1) No mention is made of the economic impact of lost revenues resulting from registrants opting not to renew their license because of continuing education requirements. (Assuming a 10% nonrenewal rate, the Dept. of Planning and Budget estimated this loss at $118,800 annually in their Fiscal Impact Statement on HB1054 for the 2006 legislature.) (My own estimate of annualized revenue loss is $123,000, based on 6,673 architects @ $55 biennial fee & 10% nonrenewal + 24,561 P.E.s @ $80 biennial fee & 10% nonrenewal + 1,438 L.S.s x $90 biennial fee & 10% nonrenewal.)

2) The present value of just 10 years of lost revenue @ $123,000 (discounted at current 10-year municipal bond rate) is close to $1 million.

3) What are the odds that this lost revenue will be recouped by raising renewal rates on the other 90% of registrants who won't be allowing their licenses to lapse?

4) The economic impact of $1029, $1106, and $838 biennial educational costs for architects, professional engineers and land surveyors, respectively is estimated at $31.7 million biennially ($15.86 million annualized) for the 90% of the 6,673 architects, 24,561 professional engineers, and 1,438 land surveyors who elect to assume the added economic burden of these regulations.

5) The present value of a $15.86 million annualized expenditure made every year for ten years, discounted at the current 10-year municipal bond rate, is $129 million. The present value of a $15.86 million annualized expenditure made every year for 20 years, discounted at the current 20-year municipal bond rate, is $198 million.

6) What are the odds that customers of architectural, engineering & surveying services in Virginia could ever gain $200+ million worth of additional present or future value from mandated continuing education?

7) As the EIA makes numerous statements about the benefit of these regulations to continuing education providers, there can be no doubt that the intent of these regulations is primarily to benefit "educator businesses" at the expense of architects, professional engineers & land surveyors. (I was amused to learn that the delegate who sponsored the legislation mandating development of these regulations held a M.Ed. degree, sat on the Education Committee, and was the recipient of various service awards from education associations; his occupation was listed as "Public School Administrator".)

8) Since 50% of the estimated cost of continuing education is productivity loss, only 50% remains as potential economic benefit for providers of continuing education. Only a minor portion of this potential economic benefit can be expected to be remain within Virginia's economy, or provide revenue for Virginia government.

9) The following statement found in the EIA borders on the absurd: "...Presuming that the affected professionals find continuing education activities that have positive value, the net loss to the value of these individuals and their employers will be less than the total fee and time cost associated with the activities." (How does a registrant who is retired or whose employer won't pay for continuing education locate "activities that have positive value" according to this definition?)