VSPE opposes the proposed language of section 18VAC10-20-270 Licensed by Endorsement, Section B, International Endorsement, that proposes to allow individuals holding a "valid license in a country that is a signatory to the mobility agreements of the International Engineering Alliance" to be given comity as a licensed PE in Virginia. The Memorandum with proposed language and our justification can be found here: VSPE Comments

As a practicing engineer in the Commonwealth for over 3 decades, I oppose the proposed language of section 18VAC10-20-270 Licensed by Endorsement, Section B, International Endorsement, and propose alternative language for this section as suggested by VSPE belos:

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 for
endorsement is submitted.

B. Eligibility.
To be eligible for licensure by endorsement, an applicant shall:
1. Hold a valid, active license as a professional engineer issued by another jurisdiction
of the United States and be in good standing in all jurisdictions in which the
applicant is licensed;
2. Have satisfied education, examination, and experience requirements that meet or
exceed the requirements for licensure as a professional engineer in Virginia, as
determined by the board;
3. Have successfully passed the Principles and Practice of Engineering examination or
an examination determined by the board to be substantially equivalent;
4. Submit verification of licensure, examination results, education, and experience in a
manner prescribed by the board; and
5. Satisfy 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 National Council of
Examiners for Engineering and Surveying (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.

The proposed rewrite of Section 18VAC10-20-270 to ease comity for individuals who have not obtained licensure through the normal rigorous process is unwarranted and will compromise the health, safety, and welfare of the public.  The proposed alternative standard to establish equivalent qualifications (i.e., International Engineering Alliance) will allow less qualified individuals to potentially obtain a license.  The long-established and highly regarded NCEES credentialing service is sufficient and serving well.  Adding another standard of suspect equivalency is not protecting the public.  International individuals already have a path to obtain comity that maintains high standards.

VSPE has suggested reasonable changes in wording that should be adopted.

The International Engineering Alliance has no mission to protect the life, safety, health, and welfare of the citizens of the Commonwealth of Virginia.  I oppose the proposed language which would lower existing protections for Virginia's citizens.

I oppose comity for engineers via licensure in International Engineering Alliance countries.

I support the recommended rewrite by the Virginia Society of Professional Engineers (VSPE).

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 for endorsement is submitted.

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

1. Hold a valid, active license as a professional engineer issued by another jurisdiction of the United States and be in good standing in all jurisdictions in which the applicant is licensed;
2. Have satisfied education, examination, and experience requirements that meet or exceed the requirements for licensure as a professional engineer in Virginia, as determined by the board;
3. Have successfully passed the Principles and Practice of Engineering examination or an examination determined by the board to be substantially equivalent;
4. Submit verification of licensure, examination results, education, and experience in a manner prescribed by the board; and
5. Satisfy 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 National Council of Examiners for Engineering and Surveying (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.

VSPE’s Justification: The rigors of the International Engineering Alliance are suspect and not governed by any US oversight; whereas VSPE has great confidence in NCEES Records and Model Law Engineer standards and practices. VSPE’s proposed re-write of Section 270 provides for a streamlined and well governed process to augment PE licensure across the US by eliminating International Endorsement and adding clear eligibility requirements to protect the life, health, safety, and welfare of the Commonwealth’s citizens, environment and infrastructure through support of the NCEES Records Program that is designed for currently licensed engineers and surveyors to complete the licensure process in multiple jurisdictions, including all 50 states, the District of Columbia, Guam, Puerto Rico, Northern Mariana Islands, and the U.S. Virgin Islands.

Lack of US oversight of international qualifications will only increase fraud and misuses of professional registration leading to unsafe work 

I oppose the proposed amendment to 18VAC10-20-270, Section B, which would allow individuals licensed in countries that are signatories to the International Engineering Alliance mobility agreements to receive comity as a Professional Engineer in Virginia.

