The proposed rewrite of Section 18VAC10-20-270 to ease comity for individuals who have not obtained licensure through the normal rigorous process is unwarranted and will compromise the health, safety, and welfare of the public.  The proposed alternative standard to establish equivalent qualifications (i.e., International Engineering Alliance) will allow less qualified individuals to potentially obtain a license.  The long-established and highly regarded NCEES credentialing service is sufficient and serving well.  Adding another standard of suspect equivalency is not protecting the public.  International individuals already have a path to obtain comity that maintains high standards.

VSPE has suggested reasonable changes in wording that should be adopted.