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