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

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.

I agree with the DPB Economic Impact Analysis provided for 18 VAC 10-20.  In my 25 years of public service it has been my experience that given similar circumstances professional services contracts generally are more expensive than non professional services contracts. The quality of the work can be controlled by careful attention to specifications, reference checking and proactive contract management.  There is no substitute for cost comparison, and the time consuming professional services contracts will raise the price of photogrammetric services.