To whom it may concern,

Fee increases are too steep. I am not against raising the fees, but license renewal increases to about double the current fees are too much! Please reconsider revising these new fees and implement a staggered increase (e.g. for Architects, from $55 to $80 for two renewal periods, and then to the proposed $110), and so on to the other affected professions.

Thank you so very much.

Why are the professions that make the least money, surveyors and landscape architects, paying more in the renewal fees than the higher earning engineers, business entities, interior decorators and architects?

The proposed doubling of the license renewal fee is ridiculous and should NOT be final.  Review is needed!  What makes this worse is little or no notice to anyone affected by those fees.  I hope Gov. Youngkin is aware of this since sudden doubling of regulatory fees makes the Commonwealth look bad and is bad for business.  Supposedly, the regulatory fees support activities of the various Boards; is doubling regulatory fees really necessary?  Are Board meetings being held at expensive hotels or resorts instead of state government offices?  Regulatory fee increases should be limited to no more than the published annual federal government inflation rate, if that.  Tighten the belt and make pennies scream!  Taxpayers and license holders are not a cow's udder for government agencies.

Why are Landscape Architects singled out for higher fees relative to all other professions? Especially for renewal - an $80 increase to $190 is far more than any other professional. What was the basis for the different cost levels? There should be consideration for the relative incomes of these professions and their ability to pay - Landscape Architects certainly do not have the most onerous requirements, nor the highest salaries of all professions. Is it because there are relatively fewer LAs? If so, saddling them with the highest cost is not an incentive to have more pursue licensure.

I find it difficult to reconcile the vagary of the fee structure - and, I'm focused on RENEWAL, but the argument applies to all the other fee category variations.

The total current renewal revenue is $3.4 million per cycle.  The proposed renewal revenue is $6.9 million.  Renewal fees are essentially doubling since they were established in 2004 (See the Agency Background Document, 2025-05-13).  An increase is reasonable - but the stated 110% inflation rate over the past 20 years is grossly inflated.  According to Google AI, the cumulative inflation since 2004 is about 65%.  The Federal Reserve calculates the cumulative rate to be 71%.

If one were to divide the current revenue ($3.4M) by the total number of licenses (47,441), the average renewal fee is $73.  Increasing that by 65% equals a updated renewal fee of $120.

Therefore, the renewal fee for each license should be $120 and should not vary by license type.  DPOR has provided no evidence that suggests a Landscape Architect should pay more than any other profession.

And, why does the Landscape Architect fee go up 173%, while all the other fees go up 200%?

Without some clear rationale and cost accounting, the variations in licensing fees appear Arbitrary and Capricious.  All professions licensed through the APELSCIDLA Board should have the exact same fee structure.  Why would there be any difference given we are all licensed by the same Board.