25 April 2008

Mr Mark N. Courtney, Executive Director
Department of Professional & Occupational Regulation
9960 Mayland Drive, Suite 400
Richmond, Virginia 23233

Dear Mr Courtney:

Recently I received your notice of proposed continuing education requirements for Architects and Engineers in Virginia.  I write to offer my experience as a licensed architect who was previously registered in another jurisdiction (New York) where continuing education requirements were in force.  I recognize that the mandate for continuing education has already passed the General Assembly and that the many comments of vociferous opposition registered on your website comment forum are, unfortunately, somewhat irrelevant at this point.  Nonetheless it's worth observing that this groundswell of opposition was neatly avoided by the proponents of the legislation by waiting until it had already been passed to notify regulants of its existence.

Meanwhile, my own experience:  Following the establishment of continuing education requirements, an enormous and bureaucratic cottage industry developed to offer "courses" and "seminars" for the ostensible purpose of providing educational benefit but which in fact merely focused on justifying themselves and consuming a tremendous amount of time and money with largely irrelevant and generally substandard presentations. 

Many courses and seminars were sponsored by the AIA, an organization which, to my knowledge, has yet to provide any tangible benefit for its members or for the public welfare.  By pressuring legislatures to make their courses (or equivalents) required, however, the AIA has managed to find an effective way to fill its own coffers. 

I'm sorry to say that the course 'instructors' were uniformly clueless, often to a truly embarassing extent.  But on one topic no one was fooled: they were there to collect their pay, we were there to satisfy an artificial requirement.   Then, adding insult to injury, the administrative requirements for documenting the CE credits to the state board wasted nearly as much time (and hence, money) as the 'courses' themselves.  As a result, some architects join or rejoin the AIA just to have them manage the accounting.  I suspect this is an intended consequence.

Any competent professional already spends a tremendous amount of time keeping up with the latest developments in his field.  To do otherwise would put one at a competitive disadvantage.  Continuing education is an idea that sounds good to non-professionals.  But in practice, it's essentially counter-productive--in the end, a colossal waste of time and money, ad infinitum.  It's essentially lip service to an admittedly worthy ideal. 

Now, I realize that I have just repeated some of the comments posted on your website.  But the point is worth repeating: CE courses often actually diminish the benefit to the public, in that they consume--for dubious purposes--the valuable time of our professionals which might otherwise be productively engaged in providing improved services to their clients who represent, after all, that same public. Every day spent satisfying artificial requirements is one less day that can be devoted to providing services to the public.  And each required hour ends up consuming several in administration, travel time, accounting, etc, such that a 16-hour requirement ends up consuming several workdays.

Therefore, what I want to propose may seem paradoxical.  It's that you permit liberal and flexible standards for what constitutes approved credit, thereby respecting the ability of the licensed professionals of the Commonwealth to determine what efforts are germane to their work and which endeavors represent productive use of their time.  Similarly, respect the licensed professionals of our Commonwealth to provide their own accounting of these efforts, sworn if necessary.  Otherwise, I fear you are simply enabling a parasitic cottage industry which provides no value to the general public and which might even be said to compromise its interests. 

 --R.L. (Licensed Architect)