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