Dear DPOR Regulatory Review Board,

Home inspectors serve a vital role not only during a real estate transaction, but also in the future lives of their clients and other community stakeholders.  The initial financial impacts from home inspection findings can be substantial for buyers and sellers.  Additionally, the long-term consequences of a home inspection affect a client’s financial, emotional, and physical wellbeing.  Unreported defects can morph into expensive future surprises for the new homeowner.  A simple roof leak may cause water damage, leading to mold growth and negatively impacting the health of occupants.  Financial strain and health problems can be emotionally distressing.

Home inspectors are oftentimes coming in behind architects, engineers, builders, tradesmen, and other skilled professionals to give their stamp of approval regarding the safety, function, and adequacy of a home’s structure and systems.  We are evaluating the work of other professions and occupations that require substantially more education and training before one is considered qualified to execute their respective services.  For example, licensed architects and engineers must hold four-year degrees in their professions.  A typical path towards a master tradesmen’s license will involve five years of education and experience.

This leads me to a confounding question:  How is it that DPOR has determined that a home inspector is adequately educated and trained with the proposed licensing requirements?  Depending on the path chosen, one could satisfy these requirements with about one month’s worth of education and experience.  DPOR will consider an individual sufficiently qualified to inspect complex structures constructed by other licensed, experienced, or otherwise qualified professionals after just one month of learning and doing.  Let that sink in.

Perhaps there is an underestimation of the knowledge that a home inspector must have in order to show up to any house prepared to perform a home inspection according to Virginia’s Standards of Practice.  Considering that our English ancestors first settled here in the early 1600’s, we have several centuries worth of structures scattered throughout the state.  There is about 400 years’ worth of carpentry in our framing systems, from the early earthfast mortised and tenoned timber frames to today’s engineered lumber products, such as LVL and I-joists.  One may be fortunate enough to come upon a surviving “Virginia home” comprised of clapboard siding and roofing, while modern houses might use fiber cement, vinyl, and masonry veneer siding and asphalt shingle roofing.  There are two centuries of plumbing systems ranging from clay and cast iron to today’s PE, PEX, CPVC, PVC, copper, and more.  100-year-old knob and tube electrical systems are still present in some houses, while there are modern systems where houses have more complex needs and protections than ever before, such as GFCI and AFCI.  Mechanical systems have transformed from hydronic radiant heating paired with an oil-fired boiler to energy efficient heat pumps and fresh air ventilation systems to complement today’s air tight construction.  Proper application of building science requires understanding how all of these systems interact with each other to influence the performance of a building’s thermal envelope and energy usage.  Home inspectors need knowledge of all of those systems and everything in between.

Tradesmen spend many years, if not their entire careers, mastering their craft in just one of the aforementioned areas and often become selective in working with certain materials and systems most familiar to them.  How is it conceivable that someone with no background whatsoever in construction, engineering, or trades can learn centuries worth of building systems and materials in one month?  While it may hold true in the long run that only the competent home inspectors will survive in the free market, our current system recklessly dispatches unsuspecting consumers as guinea pigs to weed out the low hanging fruit.  Imagine the absurdity of applying the same approach for licensing medical doctors.  State-mandated licensing brings with it a burden of responsibility that DPOR now bears to set a standard that does not allow incompetent persons to compete in a marketplace where consumers falsely believe that any licensed home inspector can adequately help them make one of the biggest decisions of their lives.

But don’t take my word for it.  Ask other stakeholders in the local real estate industry.  Amateur home inspectors are a headache for everyone.  Poorly performed or reported inspection findings lead to confusion for all parties involved and avoidable poor outcomes.  If an inadequately trained home inspector fails to report a significant defect on a house, then their client will suffer the consequences for it later.  Meanwhile, a standard home inspection contract will only promise that client a refund of the fee that they paid.  A typical home inspection fee is in the hundreds, whereas home repairs can easily be in the thousands.

If a home inspector misrepresents a problem or states that there is a problem that does not exist, the clients may back out of the purchase or ask the seller to repair or give a credit.  This is unfair to buyers and sellers who are both economically impacted by the outcome of a home inspection.  Additionally, real estate agents invest significant resources into guiding their clients through a home sale or purchase.  Most of them work on a commission that is contingent upon the sale, so they are left empty-handed when a transaction falls apart after the home inspection.  Sometimes this is just the nature of the beast, however, it should not happen due to a misinformed home inspector publishing an inaccurate report.

Builders hold tremendous responsibility and risk in the development and construction of new housing.  Most builders take pride in delivering what they believe is a quality product for their customers.  However, where there are many hands involved, mistakes will happen.  A home inspector can add value to this process as a quality check for the builder that is paid for by the client.  However, a home inspector that lacks sufficient knowledge will report items that are not actually a problem, leaving the builder the displeasure of defending their work and hoping their client believes them.  Even worse, the home inspector might miss things that actually are a problem.

County-employed building inspectors wind up fielding questions and concerns over home inspection findings too, where they need to correct or clarify a home inspector’s report, taking time away from their other responsibilities and leaving taxpayers with the bill.  Home inspectors incorrectly citing the Uniform Statewide Building Code was so problematic that we have lost the discretion to do so.  Rather than to raise the standard for licensing, DPOR settled for the lowest common denominator by diminishing the professional autonomy of all home inspectors.  What is particularly concerning is that DPOR is moving further down this path by prohibiting home inspectors from advising their clients about engaging in a real estate contract or providing an opinion of value.  While I believe that either of these actions is almost always bad practice, there certainly could be rare situations where it is appropriate and the inspector is qualified to offer advice in these areas.

Instead of any further professional restrictions, I believe that is both necessary and prudent to substantially increase the eligibility qualifications for a home inspector license in Virginia.  By raising the bar on the minimum standards that our state will accept, we improve the outcomes of homeownership for consumers and for all other stakeholders.  I propose two paths to a home inspector career:

• The first is a traditional path of apprenticeship.  This path requires 240 hours of formal education and four years of practical experience under the supervision of a Licensed Home Inspector.

• The second is an entrepreneurial path for the ambitious.  This path requires the completion of a two-year degreed curriculum offered by a local community college.  Ten mock inspections where the condition of the subject properties has already been evaluated by the examiner must be performed by the graduate at a sufficient level to demonstrate field competency in a variety of house settings.

These paths in tandem will still allow for competition and fair opportunity for new entrants, but weed out amateurs that will cause harm to consumers.  Further restricting the supply of home inspectors will inevitably lead to increased prices for consumers, all else equal.  However, it is important to weigh this increased upfront cost with the long-term cost of allowing unqualified persons into the profession.  Consumers are better served paying more for their home inspections when they can count on a reasonable standard of competency from any of the available market options.  Additionally, higher prices will attract more talent, leading to greater value delivered to the consumer.

This is a great profession.  I love waking up every day to go see new places, meet new clients, learn new things, and look out for my community.  Others should have the opportunity to participate, as well, and I do not wish to close the door behind me.  Oftentimes, formerly licensed professionals are grandfathered in when new standards are set, which is an unfair disadvantage to newcomers.  As a testament to my conviction, I will also complete 240 hours of formal education and ten graded mock inspections side-by-side with other aspiring home inspectors upon the adoption of these standards.  All currently licensed home inspectors should meet this standard within two years of implementation to ensure a level playing field and consistent professionalism for consumers.

Sincerely,

Dylan Morgan