The Commonwealth of Virginia licenses Professional Engineers to protect the life, safety, health, and welfare of its citizens. The International Engineering Alliance is not a U.S. regulatory body and has no obligation or oversight responsibility to protect Virginia residents. Granting licensure based primarily on international signatory status reduces Virginia’s independent verification of education, examination, experience, and ethical accountability under U.S. law.

Foreign licensure systems may operate under different standards and enforcement structures. Lowering independent review requirements increases the risk of credential misrepresentation, inconsistent technical standards, and misuse of professional registration. Engineering decisions directly impact critical infrastructure and public safety. Any change to licensure standards should strengthen public protections, not relax them.

I support the Virginia Society of Professional Engineers’ proposed rewrite, which maintains Virginia’s authority to independently evaluate qualifications before granting licensure.  Link to rewrite provided below:

https://fampo.gwregion.org/wp-content/uploads/2026/02/VSPE.Position.InternationalEndorsementMemo226.pdf

I oppose the proposed amendment to 18VAC10-20-270, Section B, which would allow individuals licensed in countries that are signatories to the International Engineering Alliance mobility agreements to receive comity as a Professional Engineer in Virginia.

The Commonwealth of Virginia licenses Professional Engineers to protect the life, safety, health, and welfare of its citizens. The International Engineering Alliance is not a U.S. regulatory body and has no obligation or oversight responsibility to protect Virginia residents. Granting licensure based primarily on international signatory status reduces Virginia’s independent verification of education, examination, experience, and ethical accountability under U.S. law.

Foreign licensure systems may operate under different standards and enforcement structures. Lowering independent review requirements increases the risk of credential misrepresentation, inconsistent technical standards, and misuse of professional registration. Engineering decisions directly impact critical infrastructure and public safety. Any change to licensure standards should strengthen public protections, not relax them.

I support the Virginia Society of Professional Engineers’ proposed rewrite, which maintains Virginia’s authority to independently evaluate qualifications before granting licensure.

I strongly oppose the endorsement of PE licensure through International Endorsement.  This will endanger Virginia citizens as foreign engineers will suffer no liability or any real consequences for engineering errors that may result in harm or death.  

I propose the following alternative language:

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 for endorsement is submitted.

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

1. Hold a valid, active license as a professional engineer issued by another jurisdiction of the United States and be in good standing in all jurisdictions in which the applicant is licensed;
2. Have satisfied education, examination, and experience requirements that meet or exceed the requirements for licensure as a professional engineer in Virginia, as determined by the board;
3. Have successfully passed the Principles and Practice of Engineering examination or an examination determined by the board to be substantially equivalent;
4. Submit verification of licensure, examination results, education, and experience in a manner prescribed by the board; and
5. Satisfy 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 National Council of Examiners for Engineering and Surveying (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.

I do not support the proposed language and would like to see it changed to the language being proposed by the Virginia Society of Professional Engineers linked below.

https://fampo.gwregion.org/wp-content/uploads/2026/02/VSPE.Position.InternationalEndorsementMemo226.pdf

I support the re-write of 18VAC10-20-270 Licensure by Endorsement proposed by VSPE that eliminates International Endorsement and proposes endorsement through the NCEES Records Program.

I concur with VSPE's position statement and proposed substitute language for 18VAC10-20-270 Licensure by Endorsement. Thank you for your consideration.

I concur with VSPE's recommendation to strike subsection B, International Endorsement, from the proposed changes to 18VAC10-20-270 that are currently out for public comment. I strongly oppose comity / endorsement of a Virginia PE license by any person "holding a license in a country that is a signatory to the mobility agreements of the International Engineering Alliance..."

I oppose the proposed revision that would allow endorsement through the International Engineering Alliance, as it raises concerns regarding consistency with existing standards.

I oppose adopting licensure by endorsement of individuals holding a license in a country that is signatory to the mobility agreements of the International Engineering Alliance.

