Recommendation:

Adopt and follow NCEES current Model Law and Model Rules text as drafted and issued by the NCEES. Return the revised draft to AG's office for review.

Justification:

(A) Proposed changes of the objective "shall" to the subjective "will" and "must" significantly weakens the Commonwealth's PE licensing requirements, allows the Board to further lower acceptance criteria (on a case-by-case review basis) and will break legal protections for health, safety, and welfare of the Commonwealth.

(B) NCEES model text provides alignment of Virginia requirements with other jurisdictions that have adopted and use NCEES exams, records and models. NCEES model requirements simplifies Board review of applicants for Virginia PE licensure by endorsement. NCEES model requirements simplify the review and acceptance of Virginia's licensed PE's for licensure by other jurisdictions (reciprocity).

(C) The Board and Staff application review workload will significantly increase due to the proposed use of subjective or vague requirements.

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