAC10-20-730

18VAC10-20-740.F

18VAC10-20-740.G

18VAC10-20-760

18VAC10-20-780

18VAC10-20-790