Action | General Regulatory Reduction Initiative |
Stage | Proposed |
Comment Period | Ended on 12/20/2024 |
As a fellow Virginian and the Global President & CEO of CEDIA, the association for Smart Home Professionals, thank you for the opportunity to submit written comments to encourage an amendment for the “Electronic/communication service contracting” (ESC) definition within 18VAC50-22-30. Definitions of specialty services.
On October 21, 2024, the Department of Professional and Occupational Regulation posted proposed changes to regulations by the Board for Contractors. These proposed regulation changes included proposed changes to the “Electronic/communication service contracting” definition.
The current definition and proposed definition for “Electronic/communication service contracting” are limiting and do not fully support the many different technologies Smart Home Professionals or Technology Integrators support now and in the future with the ESC license throughout Virginia.
Virginia has a vibrant quality of life throughout the Commonwealth. Limited-energy systems installed and integrated by Smart Home Professionals contribute to maintaining this high quality of life for Virginians through technology systems for communication, monitoring and maintaining a healthy lifestyle, entertaining, and connecting with family and friends. Technology benefits our lifestyles by making our lives more comfortable, productive, and enjoyable.
CEDIA represents hundreds of Smart Home Professionals or Technology Integrators with bona fide qualifications and years of experience in this specialized, ever-changing, and technology-driven field who work throughout Virginia and whose work is covered by the ESC license.
Critical Work of Smart Home Professionals
Smart Home Professionals or Technology Integrators are a critical part of Virginia’s workforce and support its current and future technological needs and infrastructure. This critical workforce is projected to grow faster than other occupations as people become more dependent on technology and its benefits throughout the home and in the workplace.
The need for Smart Home Professionals or Technology Integrators will grow with the continued convergence and interdependence of many emerging technologies and limited-energy systems.
It is vital the ESC license and its scope of work definition is updated to support the critical work of Smart Home Professionals or Technology Integrators now and in the future.
CEDIA Education, Training, and Certification
Smart Home Professionals go through extensive training to support a growing number of technologies and services throughout Virginia.
One of CEDIA’s pillars is education and as the association for Smart Home Professionals, we develop training and resources to share knowledge and raise the bar on smart home integration best practices.
CEDIA Education and Training supports Smart Home Professionals at every stage of their smart home technology career.
Smart Home Professional Certification
In addition to education and training, CEDIA offers four credentials that demonstrate competence in the knowledge and skills necessary to deliver outstanding technology systems.
Smart Home Certifications for the smart home technology industry include:
The Importance of Limited-Energy Systems
The home is now a complex technological system with many interrelated limited-energy systems. These limited-energy systems are safe and work together to allow homeowners to embrace and benefit from a connected home. The National Electrical Code®, published by the National Fire Protection Association, is the foundation of the electrical and limited-energy installation regulatory infrastructure for the United States. The National Electrical Code® is revised every three years to meet modern technology and industry needs.
As technology has evolved more technology systems, limited-energy systems, and applications depend on Class 2 and Class 3 power-limited circuits for solutions used in residential and commercial projects. For these many reasons it is important the ESC license definition references Class 2 and Class 3 power-limited circuits as defined by the National Electrical Code®.
Important Licensing Language Supporting Smart Home Professionals
As a state Virginia is a leader for the technology industry and is also considered one of the safest states in the United States. Limited-energy systems support these goals for Virginia, and it is why it is vital Virginia has forward-looking licensing language to support current and future technology solutions and encourage technology adoption throughout the state.
Forward-looking licensing language for the ESC license will support current and future Smart Home Professionals and the growing smart-home technology industry.
A crucial step to support current and future technology innovation and encourage technology adoption throughout Virginia is to properly update the definition for “Electronic/communication service contracting”. The current and proposed definition for “Electronic/communication service contracting” uses a limited list of a few technologies along with a 50-volt reference. Using a limited list and a 50-volt reference restricts current and future technology innovation and the scope of work covered by the ESC license.
The proper way to support Smart Technology Professionals or Technology Integrators whose work is covered by the ESC license is to reference Class 2 and Class 3 power-limited circuits as defined by the National Electrical Code® in the scope of work for the ESC license. This makes a proper distinction between the work of Smart Technology Professionals or Technology Integrators using the ESC license and Electrical Contractors using the ELE license.
The proposed amendment below would not restrict the small businesses of Virginia-based Smart Home Professionals or Technology Integrators while also supporting numerous technology solutions utilizing limited-energy systems on projects throughout Virginia.
Proposed Amendment updating the “Electronic/communication service contracting” (ESC) definition.
18VAC50-22-30. Definitions of specialty services.
“Electronic/communication service contracting” (Abbr. ESC) means the service that provides for the design, installation, repair, improvement, alteration, or removal of Class 2 and Class 3 power-limited circuits and systems as defined by the National Electrical Code. electronic or communications systems annexed to real property including telephone wiring, computer cabling, sound systems, data links, data and network installation, television and cable TV wiring, and fiber optics installation, all of which or other systems that operate at 50 volts or less. A firm holding an ESC license is responsible for meeting all applicable tradesman licensure standards. The ELE classification also provides for the function.
Adopting the proposed amendment for the “Electronic/communication service contracting (ESC) definition will support the critical work of Smart Home Professionals or Technology Integrators while aligning their work to the National Electrical Code® revision cycle and recognize the distinction between limited-energy systems work (ESC) and electrical work (ELE).
Smart Home Professionals are critical to Virginia’s growth in technology solutions. CEDIA looks forward to working with the Department of Professional and Occupational Regulation and its staff on this important licensing issue. Together we can ensure Virginia maintains its position as a technology leader. Thank you for your time and consideration on this critical issue.
Respectfully submitted,
Daryl Friedman
Global President & CEO
CEDIA
800.669.5329