Recommendation:

Adopt and follow NCEES current Model Law and Model Rules text as drafted and issued by the NCEES.

Justification:

(A) Proposed changes to EIT requirements and table subdivisions are not in alignment with NCEES Models, 18VAC10-20-160 "Definitions" and proposed changes to 18VAC10-20-210 "Requirements for licensure as a professional engineer."

(B) Applicants with a graduate-level Master of Science or Master of Engineering degree are not specifically addressed.

(C) Subdivisions 2, 3 and 4; change the word "curriculum" to "program" (align with 18VAC10-20-160).

(D) Subdivision 4; This requirement is vague. "nonapproved engineering curriculum" / program is not defined in 18VAC10-20-160.

(E) Subdivision 5; NCEES Models require completion of a degree awarded by an ABET or non-ABET "accredited program." Non-degree EIT and PE applicants are not validated or qualified by the accredited USA colleges and institutions administering those programs. There is inherent risk to the Commonwealth by the Board's proposed review, EIT registration and PE licensure of applicants without qualified, earned, four-year, accredited BS/BE/BET degrees and NCEES examination. Revise to strike Subdivision 5.

(F) The proposed sentence "All other applicants will receive the EIT designation upon passing the FE exam." is misleading and not consistent with the prior sentence. Please revise to "An applicant qualified under subdivision 4 or 5 of this subsection shall receive the EIT designation upon passing the NCEES FE exam and verification of the applicant's qualified degree and work experience by the Board."

(G) The Board and Staff application review workload will significantly increase due to the proposed EIT registration of non-degreed applicants, and continued use of non-ABET accredited or unaccredited engineering programs, colleges and institutions.