The proposed legislation costs more than presented, does not have a tangible benefit, and is a welfare job the suppliers of the continuing education and the Board for Architects, Professional Engineers, Land Surveyors, Certified Interior Designers, and Landscape Architects.  No explanation of problem/issue that drove the proposal development.

Looking the Economic Impact Analysis (EIA), it is full errors.  Finding architects, professional engineers, and land surveyors for $34, $39, and $22 per hour is unreal. Current rate for professional help is over $200K per contract year or $100 per hour.  The 16 hour requirement is for contact time or class time.  For every class hour, three to four hours of study are needed.  If this requirement is passed on to the customer, as it will in some form, the EIA cost of $549, $625, and $358 for architects, professional engineers, and land surveyors will change to over $6.4K (i.e., $100 times 4 times 16).  

In the EIA, travel cost at $100 per hour should be used. 

Per the EIA, “The benefit of the proposed continuing competency activity requirement is more difficult to estimate than the cost,” and “There are no estimates of the magnitude of this potential benefit available.” This translates to, no tangible benefit.

Per the EIA, “The proposal to require 16 hours  . . .will likely have some positive impact on the employment for the suppliers of the continuing education. . .“ and “Suppliers of continuing education will encounter increased demand for their services.”  Architects, professional engineers, and land surveyors should not be legislated to develop and support the cottage industry.

The EIA failed to account for the architects, professional engineers, and land surveyors time and office supplies when they are “selected for audit [and] shall provide all documentation of all continuing education activities utilized to renew their license within 21 calendar days of receiving notification of audit. “

The EIA failed to account for the cost to administer, monitor, enforce, and audit the silly continuing education requirement.  Just the filing of completed courses and assessment if the course material met the requirement will be a significant cost, and again for no tangible benefit.  This requirement creates welfare jobs for the Board for Architects, Professional Engineers, Land Surveyors, Certified Interior Designers, and Landscape Architects.

Looks like career change to Certified Interior Designer is appealing, they are not addressed in this proposed continuing education requirement.