I'd like to advocate for a strong review of the time bounding that's part of the experience requirement for architects. There is currently a 36 month experience requirement that is out of date with contemporary practice and unaligned with the national standard. Experience should be mandated based on quality not time, meaning, experience requirements should illustrate the tasks, knowledge, and skills needed. Who's to say how long that experience should take? Different roles, firms, and building types all teach at different paces. In some positions 36 months is too much, in some maybe not enough - it's too variable. This is why this requirement should be stricken in favor of the national standard, the Architect Experience Program via NCARB.

Regulation 18VAC10-20-120. Experience, Paragraph B. should be stricken.

The Commonwealth's regulation requiring a duration of 36 months of experience for applicants for licensure as an architect has no valid data to support any concept that development of competency is achieved through seat time performing work tasksfor 3 years.  The regulatory requirement to complete NCARB's Architectural Experience Program® (AXP®) should stand alone.  The AXP (formerly the IDP) defines the competency necessary for a newly licensed architect to practice architecture independently - to protect the public's health, safety, and welfare.  Individuals develop competency in different areas at different speeds.  Spending more time and/or repetitive activity does not make one more competent...it's just more time and more repetition.

The proposed regulation further requires the 36 months be completed under the supervision of an architect, only. This regulation is in conflict with the requirements of the AXP, which recognizes that valuable, valid experience for an architect can be gained in other [limited] work settings.  This conflict may require Virginia licensure candidates to complete more years of work prior to becoming eligible for licensure as an architect. 

Further, the duration requirement of 36 months is inconsistent with national standards.  The proposed regulation is more restrictive, as Virginia is currently 1 of under 10 states who still carry a duration requirement.

Restrictive requirements over and above nationally recognized standards do not protect Virginians; rather they restrict and limit the opportunities for Virginians who seek to become an to protect the public through licensed practice.  We have three excellent schools of architecture.  Graduates will continue to look for opportunities in other states that support the national standards and program requirements to become an architect.

Please strike paragraph B of proposed Regulation 18VAC10-20-120 in its entirity!

Virginia should take this opportunity to align itself with NCARB.  Experience requirements should be based on the quality and content of said experience.  The AXP program, which is vetted thoroughly through NCARB's practice analysis, successfully accomplishes this objective.  As such, a 36-month rule seems like an additional hurdle to architectural licensure that has no bearing on the health, safety, and welfare of the general public.  The focus should be on quality of experience versus time duration of experience.

On behalf of the National Council of Architectural Review Boards (NCARB), I am writing in response to your request that NCARB provide comments to the proposed changes to the current Administrative Rules and Regulations for Virginia’s Board of Architects, Professional Engineers, Land Surveyors, Certified Interior Designers and Landscape Architects (APELSCIDLA).

We would like to thank the board for their proactive approach to being effective regulators by proposing these changes. We support of many of the updates, including the removal of references to the Intern Development Program, inclusion of the integrated pathway to licensure (IPAL) option, and the mutual recognition agreements. However, there are opportunities to revise several of the proposed changes that would improve the licensure process for candidates and align Virginia’s rules and requirements with the national standards.

Specifically, we recommend that the Virginia board consider making the following changes to the proposed changes:

Qualifications for Licensing of Architects

18VAC10-20-110. Education.

Applicants for original licensure shall hold a professional degree in architecture from a program accredited by the National Architectural Accrediting Board (NAAB) or be actively participating in an integrated path accepted by the National Council of Architectural Registration Boards (NCARB) to architectural licensure option within a NAAB accredited professional degree program in architecture.  The degree program must have been accredited by NAAB no later than two years after the date of the applicant's graduation from the program.

Proposed update:

Applicants for original licensure shall hold a professional degree in architecture from a program accredited by the National Architectural Accrediting Board (NAAB) or be actively participating in an integrated path accepted by the National Council of Architectural Registration Boards (NCARB) to architectural licensure option within a NAAB accredited professional degree program in architecture.  The degree program must have been accredited by NAAB no later than two years after the date of the applicant's graduation from the program.

The IPAL option requires students be allowed to take the ARE while enrolled in school. We recommend that you move the language referencing IPAL and include it under the examination section.

18VAC10-20-120. Experience.

