My name is Susan Drew and I am a Virginia Certified Interior Designer living and working in Virginia Beach, Virginia. I write this comment in STRONG support of the continued regulation of the interior design profession in Virginia.

As a graduate of Virginia Tech, with a Bachelors of Science (in Interior Design), I am a strong supporter of Interior Design Regulation.  I practice commercial design on various projects types, including Federal Department of Defense, Higher Education and Commercial Office interiors.  Every day my professional decisions affect the health and safety of the building interiors I design.  From selecting materials that meet Fire Code appropriate for the type of building to space planning with an understanding of egress requirements to designing cabinetry that meets ADA requirements, my knowledge of building codes and ADA standards is critical for the clients I serve in Virginia.  I am appalled that Virginia would even consider deregulation of my profession, in which I have worked for over 30 years.  As a Principal at Clark Nexsen and I fear that deregulation would send a message to my company that what I do, does not warrant the position I hold, which I have worked long and hard to obtain.  I am a past president of IIDA Virginia and CCVID (Previously - Coalition of Virginia Certified Interior Designers).  Our numbers are strong and we advocate for regulation.

It is clear, eliminating regulation of Interior Design would gravely harm me and other Virginia Certified Interior Designers, Interior Design small businesses, and others in the Commonwealth. For example:

– In order to hold a position on a corporate board for a “Professional Corporation,” the employee must be licensed or certified in their profession by the Commonwealth. Eliminating the interior design regulation would prevent interior designers from serving on the board of architectural-interior design and interior design-only firms.

– RFPs (Request for Proposals) and RFQs (Request for Qualifications) in the Commonwealth of Virginia and for Federal Government Projects that include Interior Design Services require that the Interior Designer providing these services be a Certified Interior Designer. Eliminating the regulation would bar Virginia interior designers from submitting for these proposals.

– Job postings for Interior Designers in the Commonwealth and for Federal departments typically require an Interior Designer to be a Certified Interior Designer. Eliminating the regulation would exclude Virginia interior designers from these opportunities.

In Virginia, of the 1,272 interior design establishments in the Commonwealth, 96% are small businesses of four or fewer employees. 83% of these small businesses are women or minority owned. Eliminating interior design regulation would crush these entrepreneurs and small businesses because of the reasons listed in this comment.

Eliminating the Interior Design statute would also harm the Commonwealth. Being a Certified Interior Designer in the Commonwealth provides the public with knowledge that a minimum set of requirements, including education, experience, and testing, has been met. Certified Interior Designers do complex design drafting work in large public and code-regulated spaces like hotels, hospitals, corporate offices, and multifamily housing where public life-safety is implicated. CIDs have a knowledge of building codes, standards, and other laws and regulations that are essential to the safe construction of public and other code-regulated buildings.

Washington D.C., Maryland, Georgia, Tennessee, and Kentucky, all have statutes in place for the regulation of the title and/or practice of Interior Design. In total, 27 states and two federal jurisdictions regulate interior design. No jurisdiction has ever deregulated the practice of interior design.

The interior design statute is not restrictive or protectionist. The title protection law—enacted during the 1990 Session of the General Assembly—does not restrict the scope of practice and serves as the framework for the voluntary certification program. While only certified interior designers may use the title “Certified,” any individual may contract with a client to render services as an interior designer, interior decorator, or similar practitioner if the client so chooses.

Eliminating the voluntary regulation of interior design in Virginia is bad public policy. Continued regulation is vital to the practice, profession, industry, consumers, and the public’s health, safety, and welfare. I ask you to not eliminate the regulation of this profession.

Thank you!