The collaborative process, described in supporting documentation, that has occurred by all parties involved in the development of the proposed licensure for “Survey Photogrammetrist” is to be commended.  In my current role as the Coordinator of the Virginia Geographic Information Network, I work closely with GIS professionals on a daily basis.  My work experience also includes time as a photogrammetrist with the federal government.  So I believe I understand the issues and concerns that have been raised during this long process.

I understand the desire of the small but significant photogrammetry community in Virginia that seeks further professional recognition and legitimacy, and I recognize the concerns of the land survey community.  I also understand that advances in GIS technology have dramatically increased the capabilities of users of this technology.  Having said all of this, I believe that a balance must be achieved that provides legitimacy to photogrammetrists as well as not prohibit Virginia from realizing the gains that Geographic Information Technology can provide.  This balance can be boiled down to the determination of acceptable use.

Acceptable use for the requirement of  a licensed “surveyor photogrammetrist” should be constrained to the development of legal documents developed in support of the recognized practice of land surveying.  “Remote sensing technologies” are much broader than a narrow definition of “photogrammetric methods or similar remote sensing technology”.

Acceptable use by the GIS professional means that, even though GIS technology makes it easier to automate photogrammetric techniques, the GIS professional does not utilize these techniques to develop legal documents that may impinge on the legitimate role and practice of land surveying.  It should not prohibit the GIS professional from utilizing this technology in governmental use if it is only for non-legal planning purposes (i.e. not for design and construction).

Lastly, I concur with the Economic Impact Analysis that requiring licensed professional photogrammetry services as a new regulation to state and local government will increase costs, though it is difficult to quantify at this time.  I would  recommend that a cost benefit analysis be completed after one year to reassess the cost benefit once some real numbers start arrive.

Thank you for the opportunity to comment.