I support the VSPE's justification for opposition of this proposed modification:

The rigors of the International Engineering Alliance are suspect and not governed by any US oversight; whereas VSPE has great confidence in NCEES Records and Model Law Engineer standards and practices. VSPE’s proposed re-write of Section 270 provides for a streamlined and well governed process to augment PE licensure across the US by eliminating International Endorsement and adding clear eligibility requirements to protect the life, health, safety, and welfare of the Commonwealth’s citizens, environment and infrastructure through support of the NCEES Records Program that is designed for currently licensed engineers and surveyors to complete the licensure process in multiple jurisdictions, including all 50 states, the District of Columbia, Guam, Puerto Rico, Northern Mariana Islands, and the U.S. Virgin Islands.

VSPE opposes the proposed language of section 18VAC10-20-270 Licensed by Endorsement, Section B, International Endorsement, and proposes alternative language for this section as follows:

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 for endorsement is submitted.

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

1. Hold a valid, active license as a professional engineer issued by another jurisdiction of the United States and be in good standing in all jurisdictions in which the applicant is licensed;
2. Have satisfied education, examination, and experience requirements that meet or exceed the requirements for licensure as a professional engineer in Virginia, as determined by the board;
3. Have successfully passed the Principles and Practice of Engineering examination or an examination determined by the board to be substantially equivalent;
4. Submit verification of licensure, examination results, education, and experience in a manner prescribed by the board; and
5. Satisfy 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 National Council of Examiners for Engineering and Surveying (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.

VSPE’s Justification: The rigors of the International Engineering Alliance are suspect and not governed by any US oversight; whereas VSPE has great confidence in NCEES Records and Model Law Engineer standards and practices. VSPE’s proposed re-write of Section 270 provides for a streamlined and well governed process to augment PE licensure across the US by eliminating International Endorsement and adding clear eligibility requirements to protect the life, health, safety, and welfare of the Commonwealth’s citizens, environment and infrastructure through support of the NCEES Records Program that is designed for currently licensed engineers and surveyors to complete the licensure process in multiple jurisdictions, including all 50 states, the District of Columbia, Guam, Puerto Rico, Northern Mariana Islands, and the U.S. Virgin Islands.

I support the re-write of 18VAC10-20-270 Licensure by Endorsement proposed by VSPE that eliminates International Endorsement and proposes endorsement through the NCEES Records Program.

I oppose the proposed language of section 18VAC10-20-270 for PE License by Endorsement, Section B, International Endorsement.  The rigors of the International Engineering Alliance are not governed by any US oversight and therefore may be suspect. 

I have held a NCEES Record for 20 years and personally know there is a high degree of confidence in NCEES Records and Model Law Engineer standards and practices.

Virginia Society of Professional Engineers has proposed new language for Section 270 that provides for a streamlined and well governed process to augment PE licensure across the US by eliminating International Endorsement and supporting the NCEES Records Program. 

The NCEES Records Program is needed to provide clear eligibility requirements to protect the life, health, safety, and welfare of the Commonwealth’s citizens, environment and infrastructure.  NCEES is designed and provided for currently licensed engineers and surveyors to complete the licensure process in multiple jurisdictions, including all 50 states, the District of Columbia, Guam, Puerto Rico, Northern Mariana Islands, and the U.S. Virgin Islands.

Please do not approve the amendment to the regulation that allows Professional Engineering licensure by International Endorsement. Thank you.  

The APELSCIDLA  Board and regulations exists to protect the public health, safety, and welfare.  Does elimination of §18VAC10-20-55 increase or decrease public health, safety, and welfare?

Repelling §18VAC10-20-55 increases the potential for more licensed professionals, but I am unsure that it increases the protection of public health, safety, and welfare.

I can appreciate the desire to be open to more professionals seeking to be licensed in Virginia.   However, the lack of a uniform language may result in unintended consequences.  Please consider your answers to the following before eliminating §18VAC10-20-55.

Will the board regulations and law be translated into understandable and comprehendible language for each person holding a Virginia License?