A. Applicants for original licensure shall successfully complete the National Council of Architectural Registration Boards (NCARB) Intern Development Program (IDP) IDP training requirements shall be in accordance with NCARB's Intern Development Program Guidelines, December 2013 Edition. administered architectural experience program.

B. Applicants must have a minimum of 36 months experience/training experience or training in architecture. Any experience/training of less than eight consecutive weeks will not be considered in satisfying this requirement, which shall be obtained in an organization offering architectural services that is led by a licensed architect in charge of the organization's architectural practice. The experience must be verified by a licensed architect in the organization's architectural practice on the board's experience verification form.

C. Of the 36 months of required experience/training in architecture, at least 12 months shall have been obtained as an employee in the office of a licensed architect. An organization will be considered to be an office of a licensed architect if:

1. The architectural practice of the organization in which the applicant works is under the charge of a person practicing as a principal, where a principal is a licensed architect in charge of an organization's architectural practice either alone or with other licensed architects, and the applicant works under the direct supervision of a licensed architect; and

2. The practice of the organization encompasses the comprehensive practice of architecture including the categories set forth in the NCARB IDP requirements.

D. C. Applicants with a NAAB-accredited degree or who are actively participating in or who have completed the NCARB-accepted integrated path to architectural licensure option are required to document their experience or training in architecture before licensure.

Proposed update:

Applicants for original licensure shall successfully complete the National Council of Architectural Registration Boards (NCARB) Intern Development Program (IDP) IDP training requirements shall be in accordance with NCARB's Intern Development Program Guidelines, December 2013 Edition. administered architectural experience program which satisfies the experience requirement outlined in section 18VAC10-20-35.

B. Applicants must have a minimum of 36 months experience/training experience or training in architecture. Any experience/training of less than eight consecutive weeks will not be considered in satisfying this requirement, which shall be obtained in an organization offering architectural services that is led by a licensed architect in charge of the organization's architectural practice. The experience must be verified by a licensed architect in the organization's architectural practice on the board's experience verification form.

C. Of the 36 months of required experience/training in architecture, at least 12 months shall have been obtained as an employee in the office of a licensed architect. An organization will be considered to be an office of a licensed architect if:

1. The architectural practice of the organization in which the applicant works is under the charge of a person practicing as a principal, where a principal is a licensed architect in charge of an organization's architectural practice either alone or with other licensed architects, and the applicant works under the direct supervision of a licensed architect; and

2. The practice of the organization encompasses the comprehensive practice of architecture including the categories set forth in the NCARB IDP requirements.

C. Applicants with a NAAB-accredited degree or who are actively participating in or who have completed the NCARB-accepted integrated path to architectural licensure option are required to document their experience or training in architecture before licensure.

The changes outlined above will ensure that Virginia meets the national uniform standards for experience. Virginia’s requirement that this experience be completed for a minimum of 36 months and only under the supervision of a licensed architect limits the valuable exposure to experience that can be gained in more diverse (but limited) work settings. By removing both the duration and supervision requirements, the Virginia board will streamline their licensure requirements and improve opportunities for architecture candidates in Virginia.

18VAC10-20-140. Examination.

A. The board is a member board of NCARB and is authorized to make available the NCARB-prepared exam. Applicants for original licensure are required to pass this exam.

B. Applications for original licensure shall be approved by the board before applicants will be allowed to sit for the exam. Applicants who have satisfied the requirements of 18VAC10-20-110 and 18VAC10-20-130 and who are currently enrolled in the NCARB IDP or have completed the NCARB-administered architectural experience program shall be admitted to the exam.

Proposed update:

B. Applications for original licensure shall be approved by the board before applicants will be allowed to sit for the exam. Applicants who have satisfied the requirements of 18VAC10-20-110 and 18VAC10-20-130 and who are currently enrolled in the NCARB IDP or have completed the NCARB-administered architectural experience program or be actively participating in an integrated path accept by NCARB to architectural licensure option with a NAAB-accredited professional degree program in architecture option shall be admitted to the exam.

I would like to thank you for allowing us to review and offer recommendations to the Board’s proposed changes to the Administrative Rules and Regulations.  Please do not hesitate to contact me or Nefertari Carver, Assistant Vice President for Volunteer Engagement (ncarver@ncarb.org) should you have any questions, comments, or concerns.

Sincerely,

Joshua C. Batkin

Vice President, Council Relations