The petitioner is asking for a significant reduction in the required hours of experience and supervision in order to be licensed in Virginia.  I oppose this petition.  A review of the 2014 report on Licensure Requirements for Professional Counselors published by ACA shows that the majority of states at that time required 3,000 or more hours of post-master's experience and at least 100 hours of supervision.  Only two states, Florida and South Carolina, required just 1000-1500 hours of post-master's experience.  I do not have the 2016 ACA report in front of me but I have no reason to suspect that the majority of states have lowered their experience requirements over the last 5 years.  Moreover, under the current regulations, the petitioner's request to reduce the required supervision hours from 200 to just 50 would mean that a resident would need only six months of weekly individual supervision in order to be licensed (since the current regs allow for 50% of supervision hours to come from group supervision).  That is simply not enough time for any supervisor to be feel reasonably assured that a new counselor is consistently reliable in their ability to competently perform all the functions of a professional counselor.  While I agree that the licensing process is long and rigorous, I do not think that reducing the required experiential and supervision hours necessary for independent practice allows the Board to adequately meet its charge to protect the public.