Regulation 18VAC10-20-120. Experience, Paragraph B. should be stricken.

The Commonwealth's regulation requiring a duration of 36 months of experience for applicants for licensure as an architect has no valid data to support any concept that development of competency is achieved through seat time performing work tasksfor 3 years.  The regulatory requirement to complete NCARB's Architectural Experience Program® (AXP®) should stand alone.  The AXP (formerly the IDP) defines the competency necessary for a newly licensed architect to practice architecture independently - to protect the public's health, safety, and welfare.  Individuals develop competency in different areas at different speeds.  Spending more time and/or repetitive activity does not make one more competent...it's just more time and more repetition.

The proposed regulation further requires the 36 months be completed under the supervision of an architect, only. This regulation is in conflict with the requirements of the AXP, which recognizes that valuable, valid experience for an architect can be gained in other [limited] work settings.  This conflict may require Virginia licensure candidates to complete more years of work prior to becoming eligible for licensure as an architect. 

Further, the duration requirement of 36 months is inconsistent with national standards.  The proposed regulation is more restrictive, as Virginia is currently 1 of under 10 states who still carry a duration requirement.

Restrictive requirements over and above nationally recognized standards do not protect Virginians; rather they restrict and limit the opportunities for Virginians who seek to become an to protect the public through licensed practice.  We have three excellent schools of architecture.  Graduates will continue to look for opportunities in other states that support the national standards and program requirements to become an architect.

Please strike paragraph B of proposed Regulation 18VAC10-20-120 in its entirity!