Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Architects, Professional Engineers, Land Surveyors, Certified Interior Designers, and Landscape Architects
 
chapter
Board for Architects, Professional Engineers, Land Surveyors, Certified Interior Designers, and Landscape Architects Regulations [18 VAC 10 ‑ 20]
Action Develop regulations for a mandatory continuing education requirement for architect, professional engineer, and land surveyor licenses.
Stage Proposed
Comment Period Ended on 5/2/2008
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4/29/08  11:10 pm
Commenter: David Darling

Economic Impact is not Clearly Summarized - Why?
 

Multiplying out the economic impact times the number of affected professionals results in over $35 million a year in outlay to comply with this requirement.    The benefit of such huge expense is not explained. 

This cost will be born by Virginians in some fashion, whether directly passed on as a expense to customers or as a decrease in expenditures to many small businesses.

As noted in the economic impact analysis statement, if the regulation impacts small businesses, the state should provide "a description of any less intrusive or less costly alternative methods of achieving the purpose of the regulation."  The state failed to provide any such description.  The regulation should be deferred until such time as the alternative methods are described as required by law Section 2.2-4007.H.

 

 

CommentID: 1451