Dear Members of the APELSCIDLA Board,

I appreciate the opportunity to comment on the proposed revisions to 18VAC10?20?270, Licensure by Endorsement. I respectfully urge the Board to reconsider the current proposed language and adopt a more clearly defined, public safety centric endorsement pathway consistent with the regulatory rigor necessary to protect the Commonwealth’s public health, safety, and welfare.

1. Opposition to International Endorsement
I oppose the inclusion of “international endorsement” mechanisms within Section 270 as currently proposed. The International Engineering Alliance (IEA) and similar bodies operate without U.S. regulatory oversight, and their standards, evaluation processes, and disciplinary mechanisms are not aligned with the expectations and legal frameworks governing engineering practice in the United States. Without consistent oversight, the Commonwealth cannot ensure that foreign?licensed individuals meet the minimum competency and ethical requirements essential to safeguarding the public.

2. Support for a Revised, U.S.–Based Endorsement Pathway
In contrast, the National Council of Examiners for Engineering and Surveying (NCEES) provides a long?standing, uniform, accredited, and nationally recognized system for verifying education, experience, examination, and professional standing. The NCEES Records Program and Model Law Engineer (MLE) standards are specifically designed to facilitate safe, consistent licensure mobility across all U.S. jurisdictions. These systems offer the Board reliable, verifiable evidence that an applicant meets or exceeds Virginia’s licensure standards.

For these reasons, I support the following rewrite of 18VAC10?20?270, which eliminates international endorsement and clarifies eligibility for applicants licensed within the United States:

Proposed Rewrite: 18VAC10?20?270 Licensure by Endorsement

A. General
An applicant currently licensed as a professional engineer in another state, territory, or jurisdiction of the United States may be granted licensure by endorsement in the Commonwealth of Virginia, provided the applicant demonstrates that he or she meets or exceeds the qualifications required for licensure in Virginia at the time the application is submitted.

B. Eligibility
To be eligible for licensure by endorsement, an applicant shall:

1. Hold a valid, active professional engineer license issued by another U.S. jurisdiction and be in good standing in all jurisdictions in which the applicant is licensed;
2. Have satisfied education, language, examination, and experience requirements that meet or exceed those required for licensure in Virginia, as determined by the board;
3. Have successfully passed the Principles and Practice of Engineering examination, or another examination deemed substantially equivalent by the Board;
4. Submit verification of licensure, education, experience, and examination results in a format prescribed by the Board; and
5. Meet all other applicable requirements of this chapter.

C. NCEES Records and Model Law Engineer
The Board shall accept and give substantial weight to a complete NCEES Council Record, including recognition as a Model Law Engineer, as evidence that the applicant meets the requirements of this section. The Board may rely on such records to streamline the review and approval of endorsement applications.

D. Applicants Not Meeting Endorsement Requirements
Applicants who do not meet the requirements of this section may apply for licensure through the requirements for initial licensure in effect at the time the application is submitted.

3. Rationale for the Proposed Rewrite
This revised structure:
• Ensures all endorsed licensees have met verifiable, consistent U.S. standards;
• Removes ambiguity and risk associated with international credentialing bodies lacking U.S. oversight;
• Aligns Virginia’s process with trusted national licensure frameworks;
• Protects the Commonwealth’s citizens, environment, and infrastructure by maintaining a high and uniform professional standard; and
• Supports efficient licensure mobility across all U.S. jurisdictions through the NCEES Records Program.

Conclusion
Safeguarding the public requires clear, consistent, and enforceable licensure standards. Restricting endorsement pathways to those vetted through U.S. regulatory systems — and relying on NCEES Records and Model Law criteria — best aligns with that mission. I respectfully request that the Board adopt the proposed rewrite of 18VAC10?20?270 to ensure that Virginia’s licensing standards continue to uphold the life, health, safety, and welfare of the public.

Thank you for your consideration.

Craig Moore