Below are four excerpts from the Virginia Department of Planning and Budget in the Economic Impact Analysis of 18VAC 10-20, the proposed regulation of photogrammetrists: 

(1)  “The costs likely exceed the benefits for this proposed regulatory change” (page 1, Results of Analysis). 
(2)  “…The proposed licensure requirements will increase the cost to become a photogrammetrist and, so, in the future, there will likely be fewer individuals to offer these services than there would be without the proposed regulation… photogrammetrists who stay in, or enter, the field, despite the barriers presented by licensure, will likely experience a bidding-up effect that would result when the pool of consumers of these services compete for the now more limited number of the photogrammetrists…. current and future photogrammetrists and users of other remote sensing technologies, as well as consumers of their services, will incur numerous costs on account of this proposed regulation” (page 4-5).   
(3)  “…State and local public agencies that intend only to use photogrammetric work product for exempt ends will have to pay an increased price because the market price for licensed photogrammetric will be higher.  State and local agencies that need photogrammetric work for non-exempt ends will see even larger cost increases…” (page 5-6). 
 
(4)  “…An effect of licensing photogrammetrists, and designating that license as a sub-licensure of land surveying, is that state and local public entities will be forced to use the competitive negotiation process to contract for all photogrammetric work products that may or will be used for non-exempt ends. This means that, in addition to bearing the increased cost caused by the increasing market price for photogrammetric services, these public entities will also see increased costs from this procurement process for “professional” services…” (page 6). 
 
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Implementation of these new professional regulations will likely result in future increased costs for Virginia businesses and organizations that procure photogrammetry services and products.  This regulation creates a disincentive for competition due to the up front investment of the certification requirements, thus will contribute to cost increases because of the following:

* It will cost labor hours, training time, travel, testing fees, licensing fees, salary increases, and other capital investment for vendors to license their staff as photogrammetrists, and those costs will be passed to consumers of photogrammetry products and services.

* There may be few licensed vendors of photogrammetry products and services to select from in Virginia. 

* There may be requirements to procure photogrammetry products and services as professional services instead of through competitive bidding, resulting in higher costs to the purchaser. 

This increased regulation may result in fewer choices and increased costs for local governments that procure photogrammetric products and services.  Local governments prefer to conduct technology solicitations through competitive bidding as non-professional procurements.  This approach enables the County to better compare and evaluate the technical and cost proposals and to negotiate the best solution at the best price.  Professional services procurements limit that ability and drive up costs.  There are aspects of this regulation that make it appear in ways as an unfunded state mandate that will result in more costs paid by local government, and ultimately the taxpayers.
 

Tom Conry
GIS Manger
County of Fairfax