While I fully support the intent to expand access to the profession, a review of the proposed regulatory text alongside the draft Architect License Application (A416-0401LIC-v5) reveals a critical administrative gap for relocated and/or out-of-state architects applying by endorsement.  I urge the Board to address how the current endorsement pathways inadvertently create an immense and unnecessary barrier for architects who utilized an alternative pathway in another jurisdiction.

Currently, the draft Architect License Application outlines only two strict methods for endorsement: applying by endorsement with an NCARB Certificate Record (Blue Cover) and applying by endorsement without an NCARB Certificate Record.  This binary approach completely ignores the actual documentation status of the very workforce this regulation targets.  Architects who obtained their license in another state via an alternative education pathway typically do not qualify for an NCARB Certificate (Blue Cover).  However, these professionals almost universally maintain a standard NCARB Record (Brown Cover).

The critical issue is that a standard NCARB Record is not empty; it already contains the applicant's verified AXP hours, official examination records, and certified proof of current state licensure.  Despite having this centralized, NCARB-verified data, the application forces these individuals into the "without NCARB Certificate" category.  This categorization requires them to manually track down supervisors from years or decades ago to sign individual Experience Verification Forms, clear individual Degree Verification Forms, and request separate Verification of Examination and Licensure Forms from every single jurisdiction they hold a license in.  This completely undermines the efficiency of having an NCARB Record and creates a punitive administrative bottleneck for experienced, licensed professionals.

Therefore, I strongly recommend that the Board edit the wording of the endorsement options or add a specific third option: "Applying by Endorsement with an NCARB Record (Brown Cover)."  This would allow the Board to accept the centralized, verified data within a standard NCARB Record to satisfy documentation requirements without forcing licensed peers to duplicate their verification efforts manually.

Additionally, as a secondary note related to these existing out-of-state architects, the Board needs to clarify the "direct supervision" requirement.  The proposed amendment states all work experience must be gained under the direct supervision of a licensed architect.  However, licensed architects applying by endorsement often practice independently or are self-employed, meaning they cannot legally or logically work under another architect's direct supervision.  While the application references a Client Experience Verification Form for self-employment, the regulatory text itself remains rigidly tied to direct supervision.  The Board should explicitly amend the regulation to recognize legal, independent practice by a licensed architect in another jurisdiction as qualifying experience under the 10-year threshold.