Will translators be present for board meetings and fact-finding conferences?

Will meeting minutes be translated into the understandable and comprehendible language of each person granted a Virginia License?

Will disciplinary cases be translated into the understandable and comprehendible language of each person granted a Virginia License?

Will translators be provided to regulants and investigators when investigating or refuting a disciplinary case?

Will a lack of understanding or comprehension of the language in which the APELSCIDLA  Board Regulations are provided be allowed as a defense against negligence or meeting the standard of care?

Will a lack of understanding or comprehension of language in which the state and/or locality’s building codes are provided be allowed as a defense against negligence or meeting the standard of care?

Ultimately, if §18VAC10-20-55 is repelled, will the APELSCIDLA  Board consider language (a lack of understanding or comprehension) as a reason NOT to discipline a regulant for failing to meet the requirements set forth in the APELSCIDLA  Board Regulations? 

If you answer "yes" to this last question, then please reconsider keeping or rewording this section to best ensure the protection of public health, safety, and welfare.

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

I've worked with many engineers who have come here from other countries and other states.  One thing that all of those transferred VA PEs have in common is that they went through the same comity process that ensures everyone meets the same standard for the good of the Commonwealth.  The international group considers all member-country engineering programs to be equivalent.  We know that requirements differ from state to state and that is why states have a comity process.  The international group can make decisions that negatively impact Virginians and Virginia will have little to no say in the process.  Let's not change the law to appease an international organization that does not have Virginia's interests as a primary responsibility.  The comity process is a legitimate way to welcome foreign engineers while ensuring that we have full control over the direction of our Commonwealth.  This proposed change is not needed nor welcome.

Recommendation:

Adopt and follow NCEES current Model Law and Model Rules text as drafted and issued by the NCEES. Return the revised draft to AG's office for review.

Justification:

(A) Proposed changes of the objective "shall" to the subjective "will" and "must" significantly weakens the Commonwealth's PE licensing requirements, allows the Board to further lower acceptance criteria (on a case-by-case review basis) and will break legal protections for health, safety, and welfare of the Commonwealth.

(B) NCEES model text provides alignment of Virginia 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).

(C) The Board and Staff application review workload will significantly increase due to the proposed use of subjective or vague requirements.

===

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.

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.

Recommendation:

[I endorse VSPE review comments, recommendations and justification on the Board's proposed changes to 18VAC10-20-270.]

"VSPE opposes the proposed language of section 18VAC10-20-270 Licensed by Endorsement, [Sub]section B, International Endorsement, and proposes alternative language for 18VAC10-20-270 as follows:

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 for endorsement is submitted.

B. Eligibility. To be eligible for licensure by endorsement, an applicant shall:
1. Hold a valid, active license as a professional engineer issued by another jurisdiction of the United States and be in good standing in all jurisdictions in which the applicant is licensed;
2. Have satisfied education, examination, and experience requirements that meet or exceed the requirements for licensure as a professional engineer in Virginia, as determined by the board;
3. Have successfully passed the Principles and Practice of Engineering examination or an examination determined by the board to be substantially equivalent;
4. Submit verification of licensure, examination results, education, and experience in a manner prescribed by the board; and
5. Satisfy 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 National Council of Examiners for Engineering and Surveying (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."

Justification:

VSPE - "The rigors of the International Engineering Alliance are suspect and not governed by any US oversight; whereas VSPE has great confidence in NCEES Records and Model Law Engineer standards and practices.

VSPE’s proposed re-write of Section 270 provides for a streamlined and well governed process to augment PE licensure across the US by eliminating International Endorsement and adding clear eligibility requirements to protect the life, health, safety, and welfare of the Commonwealth’s citizens, environment and infrastructure through support of the NCEES Records Program that is designed for currently licensed engineers and surveyors to complete the licensure process in multiple jurisdictions, including all 50 states, the District of Columbia, Guam, Puerto Rico, Northern Mariana Islands, and the U.S. Virgin Islands."