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.