Recommendation:

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

Justification:

(A) Proposed changes to PE requirements and table subdivisions are not in alignment with NCEES Models, 18VAC10-20-160 engineering "Definitions" and proposed changes to 18VAC10-20-191, EIT designation and registration.

(B) Proposed changes have deleted a clear, crucial requirement for all initial PE applicants to take and pass the NCEES Principles and Practice of Engineering (PE) exam on the applicant's engineering discipline and professional body of knowledge. Adoption and use of NCEES Model text provides alignment of Virginia PE 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). There is inherent risk to the Commonwealth's health, safety and welfare by the Board's proposed review and PE licensure of applicants without standardized NCEES PE examination and results.

(C) Provide an objective statement as follows - "All applicants seeking initial licensure as a Virginia professional engineer shall take and pass (a) the NCEES Fundamentals of Engineering (FE) examination and (b) the NCEES Principles and Practice of Engineering (PE) examination in accordance with 18VAC10-20-191 and this subsection."

(D) Provide an objective statement as follows - "All PE applicants shall complete and pass the Board's examination on the Code of Virginia, application of local laws, and the Board's rules and regulations in accordance with 18VAC10-20-85."

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

(F) Subdivisions 1, 3, 4 & 5; This requirement is incomplete and conflicts. Revise to align with NCEES Models, 18VAC10-20-191 (Subdivisions 1,2,4,5) and 18VAC10-20-160. Revise table to address the following PE applicants -

Appvd. ABET-acc'd enrg. BS/BE degree / Pass FE exam - YES / Pass PE exam - YES / Years of P. Exp. - 4.
Appvd. Non-ABET, acc'd enrg. BS/BE degree / Pass FE exam - YES / Pass PE exam - YES / Years of P. Exp. - 6.

Appvd. ABET-acc'd enrg. BET degree / Pass FE exam - YES / Pass PE exam - YES / Years of P. Exp. - 6.
Appvd. Non-ABET, acc'd enrg. BET degree / Pass FE exam - YES / Pass PE exam - YES / Years of P. Exp. - 6.

Appvd. non-acc'd enrg. BS/BE/BET degree / Pass FE exam - YES / Pass PE exam - YES / Years of P. Exp. - 6.
Appvd. acc'd related BS degree / Pass FE exam - YES / Pass PE exam - YES / Years of P. Exp. - 6.
Appvd. non-acc'd related BS degree / Pass FE exam - YES / Pass PE exam - YES / Years of P. Exp. - 10.

Appvd. enrg. BS/BE/BET degree / Pass FE exam - NO / Pass PE exam - YES / Years of P. Exp. - 20.
Appvd. related BS degree / Pass FE exam - NO / Pass PE exam - YES / Years of P. Exp. - 20.

(G) Subdivision 2; This requirement is incomplete and conflicts. Revise to align with NCEES Models, 18VAC10-20-191 (Subdivision 3) and 18VAC10-20-160. Revise table to address the following PE applicants -

Appvd. ABET-acc'd enrg. BS/BE degree / Appvd. ABET-acc'd enrg. MS/ME degree / Pass FE exam - YES / Pass PE exam - YES / Years of P.Exp. - 3.
Appvd. ABET-acc'd enrg. BS/BE degree / Appvd. Non-ABET, acc'd enrg. MS/ME degree / Pass FE exam - YES / Pass PE exam - YES / Years of P.Exp. - 4.
Appvd. Non-ABET, acc'd enrg. BS/BE degree / Appvd. Non-ABET, acc'd enrg. MS/ME degree / Pass FE exam - YES / Pass PE exam - YES / Years of P.Exp. - 4.
Appvd. ABET-acc'd enrg. BET degree / Appvd. ABET-acc'd enrg. MS/ME degree / Pass FE exam - YES / Pass PE exam - YES / Years of P.Exp. - 5.
Appvd. Non-ABET, acc'd enrg. BET degree / Appvd. ABET-acc'd enrg. MS/ME degree / Pass FE exam - YES / Pass PE exam - YES / Years of P.Exp. - 6.

Appvd. ABET-acc'd enrg. BS/BE degree / Appvd. ABET-acc'd enrg. earned doctoral degree / Pass FE exam - YES / Pass PE exam - YES / Years of P.Exp. - 2.
Appvd. ABET-acc'd enrg. BS/BE degree / Appvd. ABET-acc'd enrg. earned doctoral degree / Pass FE exam - NO / Pass PE exam - YES / Years of P.Exp. - 4.
Appvd. ABET-acc'd enrg. BS/BE degree / Appvd. Non-ABET, acc'd enrg. earned doctoral degree / Pass FE exam - YES / Pass PE exam - YES / Years of P.Exp. - 4.
Appvd. Non-ABET, acc'd enrg. BS/BE degree / Appvd. Non-ABET, acc'd enrg. earned doctoral degree / Pass FE exam - YES / Pass PE exam - YES / Years of P.Exp. - 4.

(H) Subdivision 4; 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 four-year degrees and NCEES examination. Revise to strike this subdivision.
(I) The Board and Staff application review workload will significantly increase due to the proposed PE licensure of non-degreed applicants, and continued use of non-ABET accredited and unaccredited engineering programs, colleges and institutions.