December 19, 2024

Cameron Parris

Regulatory Operations Administrator

Department of Professional and Occupational Regulation

9960 Maryland Drive, Suite 400

Richmond, VA 23233

Re: Amendment for the “Electronic/communication service contracting” (ESC) definition (18VAC50-22-30. Definitions of specialty services)

Dear Ms. Parris:

On behalf of CEDIA, the association for Smart Home Professionals, thank you for the opportunity to submit written comments to encourage an amendment for the “Electronic/communication service contracting” (ESC) definition within 18VAC50-22-30. Definitions of specialty services.

On October 21, 2024, the Department of Professional and Occupational Regulation posted proposed changes to regulations by the Board for Contractors. These proposed regulation changes included proposed changes to the “Electronic/communication service contracting” definition.

The current definition and proposed definition for “Electronic/communication service contracting” are limiting and do not fully support the many different technologies Smart Home Professionals or Technology Integrators support now and in the future with an ESC license throughout Virginia.

CEDIA represents hundreds of Smart Home Professionals or Technology Integrators with bona fide qualifications and years of experience in this specialized, ever-changing, and technology-driven field whose work is covered by an ESC license in Virginia. They are technology experts and service providers of limited-energy systems for residential projects. They are adept in a wide range of disciplines including entertainment, networking, system control and integration, user interfaces, lighting, security, and audio video systems throughout the home. Technology Integrators need an “Electronic/communication service contracting (ESC) license for their work in various residential and commercial settings throughout Virginia.

Technology Integrators design, install, integrate, and support limited-energy systems using Class 2 and Class 3 power-limited circuits, communications circuits, optical fiber cables, emerging technologies, and alarm circuits, as defined by the National Electrical Code®. Class 2 and Class 3 circuits are classified as remote-control, signaling, and power-limited circuits in the National Electrical Code®. Examples of Class 2 power-limited circuits include Power over Ethernet (PoE), low-voltage lighting, security systems, and thermostats. A Class 3 circuit is primarily for low-power, remote control, signaling and communication applications for limited-energy systems like some home theater sound systems, commercial sound systems, nurse call systems, and security systems.

Critical work of Technology Integrators

Technology Integrators are a critical part of Virginia’s workforce and support its current and future technological needs and infrastructure. This critical workforce is projected to grow faster than other occupations as people become more dependent on technology and its benefits throughout the home and in the workplace. The need for Technology Integrators will grow with the continued convergence and interdependence of many emerging technologies and limited-energy systems.

The need for Technology Integrators will increase as consumer demand for connected devices on a secure network at home and in the workplace will significantly increase along with other emerging technologies and limited-energy systems. The importance of technology and how it securely supports our lifestyle allows for the critical work of Technology Integrators to support many different technologies and systems throughout homes and businesses. Technology trends like affordability, a growing number of emerging technologies and systems, the growing number of Internet of Things (IoT) devices, the growth of Artificial Intelligence (AI), and the importance of cybersecurity will all lead to the growing importance of the work and services of Technology Integrators to support the current and future needs of Virginians. For these many reasons, it is vital the ESC license and its scope of work definition is updated to support the critical work of Technology Integrators now and in the future.

Training for Technology Integrators

Technology Integrators are properly trained to provide a growing list of technologies and services throughout Virginia. Technology Integrators are properly trained in the numerous technologies they design, install, integrate, and support needing to stay updated with the latest technologies through ongoing education to properly install limited-energy systems many of which use Class 2 and Class 3 power-limited circuits throughout residential and commercial projects.

Safety of Limited-Energy Systems

The home is now a complex technological system with many interrelated limited-energy systems. These limited-energy systems are safe and work together to allow homeowners to embrace and benefit from a connected home. The National Electrical Code®, published by the National Fire Protection Association, protects the public by establishing requirements for electrical wiring and equipment in residential, commercial, and industrial buildings. The National Electrical Code® is the foundation of the electrical and limited-energy installation regulatory infrastructure for the United States. The National Electrical Code® is revised every three years to meet new technology and industry needs.

By their very nature, both Class 2 and Class 3 power-limited circuits are safe from fire ignition or arc-flash due to their power limitations. Class 2 power-limited circuits provide acceptable protection against shock and additional safeguards are required for Class 3 power-limited circuits to protect against the slight increase in the risk of shock for that circuit class. Class 2 and Class 3 Power-Limited Circuits are safe and meet all safety precautions are inherent to the requirements included in the National Electrical Code® and applicable product safety standards.

As technology has evolved more technology systems, limited-energy systems, and applications depend on Class 2 and Class 3 power-limited circuits for solutions used in residential and commercial projects. For these many reasons it is important the ESC license definition references Class 2 and Class 3 power-limited circuits as defined by the National Electrical Code®.

Important Regulatory Language Supporting Technology Integrators

Virginia is a top location for the tech sector in America with thousands of tech companies, industry leaders, and a large tech industry workforce.

It is vital Virginia has forward-looking licensing language to support current and future technology solutions and encourage technology adoption throughout the state.

An important step to support current and future technology innovation and encourage technology adoption throughout Virginia is to properly update the definition for “Electronic/communication service contracting”.  The current and proposed definition for “Electronic/communication service contracting” uses a limited list of a few technologies along with a 50-volt reference. Using a limited list and a 50-volt reference restricts current and future technology innovation and the scope of work covered by the ESC license.

The proper way to support Technology Integrators and others using an ESC license is to reference Class 2 and Class 3 power-limited circuits as defined by the National Electrical Code® in the scope of work for the ESC license. This makes a proper distinction between the work of Technology Integrators using the ESC license and Electrical Contractors using the ELE license.

The proposed amendment below would not restrict the small businesses of Virginia-based Technology Integrators while also supporting numerous technology solutions utilizing limited-energy systems on projects throughout the state.

Proposed Amendment updating the “Electronic/communication service contracting” (ESC) definition.

18VAC50-22-30. Definitions of specialty services.

“Electronic/communication service contracting” (Abbr. ESC) means the service that provides for the design, installation, repair, improvement, alteration, or removal of Class 2 and Class 3 power-limited circuits and systems as defined by the National Electrical Code. electronic or communications systems annexed to real property including telephone wiring, computer cabling, sound systems, data and network installation, television and cable TV wiring, and fiber optics installation, all of which or other systems that operate at 50 volts or less. A firm holding an ESC license is responsible for meeting all applicable tradesman licensure standards. The ELE classification also provides for the function.

Adopting the proposed amendment for the “Electronic/communication service contracting (ESC) definition will support the critical work of Technology Integrators while aligning their work to the National Electrical Code® revision cycle and recognize the distinction between limited-energy systems work (ESC) and electrical work (ELE).

Technology Integrators are critical to Virginia’s growth in technology solutions. CEDIA looks forward to working with the Department of Professional and Occupational Regulation and its staff on this important licensing issue. Together we can work to meet Virginia’s growing technology economy and technology solutions supporting all Virginians. Thank you for your time and consideration on this important issue.

Respectfully submitted,

Darren Reaman

Director of Government Affairs

CEDIA

800.669.5329 ext. 144

dreaman@cedia.org