My name is Susan Cash and I live in Waynesboro, Virginia and co-own a design firm in Charlottesville, Virginia. I write this comment in STRONG support of the continued regulation of the interior design profession in Virginia. 

Our design firm has been providing professional interior design services to the state of Virginia for 25 years, working primarily on healthcare, senior living, corporate, and higher education projects.  After graduating from Virginia Tech, I decided to settle in Virginia due to the state's regulations certifying interior designers.  After sitting for my professional exam (NCIDQ), I immediately became a Certified Interior Designer (CID) with the Commonwealth of Virginia in 2008.  The CID seal is a mark of professionalism and experience, allowing our firm to file for building permits and work for the state.  Without the ability to add our seal to construction drawings, we would not be able to support our Small Woman-Owned Business.  Interior Design as a profession is fairly young, and often misunderstood as "fluffy" work, however our design services are invaluable; upholding and furthering building codes, protecting the public's health and safety, and positively impacting people's day-to-day lives through interior spaces that support their work and lives.

It is clear, eliminating regulation of Interior Design would gravely harm 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.

In light of the pandemic and as Virginians get back to their stores, businesses, and corporate offices, it is Certified Interior Designers who are redesigning and space planning these environments to mitigate COVID risk.

Our health is influenced by everything we touch in interior spaces. Disease-causing pathogens, like those that spread COVID-19, can be transferred from person to person, but also through everyday objects like office door handles, restroom grab bars, and schoolroom desks. It is critical to have interior environments that can protect our health by reducing pathogen transmission. Interior designers specify materials and finishes in 90% of residential and commercial construction and renovations and these professionals will be key in protecting the US against the virus.

Regulating interior design is a sensible practice. 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.

Sincerely,

Susan Cash, CID, ASID, LEED AP ID+C

Vice Principal Designer

Pye Interiors